Why industry and public entities should be paying attention to PFAS
What are PFAS?
PFAS is an umbrella term for a family of more than 4,000 chemicals.
If you aren’t dealing with them directly yourself, you’ve probably heard about them on the news or social media: perfluoroalkyl substances, more quickly and easily pronounced as PFAS. PFAS is an umbrella term for a family of more than 4,000 chemicals.
Two members of the PFAS family, PFOA and PFOS (known as the “long” or “8-chain” chemicals), have received a lot of scrutiny over the past decade for several reasons: they don’t biodegrade, they can end up in wastewaster and air emissions, and they bioaccumulate in some animals—including humans. As a result, PFOA and PFOS are no longer in production in the U.S., and chemical companies have reformulated PFAS products to create shorter-chain versions that break down more easily.
Where can PFAS be found?
The first PFAS compounds were developed by accident in the early 20th century and have been used worldwide since then in a variety of industries and consumer products. They resist grease, water, and oil, and they’re used in everything from raincoats and mascara to ski wax and firefighting foam. They keep grease from soaking through your pizza box or microwave popcorn bag. They keep vegetables from sticking to the bottom of your frying pan. They keep spilled drinks from staining your carpet.
PFAS chemicals are also found in certain industries on which the Environmental Protection Agency (EPA) is now focusing its regulation. For example, aqueous film-forming foam (AFFF) contains PFAS but is commonly used by firefighters to effectively put out fuel and other flammable liquid fires, especially at facilities like oil and gas refineries and airports, where such fires are more common.
Other industries that may use PFAS include chrome plating and metal finishing, as well as chemical, medical device, pulp and paper, and performance plastics manufacturing. An expanding list of industries, such as mining, metal recycling, and power generation, are being asked to monitor their PFAS releases as well.
As a result of the variety of potential release pathways of PFAS, the public sector is becoming increasingly focused on PFAS and is beholden to similar EPA regulations. Landfills and water treatment facilities, for example, are both concerned with how PFAS gets into—and out of—our water supply.
What is driving this attention?
Until recently, the PFAS risk to human health and the environment was not well understood. Although there was a recognition that risks exist, the understanding of those risks has increased due to ongoing research aimed at addressing the types and amounts of PFAS exposure that may contribute to adverse health effects. The public has become more aware of the ubiquitous nature of PFAS chemicals over the last decade. In turn, this awareness has driven an increase in PFAS regulations, which are getting broader at both the state and federal levels every year. In the fall of 2021, the EPA released its PFAS Strategic Roadmap, which lays out its continued commitment to action on PFAS through 2024. The roadmap’s focus is three-pronged: public health, the environment, and accountability for the industries that use PFAS.
The attention on PFAS isn’t unique to the U.S. On April 25, the European Union announced its own "restrictions roadmap" to potentially ban up to 12,000 substances—including all PFAS chemicals. The plan is being hailed as the world’s largest-ever ban of this class of chemicals.
In short, countries all over the world are recognizing that it’s best to address potential releases of PFAS chemicals quickly and thoroughly for the sake of humans and the environment alike.
What can you do about it?
If the past few years are any indication, PFAS regulations are only going to get tighter. That means a proactive approach is key to ensure PFAS compliance.
If the past few years are any indication, PFAS regulations are only going to get tighter. That means a proactive approach is key to ensure PFAS compliance. For nearly two decades, Barr has helped industrial and public clients address PFAS risks and liabilities through a variety of processes and pathways. With the constantly changing regulations, Barr has been advising clients to meet with legal counsel and an experienced consultant to evaluate the potential PFAS risk associated with their current and historical operations and to develop a strategy going forward.
Facilities may have a false sense of security based on the 2020 Toxic Release Inventory (TRI) reporting. Only 63 facilities across the U.S. reported PFAS, based on the reporting threshold criteria of 100 lbs. or more of PFAS-containing product. Our work with clients indicates it is likely that many more facilities unknowingly have PFAS onsite but do not meet the current 100-lb. threshold for reporting.
As regulations change, including the strong possibility that the EPA will remove or revise the 100-lb. threshold in future TRI reporting, facilities’ potential liabilities may increase. These liabilities could include being required to sample as part of a permit renewal or a state’s monitoring plan. Once reported through TRI, the information is public knowledge, which may result in additional inquiries and attention in the court of public opinion.
Barr has developed screening tools to identify potential PFAS sources, and we have conducted desktop studies in collaboration with legal counsel to assess these liabilities. This has led to the development of strategies to plan for future action as regulations evolve. With regulations changing so quickly, the threshold for action related to PFAS chemicals likely lowering, and the ubiquitous use of PFAS in many products, we continue to advise clients to plan proactively to stay ahead of the game.
Stay tuned for regulation updates as they become available and a more technical, in-depth discussion of the PFAS family of chemicals. For additional information, contact our team of PFAS experts.
About the author
As PFAS market lead, Nick Palatiello represents Barr’s comprehensive PFAS engineering and environmental services, from preliminary investigation to detailed design of treatment systems and remediation. For more than five years, Nick has worked with clients and regulators to address PFAS issues across the U.S. and around the world. He is involved in regulatory tracking and analysis, as well as developing strategies for clients to address PFAS. Nick has been part of Barr’s Corporate Business Development group for more than eight years and focuses on market and strategy development for energy and manufacturing.
PFAS stack testing services for a manufacturing client
Barr has been measuring per- and polyfluoroalkyl substances (PFAS) in stack emissions at facilities in the U.S. for two decades. Because of this experience, a confidential manufacturing client hired Barr to perform compliance testing to evaluate the performance of thermal oxidation as a best available control technology (BACT) to control PFAS emissions from its processes.
Multi-site PFAS remedial investigation and remediation
Per- and polyfluoroalkyl substances (PFAS) have been detected in public water supplies and private wells at or near active and former manufacturing facilities owned by Saint-Gobain. Barr is part of a collaborative consulting team conducting remedial investigations and feasibility studies.