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PFAS: What You Don’t Know Can Hurt You

By October 12, 2018 March 11th, 2019 No Comments
You’ve heard of health hazards of certain metals, like arsenic, mercury, and lead.  Maybe even chromium, from the movie Erin Brockovich.  You also may know that volatile organic compounds (VOCs) like petroleum hydrocarbons and chlorinated hydrocarbons are known to cause cancer and other ailments in humans.
But have you heard about PFAS?  That’s the acronym for perfluoroalkyl and polyfluoroalkyl substances.  It is only in the past few years that PFAS in drinking water have been studied and found to have deleterious health effects on people.  What is more, the concentrations in water necessary to damage human health are very low.
So, what are PFAS?  PFAS are highly fluorinated synthetic hydrocarbons.  They are surfactants.  That is, they tend to reduce the surface tension of a liquid in which it is dissolved.  In other words, they make substances waterproof, and liquids “slide” off of them.  PFAS are used to coat clothing and shoes to make them waterproof.  PFAS are used to make non-stick cookware.  They are used to coat solar panels.  They are used on paper food wrappers – like the ones you get at fast food restaurants and diners.  They are used in large quantities as fire-fighting materials at airports and military bases (see the accompanying photograph), where they are often released in large quantities.   PFAS have been detected in aquifers throughout southern California, the Central Valley, and the San Francisco Bay Area, as well as in numerous other areas of the United States, especially where there are industrial chemical manufacturing plants, military bases, and airports.  PFAS are detectable in nearly any biological tissue.
So, what are the health hazards of PFAS?
The United States Federal government’s Centers for Disease Control (CDC)’s National Center for Environmental Health (NCEH) and Agency for Toxic Substances and Disease Registry (ATSDR) have found that exposure to PFAS has been linked to various cancers in adults and children, kidney disease, birth defects, autoimmune diseases, and developmental disorders.  There is growing pressure for the US Environmental Protection Agency (USEPA) to regulate PFAS.  In September 2018, the PFAS Accountability Act of 2018 in the House and PFAS Accountability Act (S. 3381) in the Senate, would require federal agencies to work with impacted states to “facilitate testing, monitoring, removal, and remediation” of PFAS from contaminated drinking water resources. Agencies would be required to come up with a plan of site remediation and enter a cooperative agreement with affected states within one year of a request.
Currently, the USEPA has a nonenforceable lifetime health advisory of 70 parts per trillion (ppt) for PFAS exposure.  The USEPA has also indicated that they will set screening levels and site-specific cleanup levels at Superfund sites, which will be used to determine if long-term groundwater remediation or soil remediation is needed.  The CDC has recommended that this health advisory be reduced to 10 ppt. The EPA has already begun executing a crucial part of that process. The agency held a series of “listening sessions” in impacted communities across the country during the summer of 2018. EPA officials flew to town-hall-style meetings, where people who live near PFAS-contaminated waterways shared their experiences, drilled officials with questions, and demanded federal and industrial accountability.  A National Management Plan expected by the end of 2018.
Currently, individual states are responsible for PFAS cleanups.   California has adopted the US EPA drinking water standard of 0.07 µg/L (micrograms per Liter).  The SWRCB (State Water Resources Control Board) adopted Notification Levels of 14 ppt for perflurooctanoic acid (PFOA) and 13 ppt for perflurooctane sulfonate (PFOS).  The Office of Environmental Health Hazard Assessment (OEHHA) is currently in the process of setting legally enforceable limits for groundwater and drinking water.  In November, 2017, the OEHHA listed PFOA and PFOS as known to the state to cause reproductive toxicity under the Prop 65 law.   In addition, OEHHA, has just (November 10, 2018) instituted warning requirements for listed chemicals, and will prohibit discharge into source of drinking water as of July 10, 2019.   California law also allows for private enforcement on behalf of the state if state fails to enforce Proposition 65.
So, what does it take to remediate  PFAS contamination in groundwater?  PFAs cleanups are
more complicated and expensive than VOC cleanups. In-situ biodegradation typically unavailable – bugs don’t eat PFAS.  Contaminant plumes are usually a complex mixture of hundreds of PFAS.   Perfluoroalkyl substances are inherently stable.  Currently, liquid activated carbon and/or a mineral media such as clay are the only demonstrated remediation strategies that have been shown to be effective.  Numerous other strategies, including excavation of soil, soil amendments, thermal radiation, biochar, ion exchange, membrane filtration, and reverse osmosis, as well as others, are currently the subject of intensive study.
But what is someone involved with due diligence recommended to do on behalf of their clients?  The consultant should
  1. consider likely PFAS use at on-site or off-site activities (particularly any fire suppression methods);
  2. ensure that any PFAS compounds included on the list of hazardous materials located at a site;  and
  3. include a “Reopener” provision in any existing consent decrees if new chemicals of concern like PFAS are discovered at the site.
Be aware!  Regulatory agencies, after several decades of delay, may require product reformulation for PFAS-containing products or new permitting rules.  You can stay current on the regulatory and technical landscape by visiting:
ITRC Fact Sheets here.
Regarding risk assessment, property owners should hire and independent environmental consultant to determine the exposure of employees within the organization.  In addition property owners should analyze disposal practices, institute litigation holds for retention of records related to PFAS at your business or organization, review relationships with potential PFAS suppliers, and assess the magnitude of exposure from PFAS-containing products to your consumers.
To reduce risk, property owners can transition to PFAS-free equipment at all levels of business and require warranties from your supplier that their products are PFAS-free.  Ask for certified laboratory results that demonstrate that these products do not contain any PFAS.  Once it has been determined that your products are PFAs-free, let your customers and potential customers know that your products contain no PFAS.
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