Paying Attention to PFAS

26 Oct


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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:

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.

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