Guiding industry on PFAS management

PFAS is an abbreviation for per- and poly fluoroalkyl substances.  These are manufactured chemicals that have been used for more than 50 years to make products non-stick, water-repellent and fire, weather and stain resistant.  PFAS have been used in a range of consumer and industrial products such as firefighting foams, carpets, clothes, paper, stain repellents and pesticide.  PFAS fall into the category of chemicals that are persistent, bioaccumulative  and toxic, and hence require stringent regulation and control. For more information about PFAS and its impact contact, Lee Gedge

There has been an increasing number of regulations and guidelines that pose criteria for acceptable levels in soils, groundwater, water and foodstuffs, and provide guidance on how practically PFAS can be managed in different parts of the world.  In Australia the PFAS National Environmental Management Plan (PFAS NEMP) is the key guideline, enabling a consistent, practical, risk-based framework. Contributing to and implementing guidlines is a key focus of GHD's work to what is often a complex and broad ranging problem. To help you target where effort can be best directed please contact, Peter Nadebaum.

PFAS chemical were most often used in quantity in firefighting foam products (including in fire extinguisher cylinders and as bulk additives to commercial industrial firefighting systems), in outdoor clothing, carpet and furniture manufacture and sales (where it was sold under the name "scotchguard"). PFAS compunds were also frequently used in the metal finishing industry. Waste and wastewater handling and management facilities finally receive all of these materials as waste and could be affected. For more information on where PFAS may impact your site contact, Lee Gedge.

PFAS was commonly used in fire fighting products in Australia up until the late-2000s when alternative products were adopted. However, PFAS can still be present in products due to lack of decontamination of infrastructure, contaminated product sources and some products claiming to be fluorine-free but still containing measureable levels of PFAS.  It is therefore critical to understand your inventory and where potential releases may or may have occured. For more information on how your organisation can understand how to assess the presence/absence of PFAS, contact Mark Clough.

The majority of historical PFAS releases have occurred during the preventative maintenance and periodic testing activities required by Codes. You should be looking now to adjust your procedures, systems and  decontaminate your hardware as required to eliminate potential releases. For more information on how to minimsie potential PFAS releases, contact Mark Cahill.

Understanding the risks posed to local receptors from a release of PFAS to the environment requires a detailed understanding of the properties of PFAS, the local environment, geology, hydrogeology and hydrology, and the sensitivity of nearby receptors.  Not all sites are the same and site-specific conceptual site models are critical in understanding risk.   For more information on how your organisation can understand the risks from PFAS releases, contact Mark Clough

With the focus often on PFAS contamination in soil and groundwater, the potential environmental liabilities from PFAS in above ground infrastructure may be overlooked. For many industrial facilities with foam systems or exposure to  Aqueous Film Forming Foam (AFFF), of greater immediate concern may be the PFAS leaching from contaminated infrastructure (such as concrete pads, pipework and foam delivery systems) and migrating off-site. Understanding this risk through sampling surface water runoff and infrastructure is critical to any PFAS liability reduction strategy. To learn more about quantifying your PFAS emissions to the environment from contaminated infrastructure, contact Lee Gedge

Preventing PFAS discharge to the environment can be challenging. Even after PFAS use has been discontinued legacy contamination can leach from porous surfaces such as concrete or be released from systems that have not been fully decontaminated. The chemical properties of PFAS and its behaviour on different substrates means that various removal and containment approaches are often required for different materials. Undertaking bench-trials and specifying the right encapsulation coating or decontamination procedure at the outset is critical, as is designing and implementing a targeted baseline and 'post-construction' validation sampling program to measure success. To learn more about reducing your PFAS emissions to the environment from contaminated infrastructure, contact Lee Gedge

Replacing firefighting foams is not as simple as swapping one for another. The systems that held the old foams must be thoroughly decontaminated before introducing new non PFAS foams. The degree to which a system needs to be decontaminated is driven by a number of factors including specialist industry guidance, State regulation and guidance, community expectation, and physical practicality. For more information on how to remove PFAS from your systems and infrastructure contact Lee Gedge

Replacing firefighting foams will inevitably result in creation of stocks of old foams.  In order that these not be inadvertently re-used or re-incorporated into non PFAS foam stocks it is recommended that these waste foams be removed from site. Destruction of PFAS is typically by co-disposal in high-temperature furnaces or by specialist electric arc destruction. For more information on how to rid your organisation of PFAS contact Lee Gedge

Most existing foam systems have been designed for AFFF foam concentrate. The new fluorine free foams are significantly different and likely require cleaning out of the old system and decontamination of ther pipework, tanks and associated infrastructure. Consideration should be given to the hardware and its suitability to achieve the required proportioning ratio for a replacement fluid with different characteristics. As the new foams apply a 'mechanical blanket' (as opposed to the old film forming concentrates that were much more forgiving of application method) the application method for the new foam will need to be considered as will the  quantity of concentrate required, the application rate and time of application. For more information please contact Mark Cahill

Decontamination needs to be thoughtfully planned and carefully executed to ensure an outcome that meets decontamination targets. Good outcomes can be achieved by a skilled decontamination team led by an experienced environmental engineer.  Key considerations include the sequence in which the work is undertaken and management of waste but these things are manageable.  For more information on how to decontaminate your systems contact Lee Gedge

Certain older firefighting systems showing evidence of significant corrosion, or systems with aluminium componentry where surface etching is visible, can provide crevices and voids where PFAS chemicals can remain and resist removal.  In some cases these systems can be cleaned using specialist techniques, but equally, experience has shown that severely affected systems cannot be successfully decontaminated, meaning that some parts , or the whole system, may need to be replaced.   For more information on how to rid your organisation of PFAS contact Lee Gedge

Raw firefighting foams are viscous as such they adhere strongly to the inside walls of tanks and pipes, joints and gaskets.  Older foams also solidify in any gaps and voids in tanks and pipe systems.  Simply draining the old foams and replacing with new 'Fluorine-Free' foam does not clear the PFAS foam products in the inside of these types of infrastructure. Careful consideration to decontamination of your infrastructure will reduce the generation of significant volumes of waste water that requires management.  For more information on how remove legacy foam product from your systems contact Lee Gedge

Firefighting systems must work when called upon. That means they must be tested periodically.  Fire-fighting systems can be tested safely and securely and foams created can be managed, collected and safely disposed of.  For more information on how avoid legacy foam products from impacting your site during testing and training contact Lee Gedge

Controlling PFAS discharge to the environment from contaminated buildings and structures can be challenging. The behaviour of PFAS on different building materials means that various removal and containment approaches need to be considered. Specifying the right encapsulation coating or decontamination procedure at the outset is critical. A targeted baseline and 'post-construction' validation sampling program should be implemented to measure success.  To learn more about decontaminating buildings and structures, contact Lee Gedge

Concrete is a sponge for PFAS. Studies have shown that even low concentrations of PFAS can be absorbed into concrete and leach to stormwater for decades. Any PFAS site remediation or contamination management plan must also address contaminated concrete for it to be effective.  There are a range of mitigation measures ranging from encapsulation through to complete removal. To learn more about reducing your PFAS emissions to the environment from contaminated concrete, contact Lee Gedge

The most common release mechanisims for PFAS contamination have occurred as part of above ground activities meaning that the highest concentrations are typically found at the surface. This makes stormwater particularly vulnerable to PFAS contamination and for most sites the dominant pathway for migration of PFAS off-site.   To learn more about quantifying your PFAS emissions to the environment from contaminated stormwater, contact Lee Gedge

Although PFAS has been largely phased out of newer fire fighting products and other industrial chemicals, our experience has shown that legacy contamination is common. Understanding whether such legacy contamination is important in assessing risks associated with existing infrastructure and in due diligence prior to purchase of a potentially contaminated site. This understanding can only come from a detailed site history assessment. For more information on how such site history assessments can assist your organisation in decision making, contact Mark Clough

Whether a site is contributing contamination is based on an assessment of potential sources, release mechanisms and transport pathways. Sources can range from obvious, well known products (e.g. AFFF, misting agents) to less well understood sources such as old landfills or contaminated infrastructure. Understanding the source(s) is critical in determining whether a site may be contributing contamination.  For more information on how your organisation can understand whether your site is a continuing contributing source of contamination, contact  Mark Clough

The fate and transport of PFAS is a complex problem due to the physical and chemical properties of PFAS and the individual configurations of each site. A strong conceptual site model that combines the physical setting of the site with a knowledge of how PFAS behaves in the environment is essential in helping to understand whether PFAS may or has left a site and via which pathway. For more information on the development of conceptual site models, contact  Mark Clough

PFAS products have been used in a number of site settings from highly industrialised urban areas to more rural settings. The sensitivity of receptors associated with each site can vary considerably from highly modified ecosystems of little ecological value to pristine and protected natural environments.  Understanding the nature of receptors near your site and how PFAS may enter these receptors is critical in determining any response action to PFAS releases.   For more information on how your organisation can understand the ecological setting of your site and risks from PFAS releases, contact Mark Clough

PFAS can migrate in an number of different ways when released to the environment. It can be localised in soil around the release area and can then leach from soils to groundwater. It can also migrate via wind, surface water, drainage systems and groundwater. Understanding the extent of PFAS is critical in understanding environmental liability and risks. It requires a focussed and systematic approach using desk top analysis of sources and migration pathways and a detailed targeted sampling program. For more information on how such assessment programs are planned and conducted, contact Mark Clough

In order to determine if your site is impacted by PFAS contamination, an environmental site assessment (ESA) can be undertaken by an experienced environmental consultant. The assessment involves a Preliminary Site Investigation (PSI) which is a desktop review of the site history (including historic use of PFAS containing products both on site and surrounds) to assess the potential for contamination. If PFAS contamination is suspected the PSI is followed by a more detailed site investigation (DSI) involving sampling of potentially affected media (soil, groundwater, surface water, concrete etc.) to identify and quantify the presence and levels of PFAS on the site.  The DSI will also assess the risks to human health and/or environment at, or emanating from, the site. For more information on how to assess your site, contact Monika Janiak

The key is to adopt a consultative risk-based approach - to direct work to understand:  where risk is or may be significant, address the concerns of stakeholders, what the key contributing factors are, and how effort may be practicably best directed to reduce the risk to an acceptable level. In the case of soil, groundwater and water contamination, often there will be many possible sources contributing to the problem. In our experience, it can often be possible to show through more detailed consideration that either the risk is acceptable, or that only a few source areas account for most of the risk and this is where effort should be directed. Involving and consulting stakeholders is also a key matter, and retaining advisors that specialise in this field is important. For more information on reducing your PFAS risk, contact Peter Nadebaum

Once PFAS has been identified in a site's groundwater, stormwater or wastewater,  the need for and the magnitude of any response to this needs careful and considered thought. Our experience has shown the value of risk-based approaches to this issue to ensure any response is commensurate with the risks posed by the contamination, to avoid any unnecessary remediation or clean up. For more information on how informed, risk-based and practical responses are developed, contact Mark Clough

Managing legacy PFAS within your firefighting foam stocks will be key to minimising the costs and liabilities associated with this product. Understanding what foams types you have is essential to enable you to appropriately manage that foam stock.  How you manage your legacy foam stock is likley to become a significant business risk issue, with foam management cost being the main driver.  For more information on how to formulate a PFAS management policy, contact Dylan Galt

If you have foam systems you should develop a plan to address any potential releases, either at times of maintenance or testing, or in an actual event. For more information on non-PFAS equivalent products, contact Mark Cahill

Managing legacy PFAS within your firefighting foam stocks will be key to minimising the costs, and liabilities, associated with this product.  Having a policy will clearly demonstrate that your organisation is committed to a management process that can address the concerns of regulators, staff, clients and local property owners.  Understanding what foams types you have and how your staff will manage these going forward is likley to become a significant business risk issue, with foam management cost being the main driver.  For more information on how to formulate a PFAS management policy, contact Dylan Galt

Understanding what foams types you have and how you will manage these going forward will soon become a significant business and commercial issue, with foam management cost and reputation risk being the main drivers.  Beginning from the startpoint of a PFAS management plan your stewardship of existing foam stocks and how these are safely phased out is a critical step in that process. For more information, contact Dylan Galt

Replacing firefighting foams is not as simple as swapping one for another. Older foams can solidify and congeal on the inner surfaces of tanks, pipelines, pumps and valves. The systems that held the old foams must be thoroughly decontaminated before introducing new non PFAS foams.  This can be a complex exercise that requires detailed planning to minimise and manage wastewater creation and achieve an effective result,  For more information contact Lee Gedge

You need to develop a procedure or install hardware systems that allow for the periodic testing of foam systems without release to the environment. You  then need to consider what foam best suits your needs in the future, with consideration of the potential for releases to the environment and/or legislation that may apply. In our experience, careful and detailed design of foam containment and recovery systems can provide protection against future liabilities and reputational risks. For more information on managing of PFAS foam during periodic testing, contact Mark Cahill

There are many variables and standards that flourine free foams (F3) claim to achieve.
GHD works with our clients and foam suppliers to assess the suitability of F3 foams for the application proposed and require suppliers to warrant that the system and equipment that the foam is to be used with is suitable for their foam and the risk that is to be protected.
The foam manufacturer should guarantee that their foam is suitable for the likely design fire scenario. For more information on flouring free foams and performance specifications, contact Mark Cahill

This requires knowledge in the individual systems design basis and risk, the existing equipment , the foam to be used and the application method. There are many variables to be considered. F3 foams perform differently to the AFFF concentrates. Some questions to consider are: Is the foam suitable for the risk being protected? Will the existing proportioning equipment correctly pick-up and proportion the foam at the correct ratios? Is the application method for the F3 foam suitable for the risk? It can be a very complex consideration. For more information on design of your replacement firefighting system, contact Mark Cahill

The type of foam, the proportioning and application rate are functions of the risk being protected. For F3 foams the manufacturer should be consulted to ensure their foam is suitable for the proposed liquid and advice on the recommended application methods.
The F3 foams are different to the old AFFF foams, with careful attention to be given to the aspiration rate (expansion rate) of the foam and the method of application (the old foams were more forgiving). The F3 foams, being a ‘mechanical foam’, must be applied in a manner that maintains the blanket. Manufacturers will require a minimum aspiration rate for their foams to be representative of the small scale tests that have been used to test the foam. For more information on replacement foams, contact Mark Cahill

Not all systems are universal and match all types of foams. There are many aspects to be considered. You need to have the right foam for the application and the correct equipment to achieve the correct proportioning ratio. You also need to have sufficient concentrate stocks to support the required application rate and time.
You also need to have the correct hardware to allow the required expansion rate to be achieved, to apply a high quality mechanical blanket to any fire. For more information on your fire fighting system, contact Mark Cahill

Replacement of PFAS fire fighting foams with non-PFAS equivalents may result in fire fighting systems not operating as originally designed. Flourine free foams have different flow characterists and may require signficiant alternation to or replacement of proportionators, pumps, pipework etc. GHD's experienced professionals can advise on foam replacement and/or upgrade requirements for engineered, fixed foam systems. For more information on flourine free fire protection systems, contact Mark Cahill

Any foam release during testing may have an adverse impact on the environment. Any system commissioning including F3 foam systems should avoid releasing foam into the environment. New or modified systems should involve the use of procedural or hardware solutions to avoid foam release during testing and/or commissioning. For more information on your fire fighting system, contact Mark Cahill

PFAS, like other contaminants that cause concern, can be alarming when you first discover that it is on your site. This alarm, fear or worry can be disguised in a number of forms. Mostly you worry about what you don't know, how much there is, whether it has migrated off site, whether you may have impacted workers or local communities, what it will cost to fix it. Staff however, will worry about whether they have been exposed and if they have, what that means. Your engagement process should be personal and reflect their values (rather than yours) if you hope to allay their concerns. i.e. you must share what you know, and be willing to share what you don't know. Be open and authentic; allow time for discussion, echo what they say and acknowledge the valid concerns; plan for emotional reaction, and be prepared to work together towards an outcome that meets the needs of you and them. For more information about communicating PFAS issues with your staff contact Barbara Campany

A regulator's role is to make sure companies are complying with regulations.  The style of communication between a regulator and a local resident for example, is quite different, reflecting the different interests in PFAS. Local residents are likely to be worried more about PFAS potentially affecting their health, local amenity or quality of life; regulators want to make sure companies meet legislative and regulatory requirements. They have a less emotive stake. Regulatory communication doesn't require the same level of personal engagement as the local community, rather an initial briefing and presenting information in a factual summary is usually adequate. Regulators expect companies to provide intensive and meaningful engagement with communities about PFAS. For more information on communicating with regulators or other government agencies about PFAS issues, contact Barbara Campany

PFAS has become a highly emotive issue, often magnified through the media. When communities first learn about the potential for PFAS being in their environment, their immediate reference is either what they have seen in the media, or what they can discover on-line. Either way, the perception of PFAS risks is usually out of context with the actual risk. At GHD we have worked closely with Dr Peter Sandman and apply his model of Risk = Hazard + Outrage, to communities potentially impacted by PFAS. It provides a useful framework to effectively manage community concerns and expectations. This framework is based on a number of engagement principles that can assist organisations change their engagement practices to more humble, personal and authentic processes, requiring more proactive and intensive engagement at the front end of a project, rather than reactive and often a 'crisis' driven response at the back end.   For more information communicate PFAS issues with your community, contact Barbara Campany

If not carefully managed, media communication can provide another layer of complexity when addressing PFAS concerns in communities.  Proactive and authentic engagement at the grass roots level should be the focus rather than trying to appease the media. Factual, consistent and planned messaging and response to media enquiries is important.  An integrated communication approach across all stakeholder groups is important to ensure consistency across the project. For further information on managing media interests regarding PFAS contact Barbara Campany

GHD provides expert witness services on a number of topics, including PFAS control and management. As expert witness, GHD provides impartial professional and technical assessment and review to assist legal professionals to navigate the complex environmental issues presented by PFAS. For more information on expert witness services contact Lee Gedge.