Regulations are nothing new across the increasingly important corporate environment, social, and governance landscape, but one looming policy piece that manufacturers and their suppliers should not overlook has to do with per- and polyfluoroalkyl substances or PFAS.
The chemicals, which have been labeled forever chemicals because they do not break down naturally in the environment, are in a variety of everyday materials. While they are most commonly associated with items like waterproofing or firefighting materials, they generally are found in many more items from household cleaners to personal care products to transportation equipment. On top of that, there can be thousands of different PFAS classified by regulatory bodies.
With a growing focus on pollution from PFAS, especially in water systems that cause human health impacts, regulations could mean many materials that might contain PFAS will be targeted. That presents significant supply chain risk, and where Assent’s Supply Chain Sustainability Platform can play a crucial role for companies trying to stay compliant while also maintaining their operational standards.
The Assent Supply Chain Sustainability Platform includes a wealth of data points to manage risk across an organization’s operations. PFAS information has grown out of that system’s foundation, a platform that has been named a Top Product in the Environment+Energy Awards 2023.
PFAS Risk Will Continue to Grow
One thing about PFAS that Assent Director of Product Sustainability Cally Edgren says companies may not yet recognize, is just how impactful pending regulations may be. The concern over the chemicals, especially in the United States, continues to grow.
The EPA is expected to issue reporting and recordkeeping requirements for PFAS under the Toxic Substances Control Act as early as this year. In June 2023, 3M, the largest manufacturer of PFAS announced a $10.3 billion settlement regarding the contamination of public water systems.
Past regulations for other safety concerns that required changes in industry and manufacturing took years to come to fruition, which could mean plenty of time and workarounds to become compliant. PFAS rules are quickly becoming a part of the sustainability discussion, the chemicals are found in a wealth of materials that could impact any number of products, and potential laws are far from standard.
In the United States, for example, there are more than 1,400 chemicals that are expected to be included in forthcoming EPA rules. In the European Union, that number grows to more than 10,000. In the United Kingdom, it is just a few hundred. Then rules may start to vary by location, such as individual states in the U.S. coming up with their own rules that add to the regulation complexity.
That makes for a difficult landscape for companies to figure out, and where a system like the Assent Supply Chain Sustainability Platform becomes a necessity.
“There are a lot of unique aspects of this compared to a lot of the product regulations of the past that are really starting to alarm manufacturers,” Edgren says. “There are all these different pressures coming to make these companies say, we need to know where these PFAS are, and just saying we tried is not going to be good enough.”
Assent’s Supply Chain Sustainability Platform
Assent’s solution allows manufacturers to gather supplier data on PFAS substances present in parts and products and align this data with TSCA requirements, including detailed reporting by supplier, content, and regulation. Companies can then leverage the data to make informed decisions about their parts, products, or processes.
Assent also monitors targeted chemicals and any new regulations to create up-to-date risk mitigation programs to help organizations stay ahead of potential liability. Assent goes a step further in these processes with its own regulatory and chemical experts on staff.
This helps the company sort through the ever-changing number of PFAS that the regulations seek to address. The lack of concrete ways for manufacturers to address PFAS that likely won’t be cleared up by standard international policy any time soon makes having such in-house resources especially important, Edgren says.
“The trickiest part of this is that the regulations don’t necessarily list all of the substances for PFAS,” Edgren says. “We had to use our in-house chemists and toxicologists to really scrub through that task of what the EPA has on their June 2021 proposal and what the European Chemicals Agency has on their list. To create that list (for the platform), the knowledge piece was the hardest part of building the PFAS solution.”
Developing the PFAS element of the platform was made easier with a solid foundation of supply chain risk management already in place.
Assent’s Supply Chain Sustainability Platform tracks and collects a range of data in multiple areas, including product compliance, trade compliance, and ESG. The solutions are also supported by managed services to enhance supplier operations and run supply chain due diligence programs. The ESG element, and resiliency among other matters.
“What we know to be true is the number of substances of concern, substances to be declared and substances to be restricted only continues to grow as do the number of regulations that put these requirements in place,” Assent Vice President of Product Management Krystal Cameron says. “The technology aspect shines and in fact is critical, in that managing the amount of data pertaining to regulations and sustainability. Correlating that data to the parts and products being manufactured, identifying the risks, adjusting as those regulations and requirements continually evolving, managing the responses to regulatory bodies and their customers is a large undertaking and extremely challenging to manage manually – some would in fact say impossible – on an ongoing basis.”
Assent Addressing Supply Chain PFAS Risk
Adding a PFAS module to the platform built on information that was already gathered from other users and supply chain data. Some of that information included other risk levels concerning items such as perfluorooctane sulfonic acid or lead. That helps keep users comfortable, too, with using new Assent platform tools such as PFAS because they have already participated in mitigating supply chain risks from other factors.
“This is the same process that our customers’ suppliers are already familiar with, and this is just another regulation,” Edgren says.
PFAS is an increasingly important piece of sustainability strategies for manufacturers, especially considering the pollution and health concerns of the chemicals. Plus, they are used in so many materials, such as electrical components that are in so many parts of a technology-driven world that it could change how many products are made – if they are even made at all.
Once the EPA rules are in place, companies will have 12 months to report on the listed PFAS (provided the final rule matches the original 2021 proposal). This is why tracking PFAS throughout supply chains and overall business operations should be a priority for companies, Edgren says. She believes 90% of companies aren’t paying attention to the potential impacts of strict regulations.
“There are just so many moving pieces here and think not anticipating the complexity of this is a real risk to manufacturing,” Edgren says. “That’s my biggest plea when I go out to talk to companies, please don’t ignore this.”