Report on Critical Per- andPolyfluoroalkyl Substance Uses
Pursuant to Section 347 of the James M. Inhofe National Defense Authorization Act for
Fiscal Year 2023 (Public Law 117-263)

August 2023
Office of the Assistant Secretary of Defense for Energy,
Installations, and Environment
Office of the Assistant Secretary of Defense for Industrial
Base Policy

The estimated cost of this report or study for the Department of Defense is approximately $83,000 in Fiscal Year
2023. This includes $47,900 in expenses and $45,100 in DoD labor.
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Table of Contents
Acronyms.......................................................................................................................... iii

I.

Introduction ........................................................................................................................... 1

II.

Definitions ........................................................................................................................... 2
II.1 Per- and Polyfluoroalkyl Substances ............................................................................ 2
II.2 Critical to the National Security ................................................................................... 3
II.3 Sectors Considered ....................................................................................................... 4

III.

Data Collection Methodology................................................................................................ 4
III.1 CMRMP Data Call ....................................................................................................... 5
III.2 Additional Industry Engagement.................................................................................. 5
III.3 OASD(IBP) Industry Sector Data Collection Process.................................................. 5

IV. Results........................................................................................................................... 5

IV.1 Kinetic Capabilities ...................................................................................................... 5
IV.2 Energy Storage and Batteries ....................................................................................... 6
IV.3 Microelectronics and Semiconductors.......................................................................... 7
IV.4 Castings and Forgings and Strategic and Critical Minerals ......................................... 8
IV.5 Additional Mission Critical PFAS Uses ....................................................................... 9
IV.5.1 Refrigeration and Air Conditioning, Cooling, and Electronics Thermal Control........ 10
IV.5.2 Fire Suppression in Naval Vessels, Aircraft and Ground Combat Vehicles................ 10
IV.5.3 Aqueous Film Forming Foam...................................................................................... 11
IV.5.4 Lines, Hoses, O-Rings, Seals and Gaskets, Tapes, and Cables and Connectors.......... 11
IV.5.5 Electronic/Dielectric Fluids ......................................................................................... 12
IV.5.6 Advanced Oils, Greases, Fluids, and Lubricants ......................................................... 12
IV.5.7 Precision Cleaning Fluids ............................................................................................ 12
IV.5.8 Degreasing/Cleaning Fluids......................................................................................... 13
IV.5.9 Adhesives..................................................................................................................... 13
IV.5.10

Insulation and Foam Blowing ................................................................................. 13

IV.5.11Resins for Specialty Materials ................................................................................ 13

IV.5.12Specialty Filters and Membranes ............................................................................ 14

IV.5.13Fabrics, Fabric Liners, and Fabric Barriers............................................................. 14

IV.5.14

Customized Applications ........................................................................................ 14

Report on Critical Per- and Polyfluoroalkyl Substance Usesi

V.

Conclusions ......................................................................................................................... 14

FigureFigure:Overview of PFAS Groups (refined from OECD 2021) .............................................. 3

Appendix
Appendix: Summary of Known Mission Critical PFAS Uses ................................................... A-1

Report on Critical Per- and Polyfluoroalkyl Substance Usesii

Acronyms
AFFF
AIM Act

Aqueous film forming foamAmerican Innovation and Manufacturing Act of 2020

CMRMP

Chemical and Material Risk Management Program

DoD

Department of Defense

ECTFE
EPA
EU

Ethylenechlorotrifluoroethylene
U.S. Environmental Protection Agency
European Union

F3
FY

Fluorine-free foam
Fiscal Year

HFCs
HFOs

Hydrofluorocarbons
Hydrofluoroolefins

Li-ionLithium-ion

MCMEU
MilDepMission-critical military end use
Military Department

NDAA
NDT

National Defense Authorization Act
Non-destructive testing

OASD(IBP)ODASD(E&ER)
OECD

Office of the Assistant Secretary of Defense for Industrial Base Policy
Office of the Deputy Assistant Secretary of Defense for Environment andEnergy Resilience
Organisation for Economic Co-operation and Development

PA&T
PFA
PFAA
PFAS
polyFAAPTFE
PVDF

Policy, Analysis, & Transition
Perfluoroalkoxy alkanes
Perfluoroalkyl acid
Per- and polyfluoroalkyl substances
Polyfluoroalkyl acid
Polytetrafluoroethylene
Polyvinylidene fluoride

SOTA
SOTP

State-of-the-Art
State-of-the-Practice

U.S.
USS
UV

United States
United States Ship
Ultraviolet

Report on Critical Per- and Polyfluoroalkyl Substance Usesiii

I. Introduction
Section 347(a) of the James M. Inhofe National Defense Authorization Act (NDAA) for
Fiscal Year (FY) 2023 (Public Law 117-263) directs the Secretary of Defense, in consultation
with the Defense Critical Supply Chain Task Force (i.e., the Office of the Assistant Secretary of
Defense for Industrial Base Policy (OASD(IBP))) and the Chemical and Material Risk
Management Program (CMRMP) of the Office of the Assistant Secretary of Defense for Energy,
Installations, and Environment (OASD(EI&E)), to submit to the Committees on Armed Servicesof the House of Representatives and the Senate a report outlining the uses of per- andpolyfluoroalkyl substances (PFAS) that are critical to the national security of the United States.
This report focuses on critical uses in the sectors outlined in the February 2022 Department of
Defense (DoD) report titled Securing Defense-Critical Supply Chains and sectors of strategic
importance for domestic production and investment to build supply chain resilience.
PFAS are common chemicals used across DoD. Most weapons platforms incorporate
PFAS, and PFAS are found throughout the defense industrial base in roles supporting mission
critical component production and supply. PFAS uses may be direct, where a PFAS is aconstituent in a consumable item or is incorporated into an article (e.g., end item), or indirect,
where a PFAS is used to formulate another chemical or is part of a manufacturing process.
These uses and processes are necessary to the production of key components of the defense
industrial base, such as microelectronic chips and lithium-ion (Li-ion) batteries.
PFAS are chemically quite stable, and many are water and oil repellent, heat resistant,and/or stain resistant, often leading to non-stick surfaces on various materials. Examples ofapplications of PFAS are in plastics, o-rings, gaskets, lubricants, coolants, and fabrics. DoD isreliant on the critically important chemical and physical properties of PFAS to provide required
performance for the technologies and consumable items and articles which enable military
readiness and sustainment. Losing access to PFAS due to overly broad regulations or severemarket contractions would greatly impact national security and DoD’s ability to fulfill its
mission, and impact domestic defense industrial base manufacturing and supply.
This report provides details on what is currently known about direct and indirect mission
critical PFAS uses that could impact mission readiness if the substances are no longer available.
It also highlights the challenges and costs related to finding and qualifying equal or improved
performing alternatives to existing PFAS materials in sectors of strategic importance to DoD. It
is important to note that the information contained in this report is limited to what was available
at the time of its drafting. As such, the information presented represents a fraction of the mission
critical PFAS uses due to a lack of knowledge of the complete chemical composition in
consumables and articles (e.g., end items) 1. In addition, there is significant uncertainty regarding
A consumable is defined as “an item of supply or an individual item (except explosive ordnance and major end
items of equipment) that is normally expended or used up beyond recovery in the use for which it is designed or
1

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the presence of PFAS in products that make up a complex value chain. A more complete
understanding of PFAS essential uses would require an extensive and complex evaluation of themarket, a gap analysis of current requirements for manufacturer-provided product information,and illumination of the value chain of products.

II. Definitions
For purposes of this report, the terms used within section 347(a) of the NDAA for FY
2023 are defined in the following sub-sections.
II.1 Per- and Polyfluoroalkyl Substances
There is currently no consensus definition of PFAS as a chemical class. 2 Congress did
not define PFAS within section 347(a) of the NDAA for FY 2023 for purposes of this report. 3
While there is no consensus definition, regulators in the European Union (EU) and the UnitedStates have proposed, but not yet adopted, different chemical-structure-based (rather thanhazard- or risk-based) definitions. In anticipation of the most stringent future regulatory actions,
DoD used the definition put forward by the Organisation for Economic Co-operation andDevelopment (OECD) in its 2021 report, Reconciling Terminology of the Universe of Per- andPolyfluoroalkyl Substances: Recommendations and Practical Guidance, 4 for collecting data anddeveloping this report. OECD states “The term ‘PFASs’ is a broad, general, non-specific term,
which does not inform whether a compound is harmful or not, but only communicates that thecompounds under this term share the same trait for having a fully fluorinated methyl or
methylene carbon moiety.” OECD cautions that this definition should not be used in deciding
how to group and manage PFAS in regulatory actions; however, future PFAS legal andregulatory frameworks may disregard the OECD caution and seek to restrict the use of PFAS
based on chemical structure.

intended. An end item is the “final combination of end products, component parts, or materials that is ready for its
intended use, e.g., ship, tank, mobile machine shop, or aircraft.” DoD Supply Chain Terms and Definitions (February
21, 2023). https://www.acq.osd.mil/log/LOG_SD/.policy_vault.html/DoD_Supply_Chain_Terms_and_Definitions.pdf.
2Per- and Polyfluoroalkyl Substances (PFAS) Report: A Report by the Joint Subcommittee on Environment,
Innovation, and Public Health, Per- and Polyfluoroalkyl Substances Strategy Team of the National Science andTechnology Council, March 2023.
3
Congress previously defined PFAS in the NDAA for FY 2021 for purposes of establishing the interagency working
group to coordinate federal activities related to PFAS research and development. Section 332(g)(1) defines PFAS
broadly as (A) man-made chemicals of which all of the carbon atoms are fully fluorinated carbon atoms; and (B)man-made chemicals containing a mix of fully fluorinated carbon atoms, partially fluorinated carbon atoms, andnonfluorinated carbon atoms. William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year
2021, Pub. L. 116-283 (2021).
4“PFASs are defined as fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon
atom (without any H/Cl/Br/I atom attached to it), i.e., with a few noted exceptions, any chemical with at least a
perfluorinated methyl group (–CF3) or a perfluorinated methylene group (–CF2–) is a PFAS.” OECD, Reconciling
Terminology of the Universe of Per- and Polyfluoroalkyl Substances: Recommendations and Practical Guidance(Series on Risk Management No. 61), July 9, 2021.
https://one.oecd.org/document/ENV/CBC/MONO(2021)25/En/pdf.
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The figure below provides an overview of the PFAS groups based on the OECD
definition. This very broad definition encompasses more than 38,000 individual PFAS
chemicals. 5 DoD uses are represented in each major category of PFAS (i.e., perfluoroalkyl acids(PFAAs) and polyfluoroalkyl acids (polyFAAs)), PFAA precursors, and other PFAS (e.g.,
fluoropolymers, fluoroelastomers).

Figure: Overview of PFAS Groups (refined from OECD 2021)
II.2 Critical to the National Security
Congress did not define “critical to the national security of the United States” within
section 347(a) of the NDAA for FY 2023. The term “mission-critical military end use(MCMEU),” however, is defined in regulations promulgated by the U.S. Environmental
Protection Agency (EPA) under the American Innovation and Manufacturing Act of 2020 (AIM
Act). 6 The AIM Act addresses the phasedown of production and consumption ofhydrofluorocarbons (HFCs) (e.g., regulated substances). MCMEUs are “[t]hose uses ofregulated substances by an agency of the Federal Government responsible for national defensethat have a direct impact on mission capability, as determined by the U.S. Department of
Defense, including, but not limited to uses necessary for development, testing, production,
training, operation, and maintenance of Armed Forces vessels, aircraft, space systems, groundvehicles, amphibious vehicles, deployable/expeditionary support equipment, munitions, andcommand and control systems.” 7
The MCMEU definition focuses on regulated substances. As with HFCs, PFAS areundergoing increased regulation. But in addition to regulation, market forces can directly impact
mission capability by limiting DoD’s ability to source and use PFAS and PFAS-containing

Williams, et al. 2022. Assembly and Curation of Lists of Per- and Polyfluoroalkyl Substances (PFAS) to Support
Environmental Science Research. Front. Environ. Sci. 10:850019. doi:10.3389/fenvs.2022.850019.
6
42 U.S. Code 7675.
7
See 40 Code of Federal Regulations 84.3, “Phasedown of Hydrofluorocarbons” (October 5, 2021).
5

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products. The most recent example is 3M’s decision to phase out production of PFAS and
PFAS-containing products by 2025. 8
For purposes of data collection and report development, DoD used the MCMEU
definition with the recognition that both market forces and increased regulation can have a direct
impact on mission capability.
II.3 Sectors Considered
Section 347(a) of the NDAA for FY 2023 directs DoD to focus this report on critical
PFAS uses in the four focus areas identified in DoD’s February 2022 report Securing DefenseCritical Supply Chains. 9 The four focus areas—kinetic capabilities, energy storage andbatteries, microelectronics, and castings and forgings—have critical supply chain vulnerabilities
posing the most pressing threats to national security. In addition, this report focuses on
semiconductors—a sector of strategic importance for domestic production and investment tobuild supply chain resilience—and strategic and critical minerals. These areas are described as:
•

•
•
•
•

Kinetic capabilities: Current missiles systems and advanced and developing
missile capabilities, including hypersonic weapons technology, as well as directedenergy weapons.
Energy storage and batteries: High-capacity batteries, with a particular focus
on lithium batteries.
Microelectronics and semiconductors: State-of-the-Practice (SOTP) and legacy
microelectronics, State-of-the-Art (SOTA) microelectronics, and semiconductors.
Castings and forgings: Metals or composites developed into key parts andmanufacturing tools through high-intensity processes.
Strategic and critical minerals: Minerals to supply U.S. military, industrial, andessential civilian national emergency needs, with emphasis on those that are notproduced in sufficient quantities in the United States.

III. Data Collection Methodology
Data collection efforts for this report were led by the CMRMP of the ODASD(E&ER)
and the OASD(IBP) and included engagement with the DoD Components and Military
Departments (MilDeps), industry, and industry associations.

“3M to Exit PFAS Manufacturing by the End of 2025” (December 20, 2022). https://news.3m.com/2022-12-203M-to-Exit-PFAS-Manufacturing-by-the-End-of-2025.
9
Securing Defense-Critical Supply Chains: An Action Plan Developed in Response to President Biden’s Executive
Order 14017 (February 2022). https://media.defense.gov/2022/Feb/24/2002944158/-1/-1/1/DOD-EO-14017REPORT-SECURING-DEFENSE-CRITICAL-SUPPLY-CHAINS.PDF.
8

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III.1 CMRMP Data Call
In March 2023, the CMRMP asked the DoD Components and MilDeps to provide
information about its critical uses of PFAS, to include use of neat PFAS, use of PFAS-containing
products, the functionality provided by the PFAS, specific uses and applications, and availabilityof alternatives (if known).
III.2 Additional Industry Engagement
The CMRMP held engagement sessions with various industries and industry associations
to obtain information about the PFAS and PFAS-enabled products that they (or their member
industries) manufacture and how DoD uses those products. The CMRMP shared thisinformation with the DoD Components and MilDeps to inform their data collection efforts.
III.3 OASD(IBP) Industry Sector Data Collection Process
The Kinetic Capabilities Team at Policy, Analysis, & Transition (PA&T), OASD(IBP),
engaged with PA&T Industry Sector leads and their industry partners to identify PFAS uses thatare critical to U.S. national security. These sectors include Kinetic Capabilities, Energy Storageand Batteries, Microelectronics and Semiconductors, Castings and Forgings, and Strategic andCritical Materials. The Sector leads identified PFAS uses in industry, operation, manufacturing,processes, components, parts, and materials. They also discussed how and where losing accessto PFAS could have significant mission readiness impacts and what they could do or are doing to
mitigate those impacts.

IV. Results
DoD’s known critical uses of PFAS are summarized in the following sub-sections,organized by focus area, and in the Appendix. The complexities in dissecting the defense
industrial base value chain and supply chain dependencies, in addition to the lack of transparency
in chemical and material content data, prevented the CMRMP from gathering comprehensive
data on all critical PFAS uses.
Critical PFAS uses were identified in almost every major weapon system category
including but not limited to fixed wing aircraft (trainers, fighters, bombers, transports, refuelers,
ground support, unmanned, and associated support equipment); rotary wing aircraft (attack,transports, heavy lifts, search-and-rescue, and associated support equipment); surface ships(combat, destroyers, aircraft carriers, cutters, landing crafts); submarines; missiles (air-to-air,ground-to-air, air-to-ground, ballistic); torpedo systems; radar systems; and battle tanks, assault
vehicles, and infantry carriers.
IV.1 Kinetic Capabilities
Kinetic capabilities represent a direct use of PFAS, as PFAS are found in a variety of
applications across the DoD munitions portfolio. About a dozen fluoropolymers, including

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fluoroelastomers, are ingredients in polymer bonded explosives, pyrotechnics, and propellant
components used in munitions, decoy flares, and chaff. They serve as high temperature resistantbinders and resins. These uses, which represent some of the few purely military PFAS
applications, include:•••

Unique binder materials specifically developed for use in the energetic portion of
conventional and strategic weapons platforms.
Fluoroelastomers, such as VitonTM, used as a binder in explosive and booster
charge formulations integrated into many DoD munitions.
Fluoropolymers, such as TeflonTM, used in pyrotechnics and as a material used in
the manufacture of munitions for a variety of missile systems.

PFAS are used in a variety of applications during energetics processing and testing.
Currently, non-PFAS alternatives do not exist for most of these applications, and the likelihoodof developing alternatives for these uses is estimated to range from moderate to almost
impossible. If available, alternatives require multi-year processes and cost program offices
millions of dollars to requalify every missile system that used the material, even if products are
similar.
IV.2 Energy Storage and Batteries
Impacts to national security from PFAS applications in energy storage and battery
applications are indirect. Manufacturers use fluoropolymers (e.g., polytetrafluoroethylene(PTFE)) and polyFAAs in multiple subcomponents in modern Li-ion batteries. They serve asheat transfer materials or insulation and provide weather resistance and ultraviolet (UV) lightresistant functionalities to final components. Military applications rely on Li-ion battery
technologies that are largely innovated in the civilian sector. Manufacturers use PFAS in theelectrolyte solutions, cathode binders, and separator coatings; and, to a lesser extent, PFAS arefound in casing materials and gaskets due to their deterioration resistance properties.
PFAS materials also play an important role in battery manufacturing. Filters and othercomponents of manufacturing equipment are essential to battery production. The battery
industry’s ability to make products for a broad range of commercial and military applications
would be greatly impacted if PFAS were no longer available for use in these components. The
significant time and money needed to identify and qualify alternatives as replacements would
cause ripple effects throughout the economy as consumers and users absorb the additional cost.
Fully eliminating PFAS from energy storage in the U.S. economy would likely take morethan 10 years. Energy storage is a broad issue for U.S. industrial competitiveness as well as animportant part of Federal initiatives around combating climate change. DoD is not the primaryconsumer of batteries in the United States, but battery supply chain issues would impact theability to produce missiles and field military vehicles that increasingly rely on batteries.

Report on Critical Per- and Polyfluoroalkyl Substance Uses6

IV.3 Microelectronics and Semiconductors
The semiconductor industry produces the chips that drive modern electronic devices.
The microelectronics packaging and assembly industry integrates these chips into the electronic
products used every day across the defense enterprise. In the semiconductor industry,fluoropolymers, fluoroelastomers, polyFAAs, and other fluorochemicals are used in a number ofapplications and at every stage of semiconductor fabrication. These uses include etchingmaterials (photoresists), etching coolants, masks in photolithography processes, packaging
materials that provide heat dissipation for the chip, and cleaning gases at various stages in the
microchip production process. Examples of specific PFAS in the semiconductor industry
include polyvinylidene fluoride (PVDF; a fluoropolymer), ethylenechlorotrifluoroethylene(ECTFE; a fluoropolymer), FKM/FFKM (fluoroelastomers), and perfluoroalkoxy alkanes(PFAs).
One significant use of PFAS in semiconductor manufacturing is during thephotolithography process, where the patterns that define the microchip circuitry are developed
onto bare silicon surfaces. Manufacturers use photolithography specialty formulations
containing fluorinated compounds in various steps of this process to ensure final chip quality andreduce the probability of defects. PFAS are ideal for these purposes due to their low surface
tension and compatibility with other chemicals. The PFAS materials used in these processes are
typically no longer present in the finished product, except in some specific applications, such as
imaging chips used in cameras, displays, and some medical devices.
Similar to the energy storage industry, PFAS are essential for semiconductor
manufacturing equipment and factory infrastructure. The exceptional combination of heat andchemical resistance and chemical inertness allows fluoropolymers to be used both in equipment
components (e.g., tubing, gaskets, containers, filters) and lubrication (e.g., various oils andgreases). These same properties are also needed to ensure the functioning of the surrounding
infrastructure.
In wider microelectronics applications, PFAS remain key industrial materials inapplications that integrate microchips into electronic products, such as printed circuit boards.
PTFE and PFA base laminate materials are currently used in many radio frequency (RF) andmicrowave circuits, as they provide unique properties related to isolating RF and microwave
signals. Identifying and qualifying potential replacement materials will require significant time,
particularly for use in fielded systems. There currently are no available drop-in replacement
materials for a PTFE designed printed board. Lack of access to PTFE laminate will necessitate
the redesign and requalification of the printed board, the assembly, and potentially the system.
Several PFAS-containing vapor phase soldering and flux removal products are used in
the manufacture of printed circuit boards. Vapor phase soldering is used primarily for printed
board assembly when there is a high thermal mass, in combination with advanced technologies
such as fine-pitch features, or when there are temperature sensitive components used.
Alternative materials are not currently identified and would need to be evaluated for performance

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and safety. New equipment may be required to implement new vapor phase soldering liquids.
PTFE cable jackets are used in printed circuit board and other electronic systems in connectors
and wire. PTFE has unique properties as a wire insulator including fire, smoke, and chemical
resistance to mitigate the risk of wire exposure in harsh environments. PTFE can withstand
450°C and is used widely in products that have been developed to meet MilSpec applications.
Manufacturers also use fluoropolymers as electronics sealants and encapsulants to protect
microelectronic components from degradation due to environmental, chemical, or UV-light
exposure. Vapor degreasing solvents, used in a variety of cleaning processes during
microelectronics production, contain hydrofluorocarbons (HFCs) and hydrofluoroolefins(HFOs), which, in many cases and in the broadest sense, are defined as PFAS. These materials
impart fire suppression properties to the degreasing solvent, creating safer manufacturing
environments for workers.
Currently, no alternatives to PFAS have been identified that can provide the functional
properties required for photolithography or some applications in semiconductor manufacturing
equipment. Even if alternative chemicals and technologies were discovered today, due to theextremely complex qualification process throughout the value chain, it would take another 15
years to deploy them in high-volume manufacturing. Therefore, continued access to PFAS is aprerequisite for high-volume and advanced semiconductors. Lack of continued access to PFAS
could lead to an inability to produce and supply semiconductor manufacturing technology.
Replacing most PFAS uses in semiconductor fabrication would require industry-wide retooling and other process innovations, at a minimum. Some might be achievable within 10
years, but many would not. As stated above, there are some PFAS uses for which no alternatives
are known. For these uses, it may be necessary to invent novel chemistries and processes.
Replacing PFAS in semiconductor fabrication could be a 25-year effort and may not succeed in
all respects if alternatives cannot be identified or qualified at the microchip level.
Consideration must also be given to the resultant impact on DoD programs. It is highly
probable that manufacturers would need to change semiconductor manufacturing processes toaccommodate PFAS replacements. This change has the potential to result in the costly
requalification of specific components. For example, radiation hardened microelectronics
applications typically mandate requalification if a manufacturer substantively alters the
fabrication process, which can easily exceed $10 million; many programs lack intrinsic funding
for requalification.
IV.4 Castings and Forgings and Strategic and Critical Minerals
Specialty fluorochemical gases and fluids are used for advanced metalworking, casting,and fabrication due to the temperature and wear resistance functionalities they provide. These
gases and fluids are used in the production of advanced metal parts throughout U.S. industry,including military-specific parts. Requiring a move to PFAS-free alternatives in under 10 years
may make construction using certain alloys impossible and require returning to previous methods

Report on Critical Per- and Polyfluoroalkyl Substance Uses8

of construction leading to lower performance, shorter life, and higher weight of constructedparts.
In both the casting and forging and strategic and critical minerals industries, loss ofaccess to PFAS is an indirect threat to national security and a potential source of significant
disruption to supply chains vital to the DoD mission. These industries depend on PFAS in
products used during normal business operations. A product used as a liquid cold spray incastings and forgings or coolant in drilling operations for critical minerals may contain PFAS,
but the product user would not know that PFAS are present until the product is discontinued.
Both industries are at risk of losing critical capabilities with little warning, as there are limited
requirements for companies to provide composition information for the materials used to create
the products they sell to DoD or on the commercial market. The risk for these industries isparticularly high, even if the probability is low, because there may be no warning for criticalproduct obsolescence and no ability to develop and qualify alternatives in a timely fashion.
PFAS are also contained in mold release chemicals and release films typically used incomposite manufacturing processes. Loss of access of PFAS would impact the commercial
composites manufacturing industry and, indirectly, the DoD who is reliant on the commercial
industry for applications.
Mold release chemicals are applied to mold hardware to prevent the composites fromstrongly adhering to the mold hardware during cure. The mold release chemicals typicallycontain PFAS chemicals or a PTFE polymer spray. Peel plies are used to prevent attachment ofvacuum bag materials and other disposable molding materials to the composite part and to imparta textured surface to the molded component to improve adhesion in secondary bonding or
painting. Peel plies are typically made of non-PFAS polymers, such as polyamides andpolyesters; however, to prevent adhesion of the composite to the peel ply, PFAS modification(most commonly) or silicone modification is done to the fabric. Additionally, if high curetemperatures are required, PTFE and PVDF peel plies are typically used. Polymer release films
are similar to peel plies but are generally used with composite resins that need to release gasses
during cure. Many of these release films are polyethylene, polypropylene, or other polyolefins
and work well for many applications; however, certain applications (typically higher temperature
curing systems) require use of fluoropolymers, such as PTFE, PVDF, and others. Pre-preg
release film is used to keep individual layers of pre-pregs (e.g., fabrics that are pre-impregnatedwith a fully curable, mixed resin system during manufacture) separated from each other within
the rolls of materials that are prepared and transported for use in composites manufacturing
facilities. Fluoropolymer release films are generally used to ensure the releasability of therelease film during composite layup. Silicones are also useable for this application but are
generally not used because of the low rigidity of silicone films.
IV.5 Additional Mission Critical PFAS Uses
Mission critical PFAS uses extend beyond the five industries discussed to this point.
DoD identified a range of additional critical uses for which the potential risk of supply chain

Report on Critical Per- and Polyfluoroalkyl Substance Uses9

disruption would undercut not only mission readiness but the U.S. economy. These uses are
discussed in more detail in the following sub-sections.
IV.5.1 Refrigeration and Air Conditioning, Cooling, and Electronics Thermal Control
Most refrigerants used in civil and military cooling and refrigeration applications can beclassified as PFAS. Many next-generation refrigerant alternatives adopted by U.S. industry (andU.S. households) between now and the end of 2025 are also PFAS. Under the AIM Act and
EPA technology transition regulations, the U.S. economy is in the process of switching from one
set of PFAS-classified refrigerants (e.g., HFCs) to a new generation of refrigerants (e.g., HFOs),
which are also, in the broadest definitions, considered to be PFAS. Known non-PFAS
alternatives (e.g., hydrocarbon or ammonia alternatives) pose flammability, toxicity, or highpressure concerns. The same PFAS that are used in quantities of several hundred million pounds
per year throughout the U.S. economy for cooling applications are used in much smaller
quantities (i.e., a fraction of one percent) for military cooling and military thermal control of all
kinds.
IV.5.2 Fire Suppression in Naval Vessels, Aircraft and Ground Combat Vehicles
Fluorochemical specialty gases are used in “clean agent” fire suppression in naval
vessels, aircraft, and ground combat vehicles. Most known clean agent, low-corrosion, lowweight, low-toxicity alternatives will likely be classified as PFAS, broadly defined.
Since the advent of regulations against halogenated agents, Naval vessels commonly
utilize an HFC clean agent in compartments subject to flammable/combustible liquid fuel fires
such as engine modules and hazardous material storage spaces. For new U.S Naval ship designs,
the Navy continues to move to alternate fire suppression technologies (e.g., water mist) where
suitable, however limited use of HFC remains for those spaces where the alternatives are notappropriate. For existing ship HFC uses, there is no “drop-in” replacement for these HFC
agents.
Well over 10 million pounds of PFAS fire suppressants are installed in civil aircraft
engine, cargo compartment, and lavatory fire suppression systems, and in hand-held aircraft fire
extinguishers, worldwide. This includes halons (which meet PFAS definitions but are frequently
excluded from draft PFAS regulations because they are separately covered by ozone depleting
substance regulations) and all currently implemented aviation replacements for halons. In 2022,
Working Paper 96 presented at the 41st Assembly of the International Civil Aviation
Organization recommended considering PFAS use in aircraft fire suppression an essential use inprospective PFAS regulations to maintain progress in replacing halons. 10

International Civil Aviation Organization (ICAO), Working Paper 96: Aircraft Halon Replacement, A41-WP/96,
28 July 2022. https://www.icao.int/Meetings/a41/Documents/WP/wp_096_en.pdf.
10

Report on Critical Per- and Polyfluoroalkyl Substance Uses10

IV.5.3 Aqueous Film Forming Foam
Mission critical ocean-going vessels employed by DoD and the Military Services
continue to use aqueous film forming foam (AFFF) containing PFAS for combating Class B(flammable/combustible liquid) fuel spill fires. U.S. Navy ships are required to use AFFF
qualified to MIL-PRF-24385. MIL-PRF-24385 qualified AFFF provides the capability to
rapidly control and extinguish shipboard fires. AFFF is critical for fire emergencies on flightdecks where aircraft movement, fueling, launch/recovery, and weapons loading occur, andsubstantial risk exists for loss of aircraft, ship, and life if a fire is not rapidly controlled andextinguished.
Past flight deck fires, such as those that occurred on the United States Ship (USS)FORRESTAL, USS ENTERPRISE, and USS NIMITZ, all demonstrate the potential for suchcatastrophic events to occur. The risk of devastating loss of life and warfighting capability inincidents such as these, and the more recent fire emergency which resulted in the loss of the USS
BONHOMME RICHARD, necessitates the use of the most effective firefighting agentsavailable.
Beyond the potential for the immediate loss of life and impacts to operational capability
that can result from an uncontrolled fire on a warship, the defense industrial base has limitations
with respect to repairing or delivering replacement national security assets, including ordnance,
aircraft, and ships. It could take a decade or longer to replace large amphibious assault ships andaircraft carriers.
Currently available fluorine-free foams (F3s) have significant limitations compared to
AFFF that preclude their use on DoD ocean-going vessels, including the U.S. Navy fleet. Thoselimitations include reduced firefighting performance; chemical and physical properties that makethem unsuitable for use with existing ship firefighting foam storage and delivery systems; andcross-agent compatibility issues. There are currently no equivalent, fully performing firefighting
alternatives to AFFF for shipboard use.
DoD continues to sponsor research and development for F3 technologies to address theselimitations, with the goal that continued technology improvements will support efforts toward afuture path for use on ships. To date, DoD has invested approximately $45.8M since 2017
toward the development and qualification of F3 technologies.
Until such time that a capable F3 alternative is found, the safety and survivability ofnaval ships and crew from shipboard fires depends on the continued availability of MilSpec
AFFF products and their PFAS-containing constituents, which were formulated, tested, qualified,and implemented in order to save lives and military assets.
IV.5.4 Lines, Hoses, O-Rings, Seals and Gaskets, Tapes, and Cables and Connectors
Dozens of different fluoropolymers (e.g., PVDF, ECTFE, PTFE) and fluoroelastomers(e.g., FKM/FFKM) are critical to modern UV-resistant, ozone-resistant, weather-resistant,
Report on Critical Per- and Polyfluoroalkyl Substance Uses

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temperature-resistant, high pressure-resistant, chemical-resistant “rubberized” fuel lines. They
are also key materials in hoses, tubing, hydraulic system lines, O-rings, seals and gaskets, tapes,
and cables and connectors widely used in civil and military aircraft, space systems, vehicles,
weapon systems, utility systems, and other applications. Alternatives are not as resistant toembrittlement and break-down and have a much shorter useful life, leading to more frequent part
replacement, which is not feasible for space or satellite uses.
IV.5.5 Electronic/Dielectric Fluids
Fluorochemicals are found in electronic and dielectric fluids that are used in civil andmilitary radars and high-power electronics and electrical system/utility system components
because of their dielectric and heat transfer properties. Industry and DoD have repeatedly
investigated alternatives for these applications. Known alternatives have high global warming
potential (e.g., sulfur hexafluoride) or may pose health/environmental risks (e.g., thepolychlorinated biphenyls banned by the U.S. Toxic Substances Control Act and the Stockholm
Convention on Persistent Organic Pollutants). Examples of PFAS-containing electronic/
dielectric fluids used by DoD include 3M™ Fluorinert™ Electronic Liquids FC-40, FC-72, FC770, and FC-3283.
IV.5.6 Advanced Oils, Greases, Fluids, and Lubricants
PFAS are used in many advanced turbine engine oils, greases, fluids, and lubricants dueto their wear- and heat-resistant properties. These uses are common throughout the mostdemanding applications in the U.S. civil transportation, industrial, and space sectors. Analogous
PFAS-containing oils, lubricants, and fluids are used in military critical ground, sea, air, andspace applications. Previous generations of oils, fluids, and lubricants approached, but did notequal, the performance of PFAS additives that have become more prevalent in high performanceoils, greases, fluids, and lubricants over the past 20 years.
Castrol Braycote 640AC is an example of a PFAS-containing grease, designed to beoxidizer and propellant compatible for use in aerospace vehicles, spacecraft, rocket and aircraft
engines, and associated ground support equipment, oxygen equipment, and transport equipment.
Braycote 640AC is typically used to lubricate threaded fasteners, connectors, valves, gaskets,
elastomers, and bearings. Perfluorinated greases, in general, exhibit excellent shelf lives due totheir intrinsic inertness.
Two additional examples of PFAS-containing greases used by DoD (and original
equipment manufacturers and the maintenance, repair, and overhaul industry) are NYCO
GREASE GN25013 and NYCO GREASE GN617. PTFE is used as a thickener in both products
and perfluoropolyether is used as the base stock for GN617.
IV.5.7 Precision Cleaning Fluids
Fluorochemicals are used in precision cleaning applications, including the cleaning ofsensitive oxygen systems in civil and military aerospace.
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IV.5.8 Degreasing/Cleaning Fluids
The MilDeps reported the use of PFAS-containing degreasing/cleaning products andcontact cleaners (e.g., 3M™ Novec™ Engineering Fluids, 3M™ Novec™ Contact Cleaners,
3M™ Novec™ Contact Cleaner/Lubricant) in vapor degreasing and flux removal.
The Army reported the use of FCC2 Enhanced Fiber Connector Cleaner and Preparation
Fluid, which contains butane, 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy, for cleaning fiber optic
connectors in secure link manager assemblies and primary modem assemblies.
The MilDeps reported the use of fluorinated non-destructive testing (NDT) solvent
cleaner/remover for precleaning before NDT and for removing excess surface penetrant from aninspection area before applying developer during liquid penetrant testing.
The MilDeps also reported that PFAS-containing degreasers are used to effectively
remove grease, oil, tar, and other substances from military equipment to increase its operating
efficiency. These degreasers leave no residue, have no flash or fire point, and serve as analternative to legacy solvents (e.g., n-propyl bromide, trichloroethylene, tetrachloroethylene).
IV.5.9 Adhesives
The MilDeps reported the use of the following adhesives, which contain PFAS: 3M™
Super Foam Fast Spray Adhesive 74-Orange, 3M™ Hi-Strength Spray Adhesive 90 (aerosol),and 3M Scotch-Weld Epoxy Adhesive DP420 Off-White, Part A.
IV.5.10

Insulation and Foam Blowing

Fluorochemicals are components of insulation and foam blowing products used in civil
and military aircraft and space vehicles/rocket motors.
IV.5.11Resins for Specialty Materials

Fluoropolymers are used in resins for specialty high-temperature or weather-/UVresistant composites due to their temperature-, pressure-, wear-, and chemical-resistanceproperties. Fluoropolymers are also used in high cleanable, high weathering and chemical
resistant coatings for military assets. Many aircraft topcoats contain fluoropolymer resins due totheir UV and chemical resistance properties. PFAS are not actually in the coatings themselves
but are used in fluoropolymer resin manufacturing.
Moving to alternatives in under 10 years may require a return to previous methods ofparts construction which produced shorter life and higher weight composites with lower
performance characteristics.

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IV.5.12

Specialty Filters and Membranes

Fluoropolymers are used in specialty filters and membranes (e.g., aviation filters) due totheir temperature-, pressure-, and wear-resistance properties. PFAS are also found in several air
filtering masks and air filtering respirators used by DoD.
IV.5.13Fabrics, Fabric Liners, and Fabric Barriers

A variety of textiles used in uniform clothing and footwear items, tents, and duffle bags
are treated with PFAS to repel water and oils while providing durability to laundering, UV light
exposure, and temperature cycling. The main PFAS used on textiles are fluoropolymers, such as
PTFE and short chain PFAS, known as C6 or C4 chemistries. PFAS can be incorporated as anadditive mixed into individual fibers or sprayed as a coating onto finished fabrics during
manufacturing or after sale and are present in/on textiles in two forms: a non-polymerizedcompound that can be washed out or evaporated or as a molecule integrated into a fluorine freepolymer network via covalent bonds. The MilDeps reported the use of PFAS in chemical,
biological, radiological, and nuclear protective equipment (the Uniform Integrated Protection
Ensemble Family of Systems) and in a number of uses within health care communities.
Coretech, the biological protective fabric lining used on the Joint Biological Agent
Decontamination System, includes a barrier layer for biological protection during thedecontamination of aircraft. The barrier layer contains PFAS.
IV.5.14

Customized Applications

Customized applications like gyroscope suspension fluids and analytic gases and fluids
for thermometric and other sensors use specialty fluorochemicals because of theirpressure-resistant, wear-resistant, and temperature control properties. These applications requirevery small quantities of specialty PFAS and are particularly susceptible to disruptions in PFAS
supply chains due to challenges in attracting manufacturers to develop low-volume commodities.

V. Conclusions
This report summarizes known direct and indirect uses of PFAS that are critical to thenational security of the United States, but it is not comprehensive. Also highlighted are thechallenges and costs related to finding and qualifying alternatives to existing PFAS materials in
sectors of strategic importance to DoD. The information contained in this report is limited towhat was available at the time of its drafting. As such, the information presented represents a
fraction of the mission critical PFAS uses due to a lack of transparency in the chemicalcomposition in consumables and articles. In addition, there is significant uncertainty regarding
the presence of PFAS in products that make up a complex value chain. A more complete
understanding of PFAS essential uses would require an extensive and complex evaluation of themarket, a gap analysis of current requirements for manufacturer-provided product information,and illumination of the value chain of products.
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PFAS are critical to DoD mission success and readiness and to many national sectors ofcritical infrastructure, including information technology, critical manufacturing, health care,renewable energy, and transportation. DoD relies on an innovative, diverse U.S. industrial
economy. Most of the structurally defined PFAS are critical to the national security of theUnited States, not because they are used exclusively in military applications (although a few are)but because of the civil-military commonality and the potentially broad civilian impact. This
report provides details on what is currently known about direct and indirect mission critical
PFAS uses that could impact mission readiness if the substances are no longer available.
Emerging environmental regulations focused on PFAS are broad, unpredictable, lack the
specificity of individual PFAS risk relative to their use, and in certain cases will have unintended
impacts on market dynamics and the supply chain, resulting in the loss of access to mission
critical uses of PFAS. These market responses will impact many sectors of U.S. criticalinfrastructure , including but not limited to the defense industrial base. Collectively,international and U.S. regulatory actions to manage PFAS’ environmental impacts and identify
and eliminate PFAS from the market, and the resulting market changes, pose risks to DoD
operations and the defense industrial base supply chain. In addition, impacts to the global PFAS
supply chain will present risks to the DoD Foreign Military Sales program and to North Atlantic
Treaty Organization interoperability.
The Department will continue to oversee coordinated lines of effort to expeditiously
identify essential uses of PFAS, prioritize actions according to vulnerabilities to national
security, and address mission readiness associated with the potential loss of access to PFAS.
Actions include:● Implementing DoD PFAS policy directing the DoD Components and MilDeps todetermine the PFAS content in DoD weapon systems, to the extent feasible, andenabling continued access to mission critical uses, while encouraging safe use by
DoD personnel and adoption of PFAS-free alternatives.
● Engaging with industry to identify PFAS content in other materials commonlyused within the DoD to assess potential obsolescence risks and potential PFAS
alternatives.
● Engaging with industry and federal agencies during routine meetings to assess
obsolescence risks, mission criticality, and potential PFAS alternatives.
● Investing in research, development, and qualification efforts required todemonstrate conformance with Military Standards or Specifications.
● Collaborating across the Federal Government to develop a long-term researchplan for the most challenging applications where it will take a decade or more tofind viable replacements.
● Investing in research to support advanced manufacturing approaches byimproving purification, deconstruction technologies, scale-up of sustainable
materials design and manufacturing, and circularity for the most critical andirreplaceable PFAS.

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Concurrent with efforts to identify essential uses of PFAS, the Department is phasing out
non-essential and non-critical PFAS uses in accordance with NDAA requirements where there isno mission impact (e.g., in food packaging, cookware, furniture, personal protective firefighting
equipment). Additionally, per the 2023 U.S. Government Accountability Office (GAO)
recommendations, 11 the Department is developing an approach to implement the April 2023
prohibition for military exchange resale procurements. The Department is also updating DoD
Instruction 4105.72, Procurement of Sustainable Goods and Services, to include procedures
specifically targeted to implementing the provisions of Executive Order 14057, Catalyzing Clean
Energy Industries and Jobs Through Federal Sustainability, with respect to limiting the
procurement of items containing PFAS.
Eliminating PFAS from non-essential uses is an important step toward addressing publicconcerns and protecting human health and the environment. Mission critical PFAS uses provide
significant benefits to the framework of U.S. critical infrastructure, and national and economic
security. DoD will consider future policy actions to manage non-essential and essential PFAS
uses and will implement these actions with the intent of protecting human health and theenvironment while ensuring no adverse impacts to U.S. critical infrastructure and national
security.
If future PFAS legal and regulatory frameworks ignore the OECD caution on the use of
its PFAS definition and seek to broadly restrict the use of PFAS based on chemical structure,
there could be extensive economic, industrial competitiveness, and quality-of-life impacts to
U.S. society. The PFAS universe is structurally and physiochemically diverse and subgroups of
PFAS may be more or less stable, persistent, and/or bioaccumulative compared to well-studied
PFAS such as perfluorooctane sulfonate and perfluorooctanoic acid. 12 Congress and the Federal
regulatory agencies should avoid taking a broad, purely “structural” approach to restricting or
banning PFAS. It is critical that future laws and regulations consider and balance the range ofenvironmental and health risks associated with different individual PFAS, their essentiality to the
U.S. economy and society, and the availability of viable alternatives.

U.S. Government Accountability Office (GAO). Persistent Chemicals: Actions Needed to Improve DoD’s Ability
to Prevent the Procurement of Items Containing PFAS. GAO-23-105982. April 2023.
12
EPA Framework for Estimating Noncancer Health Risks Associated with Mixtures of Per- and Polyfluoroalkyl
Substances (PFAS) (Public Review Draft), EPA-822-P-23-003 (March 2023).
11

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Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Time Frame / Cost to
Develop and Qualify
Alternatives*

Application

Functionality

Availability of Alternatives

Ingredients in binders andresins used in PBX,
pyrotechnics, and propellant
components that are used in avariety of applications acrossthe DoD munitions portfolio.

High temperature resistance

NA*

NA

Used in energetic slurry
processing.

Enables high levels of mixing
between key energetic
components.

NA

NA

NA

NA

NA

Serve as heat transfer material
or insulation. Provide
weather-resistance, UV
light-resistance, anddeterioration-resistanceproperties.

NA

Fully eliminating PFAS fromenergy storage in the U.S.
economy would likely take10+ years.

NA

Possibly available

Time and cost to identify andqualify alternatives would besignificant and have ripple
effects throughout theeconomy.

Dielectric, heat transfer, andinsulation functionalities.

Currently no alternatives to
PFAS for photolithography.

NA

Kinetic Capabilities
Fluoropolymers (e.g.,
Teflon™)
Fluoroelastomers (e.g.,Viton™)
PFAS

Enable energetics laboratory
research. Are critical fordeveloping and transitioning
new energetic materials.
Energy Storage and Batteries
Fluoropolymers (e.g.,
Multiple subcomponents inpolytetrafluoroethylene
modern Li-ion batteries:(PTFE))
electrolyte solutions, cathodebinders, separator coatings,
Polyfluoroalkyl acids
casing materials, and gaskets.
(PolyFAAs)

Fluorinated performance
fluids (e.g., 3M™
Fluorinert™ fluids)

PFAS

Battery manufacturing: filtersand other components
essential to production.

Microelectronics and Semiconductors
Fluoropolymers
Semiconductor fabrication:
Fluoroelastomers
etching materials and masks inphotolithography processes;
PolyFAAs
cleaning gases.
Other PFAS

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Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Fluoropolymers

Application

Semiconductor manufacturing
equipment and factory
infrastructure: equipment
components (e.g., tubing,gaskets, containers, filters)
and lubrication (various oils
and greases).

Report on Critical Per- and Polyfluoroalkyl Substance Uses

Functionality

Availability of Alternatives

Heat and chemical resistance,and chemical inertness.

Currently no alternatives forsome applications insemiconductor manufacturing
equipment. Replacing most
PFAS uses in semiconductor
fabrication would require
industry-wide re-tooling andother process innovations.
Some might be achievable
within 10 years, but many
would not.

Time Frame / Cost to
Develop and Qualify
Alternatives*
Development of alternatives
for some uses may require theinvention of novel chemistries
and processes. Due to theextremely complex
qualification process, it would
take another 15 years to
deploy alternatives, once
developed, in high-volume
manufacturing. Replacing
PFAS in semiconductor
fabrication could be a 25-year
effort and may not succeed in
all respects if alternatives
cannot be identified or
qualified at the microchip
level. Replacing PFAS has
the potential to initiate costly
requalification of specificcomponents. Example:
radiation hardened
microelectronics applications
typically mandate
requalification if amanufacturer substantively
alters the fabrication process,which can easily exceed $10
million.

A-2

Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Application

Availability of Alternatives

Microelectronics applications:base laminate materials usedin many RF and microwave
circuits.

Provide unique properties
related to isolating RF andmicrowave signals. Used inradar, antenna, guidancesystems, 5&6 G infrastructure,and other network/transmission applications.

There is no drop in alternative
material. Any material
replacement for fieldedsystems would requireredesign of the printed board
and potentially the electronicsystem to account for material
property differences. Fieldedsystems that have beenredesigned may require
requalification.

Manufacture of printed circuitboards (PCBs): vapor phasesolder and flux removerproducts.

Vapor phase soldering process
is used for PCB assemblies
with high thermal mass, finepitch structures, andtemperature-sensitive
components to minimize risk
to materials, structures andcomponents. The material
stability and flame retardantqualities are well suited for theenclosed high temperature
operation of the process.

It is unknown if there aresuitable materials that can beused, however it is likely thatcurrent equipment may need
to be replaced or modified toaccommodate the replacement
materials.

Developing and evaluating
new materials could take 5
years or more. Equipment
replacement would add timeand have a cost impact.

It is unknown if there aresuitable replacement materials
for all of the applications for
PTFE wire jacket material.
PTFE is higher cost than someother wire jacket materials.
When it is selected for use
there are typically no othersuitable replacement
materials.

Qualification of alternatives
will be both costly and time
consuming. Many materials
will require new UL or othercertification body approval
before they can be
implemented. Many current
products are MilSpec
certified.

PTFE

PFA

PFAS

PTFE

Time Frame / Cost to
Develop and Qualify
Alternatives*
Developing and or identifying
suitable alternative materials
and qualifying them could bea forward-looking action for
all future DoD systems. This
however does not address
sustainment of existing
systems. There will continue
to be a need to have PTFE
laminate materials available
for system sustainment until
all systems currently designedwith PTFE are retired.

Functionality

PCBs: cable jackets used in
PCB connectors.

Report on Critical Per- and Polyfluoroalkyl Substance Uses

Used because it has excellent
fire, smoke, and chemical
resistance. Wide temperature
range -200 to 260C constantuse and up to 450C for peak
exposure.

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Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Application

Functionality

Castings and Forgings and Strategic and Critical Minerals
Advanced metalworking,casting, and fabrication
Specialty
processes used in theTemperature and wear
fluorochemical gases
production of advanced metal
resistance.
and fluids
parts throughout U.S.
industry, including militaryspecific parts.
Mold release chemicals andPrevent composites from
PTFE, PVDF, otherrelease films typically used instrongly adhering to mold
PFAS
composite manufacturing
hardware.
processes.
Refrigeration and Air Conditioning, Cooling, Electronics Thermal Control
HFOs

Next-generation refrigerant
alternatives (to HFCs) used incivil and military cooling andthermal control applications.

NA

Moving to alternatives inunder 10 years may require
returning to previous
construction methods and may
make construction using
certain alloys impossible.

NA

NA

Known non-PFAS alternatives(e.g., hydrocarbon orammonia alternatives) pose
flammability, toxicity, or
high-pressure concerns.

NA

NA

Most known clean agent, lowcorrosion, low-weight, lowtoxicity alternatives will likely
be classified as PFAS, broadly
defined.

NA

MIL-PRF-24385 qualified
AFFF provides the capability
to rapidly control andextinguish shipboard fires.

Current F3s have significant
limitations compared to AFFF
that preclude their use on DoD
ocean-going vessels, including
the U.S. Navy fleet.

NA

NA

Fire Suppression in Aircraft and Ground Combat Vehicles
Fluorochemical
specialty gases“Clean agent” fire suppression
in aircraft and ground combat
vehicles.

Aqueous Film Forming Foam (AFFF)
AFFF use to combat Class B(flammable/combustible
liquid) fuel spill fires on
PFAS
mission critical ocean-goingvessels employed by DoD andthe Military Services.

Report on Critical Per- and Polyfluoroalkyl Substance Uses

Time Frame / Cost to
Develop and Qualify
Alternatives*

Availability of Alternatives

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Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Application

Functionality

Lines, Hoses, O-Rings, Seals and Gaskets, Tapes, and Cables and Connectors
Critical to modern“rubberized” fuel lines. Key
Fluoropolymers (e.g.,materials in hoses, tubing,
Functionalities include UVPVDF, ECTFE, PTFE)
hydraulic system lines, Oresistance, ozone-resistance,rings, seals and gaskets, tapes,
weather-resistance,and cables and connectors
temperature-resistance, highwidely used in civil andpressure-resistance, andmilitary aircraft, space
Fluoroelastomers (e.g.,chemical resistance.
systems, vehicles, weapon
FKM/FFKM)
systems, utility systems, andother applications.
Electronic/Dielectric Fluids

Fluorochemicals

Used in electronic anddielectric fluids used in civil
and military radars, highpower electronics, andelectrical system/utility
system components.

Advanced Oils, Greases, Fluids, and Lubricants
Used in many advanced
turbine engine oils, greases,
fluids, and lubricants common
throughout the U.S. civil
PFAS
transportation, industrial, andspace sectors. Analogous oils,
lubricants, and fluids are usedin military critical ground, sea,
air, and space applications.

Report on Critical Per- and Polyfluoroalkyl Substance Uses

Provide dielectric and heattransfer properties.

Wear- and heat-resistantproperties.
Perfluorinated greases exhibit
excellent shelf lives due totheir intrinsic inertness.

Time Frame / Cost to
Develop and Qualify
Alternatives*

Availability of Alternatives

Alternatives are not as
resistant to embrittlement andbreak-down and have a much
shorter useful life, leading tomore frequent part
replacement, which is not
feasible for space or satellite
uses.

NA

Industry and DoD haverepeatedly investigatedalternatives in theseapplications. Known
alternatives have high global
warming potential (e.g., sulfur
hexafluoride) or may pose
health/environmental risks(e.g., the polychlorinatedbiphenyls).

NA

Previous generations of oils,
fluids, and lubricants
approached, but did not equal,
the performance of PFAS
additives that have become
more prevalent in highperformance oils, greases,
fluids, and lubricants over the
past 20 years.

NA

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Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Application

Functionality

Time Frame / Cost to
Develop and Qualify
Alternatives*

Availability of Alternatives

Precision Cleaning Fluids

Precision cleaning
applications such as cleaning
Fluorochemicals
of sensitive oxygen systems incivil and military aerospace.
Degreasing / Cleaning Fluids
Degreasing/ cleaning products
and contact cleaners used invapor degreasing and flux
removal.
Non-destructive testingsolvent cleaner/remover used
for precleaning and forremoving excess surface
PFAS
penetrant before applying
developer during liquid
penetrant testing.
Degreasers used to effectively
remove grease, oil, tar, andother substances from militaryequipment to increase its
operating efficiency.
Connector cleaner andpreparation fluid used for
Butane,cleaning fiber optic connectors
1,1,1,2,2,3,3,4,4in secure link manager
nonafluoro-4-methoxy
assemblies and primarymodem assemblies.
Insulation and Foam Blowing
Components of insulation andfoam blowing products used
Fluorochemicals
in civil and military aircraft
and space vehicles/rocket
motors.

Report on Critical Per- and Polyfluoroalkyl Substance Uses

NA

NA

NA

NA

NA

NA

NA

NA

NA

Leaves no residue, has no
flash or fire point, and serves
as an alternative to chlorinatedsolvent-based cleaners (e.g.,
1,1,1-trichloroethane).

NA

NA

NA

NA

NA

NA

NA

NA

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Appendix: Summary of Known Mission Critical PFAS Uses

PFAS

Application

Functionality

Resins for Specialty Composites

Fluoropolymers

Resins for specialty hightemperature or weather-/UVresistant composites.

Specialty Filters and Membranes
Used in specialty filters andFluoropolymers
membranes (e.g., aviation
filters); and in air filteringmasks and air filtering
PFAS
respirators used by DoD.
Fabrics, Fabric Liners, Fabric Barriers• Fabrics used in a variety of
uniform clothing andfootwear items, tents, andduffle bags.
• Reported use in chemical,
biological, radiological, andPFAS
nuclear protective
equipment.
• Used in the biologicalprotective fabric lining usedin the Joint Biological Agent
Decontamination System.
Customized Applications
Used in customized
applications like gyroscope
Specialtysuspension fluids and analytic
fluorochemicals
gases and fluids forthermometric and othersensors.

Time Frame / Cost to
Develop and Qualify
Alternatives*

Availability of Alternatives

Temperature-, pressure-,
wear-, and chemical-resistanceproperties.

NA

Moving to alternatives inunder 10 years may require areturn to previous methods ofparts construction and an
acceptance of lower
performance, shorter life, andhigher weight composites.

Temperature-, pressure-, andwear-resistance properties.

NA

NA

Water and oil repellency.

NA

NA

Pressure-resistant,wear-resistant, andtemperature control properties.

NA

NA* NA = no information provided through data collection efforts.
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