How BV is helping to unravel the PFAS Conundrum: The Environmental Challenge of Our Time

Understanding PFAS: Origins and Uses

PFAS are a group of thousands of man-made chemicals characterized by strong carbon-fluorine bonds. This robust molecular structure renders them resistant to heat, water, and oil, making them invaluable in a myriad of industrial and consumer applications. From non-stick cookware to firefighting foams, PFAS have found their way into countless products. PFAS is also associated with many industrial/manufacturing processes and property uses. 

Research into the nature of PFAS materials, their impact on human health and the environment, as well as properties that may be associated with PFAS contamination, is on-going and subject to change.

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The prevalence of PFAS in our environment stems from their ubiquitous use and persistence. Once released, these compounds linger in soil, water, and air for extended periods, earning them the moniker "forever chemicals." This persistence, coupled with their bioaccumulative nature, poses significant challenges to ecosystems and human health.

Some General Chemical Properties of PFAS

• High electronegativity – the tendency to attract shared electrons in a bond 
   
• Low polarizability – electron cloud density not easily impacted by electric fields of other molecules. 
   
•  Small atomic radius 
   
• Hydrophobic – the ability to repel water is one of, if not the single largest reasons, for the widespread use of PFAS materials. 
   
• Long half-life – the current half-life of most PFAS materials is not known. The chemicals are known as the "forever chemicals" as the half-life appears to be much longer than other contaminants of concern. 
   
• Due to the chemical structure and properties of PFAS, these materials have been used in a variety of products including food packaging, stain and water-repellent fabrics, non-stick surfaces (including Teflon), fire-fighting foams, etc. 
   
• Physical and chemical properties can vary greatly across different PFAS compounds

History and Usages of PFAS

•  PFAS materials were introduced in the 1940s and have been used extensively at manufacturing facilities, electronic plating facilities, airports, and firefighting training facilities. 
• Health concerns were raised in the 1970s, and by the 1990s and early 2000s, PFAS began to be recognized for their potential risks to human health and the environment including low infant birth weights, effects on the immune system, cancer, and thyroid hormone disruption amongst many potential other concerns. 
• Regulatory actions in the early to mid-2000s were designed to limit the manufacturing/importation of materials made with PFAS, and under the PFAS Stewardship Program, the 8 leading producers of certain materials agreed to cease production starting in 2015.

The Regulatory Landscape: Navigating the Maze

As the adverse effects of PFAS exposure became apparent, regulatory agencies worldwide scrambled to address the issue. In the United States, the Environmental Protection Agency (EPA) has taken the lead in regulating PFAS. However, the absence of comprehensive federal regulations specific to PFAS has led to a patchwork of state-level initiatives.

Several states, including California and Michigan, have set stringent limits on PFAS in drinking water, prompting industries and municipalities to monitor and remediate contamination. Additionally, the EPA has issued health advisories for some PFAS compounds, such as PFOA (perfluorooctanoic acid or C8) and PFOS (perfluorooctanesulfonic acid), establishing reference levels for safe consumption.
Internationally, the Stockholm Convention, a global treaty aimed at eliminating persistent organic pollutants, has proposed listing PFOS, PFAS and their precursors for restriction. The growing consensus among regulatory bodies underscores the urgency of addressing PFAS contamination on a global scale.

It’s also important to note that PFOA and PFOS are slated to be listed as hazardous substances under CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act). The USEPA announced the Final Rule on April 19, 2024, the Final Rule was published in the Federal Register on May 8, 2024, and the Final Rule will be effective as of July 8, 2024. A link to the announcement is here

PFAS and Environmental Site Assessments: 
Connecting the Dots

Environmental Site Assessments (ESAs) are crucial tools for evaluating the environmental liabilities associated with real estate transactions and development projects. PFAS contamination has emerged as a key consideration in ESAs, particularly in sites with historical or current industrial activities involving PFAS.

Phase I ESAs involve a thorough review of site history, regulatory records, and on-site inspections to identify potential sources of contamination. Given the widespread use of PFAS in various industries, assessing the risk of PFAS contamination is now a standard practice in Phase I ESAs .

Until the April 2024 announcement of the Final Rule designating PFOA and PFOS under CERCLA, all PFAS compounds were considered “emerging contaminants”, and as such were outside the scope of the ASTM E1527-21 Standard Practice for Environmental Site Assessments, the purpose of which is to identify Recognized Environmental Conditions (RECs) related to (CERCLA-designated) hazardous substances and petroleum products. With the new inclusion of these two compounds, the identification of the presence, likely presence, or material threat of a future release of these compounds will now be evaluated as a REC as part of the Phase I ESA process.  

The remaining PFAS compounds are still technically outside the ASTM standard as emerging contaminants. However, as it will likely be impossible in most cases to distinguish which specific PFAS compounds represent a concern (i.e. PFOA/PFOS vs. everything else), there will likely be a blanket approach to include an evaluation of PFAS in the Phase I ESA process.

Phase II ESAs typically involve sampling and laboratory analysis to confirm the presence of contaminants identified during Phase I. For sites suspected of PFAS contamination, specialized sampling protocols targeting soil, groundwater, and surface water are employed to quantify PFAS concentrations. ¹

Upon detection of PFAS contamination, Phase III ESAs focus on remediation strategies to mitigate environmental and public health risks. Remediation techniques vary depending on the extent and severity of contamination but may include soil excavation, groundwater treatment, and in-situ remediation technologies.

PFAS and Vapor Intrusion: What you need to know, how BV can help. 

Vapor intrusion occurs when volatile chemicals migrate from contaminated soil or groundwater into indoor air spaces, posing risks to human health. PFAS contamination can exacerbate vapor intrusion concerns, particularly in areas where these compounds have been used or disposed of improperly.
The EPA concluded that “The vapor intrusion of volatile PFAS may pose health risks to building occupants and should, therefore, warrant consideration during vapor intrusion assessments at facilities where high concentrations are present in shallow soils and groundwater.” However, the EPA acknowledges that the test results do not confirm VI as an exposure pathway.

Assessing and mitigating PFAS-related vapor intrusion requires a multifaceted approach. Environmental professionals conduct vapor intrusion assessments as part of Phase I and Phase II ESAs, evaluating the potential for PFAS contamination and indoor air impacts. Remediation strategies may include installing vapor barriers, ventilation systems, or soil vapor extraction systems to prevent or mitigate vapor intrusion.

Looking Ahead: Challenges and Opportunities

While significant strides have been made in understanding and addressing PFAS contamination, numerous challenges persist. The sheer complexity and diversity of PFAS compounds pose challenges for regulatory agencies and environmental professionals alike. Additionally, the lack of standardized analytical methods and regulatory thresholds complicates the assessment and management of PFAS contamination.

However, amid these challenges lie opportunities for innovation and collaboration. Advances in analytical chemistry and remediation technologies offer promising avenues for detecting and treating PFAS contamination more effectively. Moreover, enhanced regulatory frameworks and public awareness can drive proactive measures to prevent PFAS pollution and protect human and environmental health.

In conclusion, PFAS represents a multifaceted environmental challenge that demands collective action at the local, national, and global levels. By integrating PFAS considerations into Environmental Site Assessments and embracing science-based solutions, we can navigate the complex landscape of PFAS contamination and pave the way toward a cleaner, safer future.²
 
PFAS contamination represents a complex environmental challenge that requires coordinated action from regulatory agencies, industry stakeholders, and environmental professionals. By integrating PFAS considerations into vapor intrusion assessments and Environmental Site Assessments, we can identify and address contamination risks effectively

Moving forward, continued research, innovation, and collaboration will be essential to develop comprehensive strategies for managing PFAS contamination and protecting public health. By embracing science-based solutions and proactive measures, we can navigate the complexities of PFAS contamination and work towards a cleaner, safer future for all. ³

What is the BV Strategy for Investigating PFAS?

Bureau Veritas, as a leading provider of testing, inspection, and certification services, plays a pivotal role in investigating PFAS contamination and assisting clients in managing associated risks.

Here's how Bureau Veritas can help with investigating PFAS:

1. Specialized Testing Services: Bureau Veritas offers comprehensive testing services to detect and quantify PFAS in various environmental matrices, including soil, water, sediment, air, and biota. Using state-of-the-art analytical techniques such as high-resolution mass spectrometry, Bureau Veritas can accurately identify numerous PFAS compounds at trace levels.
2. Environmental Site Assessments (ESAs): Bureau Veritas conducts Phase I, Phase II, and Phase III Environmental Site Assessments to evaluate the presence and extent of PFAS contamination at industrial, commercial, and residential properties. These assessments involve historical research, site inspections, sampling, and laboratory analysis to assess potential risks to human health and the environment.
3. Vapor Intrusion Assessments: Bureau Veritas specializes in assessing vapor intrusion risks associated with PFAS contamination. By conducting indoor air sampling and modeling, Bureau Veritas can determine if PFAS vapors are infiltrating buildings and evaluate potential exposure risks to occupants.
4. Regulatory Compliance Support: Bureau Veritas provides regulatory compliance support to help clients navigate the complex landscape of PFAS regulations and guidelines. With expertise in local, state, and federal regulations, Bureau Veritas assists clients in understanding their obligations and developing strategies to comply with regulatory requirements.
5. Remediation Consulting: In cases of PFAS contamination, Bureau Veritas offers remediation consulting services to develop and implement effective remediation strategies. From soil excavation and groundwater treatment to the installation of vapor mitigation systems, Bureau Veritas provides tailored solutions to mitigate PFAS risks and restore impacted sites.
6. Risk Assessment and Management: Bureau Veritas conducts risk assessments to evaluate the potential impacts of PFAS contamination on human health and the environment. By integrating exposure pathways, toxicological data, and site-specific factors, Bureau Veritas helps clients make informed decisions and prioritize mitigation efforts.
7. Expert Support and Training: Bureau Veritas employs a team of highly skilled scientists, engineers, and regulatory experts who provide technical support and training on PFAS investigation and management. Through seminars, webinars, and customized training programs, Bureau Veritas equips clients with the knowledge and tools needed to address PFAS challenges effectively.
8. An evaluation for the potential for PFAS risks will be conducted for inclusion in the existing Phase I ESA reports. The assessment will include a review of Federal and State regulatory database records related to PFAS, a review of available mapping resources for known and suspected PFAS uses and releases, and the identification of any current and/or past uses of the subject property that may indicate the potential for PFAS contamination. No sampling will be performed. It should be noted that BV's assessment of potential PFAS concerns is based solely on review of the resources cited, and this discussion is not intended to guarantee the presence or absence of PFAS at a given site. BV can Identify risk based on findings (known regional impacts, significant onsite or adjoining use, significant proximal use, etc.) Identify onsite water use (drinking, irrigation, waste, etc.) and review local municipal drinking water sampling results for PFAS and Assess/discuss potential exposure risk, liability, and potential regulatory action.

In summary, Bureau Veritas offers a comprehensive suite of services to investigate PFAS contamination, assess associated risks, and support clients in compliance with regulatory requirements. 

With cutting-edge technology, regulatory expertise, and a commitment to environmental stewardship, Bureau Veritas helps clients navigate the complexities of PFAS investigation and management with confidence.

sources: 
² https://www.scsengineers.com/scs-articles/what-does-epas-proposed-pfas-regulation-mean-for-commercial-real-estate
¹ https://www.foley.com/insights/publications/2024/04/us-epa-pfas-chemicals-hazardous-substances-cercla/
³ https://www.epa.gov/sciencematters/addressing-challenges-pfas-protecting-groundwater-and-treating-contaminated-sources
https://www.scsengineers.com/environmental-assessments-post-pfas-regulation/