The PFAS debate: Hydraulic Institute highlights the impact of new reporting requirements

Michael Michaud, executive director of the Hydraulic Institute speaks to World Pumps as part of its “PFAS: The big debate” series about new PFAS reporting requirements coming into effect in the US and the impact these will have on the pump sector and its supply chain.

Michael Michaud, executive director of the Hydraulic Institute.
Michael Michaud, executive director of the Hydraulic Institute.

The Hydraulic Institute (HI) is a global authority on pumps and pump systems. The organization develops industry standards through a vast array of technical resources including application guidebooks, online tools, and calculators. Founded in 1917, the HI is the largest association of pump manufacturers in North America.

 

WP: What new PFAS regulations are currently having an impact on the pumps sector?

MM: At the PFAS Implications for the Flow Control Industry Conference, which HI hosted alongside the Valve Manufacturing Association in Alexandria, Virginia in November 2024, we covered current regulations in the US, Canada and around the world, and while several jurisdictions are discussing bans, the current focus for pump, valve and sealing companies is on reporting requirements.  

The US Environmental Protection Agency (EPA), Environment and Climate Change Canada (ECCC) and some states like Minnesota will require manufacturers to identify and report any PFAS in their products. Deadlines for reporting will start to take effect as early as January 2025. The industry remains concerned about the recent focus at the US State level to ban PFAS. There are currently 46 US States that have proposed bans or legislation, however most of these are clearly focused on consumer products. 

 

WP: What problems are these regulations causing the pump industry?

MM: Reporting requirements will have a significant impact on the pump and sealing industry because pump and seal manufacturers will need to do a lot of research and outreach to their vendors to get the required information. With the recent extension of the EPA’s TSCA reporting deadline, we caught a little bit of a break, but the challenge will continue to be identifying PFAS in our supply chain and reporting by 11 July 2025. 

Our industry tends to have long and complex supply chains. Finding it and keeping track of it is enough of a daunting task if we had to do it today, but the TSCA rule requires anyone who imported PFAS between 2011 and 2022 to report. Looking back that far can be difficult. Record retention policies have expired, and some suppliers may no longer be in business so estimates and best guesses will have to be made.  

 

WP: What other regulations are due to come into force in this area?

MM: Canadian reporting will need to begin in 2025 for PFAS that is manufactured, imported (including articles) or used above threshold limits in 2023. The Canadian list is more focused and specifically calls out 312 specific PFAS (where the EPA list is much more broad-based covering 1,462 active PFAS). 

 

WP: Which pump parts are there no viable PFAS alternative for?

MM: At the moment most of the concern is around sealing technologies such as gaskets, O-rings, diaphragms, and coatings. Certain seals and coatings are critical to ensure that other high temperature or harmful liquids do not leak during critical processes. These are essentially used when failure is not an option. Nuclear power generation, computer chip manufacturing, ammonia production, wastewater treatment – these processes all require fluid systems to handle difficult, sometimes toxic fluids safely. Without the fluoropolymer components, these fluid handling systems could simply not perform these critical functions safely. 

 

WP: What impact would a full PFAS ban have on the pump sector?

MM: A complete ban would be impossible at this point. It would take society back to the 1940s virtually overnight. PFAS are embedded in modern life in ways people don’t imagine. In products like computers, cell phones, but also in processes like power generation, wastewater treatment, and manufacturing.  The materials we primarily use – fluoropolymers and fluoroelastomers – get dragged into this because chemically, they are in the very broad PFAS family, but they do not have the same characteristics as the small-chain, water-soluble PFOS and PFOA that are the main concern. Fluoropolymers are long-chain, large molecules that can’t enter cells. They are not soluble in water and, in most cases in our industry, not designed to come in contact with consumers.  

 

WP: How are pump manufacturers working to reduce their use of PFAS?

MM: The manufacturers in the flow control space don’t use fluoropolymers as a first-choice material. It is not a freely available, or a low-cost choice. When these materials are used, it is typically the option of last resort. It is more expensive and is generally the only material that performs to specific engineering specifications and performance requirements. Any material that stands up to high temperatures and harsh chemicals will have similar properties.

As alternative solutions, if any, will have similar, persistent properties, responsible use of these materials is paramount for manufacturers. New end-of-life studies now show that it is possible to recycle and destroy fluoropolymers. When an O-ring is replaced, its end-of-life can be managed. Manufacturers have a role in recommending appropriate recycling or disposal methods.

 

WP: Does more R&D need to be undertaken to develop suitable PFAS-free materials for use in pumps?

MM: Absolutely – and more R&D will happen. A US Department of Defense study said it will take at least 20 years to develop alternatives. Those alternatives then need to be tested to ensure that new materials will not be more harmful than the ones they replace. At the conference, we heard from several companies that are working on alternatives and testing. We can expect to see studies focused on disposal and recycling, but also determining a useful lifespan. They are not called “forever chemicals” for nothing – so more research into how long these materials remain “fit-for service” will also be needed.   

 

WP: Tell us more about your work in this area.

MM: HI is doing its best to continue to monitor the regulatory space so our members can prepare for compliance in a rapidly changing landscape. We are also trying to move beyond regulatory issues and look at supply chain concerns. At our conference, several speakers touched on the fragility of our supply chains if regulatory or legal pressures limit the production of the base materials themselves. As an industry that relies on fluoropolymer PFAS materials, we need to understand this risk so we can continue to keep our end-customers flowing safely.

A big piece of this moving forward will be advocacy and education. Advocacy on how PFAS are defined to ensure that fluoropolymers and their critical uses are clearly recognized by regulators. Education on the critical role our industry plays in industrial processes and modern society.

 

WP: Is there anything else you would like to add?

MM: We’re sort of in a catch-22 situation where the regulators include fluoropolymers in the family of PFAS, while relying on fluoropolymers to contain methane, or to line landfill sites so leaching of other PFAS doesn’t occur. As we advocate and educate, hopefully we can limit potential scope creep so regulatory agencies don’t move beyond specific products to all products, or from specific chemicals to entire families of chemicals. 

 

*Part of this interview was first published in World Pumps, November/December 2024 issue as part of a focus on PFAS restrictions. Read the full story here: The Big Debate.