Pollution Prevention Workgroup

the letter p squared

Mission

To review, develop and recommend policies to prevent exposure to PFAS, PFAS containing materials and other emerging contaminants.

Recent Accomplishments

  • The Pollution Prevention Workgroup has developed recommended policies to address risks posed by PFAS containing Aqueous Film Forming Foams (AFFF). 

Next Steps

  • Explore drafting a plan to encourage industries to advertise products as “PFAS-free”.

Research/Studies

  • Continue to work with the USEPA to identify Michigan companies reporting quantities of PFAS compounds.
  • Continue to participate on the Interstate Chemicals Clearinghouse (IC2) PFAS Workgroup.
  • Continue to communicate with other states (Washington, Virginia, Wisconsin, New York), etc. as it relates to their P2 efforts with PFAS and AFFF.

P2 Progress

The following list includes statements from some of the largest companies in the United States regarding their efforts and progress in limiting use of priority chemicals listed in the Pollution Prevention for Our Future Act (HB 1194/ SB 5135).  For even more information on the state of retailers and toxic chemicals, check out Safer Chemicals, Health Families’ Retailer Report Card.

Challenges

  • Challenging a mindset focused on “clean-up” to focusing on “prevention” to reduce the need for future clean-ups.
  • Safety Data Sheets (SDSs) do not disclose PFAS or other chemicals of interest which makes it complicated to identify products containing PFAS.

Timeline of Accomplishments

  • Provided research for district staff of identified AFFFs used at the former DNR Toxaphene Storage Facility, Roscommon.  Chemicals of concern researched included Firetrol by Chemonics and 2,4,5-TP Silvex by LorCon.
  • Assisted with analysis of House Bill 4389 which proposed requirements pertaining to AFFF.
  • Analyzed House Bill 6373 with Air Quality, Remediation and Development, and Water Resources Divisions along with MDHHS, which proposed regulations for handling, storage, disposal, and cleanup of substances containing PFAS.
  • Performed a data pull for all wastes described as having “fluor-“in the description to identify possible PFAS use in industry and to assist in replacement chemicals.
  • Drafted recommendations for fire suppression system installers concerning hauling and disposal of PFAS containing AFFF material and PFAS contaminated AFFF material.
  • Identifying Class B Foam through the US Coast Guard along the Great Lakes for training and emergency purposes.
  • Working with the USEPA to identify Michigan companies reporting quantities of PFAS compounds listed in 40CFR721 Subpart E for further Pollution Prevention efforts.
  • Participating with a national group organized by the Interstate Chemical Clearinghouse to share information about PFAS containing products and materials in use by industry and consumers.
  • Reviewed and commented on the EPA Pre-Publication Notice Long-Chain Perfluoroalkyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances; Significant New Use Rule; Docket ID #: EPA-HQ-OPPT-2013-0225, FRL #: 10003-21.

Workgroup Lead

Chris Babcock
BabcockC4@Michigan.gov