There are currently more than 4,700 known per- and polyfluoroalkyl substances—more commonly known as PFAS—and these numbers are growing as industry continues to invent new PFAS chemicals.

Because of their persistence in the environment, persistent nature, and widespread use in firefighting foams and products that resist grease, water, and oil, PFAS are found in the blood of people and animals all over the world. In fact, a 2011-2012 report by the Centers for Disease Control (CDC) and Prevention National Health and Nutrition Examination Survey (NHANES) found PFAS in the blood of 97% of Americans tested.

As of August 2021, 2,854 locations in 50 states and two territories are known to be contaminated with PFAS (Environmental Working Group (EWG)). Because of the sheer magnitude of chemicals that fall into this category and its persistence in the environment, PFAS contamination is an extremely complicated issue to regulate and manage—one that no single agency will be able to address alone. And one that industry must pay attention to, because it is not going away.  

Preparing for the Perfect PFAS Storm

All the various impact studies, regulatory actions, and legislative efforts are coming together to form a perfect PFAS storm, and industry must be ready to respond. Consider the following questions and best management practices (BMPs):

• Have you considered the risk(s) of introducing PFAS to your site—or do you know what PFAS you currently have on your site (either in current use or due to historical contamination)?
• Do you have an environmental management system (EMS) to help identify, manage, and prevent the risks associated with PFAS? Is PFAS included as part of your aspects and impacts analysis?
• Do you have the appropriate operational controls and training in place to prevent or minimize a fire at your facility?
• Do you have an Emergency Response Plan?
  • Have you contacted your local emergency responders to discuss the potential for using PFAS-containing aqueous film-forming foam (AFFF) at your facility in the event of a fire?
  • Do you have an emergency response checklist? Does it include inquiring about the foam being used to fight a fire?
  • Have you evaluated when and how to use PFAS-containing foams considering likely fire hazards; properties of the foam; nature of the emergency; risks to life, public safety, and property; and potential environmental, public health, and financial liabilities?
  • Do you conduct any emergency response testing that includes the use of AFFF?
  • Do you have controls in place (e.g., floor drain covers) and adequate supplies to keep foam runoff from leaving your site in the event of a fire?

PFAS Primer

PFAS are a group of manmade chemicals that have been manufactured and used in a variety of industries since the 1940s. PFAS can be found in:

• Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAS-contaminated soil/water
• Commercial household products (e.g., stain- and water-repellent fabrics, nonstick products, polishes, waxes, paints, cleaning products)
• Firefighting foams (i.e., aqueous film-forming foam (AFFF))
• Industries such as chrome plating, electronics manufacturing, oil recovery, automotive
• Drinking water, typically associated with a manufacturer, landfill, wastewater treatment plant (WWTP), firefighter training facility, etc.

PFAS are made of chains of carbon and fluorine linked together. This carbon-fluorine bond is one of the shortest and strongest bonds in nature. It does not easily break down under natural conditions—hence the reason PFAS are often referred to as “forever chemicals”. Correspondingly, PFAS are very persistent in the environment and the human body, where they bioaccumulate in blood and organs over time.

Scientific studies have begun to show that exposure to some PFAS may be linked to harmful health effects in humans and animals, including developmental delays, reproductive health issues, neuroendocrine issues affecting the kidneys and liver, cancer, thyroid imbalances, and cardiovascular concerns.

Most PFAS exposure comes through ingesting food and water that becomes contaminated with PFAS when it migrates into soil, water, and air during use and/or disposal. Disposal of PFAS-containing items into municipal solid waste landfills can be a significant source of PFAS transport and contamination since PFAS can migrate into the leachate collection system. Since wastewater treatment does not remove PFAS, the subsequent use of wastewater biosolids as fertilizer, etc. may further distribute PFAS into the soil, surface water, and groundwater.

Focus on Firefighting Foam

Aqueous film-forming foam (AFFF) is highly effective foam for fighting high-hazard flammable liquid fires that has garnered a lot of attention for its role in contributing to PFAS contamination. AFFF are Class B commercial firefighting foams historically produced with PFOS or polyfluorinated precursors that break down to PFOA—the two most extensively produced and studied PFAS chemicals. Long-chain PFAS like PFOS and PFOA are of particular concern because they are recognized as persistent, bioaccumulative, and toxic (PBT).

When used, AFFF has the potential to create adverse environmental impacts, particularly if the foam is uncontrolled and reaches drinking water sources, groundwater, or surface waters. Many states and companies have been forced to deal with the aftermath of PFAS used to extinguish fires. State legislatures are considering not only how to remediate the chemicals found on these sites, but also who is responsible for the associated cleanup.

Regulatory Actions

Federal regulatory action related to the management of PFAS contamination thus far has been limited. However, on October 18, 2021, EPA Administrator Michael Regan announced EPA’s comprehensive Strategic Roadmap to tackle PFAS contamination. According to the EPA press release, the Roadmap is centered on three guiding strategies:

1. Increase investments in research.
2. Leverage authorities to act now to restrict PFAS chemicals from being released into the environment.
3. Accelerate cleanup of PFAS contamination.

Strategies are intended to advance more concrete actions that will address the entire lifecycle of PFAS chemicals. Per EPA, this specifically includes:

• Aggressive timelines to set enforceable drinking water limits under the Safe Drinking Water Act (SDWA) to ensure water is safe to drink in every community.
• A hazardous substance designation under CERCLA, to strengthen the ability to hold polluters financially accountable.
• Timelines for action on Effluent Guideline Limitations under the Clean Water Act (CWA) for nine industrial categories.
• A review of past actions on PFAS taken under the Toxic Substances Control Act (TSCA) to address those that are insufficiently protective.
• Increased monitoring, data collection, and research so that the agency can identify what actions are needed and when to take them.
• A final toxicity assessment for GenX, which can be used to develop health advisories that will help communities make informed decisions to better protect human health and ecological wellness.
• Continued efforts to build the technical foundation needed on PFAS air emissions to inform future actions under the Clean Air Act (CAA).  

Along with the Roadmap, EPA has also announced a new testing strategy requiring PFAS manufacturers to provide EPA with toxicity data and information on categories of PFAS chemicals.

Congress has also been working to develop legislation in absence of federal regulations, with more than 80 pieces of legislation introduced within the 116th Congress. The fiscal year 2021 omnibus appropriations bill included nearly $300 million to address the regulation and cleanup of PFAS split among several federal agencies, including Department of Defense (DOD) – remediation efforts; EPA – scientific, regulatory, and cleanup work; and Food and Drug Administration (FDA) – safety of PFAS in food packaging.

In addition, states are taking their own measures. In 2020, state legislatures considered over 180 bills related to PFAS, many of which have focused on efforts such as restricting PFAS in firefighting foam and consumer products, regulating PFAS in drinking water, and appropriating funds for remediation activities. For more information on state actions, visit:

• Safer States
• Environmental Council of the States

Seeking Assistance

KTL does not see the challenges associated with PFAS going away any time soon. If anything, we anticipate more and more facilities will be directly impacted by mitigation efforts and future regulatory action. Proper usage strategies, a comprehensive EMS, and a forward-thinking Emergency Response Plan will remain vital tools for companies potentially dealing with PFAS to effectively manage the associated risks.

If you are facing challenges related to PFAS or would just like a fresh set of eyes to evaluate your current environmental risk level, please contact KTL. Our staff has hands-on experience assessing environmental risks and developing strategies to minimize them to the extent possible. Our team writes Emergency Response Plans and routinely works with LEPCs to coordinate emergency response efforts and exercises to keep communities informed and safe. In addition, we have a strong network of partners that can assist with testing and remediation strategies, when necessary.

Read the entire October 18, 2021 EPA press release: EPA Administrator Regan Announces Comprehensive National Strategy to Confront PFAS Contamination.

As discussed in Part 3 of KTL’s series on Creating Sustainable Impacts, wasting food has impacts on the sustainability of our economy, our society, and the environment. Whether it comes from filling landfills, contributing to greenhouse gas (GHG) emissions, consuming valuable resources, or contributing to food insecurity, the magnitude of these impacts is substantial.

Food loss occurs at every stage of the supply chain—from farm to table. How that loss is managed plays a vital role in how it impacts our society. Federal and state regulatory agencies are taking notice of this and incenting—or requiring—organizations to incorporate sustainable food management practices into their operations.

Joining Forces to Address Wasted Food

In 2016, the Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA), and Food and Drug Administration (FDA) joined forces to address the magnitude of wasted food impacts across the U.S. through the U.S. Food Loss and Waste 2030 Champion program. This joint initiative includes more than 35 member organizations that have made a public commitment to reduce food loss and waste in their own operations by 50% by 2030. This commitment to sustainable food waste management aligns directly with the United Nation’s (UN’s) Sustainable Development Goals.

The Food Recovery Challenge offers participants access to data management software, as well as technical assistance to help them quantify and improve their sustainable food management practices. Participants create data-driven goals, implement targeted strategies to reduce wasted, and report food waste diversion data. They then receive an annual climate profile report that translates their food diversion results into GHG reductions, as well as other measures to help demonstrate the benefits of activities implemented.

The ultimate goal of the Challenge is to encourage organizations to use materials more productively over their entire lifecycle through actions that reflect the food recovery hierarchy, including source reduction, donation, feeding animals, industrial uses, and composting, to divert and prevent food from entering landfills.

Efforts to promote sustainable food management have also extended to the state level. California Senate Bill (SB) 1383 is currently the most far-reaching state-level wasted food legislation. The bill mandates a 50% reduction in organic waste disposal from 2014 levels by 2020 and a 75% reduction by 2025. In addition, SB 1383 requires that not less than 20% of edible food that is currently disposed be recovered for human consumption by 2025. The enforcement provisions of the SB 1383 regulations become effective on January 1, 2022.

Harvesting the Benefits

Transitioning to an organization that champions and promotes sustainable food management requires a culture change across the entire entity, not just a single person or department. That is because the potential to create positive impacts—financial, community, environmental—span the entire food supply chain. Wasted food is a problem on many levels. Sustainable food manage provides the opportunity to not only solve that problem, but deliver many benefits:

• Financial
  • Pay less for trash pickup by keeping wasted food out of the garbage.
  • Receive tax benefits by donating safe and edible food to those who are food insecure.
  • Spend less—and waste less—by buying only food that will be used.
  • Reduce costs (e.g., energy, labor) associated with throwing food away.
• Societal
  • Feed the people who need it by donating food to hunger relief organizations.
  • Create job opportunities; food recycling employs more than 36,000 people.
• Environmental
  • Reduce methane emissions by keeping wasted food that rots and produces methane gas out of the landfills.
  • Save the resources required to make food that ends up wasted (e.g., water, gasoline, energy, labor, land).
  • Return nutrients to the land by composting wasted food to make healthy soils.

Through sustainable food management, it is possible to help businesses and consumers save money, create outlets for those in our communities who do not have enough to eat, and conserve resources for future generations.

KTL will once again be sponsoring the Midwest Environmental Compliance Conference (MECC) held by live streaming video October 26-27. MECC takes a fresh, regional approach to the increasingly difficult task of environmental compliance, permitting, enforcement, and other critical environmental issues that impact Midwest facilities and institutions. KTL will a featured presenter as part of the technical agenda:

Preparing for U.S. EPA Inspections in Region 7
Tuesday, October 26
2:00 pm – 2:40 pm CT

In recent months, regulated facilities have experienced an uptick in U.S. EPA information surveys and multimedia inspections. KTL’s Becky Andersen will present guidance on steps you can take to prepare for inspections and minmize your risk of compliance findings and enforcment actions.

BioForward Wisconsin recently reached out to KTL to tell more of our story and to highlight how our company is helping to support the rapidly growing biotech/biohealth industry. Read our recent interview to learn more about KTL’s work with BioForward, its member companies, and the industry overall.

Get to know our KTL team! This month, we are catching up with KTL Senior Consultant and Partner Andy Smith.  Andy has over 10 years of experience providing project oversight, technical support, and IT solutions on a variety of EHS and engineering projects for a wide range of clients and industries. Andy is based out of our Madison, WI office.

Tell us a little bit about your background—what are your areas of expertise?

I started working at KTL in 2011, mainly to support a large data gathering and management project. From there, I managed to prove myself useful in other areas and stuck around. Since joining KTL, I’ve worked on a wide variety of projects and developed plenty of IT skills, including SharePoint development, GIS, statistics/data analysis, etc. My primary areas of expertise these days would be leveraging those IT skills on projects involving asset retirement obligations (AROs), EHS and regulatory compliance, and general project management.

What types of clients do you work with? What are the biggest issues you see them facing right now?

Most of my client work has been focused on the private sector, with the bulk of my current time spent with chemical manufacturing companies. However, I have also worked extensively with transportation and manufacturing companies.

Overall, the most common issue the clients I work with face is managing regulatory, environmental, and workplace safety risks while balancing the need to maintain and manage a productive company.

What would you say is a highlight of your job?

I enjoy working on a wide variety of projects and continuously improving the work KTL performs. Sometimes this will show up in doing a task more efficiently than we had in the past. Other times it might mean leveraging an IT platform like SharePoint or management system approach to make the work considerably more repeatable and manageable.

What do you like to do in your free time?

I bike a fair amount and play semi-convincing soccer regularly. Beyond that, my free time is consumed by books, random stuff, and hanging out with the cat.

Read Andy’s full bio.

The Food Safety Consortium Fall Edition is kicking off this October with five weekly sessions featuring critical thinking topics that have been developed for both industry veterans and knowledgeable newcomers. KTL will be a featured presenter during the Recalls: Trends and Analysis episode on Thursday, October 14:

How to Respond to Recalls
Thursday, October 14
1:10 pm – 1:55 pm ET (includes Q&A)
Presented by KTL Senior Consultant Roberto Bellavia

In October 2020, the Safe Quality Food Institute (SQFI) published SQF Codes Edition 9 (SQF V9) as the most recent edition of the SQF Food Safety Codes. SQF V9 is comprised of 13 industry-specific codes that provide step-by-step instruction for production and manufacturing sites to become SQF certified. This certification is recognized by the Global Food Safety Initiative (GFSI) and showcases certified sites’ commitment to a culture of food safety and operational excellence in food safety management. Implementation of SQF V9 is effective as of May 24, 2021.

In August 2021, SQFI introduced four code amendments to this most recent edition. These amendments are required to be implemented along with applicable SQF V9 codes by October 4, 2021, and will be audited accordingly. A summary of the amendments is included below:

SQFI has a number of resources and guidance documents available to help ensure compliance with these amendments and the other requirements of SQF V9.

Lithium-ion batteries (LIBs) are powerful, relatively inexpensive, and lightweight energy sources that are used to power a vast assortment of electronics and portable tools. Given this, it is not surprising that the number of LIBs in circulation is continuing to increase at a near exponential rate with technology advances. Subsequently, the number of fires caused by LIBs in the waste management process is also on the rise.

The Risks of LIBs

Many in industry know firsthand the risks associated with LIBs in waste/recycling. LIBs have high energy density and are made from materials that make them more prone to combustion or explosion when they are damaged. This is attributed to “thermal runaway”, a reaction in which the battery unexpectedly releases its energy and begins self-heating. This reaction can produce enough heat to ignite materials near the battery, even if the battery itself does not ignite.

The Environmental Protection Agency (EPA) is really taking notice. In a recent report, An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling, EPA provides an evaluation of areas of risk associated with LIBs, as well as some excellent data and case studies of events that have occurred. The report discusses that physical damage to the LIB is one of the most common causes of thermal reaction and that much damage can occur at many different steps of the waste management system.

This information serves as a good reminder of just how risky and prevalent these batteries are—and how important it is to manage them appropriately. 

Mitigating Risk

While the EPA information is very good, the report doesn’t offer suggestions in how to improve operations and mitigate this type of risk—and it can be a very challenging risk to try to address.

KTL has staff with strong backgrounds working in recycling facility operations with hands-on experience developing strategies to minimize this risk. Solutions may be as simple as identifying and using special storage containers in designated areas, to as comprehensive as conducting onsite process evaluations to determine the best ways to segregate batteries and safely transfer them for further processing. 

KTL does not see this problem with LIB management going away any time soon—nor does EPA. We continue to explore alternatives and work with companies to mitigate risk to the extent possible. Please contact us if you are facing challenges with LIB recycling and management or would just like a fresh set of eyes to evaluate your current risk level. We can work together to make your company operations safer.

Get to know our KTL team! This month, we are catching up with KTL Consultant Joseph Kunes.  Joseph supports KTL’s information management projects, including Microsoft SharePoint®, dynaQ™, and other database applications. As an educator by training, he excels at guiding clients through technology implementation. Joseph is based out of St. Louis, Missouri. 

Tell us a little bit about your background—what are your areas of expertise?

I started my professional career as a French teacher and taught Middle School French in Milwaukee, Wisconsin before I joined KTL in 2012. My first project at KTL was performing some outreach work with the National Association of Chemical Distributors (NACD). At that time, KTL offered a dynaQ™ assessment/audit tool designed to help our clients establish and/or maintain compliance with NACD’s Responsible Distribution standard.

This initial assignment of providing dynaQ support to KTL’s chemical distribution clients, allowed me to start developing a greater skillset and deeper understanding of KTL’s database tools and the information technology (IT) side of developing them. As my technology skills have grown, my role at KTL has also changed and expanded over time. To this day, however, I continue to work directly to provide IT support on KTL projects (e.g., dynaQ, database applications, and SharePoint tools) and to maintain and grow our client relationships.

What types of clients do you work with? What are the biggest issues you see them facing right now?

I work with public and private clients across a number of sectors—most of which are focused on developing or improving environmental program management. Despite this diverse clientele, I continually see a universal challenge of staying organized enough to grow operational productivity while maintaining the various aspects of regulatory compliance. It is a difficult balance for many organizations to strike, particularly when so many are resource-constrained right now.

What would you say is a highlight of your job?

I take great pride in seeing the fruits of my labor evident in everyday life.  I am currently part of a team tasked with maintaining bridge and rail infrastructure, thus leading to the distribution of goods throughout the nation. In the past, I have worked with organizations to rebuild the electrical grid in the southeast and Puerto Rico after having been devastated by hurricanes. It’s rewarding to play a role on projects like that. I also truly enjoy the client satisfaction and appreciation we often experience once we have restored order to sometimes chaotic systems by setting up custom SharePoint sites with the appropriate tools tailored to suit the client’s needs.

What do you like to do in your free time?

I’m a man of simple pleasures—I enjoy good food and good drink in good company. I am also (and hope to soon be again) an avid traveler and enjoy exploring new places to take in the local fare.  I’m also a big fan of the arts—be it musical, performance, or material—as well as any cultural experiences.

Read Joseph’s full bio.