Orla McCoy

UPM Community Engagement Manager

Based in Oxford, UK

Policy and Regulation;

Five things we learned about PFAS at UPM 2021

UPM is holding a panel event to discuss industry response to legislation on 20th of January 2022 , kicking off a series of UPM Community events. Below are key takeaways from UPM 2021’s PFAS-focused presentations.

These five points were distilled from presentations made by Bob Mcintosh, Principal at Enviro-Energy Solutions, who gave a technical presentation and hosted a roundtable on regulation of PFAS in the EU and the US; and Ryan Thomas, associate at GHD, who hosted a roundtable on the US regulatory framework for PFAS. Bob McIntosh's technical presentation is available through the UPM Conference Library.

Visit the
calendar to register for the January 2022 follow-up event.

1. PFAS are everywhere in a semiconductor fab and there are no viable alternatives for use in critical components 
PFAS are commonly used in etching agents, anti-reflective coatings, drying and cleaning fluids, piping, gaskets, filters, membranes, mechanical components and aqueous film-forming foam.  
Vital chemically inert materials, such as polyvinylidene fluoride and Teflon fluoropolymers, contain PFAS. There are currently no alternative materials with the correct properties for manufacturing these high-purity fluoropolymer components.  
Ongoing research seeks to understand the leaching potential of PFAS from equipment. PFAS-containing polymer-based components are used in semiconductor manufacturing due to their chemical inertness, so the contribution of PFAS to liquid waste is disputed. 
2. The complexity of PFAS as a group of substances brings difficulty in adhering to regulations 
PFAS comprise 4,700 man-made substances, which have a range of physical and chemical properties. It is a long and costly process for facility operators to learn these different variations and track which components contain PFAS. Suppliers of PFAS-containing materials may also not know which PFAS are in the materials.  
The breadth of varieties of PFAS should be kept in mind regarding the pending EU legislation, which treats the group as one.  

3. The US and EU are looking to regulate PFAS 
PFAS exposure is being increasingly linked to cancer, impacted infant development, and hormone interference, in addition to environmental effects.    
The US Environmental Protection Agency (EPA) introduced a regulatory roadmap for 2021-2024 with three main strategies: increasing research into the environmental and health effects of PFAS; classing perfluorooctane sulphonate (PFOS) and perfluorooctanoic acid (PFOA) as hazardous substances; and implementing industrial effluent guidelines. If the regulations are implemented, fabs may need to report and control all incoming and outgoing PFAS.  
The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Act is pending EU legislation which may completely ban manufacturing of PFAS. Since a fab’s core infrastructure contains PFAS, REACH would have extreme consequences. Implementation of restriction on manufacturing PVDF is expected by July 2023, and restriction of using PFAS in photolithography or etching is expected by July 2025. 

4. The industry must communicate with regulators 
Industry groups, especially integrated device manufacturers, must demonstrate awareness of responsible PFAS-handling methods. At the same time, the industry must communicate to regulators the consequences of severe PFAS regulation on losing business from semiconductor manufacturing. For example, the EU proposed a Chips Act in October 2021 to drastically increase regional semiconductor manufacturing, but this goal is not possible without PFAS. 
SEMI and Plastic Groups Europe produced a rebuttal of the proposed EU legislation, aiming to derogate fluoropolymers and fluoroelastomers from the legislation, or, failing this, classify semiconductor manufacturing as an essential industry exempt from REACH regulations. SEMI and the Semiconductor Industry Association are producing a rebuttal for the US roadmap.  

5. The industry may require better ways to destroy PFAS 
Adsorption through activated carbon is the most widely demonstrated technology for removing PFAS from liquid waste; however, reverse osmosis, ion exchange and nanofiltration are also used. A PFAS-contaminated membrane must then be incinerated, which has negative environmental effects, or sent to landfill. The potential for PFAS to gradually degrade in a landfill is disputed, but heightened awareness of the long-lasting nature of fluoropolymer materials is leading landfills to refuse PFAS-impacted materials. 
The US EPA intends to issue updated guidance on destroying PFAS-containing materials by Autumn 2023.