PFAS

History

PFAS are a class of fluorine containing human-synthesized chemicals that have been widely used in consumer and industrial products since the 1950s. PFAS do not readily break down, so they can accumulate in people and in the environment.

PFAS have useful properties that make them common in many industries. Some of the most common uses are to reduce friction or surface tension, to increase wettability and to repel water, dirt or grease. Some industries are known for using PFAS, such as

plating, which has historically used PFAS for fume suppressing,
printing, which often has PFAS in inks to help them flow more smoothly, and
semiconductor manufacturing, which typically uses PFAS for photolithography and etching.

However, other common uses of PFAS show up in any industry. Some of the most common of these include floor waxes, roofing materials, Teflon coated bearings and surfaces, lithium batteries, and Teflon tape.

Definition

There are multiple ways to define what is or is not considered a Perfluoroalkyl and polyfluoroalkyl substance (PFAS). Minnesota defines PFAS as a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom. This is one of the broadest definitions of PFAS, so some substances that may not be considered PFAS by others are considered PFAS by Minnesota law.

For the purposes of the TSCA PFAS 8(a)(7) Reporting Rule, EPA defines PFAS as any chemical substance that includes at least one of these three structures:

R-(CF2)-CF(R’)R’’, where both the CF2 and CF moieties are saturated carbons
R-CF2OCF2-R’, where R and R’ can either be F, O, or saturated carbons
CF3C(CF3)R’R’’, where R’ and R” can either be F or saturated carbons

Under the Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), the 189 PFAS included on the Toxics Release Inventory (TRI) Chemical List have been designated as chemicals of special concern, which excludes them from the de minimis exemption.

Health Effects

Some PFAS are known to cause health problems such as immune suppression, cholesterol elevation, hormone disruption, decreased fertility, and kidney and testicular cancers.

More health information, including health risks, routes of exposure, ways to reduce exposures, and health-based guidance values is available on the Minnesota Department of Health PFAS and Health site.

For Wastewater Treatment Plants (WWTP)

What it means for WWTP

In December 2022, the US EPA sent a memo with recommendations for POTWs and NPDES permittees for addressing PFAS discharges. Although these recommendations have not yet been formally required and fully implemented, they are a preview for potential PFAS requirements that may be incorporated into future wastewater permits. Therefore, many Minnesota wastewater facilities are working to identify likely upstream sources of PFAS and making plans manage PFAS in their systems.

How can MnTAP Help WWTPs?

We have found that while most WWTPs have a good understanding of the permitted significant industrial users (SIUs) in their system, they are often not very familiar with the smaller, non-permitted businesses in their communities.

MnTAP can help you understand your customers and identify potential sources of PFAS in your system. We use a commercial database to create a list of businesses in the community, and then use their NAICS (North American Industrial Classification System) code to identify those in industries more likely to use significant quantities of PFAS. We can map the locations of these businesses to the sewer system to inform the design of sampling plans.

MnTAP can also reach out to your customers directly to help them identify & reduce sources of PFAS in their operations and their wastewater. We can offer them self-service tools, a road map for PFAS identification and elimination, and personalized support. See the “For Industry” section for more information.

For Industry

Why be concerned about PFAS?

Beginning in 2024, Minnesota has prohibited PFAS use in a number of applications. January 1, 2024, intentionally added PFAS was prohibited in food packaging, and in firefighting foam for most situations. On January 1, 2025, intentionally added PFAS was prohibited in an additional 11 categories of products: carpets or rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, and upholstered furniture. Products covered by these prohibitions may not be sold, offered for sale, or distributed for sale in the state of Minnesota.

In 2026, new reporting requirements will go into effect from the Toxic Substances Control Act (TSCA) and the State of Minnesota. EPA will require current and former (since Jan 1, 2011) manufacturers or importers of PFAS or PFAS-containing to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards. Minnesota will require manufacturers or importers of any product sold, offered for sale, or distributed in the state that contains intentionally added PFAS to submit information including: a product description, the purpose of the added PFAS (including in any product components); the amount of each PFAS, identified by its chemical abstracts service registry number (CAS#) (or another chemical identifying number if a CAS# is not available), and the name and address, phone number, and contact person for the manufacturer. Minnesota will also establish a fee to be paid upon submission of the required information about products containing PFAS.

A 2022 EPA memo directed POTWs and NPDES permitees to begin monitoring PFAS discharges, follow best management practices to minimize PFAS discharges, and to identify and locate all possible industrial users (IUs) that might be subject to the pretreatment program, including all IUs in industry categories expected or suspected of PFAS discharges. Therefore, many Minnesota wastewater facilities are working to identify likely upstream sources of PFAS and making plans manage PFAS in their systems and your wastewater facility may contact you for information about your use of PFAS.

How can MnTAP Help Industry?

Identifying PFAS in industrial operations is a multi-step exercise that can often span several months. We suggest developing a plan to guide your organization through the process and creating a framework for documenting the progress and outcomes. We have developed a sample framework and tools to help you identify and reduce the use of PFAS in your facility. Given the scope of the materials to evaluate and the length of timeline, we encourage documenting as much of the plan as possible early in the process. This will help characterize the scope of the activity and provide the ability to shift the project between personnel as turnover occurs.

Sample PFAS Management Framework

Investigate facility for potential sources of PFAS.
1. Evaluate production activities and raw materials for potential sources of PFAS based on characteristics such as processing steps to increase water resistance, decrease friction, and decrease surface tension using MnTAP assessment tools or other resources.
2. These will be the products that should be prioritized in step 2.
Work with vendors/suppliers to evaluate raw materials and products for any intentionally added PFAS.
1. Our recommendation is to send suppliers a letter requesting information on the presence of PFAS in their materials.
2. MnTAP has developed a supplier letter template for this purpose, which includes information to ensure vendors are aware of the MN definition of PFAS.
Maintain a full list of materials to be considered.
1. Document what has been evaluated, responses received, and dates of correspondance.
Identify potential alternatives for PFAS containing materials.
1. Evaluate alternatives for substitution.
2. Document decision making criteria and reasons for whether products can or cannot be substituted
Develop a timeline for substituting or eliminating PFAS.

Desktop Screening Tool

A good first step is using the desktop screening tool developed by the MPCA. This screening is intended as an educational and awareness tool to help identify sources of PFAS in your operations, understand your risk of unintentional disposal or discharge of PFAS, and develop a source reduction plan. The self-evaluation includes questions about general industry and activity, NAICS code(s), and additional risk factors, and it should take no longer than 10 to 15 minutes to complete. It will provide an estimate of your business’ PFAS risk as lower, medium, or higher compared to other facilities.

MnTAP’s Customized ChemSec Tool

MnTAP’s Customized ChemSec list tool (based on the PFAS Guide developed by ChemSec) is and Excel based tool that can generate a list of the most common applications for PFAS in your specific industry or industries. This tool also highlights common uses of PFAS that are found in many facilities regardless of industry, such as floor coverings and waxes, bearings, and roofing materials. This will give you an idea of where to begin looking for products that may contain PFAS.

Product List Analysis

Along with common uses, it can be helpful to screen your materials based on their function. Some of the most common functions of PFAS compounds include:

Water, oil, and stain repellence
Friction reduction
Durability
Non-stick coatings
Lubrication
Anti-static properties
Mold release
Flame retardance

Any products which demonstrate these functions have an increased potential to contain PFAS and therefore should be investigated further.

To assist in these reviews, MnTAP is developing a tool to assess product lists for these and other common PFAS functionalities. If you would like MnTAP to assess your product list as part of our pilot testing, please reach out to us for more information.

Confirming presence or absence of PFAS – Supplier letter template

Once you know which products in your facility are most likely to contain PFAS, you will need to investigate further. Determining the presence of PFAS will become easier once Minnesota reporting requirements go into effect in 2026, but in the meantime, requesting information directly from suppliers is the best route available.

Given the various definitions of PFAS, it can be difficult to get the right information. For instance, we found that in one supplier’s response to a company’s inquiry about PFAS, they indicated that their products do not contain PFAS but then later mentioned that some of their products do contain PTFE. PTFE is considered PFAS under the Minnesota definition of one fully fluorinated carbon. While the supplier was responding accurately according to their working definition of PFAS, it became apparent that Minnesota businesses need to be explicit in the definition within their request.

To help manufacturers get accurate information from their suppliers, we have prepared a supplier letter template to clearly explain what information is needed to comply with Minnesota regulations. It includes specific information for Minnesota, EPCRA, and TSCA reporting requirements as well as PFAS definitions and a data table the supplier can use to provide the requested information.

Evaluating alternatives to products containing PFAS

Once you have identified products that contain PFAS, you can begin to evaluate alternatives for substitution. MnTAP is gathering resources to help with this process.

It is helpful to document whether each product can be substituted, the reasons a product can or cannot be substituted, and what criteria were used to make this determination.

Other Resources

Outreach Mailing: Source Reduction Tools & Links

If you received a paper mailing regarding PFAS Source Reduction tools, here are the links and resources you need.

Key Resources

Complete List of Links