The PFAS Response

The PFAS Response

Why is PFAS an issue in today’s society?
The rise of Per- and Poly-fluoroalkyl Substances (PFAS) investigations in Australia over the past decade has resulted in recent focus on the potential negative health effects posed by PFAS. It seems not a week goes by without media coverage of newly discovered PFAS contamination at sites across Australia and New Zealand. Recent articles alerted us to some farmers in Gippsland, Victoria being warned not to eat the beef they sell due to PFAS detections in livestock. We have also seen local and international media outlets cover the stories of alleged cancer clusters in the US town of Oakdale, Minnesota, which is the location of 3M’s global headquarters, where significant manufacturing operations of PFAS and other associated chemicals occurred.

The persistent nature of PFAS and their ability to travel up to thousands of kilometres from the site of their original release into the environment has created concern amongst communities close to sites where PFAS was once used, and globally, where PFAS were manufactured. Produced for industrial purposes since the 1950s, PFAS’ unique properties have been exploited for a vast array of commercial and industrial applications; notably in historical formulations of Aqueous Film Forming Foam (AFFF), which is used to rapidly extinguish fuel-related fires.

Some people who live in exposed communities have been found to have higher concentrations of PFAS in their bodies than the broader public. As new sites emerge that could potentially be contaminated with PFAS, a growing number of communities have discovered their town or suburb is affected. Some communities in Australia have been advised by Government authorities not to consume local produce and water due to elevated concentrations of PFAS and the likelihood of potential risks to their health.

 

What does this mean for your organisation?

 Uncertainty globally and within Australia and New Zealand in conjunction with the persistent nature of PFAS has resulted in a higher level of environmental regulatory scrutiny, which is expected to continue — and even intensify — over the next decade. The focus on PFAS assessments and subsequent remediation has largely been related to the aviation, defence, oil and gas, fire services and industrial sectors.

 AECOM’s Director of International PFAS Program, Rachael Casson, has worked on PFAS projects for nearly a decade and says that even without conclusive information about the health risks associated with PFAS, much of industry is acting proactively and responsibly:

“We are seeing each sector manage the issue differently; some are further advanced in the management cycle and are even beginning to implement mitigation and pollution control measures (such as site clean-up) whilst others haven’t started the process yet.

“Generally, the Australian regulators and managers of PFAS-impacted sites have acted earlier than counterparts globally in investigating and evaluating risks. The Australian Environmental Protection Authorities (EPAs) have been the most active and focussed that I’ve witnessed over my 20 plus-year career,” Ms Casson says.

Organisations that have not yet initiated a strategic management process run the risk of being forced into unnecessary or emotively driven actions by regulators or other stakeholders.

“When we run workshops with clients to help start the management process, the first item on the agenda is to discuss what their organisation’s long-term goal is to manage PFAS contamination. We develop a pathway focused on reaching a successful outcome and prioritising actions. It can be used as a communication tool (internally and externally), a timeline of where the journey started, what the current situation is and what’s required in the future,” Ms Casson says.

In Australia and New Zealand, PFAS contamination is dominated largely by the release of legacy AFFF formulations. There have been hundreds of PFAS investigations across both countries on a range of different facilities, including defence sites, airports, refineries, firefighting stations and training areas, and landfills.

Ms Casson explains that some environmental authorities  have assembled dedicated PFAS teams that have undertaken the following:

• Desktop investigations identifying sites where products containing PFAS may have been stored, used and potentially released. Following identification, the authorities sent formal requests for information to all identified users of PFAS products to understand the inventory of use
• Sampling down gradient of some of these sites, which in Australia is unprecedented with other contaminants of concern.

The biggest difference locally in Australia, compared to the US, is the scale and intensity of the contamination and associated issues. In the US, not only are there legacy AFFF release sites, but there are also PFAS manufacturing sites and metal plating sites with very large impacts.

Ms Casson explains: “Companies in the US are still conducting preliminary investigations to confirm the presence and/or absence of PFAS, rather than evaluate the extent or risk. However, globally, regulators and site managers are ensuring that effected communities are provided with clean drinking water where concentrations are greater than adopted health-based guidelines in municipal reservoirs.”

Whilst Australia is generally further into the contamination project lifecycle, the number of sites requiring assessment in Australia is significantly less than in the US. Ms Casson explains that in Australia there are 613 airports compared to over 5,000 in the US. The same goes for landfills, “there are 600 registered and over 2,000 unregistered landfills in Australia, compared to over 3,000 active and 10,000 historical landfills in the US.”

AECOM’s Environmental Technical Director, Paul McCabe, has worked on some of the largest PFAS investigations in Australia and has seen a shift in the New Zealand market:

“Some of the largest PFAS investigations have been in Australia over the past five years, but we’re now seeing the number of investigations steadily rise in New Zealand.

“The majority of investigations in New Zealand have arisen from the use of AFFF at airfields and oil and gas facilities, but I’ve also seen investigations from electroplating processes that had created groundwater impacts at brownfield sites,” he says.

Ms Casson believes collaboration is the key to advancing knowledge and better managing PFAS-impacted sites.

“We recently saw the Heads of EPAs Australia and New Zealand (HEPA) and the Australian Government’s Department of the Environment and Energy collaborate to develop the PFAS National Environmental Management Plan (PFAS NEMP). This international collaboration is likely to result in continued consistency across Australia and New Zealand.”

 

Key industry challenges

Whilst the PFAS NEMP involved collaboration, the various EPAs in Australia have publically and privately acknowledged that differing legislation in each jurisdiction means their application will vary. A key challenge is inconsistency from different state, national and international health and environmental agencies with regard to tolerable daily PFAS intakes and toxicity reference values.

“When these reference values differ by state and country, affected communities can find it difficult to understand what are really ‘safe’ values and this can create distrust,” Ms Casson says.

More recently, PFAS screening levels have decreased in the US. The draft US Agency for Toxic Substances and Disease Registry (ASTDR) released in July 2018 provides ‘minimum risk levels’ for different exposure settings for various PFAS compounds. These levels are significantly lower than the Food Standards Australia New Zealand (FSANZ) Health Based Guidance Values for drinking water, released in April 2017. So too are the Vermont Department of Health’s advisory for drinking water released in July 2018.

“The trend of decreasing guidance values represents uncertainty and risks for site managers. With all of this potential change and uncertainty regarding toxicity, there is a risk of unwise expenditure and utilisation of resources,” says Ms Casson.

Mr McCabe says New Zealand is facing similar challenges: “The media profile of PFAS issues and rapidly evolving government requirements appears to have created confusion and uncertainty — particularly with airport operators”.

However, a different approach to communicating risk to impacted landholders is being undertaken in New Zealand. AECOM’s Geoscience & Remediation Team Leader, Sarah Halliday, based in New Zealand’s Hamilton office, is currently working on a New Zealand Defence Force project and says providing tailored advice to landowners can help to reassure communities.

“For some landowners, it’s as simple as ‘PFAS was not detected and therefore no change to your water use is necessary’; however, where PFAS is detected, and depending on the uses of that water, we do provide specific advice.

“Where these sites are farms, we have engaged with the Ministry for Primary Industries, which runs models based on a landowner’s specific land and water use scenario. We can then advise landowners whether it’s recommended that they consider moderating their consumption of home-grown produce (e.g. meat, milk, eggs).”

 

What should be done to evaluate potential risks?

To fully understand potential risk exposure and measure liability, an organisation may consider consulting a team of diverse experts, including environmental and legal specialists, to develop a programmatic approach to mitigating risk. Key things to undertake to ensure the company and the community are protected are:

• Vulnerability assessment (PFAS inventory, prioritise sites, identify populations at risk, and calculate costs)
• Develop an internal and external strategy (including a systematic, process-driven response), and a stakeholder tool kit
• Determine mitigation and pollution control measures (e.g. control off-site exposure for at-risk populations; replacement of PFAS products with suitable alternatives; and discharge control).

What’s next?

 The number of PFAS investigations in Australia and globally is likely to continue increasing. Whilst a large part of the current environmental regulatory scrutiny is focused on investigations, the industry is actively developing and preparing to implement remediation options.

Australian Government Departments are beginning to invest in research initiatives for PFAS. Much of the research has focussed on water treatment remedial technologies, although there has also been investment into research relating to PFAS fate and transport, ecological toxicity and soil treatment.

If your organisation has to manage a site impacted with PFAS, it is useful to understand that the broader environmental sector has made significant contributions to developing new PFAS solutions. AECOM has assembled a team of global leaders in PFAS that regularly collaborate to ascertain the state of the science and the direction of regulation. Our solutions-focused team is experienced in providing long-term advice on the mitigation of risks for affected communities, the environment and businesses.

Maintaining an open dialogue with the EPA and your environmental consultant about trends across a range of industries is a good way to stay updated. The EPAs are publishing information on their PFAS investigation programs on their websites, which also provide a good indication of current and future areas of focus.