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Greencap Risk Review
Risk Review

Managing Risks Associated with PFAS

29 May 2018

There has been significant reporting of PFAS issues in the media over the last few years, especially since the discovery of PFOS (perfluorooctane sulfonate) contamination at the Fiskville CFA training college in Victoria.

The issue of PFAS contamination in the environment also gained greater prominence in 2015, after contamination was detected both on and offsite at the Department of Defence RAAF Base at Williamtown in New South Wales, generating a lot of media and public interest.

 

What is PFAS?

’PFAS‘ refers to per- and poly-fluorinated alkyl substances, a group of fluorinated long-chain organic compounds. The PFAS group of chemicals contains:

  • PFOS (perfluorooctane sulfonate)

  • PFOA (perfluorooctanoic acid) and

  • PFHxS (perfluorohexane sulfonate), amongst others

These are man-made chemicals that have been used since the 1950s in industrial processes, some types of firefighting foam, and in a range of common household products and specialty applications – including in the manufacture of non-stick cookware; fabric, furniture and carpet stain protection applications; food packaging; personal care items such as sunscreens and other skin products.

All PFAS chemicals contain fluorine atoms attached to carbon atoms. The fluorine/carbon bond is very strong and gives the PFAS molecule its fire retarding qualities, its non-stick qualities and its persistence. Other than its potential toxicity, the most problematic issue from an environmental perspective is that PFAS persists in the environment for a very long time.

The most famous member of the PFAS group is PFOS, a chain of eight carbon atoms, each with fluorine atoms attached and a sulfonate group at one end.

 

Where is PFAS found?

The use of PFAS chemicals in some firefighting foams, and the widespread reach of their residues, has led to contamination in many Australian locations, particularly on or near historical fire training grounds; oil refineries and bulk oil terminals; airports, Defence facilities and major hazard facilities (where large quantities of hazardous materials or dangerous goods are stored, handled or processed).

In addition, their use in consumer products such as non-stick products, waterproofing agents and personal care items, has created residues in groundwater leaching from landfills and in sewerage and wastewater treatment facilities.

As outlined above, PFAS chemicals are very stable and do not break down readily in the environment. They can be found years after their use in soil, sediment, surface water (rivers, lakes, lagoons) and groundwater. They can travel away from the original site through surface water and groundwater, and can migrate to neighbouring sites. This is of particular concern when the groundwater in an area is being used for domestic or agricultural purposes.

 

Case study:  Environmental contamination from use of firefighting foam

Uncontained releases of PFAS firefighting foam from firefighting systems, whether during an actual emergency or through a system malfunction, can contaminate the surrounding environment.

PFOS was accidentally released into a creek in Canada in 2000, when around 22,000 litres of firefighting foam and 450,000 litres of water escaped from the sprinkler system at an airline hangar at the Toronto international airport. 

The PFOS levels in surface waters reached 2,210 µg/L two days after the spill, 15 km downstream. The PFOS levels at the end of the sampling period, 6 months after release, ranged from 0.2 to 0.4 µg/L. The study also found very high levels of PFOS in the liver tissues of fish living in the creek –although it noted that some of this could be due to existing PFOS contamination from the airport or other sources in the creek catchment, rather than the immediate effects of the spill.

The volume of firefighting foam discharged from the hangar fire system in Toronto is considered representative of how firefighting foam is used at Australian major hazard facilities. The use of PFOS-containing firefighting foam in Australia, without adequate controls to prevent its entry into waterways, could lead to similar environmental contamination.    (From DOEE 2017)

 

Why should PFAS concern you?

If PFAS are present on your land or in your groundwater in significant quantities, this may result in health or environmental impacts.

PFAS chemicals can persist for a long time in the environment (and subsequently in humans and other animals after eating their residues). They are readily absorbed by the body after ingestion and are eliminated very slowly.

Potential sellers or purchasers of a PFAS contaminated site are likely to receive scrutiny from regulatory authorities (if there is contamination going off-site) and even from finance brokers.

PFAS chemicals in the soils and/or groundwater on your site can:

  • Cost a significant amount of money to remediate

  • Limit land use options and/or

  • Incur reputational risk on the owner if not managed properly

 

What are the properties of PFAS chemicals that makes them of concern?

PFAS chemicals have persistence and the ability to bio-accumulate in the food chain. Experimental studies show that high PFAS concentrations cause impacts on animal reproduction, growth and development, plus systemic effects (including immune system, nervous system and digestive system impacts).

These effects are evident in animal studies rather than natural ecosystems.

In people, the evidence is less clear. Many Australian and international health authorities have reviewed potential human health impacts of PFAS exposure, concluding that there is no clear evidence of adverse health effects in humans (even in highly exposed occupational populations).

While there is no clear evidence of human health impacts as yet, health and environmental agencies consider it prudent to take a precautionary approach and limit the exposure to PFAS as far as practicable, considering its residual and persistent nature and its ability to bio-accumulate.

 

Regulation

Internationally, many uses of PFAS have been banned or phased out, with some exemptions for special uses. Australia’s National Industrial Chemicals Notification and Assessment Scheme (NICNAS) recommended that PFOS and related chemicals be restricted to only essential uses for which no suitable alternatives are available, such as certain Class B firefighting foams (NICNAS 2016). Australia is currently considering a national phase-out of PFOS and related chemicals (DoEE 2017). In January 2018, South Australia banned the use of PFAS firefighting foams.

In 2018, the Heads of EPA (HEPA) of Australia and New Zealand released a PFAS National Environmental Management Plan (NEMP) which is designed to achieve a clear, effective coherent and nationally consistent approach to the environmental regulation of PFAS. The Plan sets out a range of guidance on PFAS monitoring, contaminated site assessment, PFAS waste management.

The PFAS NEMP includes a range of health-based and environmental guideline values, outlining concentrations in water used for drinking or recreation, and water and sediments to protect freshwater and marine ecosystems. It also includes a range of soil guideline values to protect human health and ecosystems in residential areas; parks and open spaces; and commercial/ industrial areas.

The NEMP guidance has been adopted across all Australian States and Territories, as well as the Commonwealth; the Department of Defence has adopted this guidance as well as airport corporations and other Commonwealth landowners.

 

What can I do to understand my PFAS risk?

There are three key steps you should consider to establish a practical approach that will help you understand and manage your PFAS risks, especially if you buying or selling a property.

 

Step 1: Characterise the site

Is it on or near a likely PFAS source, such as a fire training ground; airport; oil or gas industry or other chemical manufacturers; landfills; wastewater treatment facilities; or where biosolids have been added? If there is no evidence of PFAS use on your site or surrounding areas, it is less likely to be a health, environmental or financial risk and you may decide to take no further action.

 

Step 2: Characterise the risk

If the site history indicates there may have been PFAS chemicals used over the last 50 years, sampling the soil and water will help determine if there is a significant risk. If results show PFAS concentrations less than the guideline values in the PFAS NEMP, then there is unlikely to be a health, environmental or financial risk and you may decide to take no further action. If some of the sampling results exceed the guideline values, a risk assessment can help decide whether the site is suitable for use or if it requires management. A risk assessment will consider the magnitude of any exceedances, where they were found on the site and whether there are sensitive receptors that need protecting.

 

CASE STUDY:

A construction site required a 5m excavation to install infrastructure. Groundwater was present at 4m and the construction crew were exposed to groundwater splashing on occasions. The site was found to have high concentrations of PFAS in the groundwater coming onto the site from a site across the road. The PFAS concentrations were 30 times higher than the guideline level for recreational water and 300 times higher than for drinking water. Greencap conducted a health risk assessment for the occupational exposure to PFAS and found that the type and duration of the exposure was considered an acceptable risk and no additional management was required.

 

Step 3: Manage the risk

Once you are aware of the risk likelihood and magnitude, you can then decide on appropriate management strategies. Depending on the circumstances, these may include:

  • Using a site for a different purpose or with different design elements to prevent PFAS exposure to sensitive receptors or mobilisation off-site

  • Remediation

  • Deciding not to buy or sell a site, or buying or selling at a discount price (to allow for management or remediation costs)

These actions can range from the simple and inexpensive to complex and costly, so should be considered carefully with sufficient information and expert advice.

 

 

Greencap’s Expert Services Environmental Team has assisted many organisations, both public and private, operating across all states and territories to manage their PFAS risks and other environmental risks.

Please Contact Greencap for further information or if you would like assistance in managing your environmental risks

 

 

References

 

The information in this material is not intended to provide, and should not be relied upon, for legal or professional advice and is subject to change.
This material provides general information only and does not take into account your particular needs or circumstances. Before making any decisions, you should assess whether this material is appropriate for you and obtain legal advice tailored to you having regard to your particular needs and circumstances.
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