It seems like I can't open a legal publication in the food and beverage or product liability space, and not see something about PFAS. Per- and polyfluoroalkyl substances, commonly referred to as PFAS, have historically been used in a wide range of consumer and industrial products due to their water- and grease-resistant properties. But according to the FDA's deputy commissioner for human foods, food manufacturers have voluntarily agreed to cease using PFAS in the packaging that comes in contact with food.

The rationale for doing so is that some PFAS chemicals have been linked to adverse health conditions, including liver, kidney and testicular cancer; thyroid problems; and impaired fetal development. Some of the processes used to create food packaging result in the formation of PFAS chemicals. As a result, PFAs can leach from the packaging into their contents, exposing people to PFAS through the consumption of food.

Of course, the above rationale only establishes the potential exposure to PFAS through food packaging. And while I doubt anyone will argue that PFAS exposure is good for you, that is true for many things we are exposed to every day of our lives. But we are not exposed to enough of those things – what science calls the dose – to do us harm. Whether that is because our exposure is too short, too de minimis, and/or too infrequent. And right now, the science surrounding PFAS exposure has not established what is the sufficient dose to cause human harm. 

No doubt there are many reasons that food manufacturers, at the behest of FDA, are ceasing the use of PFAS in food packaging. But if exposure to PFAS alone is the primary rationale, then the manufacturers of other products will surely follow suit in the future. The only question is what's next?