PFAS: What it is, how to deal with it, and where to find it.
WHAT ARE PFAS?
Per- and Poly-fluoroalkyl Substances, collectively known as PFAS, are an emerging class of environmental contaminants receiving increasing regulatory attention. These toxic chemicals have been widely used in consumer products since the 1940s and are highly mobile and resistant to biodegradation.
Because of their toxicity to humans and their persistence in the environment, releases of PFAS compounds to soil and groundwater represent a growing concern for environmental assessment and cleanup.
WHAT ARE THE STANDARDS FOR PFAS TESTING AND REMEDIATION?
PFAS are not yet designated a hazardous substance under CERCLA, so they are not included under the current ASTM Phase I scope (ASTM Standard E1527-13). However, under the proposed update to the ASTM standard (ASTM E1527-21), PFAS would be considered an example of a Non-Scope Consideration along with other “emerging contaminants.”
Given the current regulatory climate, PFAS are likely to be defined under CERCLA and thus included in the ASTM standard in the near future, and litigation settlements suggest that evaluating potential PFAS-related environmental impacts as is advisable, where appropriate.
WHO SHOULD CONSIDER PFAS TESTING?
Regulations: The map illustrates states with current or pending standards or guidance on PFAS in water and/or soil (updated as of May 2021 from the ITRC’s PFAS Technical and Regulatory Guidance Document). Some states are also developing soil and groundwater standards. PFAS regulation is also at work at the Federal level, and it is likely that the US EPA will soon designate PFAS as a hazardous substance under CERCLA.
Conditions: The list of conditions where PFAS could be identified as potential compounds of environmental concern is extensive. Because of this, the mere historic use of PFAS or PFAS-containing products at a current or former industrial property may not be sufficient to identify it as a significant environmental concern. The first step is to contact one of our Environmental Professionals who can help determine if PFAS pose an environmental concern.
Click here to read our White Paper for a deeper dive into these questions and more information on PFAS.