Why the EPA’s Designation of PFAS as Hazardous Makes Precise Identification of These Emerging Contaminants Imperative

By Dr. Solidea Maria Cristina Bonina, Senior Environmental Consultant

Why should you be thinking about PFAS?

Per- and Polyfluoroalkyl Substances (PFAS) investigation, monitoring, and potential remediation should be at the forefront of all environmental practitioners’ work moving forward. Keep reading to learn why and how you can get started building a robust approach to PFAS characterization, evaluation, remediation, and liability management.

PFAS are thousands of man-made organofluorine compounds, historically found and used in everyday life. They are valued for their resistance to heat, water, oil, and chemicals, making them useful in a wide range of applications such as waterproof products, firefighting agents, and industrial, commercial, and consumer processes. Commonly known as “forever chemicals”, PFAS have a unique chemical makeup that do not naturally break down in the environment, are highly persistent, and can travel long distances in surface and groundwater. As a result, PFAS present unique challenges because of their composition, the way they move within the environment, the learning curve for sampling, analysis, remediation, and the mounting regulatory requirements.

Concerns about their environmental and health impacts have led to restrictions and bans on certain PFAS. The U.S. Environmental Protection Agency (U.S. EPA) has identified some PFAS compounds that are environmentally significant due to their persistence, bioaccumulation, and toxicity (PBT). These emerging contaminants (particularly perfluorooctane sulfonate (PFOS) and Perfluorooctanoic acid (PFOA)) have been recently designated as hazardous substances by the U.S. EPA under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). With another EPA release, certain PFAS are also subject to drinking water enforceable standards Maximum Contaminant Levels (MCLs) under the National Primary Drinking Water Regulation (NPDWR) since April 2024. And last but not least as a forward step in the EPA’s Roadmap Initiative, on October 1, 2024, another release by the U.S. EPA issued final recommended freshwater ambient water quality criteria (AWQC) for the protection of aquatic life. Europe, in alignment with the U.S., now classifies PFAS as substances of very high concern (SVHC) under the European Union’s Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation.

These emerging contaminants are receiving increased attention from regulators and the public as a major global environmental concern due to the human health risks and environmental impacts. This makes managing and addressing PFAS a challenging task because you need to understand what you are looking for, the most effective way to identify the compound, and how to be compliant with the most current regulations.

Taking the First Step

With all this increased attention, you may want to start your PFAS investigation for several reasons including:

• protecting public health
• meeting regulatory requirements
• gathering information to make data-driven decisions
• lowering remediation costs
• preventing further contamination
• avoiding negative publicity
• preventing legal action against PFAS pollution.

Environmental practitioners will want to partner with a consultant who can provide a timely update and offer guidance in areas such as:

• sampling
• analytical methodologies
• data quality
• best practices for review, verification, validation, and usability.

This guidance will support cost-effective PFAS remediation and management decisions. Learning analytical method options will help craft an analytical strategy based on your project specific data objectives and result in defensible and usable data if there is a PFAS concern. You may also want to discuss data usability or liability with your consultant if any assessment needs arise.

Understanding PFAS chemistry is essential for accurately interpreting field data and addressing possible challenges in litigation, where the reliability of data is frequently scrutinized. Given the current landscape of new guidelines and ongoing regulatory developments, understanding the analytical processes involved is also critical. This includes evaluating available methods, understanding their strengths and limitations, and knowing the rationale behind choosing one method over another. Selecting the most effective analytical method is crucial for generating PFAS data that are consistent, reproducible, and reliable. The data quality must align with its intended use and project specific objectives/goals as well as adhere to the latest and emerging PFAS regulations. This scientifically based approach supports cost-effective PFAS management decisions, affirms the data can be defended in litigation, and addresses risk assessment questions.

An Important PFAS Question

What are you looking for? The answer will help drive the appropriate PFAS analytical method. If your goal is to characterize individual PFAS or assess PFAS levels against a threshold of concern for risk assessment, you should use the most suitable target PFAS method. Conversely, non-target PFAS methods are more appropriate for determining the presence of PFAS at a site. These methods include screening-level analyses or the identification of potential PFAS contaminants for further investigation. By knowing what you’re looking for, you can decide on the type of method and level of accuracy needed. Keep in mind that the more specific the analysis, the higher the cost, so it is essential to align your testing approach with your project objectives.

Below is a flowchart I designed to guide you through the available analytical options that can be tailored to your PFAS sampling and analytical project plan. This will help make you aware of the choices before you begin the sampling process.

What are Your Options for PFAS Testing?

PFAS testing is done by commercial laboratories, but not all labs are using the same approach to testing, making it challenging to get consistent results as PFAS analysis is still evolving with additional approaches in development. To date, all analytical methods published by USEPA for PFAS analysis use liquid chromatography/mass spectrometry (LC/MS) instruments, although other methods are available.

Laboratories can determine, identify, and quantify the PFAS in provided samples. Some PFAS have specific standards/regulated levels, and it is important to know what your sample contains so you can make the best decisions and be compliant with the current regulations. Here’s some good news: you can cost-effectively scale the testing to meet all your compliance requirements, even as new regulations appear and you learn about your site.

By better understanding the contaminants on your site and applying a thoughtful approach, you can tailor your strategic PFAS sampling and analytical plan to align with the most current science and regulations.

Let’s Collaborate

The reality is that without good, robust analytical data from very basic and fundamental analytical work performed in different venues for different environmental engineering applications, we can’t effectively address any PFAS-related issues and the PFAS challenge.

Our team offers a scientifically informed approach to PFAS-related issues, and our experts strategically support projects, helping clients make informed, cost-effective decisions related to PFAS management. Our approach covers key PFAS topics, such as selecting the most appropriate analytical methods and planning effective sampling campaigns. As strategic advisors, we provide an up-to-date overview of PFAS, along with detailed guidance on analytical methodologies, data quality, and best practices for review, verification, validation, and usability to support cost-effective PFAS management decisions.

PFAS are considered forever chemicals, but they are not supposed to be a forever problem. We are all learning together. Contact me to discuss how our team can help you.