Uncovering best practice for PFAS management

Photograph of landfill site with a digger

The Land Condition Community and Environmental Policy Implementation Community (EPIC) and National Contaminated Land Officers Group (NCLOG) collaborated on a joint roundtable discussion exploring the challenge of PFAS management and key considerations for its effective regulation.

The roundtable was chaired by Land Condition Community Steering Group Member Dan Maher, who was joined by a range of professionals with experience and insight on PFAS:

Jonathan Atkinson, CL:AIRE
David Carr, Dacorum Borough Council and member of NCLOG
Dylan Eberle, Geosyntec
Christopher Fry, EPIC Committee Member
Joanne Holbrook, Herbert Smith Freehills
Cecilia Macleod, Thrive Sciences
Nancy Tonkin, RPS
Richard Williams, VertaseFLI

PFAS, which are often referred to in the media as ‘forever chemicals’, represent a group of thousands of chemicals, with hundreds used commercially across many sectors of industry and society. There is an increasing focus on identifying the presence of PFAS in the environment, and it is understood to be ubiquitous in soils and groundwater in both industrial and domestic effluents. Once in the environment, PFAS are extremely persistent, which means that we will continue to detect them for many years, despite restrictions on their use in commercial products.

Our understanding of the risk to human health posed by PFAS is constantly evolving, as is the public perception of the presence of PFAS in our environment. There is a high level of uncertainty around how to assess and manage PFAS effectively and given their ubiquity in the environment, it's important that environmental professionals, regulators, local authority officers and planners have a good understanding of the potential risks of PFAS, how they can be identified, and the remediation techniques that can be used to address them.

A summary of key points from the roundtable discussion are provided below:

What risks do PFAS pose to human and environmental health?

A number of studies have explored the risks that PFAS pose to human health, with links found between PFAS exposure and health issues, including infertility, certain forms of cancer and thyroid functioning.
There is uncertainty around the role of different types of PFAS and their impact on human health.
There are interim human health screening values for some PFAS compounds, which provide greater information on risk but there is still significant uncertainty around health impacts of different concentrations of PFAS compounds.
It is important that PFAS risk is communicated effectively to the public so that public perception is aligned with potential risk and therefore the need for remedial action.
The Conceptual Site Model should be used as a framework when considering risk to human and environmental health, for example if high concentrations of PFAS are found in restricted areas (e.g. airports), with limited pathways to impact controlled waters, the risk is likely to be lower than a site with multiple human health pathways or minimal mitigation of PFAS contamination migrating to groundwater.
PFAS can have negative impacts on ecology and has been shown to bioaccumulate in the tissues of fish.
Vegetation can take up PFAS which has implications for agriculture and human health.

Where and how should we be investigating the presence of PFAS?

There are many sources of PFAS and it can be highly mobile through contaminated land and ground and surface waters. Therefore, random sampling for PFAS will not be effective as all sites are likely to have some level of contamination. Identifying the source of PFAS contamination for a particular site is therefore of paramount importance and using the existing LCRM framework is a good process to work through to determine this, along with potential source-receptor pathways. For example, if a site is near a water abstraction point this may increase the need for a more thorough PFAS investigation.
Certain sites are known to be at higher risk of significant PFAS contamination, such as fire training grounds, certain manufacturing plants, wastewater treatment works etc.
When considering the sites to sample for PFAS not only should the risk of the presence of PFAS be considered but also if there would have been PFAS at a site, the potential mechanism of release and magnitude associated with its release. This will help to build a clearer picture of potential risk of significant PFAS contamination.
Drinking water is a particular concern. A catchment-based approach should be used by water companies to investigate and identify sources of contamination when sampling values above the DWI’s acceptable values are flagged.
Greater guidance is needed for local authorities on the types of sites that should be sampled, effective sample collection methods and robust lab analysis so that they can assess whether appropriate action is being undertaken by developers at sites. Communication should also be maintained with local authorities on PFAS contamination and risk more generally and it should be made clear who is responsible for managing PFAS contamination when it is found.
Only appropriately accredited laboratories (e.g. ISO/IEC 17025 certification for PFAS analyses) should be used for PFAS analysis. There can be challenges around PFAS contamination in labs which can impact results so effective protocols should be used. It should be noted that only certain PFAS compounds can be detected, so this should be taken into account when considering what the risk of PFAS is in totality.

What are some remediation techniques that can be used for PFAS?

There are two broad ways to remediate PFAS in the UK:
- PFAS destruction methods, that can benefit from first concentrating the PFAS by extracting it from the contaminated media. Various methods are being tested for both concentration and destruction of the molecules. Examples include foam fractionation and electrochemical oxidation.
- Stablilise in situ – often this is done in soils. This will then limit the risk to receptors by preventing the PFAS from leaching and spreading into the wider environment.
The best remediation method to use will depend on the site specifics, including the chain length of the PFAS. Sometimes a combination of methods will be needed to treat the different PFAS of concern.
The US has piloted some innovative technologies in this space, but often the tried-and-tested methods are used in practice such as soil removal and capping and carbon resin systems for groundwater treatment, due to the risk-averse nature of some regulators.
A “treatment train” approach is likely to be the most effective for PFAS remediation, by utilising different treatment methods in the same site. Different methods may also be needed within a site.

How can we best regulate PFAS to protect human and environmental health?

Given the ubiquity of PFAS in the environment, remediation activities will need to prioritise areas with high risk of significant exposure. The cost implications of treating all areas with potential PFAS contamination will be too high and therefore prioritisation needs to take place so that sites likely to have high levels of PFAS concentration and/or high-risk mobilisation pathways (e.g. sites linked to aquifers) are managed effectively.
Existing regulation frameworks are not currently fit-for-purpose for PFAS regulation as they will likely lead to remedial costs that are not feasible given the significant legacy issues related to PFAS. The disposal of contaminated soils is a particular concern; capacity of hazardous landfill sites is limited and there are also limits on the amount of waste material that can be sent for incineration.
Regulation needs to balance risk with cost effectiveness and feasibility of the action required.
Effective prioritisation of PFAS management needs to be evidence-based, which means that robust data on PFAS contamination and concentration levels need to be obtained.
There needs to be a consistent, risk-based approach to PFAS management that does not single out certain industries. The water industry is under particular pressure with regards to PFAS.
The UK should learn from approaches used internationally to manage PFAS, both in terms of what not to do and what may be effective. For example, with PFAS having certain background concentrations that are not easily attributable to a source, we need to ensure that limit values for remediation reflect this reality and are risk-based. The focus should be on preventing meaningful exposure and limiting risk.
Guidance is key for PFAS management – there is a high level of uncertainty around PFAS management and this needs to be tackled across stakeholder groups. Regulators should be clear on their position and support a consistent approach to PFAS management.
Permitting strategy and related regulation needs to be developed that is clear, pragmatic and consistent and local authorities need to be sufficiently resourced to implement this in an effective way. Currently there is a lot of uncertainty in local authorities around how to manage this issue, who is responsible for certain remedial activities and best practice for management.
Lines of evidence are needed to support effective decision making and develop legislation that is fit for purpose. Data on background PFAS levels and screening values for PFAS risk are essential for effective assessment of sites and to contextualise the risks posed by a site.
There needs to be an acceleration of action and support for innovative solutions so that the relevant permits can bet obtained for these solutions rapidly in place.
At the moment there is no incentive to screen for PFAS, due to a lack of screening criteria, the uncertainty around what will happen if it is found, and what the implications will be for the site and potential costs.
Regulators and industry need to work together to develop a consistent, pragmatic approach that is risk-based and solution-focused.

Next steps

The IES will continue to explore the important issue of PFAS and how environmental specialisms across the sector can support its management in their work. You can get involved in these discussions in a number of ways:

Attend our upcoming Land Condition Symposium where we will be discussing PFAS alongside other future opportunities and challenges facing the land condition sector
Join one of our member-led communities, help shape your sector and network with fellow environmental professional
Take a look at other work we have done related to PFAS:

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