For the nearly 40 years of site investigation and remediation since the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and similar state programs were enacted, the regulated community has made tremendous strides in moving sites toward closure. Like no other emerging contaminants, per- and polyfluoroalkyl substances (PFAS) have the potential to set the clocks back on that progress, mobilize a new generation of technical resources, and create significant associated costs to industrial, commercial, and municipal facility owners.
There are many critical elements for organizations potentially impacted by this latest wave of emerging contaminants to consider when developing an effective PFAS strategy. They include proper planning and insight into the rapidly evolving regulations and state policies, sensitivity to public perceptions, effective communications, and a strong technical platform from which the many complexities of PFAS chemistry, toxicology, analytics, and treatment can be vetted, as needed. Strategies will typically demand a multidisciplinary approach using experts in these and other areas.
The widespread presence of PFAS chemicals in general commerce is well known through their use in common products such as Teflon™ to provide “no-stick” features to our pots and pans, GoreTex™ to keep us dry on rainy days, and ScotchGard™ to prevent wine and other spills from permanently staining our carpets, clothes, and other fabrics.
Additionally, PFAS have been extensively manufactured for the production of aqueous film forming foam (AFFF), which are largely considered essential by the insurance industry for minimizing property damage from fires. AFFF products are used at Air Force bases, commercial airports, refineries, chemical plants, and many other facilities. And because they are ubiquitous, and have been largely unregulated since they were first introduced in the 1940s, they have found their way into surface water, groundwater, and in some cases, drinking water supplies.
As science struggles to deliver human health-based information beyond the two primary PFAS chemicals, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), the public outcry and ensuing political reactions to their presence in the environment are resulting in tremendous scrutiny and pressure to take action. Many industrial, commercial and municipal facilities are studying two questions:
- What, if anything, should we do about them?
- What, if anything, must we do about them?
The difference between the two can be significant, depending on organizational philosophy and potential impacts to businesses from the court of public opinion. Brown and Caldwell provides technical expertise and collaborates with attorneys, public relations and other experts to guide clients through the maze of PFAS complexities.