Testing for PFAS
Testing might also be a consideration for investigating the presence of PFAS (especially PFAS process residues or additives in fluoropolymers and fluoroelastomers) , but this also presents challenges.
Most importantly, with regard to components, there is no nationally recognized test method available for broad spectrum PFAS that can determine the concentration (i.e., quantitative analysis) of each PFAS in any particular part (or article) of a component. There are quantitative tests available for blood, water, or soil, but not for solid matrix items.
Some laboratories offer testing services on solid matrix items for some PFAS subsets using custom modifications on PFAS test methods intended for other purposes (such as detecting PFAS in water). The better tests begin with reducing the object under test to smaller particles in order to increase the surface area to extract the PFAS molecules from. But none of these tests are very accurate. A negative result (i.e., no PFAS) from such a test cannot truly rule out the presence of PFAS, and any results value that is provided is likely well below the actual amount of PFAS that is present.
It is also important to keep in mind that as a laboratory processes a PFAS plastic or rubber polymer for testing, non-polymer PFAS can be produced (essentially portions of the PFAS polymer chain breaking off into smaller molecules). Laboratory processes that have a potential to do this include mechanical grinding, ultrasonic sonication, and heating. It is also possible that PFAS present in the laboratory equipment and process vessels can impact the test outcome.
Material Disclosure Protocols
There are many ways that material information can be exchanged in the supply chain.
- Safety Data Sheets (SDSs) are one way to do this, but they are generally only applicable to materials when they are exchanged as base, raw materials. SDS criteria are laid down in various national regulations such as EU REACH Annex II, and the US Hazard Communication System Appendix D. (Refer also to section 21)
- Standard material data exchange formats of several types are available. They are based on substance lists. These include:
- IEC 62474, “Material Declaration for Products of and for the Electrotechnical Industry” which is supported by two public access databases known as the Declarable Substance List (DSL) and the Reference Substance List (RSL) – Link. The former has an entry for “Per- and poly-fluoroalkyl substances (PFAS)” derived from the US State of Maine legislation, using their broad PFSA definition – “substances that include any member of the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom”. The latter provides examples of substances in a particular chemical family. There are only 629 substances listed in RSL for PFAS. Some fluoropolymers are included in the list. The operative threshold for the Maine requirement is given as “intentionally added”. These databases will be updated from time to time as additional PFAS regulations come into force. More targeted PFAS regulations, such as the EU POPs PFOA restriction, are also covered.
- IPC 1752, “Materials Declaration Management Standard” – Link – which is presented in two revisions: Revision A and Revision B, each of which has had a few amendments. IPC 1752A establishes a standard XML reporting format for material declaration data exchange between supply chain participants and supports reporting of bulk materials, components, printed boards, sub-assemblies, and products. The IPC-1752B standard helps companies who want to collect data from their supply chains in a format matching the data requirements of the EU “SCIP” database. The structure of the IPC-1752B standard mirrors the ECHA SCIP database submission format. IPC 1752A defines 4 classes of declaration (A thru D) related to 5 chemical list appendices (B thru F) that are publicly available in a single document (Link). The chemical appendix F mirrors the IEC 62474 list – but it might not be synchronized in time.
- ChemSherpa (Link), is a Japanese-based reporting scheme which aims to include the entire supply chain of a product from the very upstream substance producers to mixture producers to part manufacturers and then to component product manufacturers. There is specialized, publicly accessible data entry support tool provided from the ChemSherpa website and a collection of manuals and training materials in several languages.
- Full Material Declaration (FMD). While the above chemical information exchange standards are driven by a finite list of substances that various regulations require to be reported, a full material declaration is intended to be a report of all the substances that might be present in a component. The challenge with this approach is to be very clear about how articles will be considered in the FMD declaration and with what content precision each article will be reported. Recall that a single component, such as potentiometer, can have 10’s of fundamental articles as well as substances and mixtures that are also added at the component level, likewise, the PFAS concentrations of regulatory interest can be expressed as in parts per billion of each article. An FMD report that only goes to 0.1% of the reported component weight will not provide enough information for most PFAS restriction and reporting regulations.
Custom method – There are many information gathering efforts going on these days to understand the impact and respond to proposed and existing broad-spectrum PFAS reporting and restriction laws. The standardized material disclosure protocols might not cover all the PFAS necessary. Therefore, a custom PFAS inquiry protocol might be needed for use in your supply chain. This should be undertaken with careful consideration.
Companies in the supply chain, particularly suppliers of less complex assemblies, are likely to be more familiar with standard protocols. A custom protocol will require them to understand new concepts and use different response methods, which can give rise to response errors of various types. If a custom protocol is created it is best to develop one with the goal of simplifying respondent reply efforts, but based as much as possible on an existing standard protocol, and if possible, in collaboration with other companies in a similar industry sector to limit the variety of inquiries in the supply chain.
Please note: SEMI makes no warranties or representation to the accuracy or usefulness of the information contained on this webpage. Accuracy is solely the responsibility of the user. Users are cautioned to refer to other relevant literature of the subject matter herein. This information is subject to change without notice. This "explainer" was developed by members of the SEMI PFAS Working Group. Please send suggestions for improvement to ehs@semi.org