PFAS Implications to the Industrial Valve Industry

The industrial valve industry provides a vital role in the production of products essential to improving the quality of life of the public and protecting the planet. The current focus on banning all PFAS raises a significant threat to our industry and beyond, with the potential to create substantial and wide-ranging negative consequences to today’s society.

Understanding how and why PFAS are used, the highly beneficial reasons they are used to help protect health and the environment as well as provide for efficient operations; and understanding the differences in the types of PFAS is critical.

What are PFAS?
The EPA indicates that there are upwards of 14,000 PFAS (per- and polyfluoroalkyl substances).  Because the structural definition of PFAS is so broad, there are many types of PFAS – all of which possess unique physical, chemical, environmental, and toxicological properties. Recently the European Union, Canadian Government, US Government at the federal and state levels, and other countries have increased their focus on PFAS and have indicated that they would put in place various restrictions, including bans, on all PFAS – regardless of their know toxicity, or effect on health or the environment.

While it is imperative to address PFAS for which there is sound scientific evidence of environmental and human health toxicity, regulating all PFAS in the same manner would have substantial and wide-ranging negative consequences to health and safety, national security, the environment, and society at large.

How does the Valve Industry use PFAS and Why?
The valve industry relies on high molecular weight fluoroelastomers and fluoropolymers (such as PTFE, FKM, FFKM and others) in the manufacture of gaskets, seals, pumps, coatings, chemical piping and industrial valves - all of which are integral to the production of products core to maintaining modern life. 

These type of PFAS are used due to their unique properties that provide for effective sealing, creating emission barriers, reducing energy use, and meeting performance requirements in highly corrosive or high temperature environments.  This helps to provide a safe and reliable production process, particularly in scenarios where failure can have catastrophic consequences.  These solid, molded products have negligible potential for worker or consumer exposure or other safety concerns while handling the product.

The use of these fluoropolymers enables production of a wide range of everyday products used by almost every American, including semiconductors, cell phones, food and beverages, pharmaceuticals, renewable energy systems, transportation, pulp and paper products, and more.  They are also integral in the technology used in efforts to achieve zero carbon goals and in the production, transportation, and storage of hydrogen.

Further, highly skilled engineers work to design entire flow control systems to meet detailed specifications required by accepted standards and regulations designed to protect health, safety, the environment, and efficient operations. 

There are currently not reasonably available alternatives to PFAS that deliver the same level of performance in these critical applications. 

Looking forward, even if a new alternative can be identified, or if an existing, older material is to be reintroduced, it will still need to be tested and certified for use in the specific application, and product designs would need to be reengineered. This entails testing the materials regarding functionality (i.e., performance, stability and quality) and obtaining certifications from or adoption by the appropriate regulatory or standard-setting bodies.  This is a drawn-out, time-consuming process, and it is difficult to estimate the number of years that it would take to find viable alternatives to current PFAS uses.

The Need for A Currently Unavoidable Use Designation
Because of this, VMA has provided formal comments to various legislative and regulatory bodies on the need to designate the industry products as a “currently unavoidable use” or PFAS so that operations can continue and products that are key to modern life can continue to be produced.

Not All PFAS Are the Same
VMA will also continue to support efforts to address PFAS based on their unique properties, instead of treating all PFAS in the same way.  According to the Organization for Economic Cooperation and Development (OECD), “the term “PFASs” is a broad, general, non-specific term, which does not inform whether a compound is harmful or not, but only communicates that the compounds under this term share the same trait for having a fully fluorinated methyl or methylene carbon moiety.”

Instead of categorizing PFAS substances into overly broad groups or classes, they should be differentiated based on their hazard and risk, considering their physical, chemical, and biological properties.

How VMA is Helping our Members and Industry
The importance on educating our lawmakers on the impacts of their proposed legislation, regulatory rulemakings, and other activities cannot be understated. Over the past two years, VMA has done this in a few ways:

- Submitted formal comments to the States of Maine and Minnesota on why valve industry products need to be designated as a “currently unavoidable use” for intentionally added PFAS. 

- Met with over 20 Members of Congress to discuss and explain our industry and why PFAS are critical.

- Provided formal comments to EPA on how PFAS are used in critical infrastructure provided by the valve industry.

- Created a Flow Control Coalition with the Hydraulic Institute and the Fluid Sealing Association to ensure that those in the flow control system speak with a common voice.

- By working with 40+ Associations through coalitions to amplify our voice on the topic and help develop a clear definition of PFAS so that different PFAS can be managed appropriately based on their risk, environmental, health and other impacts.

What's Next
VMA holds periodic webinars for our members and provides presentations and updates at industry events.  Information to understand the current regulatory and legislative landscape on PFAS, compliance requirements, as well as technical, testing, supply chain, end use and other topics will continue to be addressed by VMA.