Some business situations call for a wait-and-see approach, keeping close watch but not taking significant action. But sometimes situations speed up, making it essential to act quickly to avoid problems and seize potential opportunities.
We’re at that inflection point right now with PFAS.
These anthropogenic (originating from human activity) chemicals, long used in fire-fighting foams as well as a host of products ranging from fast-food packaging to breathable outdoor clothing, have increasingly become a health and environmental concern. These concerns are being felt by sectors as diverse as water treatment, landfill operation, industrial site remediation and food processing. In fact, many PFAS compounds are now routinely detected in rainfall around the world. The challenge is wide reaching.
Growing scientific worry about these useful but problematic chemicals is bearing fruit in an increasing political will to act, which in turn is showing up in tighter regulations. Our environmental and water professionals have encountered this stricter regulatory environment in many ways. For example:
- The US Environmental Protection Agency (US EPA) is now taking a more conservative position about how it plans to regulate PFAS. Previously establishing a Health Advisory of 70 parts per trillion for the sum of PFOA and PFOS (two of the most studied PFAS compounds), US EPA has established interim updated Health Advisories of 0.004 for PFOA and 0.02 parts per trillion for PFOS, making these values some of the most conservative in the world.
- In June 2022, the US Senate Committee on Health, Education, Labor and Pensions passed a bipartisan amendment that directed the Food and Drug Administration to ban the use of PFAS in food packaging. Due to the widespread use of PFAS (as PFAS is one reason your cheeseburger doesn’t stick to its wrapper), this has the potential to impact the whole sector.
- The US EPA is still investigating whether PFAS meets its definition of “hazardous waste.” If it does, this will impact municipalities, particularly regarding to treating wastewater and how they operate landfills, as well as impacting any businesses that use PFAS or have a property that PFAS may have affected.
Other initiatives show that PFAS is in the regulatory cross-hairs. Not all of these initiatives are enforceable yet, but they’re a clear indication of the shape of things to come.
For an idea of the future of PFAS, consider a previous “wonder material” now found to be problematic: asbestos. It was in widespread use for years -- and now, years later, lawsuits involve not just manufacturers but the third-party acquisition of companies that historically used asbestos in their products.
Acting now, including research, planning and seeking funding
So, what can organizations do now to prepare for a PFAS-constrained world?
1. Do your research
Find out what PFAS exposures you may have – products you make that include PFAS or that use PFAS as inputs. Even if your property has no history of PFAS impacts, those impacts may still be there, blown by the wind or carried by groundwater.
Concentrations greater than these Interim updated Health Advisories have been detected in rainwater and areas with no apparent sources of PFAS. Therefore, many facilities that had not previously considered PFAS to be chemicals of concern to their operations may now need to assess and manage these chemicals.
Challenges such as these raise the importance of conducting upfront assessment to understand whether PFAS impacts a site and available options to address them if required. For example, existing technologies, such as activated carbon adsorption systems, may need to be augmented or operated differently in order to achieve the new Health Advisories levels. Emerging technologies, such as PFAS destruction systems, may undergo rapid development and become options we consider for solving our clients’ pressing challenges.
2. Plan your approach
Your assessment about your PFAS exposures and how they can be addressed is essential to your next stage – planning. It is a good idea to consider a wide range of possible scenarios based on limits yet to be set into regulations and the technologies that are now and will be available. We can help you understand what options are available, the logistics required to put them into place, and the costs associated with their implementation.
3. Seek funding
One reason it’s vital to take action now is that many federal and state agencies, which are also in learning mode about managing PFAS risk, are making funding available for PFAS-related projects. Staying up to date on funding opportunities at all levels of government can help you understand what is available and potentially how to access this funding.
The window of opportunity for funding will likely be short as the best practices continue to emerge. This is one reason to take action now, starting with finding out what information your company already has about its PFAS use and exposures.
Many organization leaders are concerned that, given the low concentration levels being discussed by regulatory agencies, they will need to come up with some prohibitively expensive solution around PFAS. But staying current with developments, supported by professional advice from firms such as GHD, can help you find opportunities for action that will help you manage risks and access benefits.
Authors
 Tamara House-Knight, PhD |
 Holly Churman |
