Forever Chemicals: Testing for and Protecting from

It is really different. It makes it far harder because contamination for food can come from different sources at different points of the food supply chain, and that makes it far more difficult. It can be in the start, in the middle, or can just be before the consumer is getting the food. PFAS contamination can occur in all these points.

Water treatments are all centralized, but it's different with farms because they have different practices, different soils, different sources of water irrigation and also their proximity to sources of PFAS contamination is varied. For example, if the farm is closer to the airport or industrial sites that produce PFAS, then you're more likely to have PFAS contamination. It's harder to predict, and PFAS contamination can come from varied sources, so it can come from the water, can come from the fertilizer, can come from the soil or from the air, even. State and federal governments can mandate the testing for PFAS in raw materials in the processing, and also in the final products. They should also mandate testing in the processing facilities to make sure there is no PFAS contamination there. Lastly, they can also mandate testing in the retail shops after the final products are released in the market.

There's a little bit of a roundabout way of addressing some of the concerns. Of course, you cannot test every single farm, and of course, that's a reluctance from the farmers to get tested because if the results show they have a major problem on their hands, they lose their income. That certainly has happened to several farmers already. Unless there's mechanisms and policy in place to protect the farmers, the incentive to test is not that high. But because there has been fairly extensive testing of water supplies across the U.S. through groundwater wells, several farms have been identified because the water from the region was highly contaminated. So, there's an indirect way of making sure that we at least catch the most likely problems through water testing. It's not perfect, clearly, because we have only tested the major water supplies, excluding private water supplies and random private wells. More water testing might be a roundabout way of making sure we don't miss out on too many farms that might inadvertently have a PFAS problem.

If we were to compare testing at the farm level compared with testing public water systems, there are obviously a lot more farms in the U.S. than public water systems. In general, the FDA does not go to each individual farm to test for PFAS. Instead, we work with states regarding testing for PFAS at the farm level. We have been alerted to environmental issues involving PFAS contamination from state officials. At that point, we would and could go on the farm at the request of the state for PFAS.

But generally speaking, we do test for PFAS at retail. We do have surveys that look specifically at PFAS in many different foods. One program is our FDA Total Diet Study, where we look at many different foods, and different regions of the country. There's six different regions. There's also different collections that we obtain food from. These foods are collected, prepared for consumption and then analyzed. In general, when we do testing, we do look at table-ready foods through our Total Diet Study. But we also do other testing through assignments where we go out at retail, or at the border and test foods there, as well.

The difference between a water supply and a food supply system does present different challenges. I think the important thing to remember when we're comparing these two is that food is taken from a particular small area compared with where a water supply system may be coming from. For example, a watershed generally leads to all water being in a particular water supply. It's capturing water from all over, whereas a farm is capturing food from only that farm. And obviously farms can be many sizes, but compared with a watershed, it's still quite small. The other important thing to consider is that while we know PFAS are ubiquitous in the environment, our testing has shown that, in general, it does not lead to detectable levels of PFAS from most farms in most of the food that we test. Really, a very small percentage of foods have shown positive detection, and most of those are in the seafood area, not in our produce, beef and other areas. Where we have seen PFAS contamination in foods is where we know we have point source contamination problems. Perhaps it's groundwater that's been contaminated by manufacturing or a military facility nearby where foams have been used, or perhaps it's the use of biosolids over a multi-year, continuous process.

There's not really this need to go out to each farm and test each farm based on the data and the understanding that we currently have. Where that food is collected is different, so the challenges are different.

Q: What can states do to protect their constituents from PFAS in food stuffs and food packaging?

Several states have already enacted or are planning to enact bans in food packaging, although there are no federal regulations yet—just guidelines. But states can help by mandating testing for PFAS in food packaging in their final products and in the raw materials, in the additives that manufacturers use, etc. They can also test for the biosolids that are used for fertilizer and the paper that is used to manufacture the packaging. They can also mandate tests in the sources of the food packaging, as well as the final food packaging. States can promote simplified and reliable testing of PFAS to ensure that our food packaging and food contact materials are safe.

When we talk about food packaging, we can get inspired by European countries because there are European regulations for food contacting materials. We can get inspired and adopt similar guidelines here in the U.S. The situation is different because we need federal regulation. There are ways to prevent PFAS moving from food packaging materials.

Luckily, the state of Rhode Island has passed a bill phasing out PFAS in food contact materials as of 2025. I think several of the neighboring states have done the same. Once there's a critical mass of states with such laws on the books, of course the incentive will be there for suppliers of these materials to go PFAS-free, and then suddenly we protect everybody. I think the reason it passed the state of Rhode Island was because of consumer advocacy groups. NGOs all banded together and said, “This is ridiculous. PFAS are dangerous. We don't really need them in food contact materials. We might need them somewhere else, but certainly not in these kinds of products.” Common sense said to just ban them, so hopefully other states will follow. Then, even without a federal mandate, the effect can still be felt. 

It's a bit of a misnomer to say there are no federal PFAS regulations because the FDA regulates in a pre-market approach. Since about 2010, there have been a series of abandonments and withdrawals across a couple of years. At this point, we've had 35 food contact notifications, either withdrawn or removed from the market. Currently, there are no food contact notifications that include PFAS on the books. The nuance here is to understand that a food contact notification is specific to that notifier. That means a company comes in and says we'd like to use this food contact substance or food contact material in either the processing or packaging of food. The FDA reviews that notification and issues a response to that notification. When a company voluntarily withdraws their food contact notification, that substance is not available on the market for someone else to use it.

For fast packaging or food contact materials, there are four categories. There are the grease proofers—35 of those have been removed from the market to date. There are small fluoropolymer gaskets. These are generally used within food processing so it's very limited contact and it's repeat use. We don't think the migration from them is very great. There are some other processing aids that use polymers or fluoro-containing compounds. And then there's the nonstick cookware. We've done quite a bit of work with nonstick cookware and that is an extremely small migration effect. Again, these are repeat use items, so after an initial use or washing, the detection from these is actually below the limits of detection.

One of the things we're working on is to expand liquid chromatography tandem mass spectrometry methods into high resolution. This is where we can do more of a non-targeted analysis to look for a broader number of PFAS compounds. Our current method looks for 30. We have a new method with USDA that expands that to 32. But these non-targeted methods could go far beyond that.