AHAM’s commitment to safety includes supporting regulations that ensure chemicals used in consumer products do not expose consumers to unreasonable health and safety risks. AHAM advocated for important reforms to the Toxic Substance Control Act (TSCA), which gives the U.S. Environmental Protection Agency the authority to regulate the use of new and existing chemicals in products. Since the reforms became law in 2016, AHAM has focused on ensuring that any regulations created under the law protect public health, are science-based and do not place unnecessary burdens on manufacturers.
At the state level, AHAM works with policymakers to ensure that chemical labeling laws and rules prohibiting the use of certain chemicals focus on health risks due to exposure. Several states, Canada
and the U.S. government have begun to regulate or are considering regulating per-
and polyfluorinated substances, more commonly known as PFAS, which are commonly
used by manufacturers of appliances and countless other products. PFAS tend to
be used in internal appliance components and are chosen for their
self-lubricating properties, durability and, in the case of HFO foam-blowing
agents, for their minimal environmental impact.
The concerns surrounding
the impact PFAS have on the environment focus on the fact that PFAS do not
break down in the environment and could accumulate in soil, waterways and
wildlife.
AHAM supports the intent
of policies that aim to protect consumers from unreasonable risks, including
exposure to potentially harmful chemicals. However, current proposals to
regulate PFAS are incredibly broad, targeting more than 10,000 chemicals. They
often are present in appliances only in trace amounts. In many cases,
manufacturers simply do not have alternatives. HFOs, for example, are currently
approved under the EPA’s Significant New Alternatives Policy (SNAP), which identifies
more environmentally friendly options for common chemicals. However, they are
listed as PFAS in many new proposals. The alternatives, hydrocarbons, are less
efficient. In addition, appliance manufacturers draw from a complex global
supply chain for appliance parts and components, making it difficult to
identify whether they contain PFAS.
Proposals to regulate PFAS
should be narrowed to consider the level of use within appliances, and whether
the chemicals are accessible to the user. Used together with proper industry
design practices, test requirements and safety mechanisms, PFAS can continue to
play a role in household appliances.
