PFAS May Be Regulated in Greases

January 2023

Author: Chuck Coe, CLGS
Grease Technology Solutions LLC
Website: www.grease-tech.com
Email: [email protected]

As some of you may or may not know, PFAS stands for per- and poly-fluoro alkyl substances. Initially, PFAS only referred to Perfluoroctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS), which were the most widely used and studied PFAS materials at the time. These C8 perfluoro materials (PFOA and PFOS) have been banned in industry, in many countries. Replacements for C8 perfluoro materials are mainly shorter C6 hexafluoropropylene oxide (HFPO) materials, which are believed to be less harmful and are widely used to manufacture PTFE and other fluoropolymers, but not used to make PFPE lubricating base stocks. Recent studies show C4-C6 fluoro materials will pose risks to animal/human health; therefore, The EU is considering putting Perfluorohexane sulfonate (PFHxS) and Perfluorobutane sulfonic acid (PFBS) on the SVHC Candidate list. In 2022 five countries proposed to the EU to ban use of Non-essential PFAS by 2030. The definition of PFAS was extended stating that any material containing C_nF_2n+1or -C_nF_2n– (where n>=1) would be considered PFAS. In our world, greases, both PFPE and other synthetic base fluids thickened with PTFE would be impacted by the PFAS definition and regulations (as well as solid lubricants based on PTFE). These greases are used extensively in the manufacture of semiconductors and other critical (aviation, military, aerospace, industrial, etc.) applications. Concerns regarding the persistence, mobility, and potential toxicity of certain PFAS are driving governments across the globe to propose broad PFAS restrictions.

While some industries, the semiconductor industry for example (Public Statement of the Semiconductor PFAS Consortium – Semiconductor Industry Association semiconductors.org), are working to “get out in front” of rapidly approaching PFAS regulations by informing public policy and regulation, we are unaware of any other industries’ efforts to do something similar regarding greases. For those member companies which are manufacturing or marketing PFAS greases, you may wish to investigate what activities may be occurring in the industries you are selling into to prepare yourselves for these imminent regulatory actions.

While PFAS regulation is occurring for many consumer items such as food packaging, furniture, carpets, outdoor gear, fire extinguishing foam and other products, many of these items can be made with similar performance properties by using non-PFAS alternatives. However the unique properties of PFAS greases makes it extremely difficult to replace them with equivalently performing non-PFAS products without major redesign of lubricated equipment and an extraordinary amount of research and development. With this in mind, the semiconductor industry is working to establish grounds for “essential use” (The Essential Use Project – Global PFAS Science Panel — Global PFAS Science Panel).

In addition, the Fluoropolymers Product Group, part of the trade organization Plastics Europe has sent a letter to the Competent Authorities in Europe preparing the PFAS REACH restriction proposal (not specifically related to lubricants or greases), advocating on behalf of the fluoropolymer industry: Fluoropolymer_Letter_5_January_2023_-_PFAS_REACH_Restriction_2.pdf (plasticseurope.org)

We believe it is within the mission of NLGI to inform our membership of this issue to help our manufacturers, marketers, and raw material suppliers to be aware of and prepare for potential regulatory impacts. Some information about current and potential regulations can be found in these sources:

PFAS Regulations in the United States: An Essential Guide (compliancegate.com)

Per- and Polyfluoroalkyl Substances (PFAS) | US EPA

New PFAS Regulations by State – Applied Technical Services (atslab.com)

PFAS Regulations in the European Union: An Essential Guide (compliancegate.com)

EPA’s PFAS Strategic Roadmap: A Year of Progress

US EPA regulation updates: