PFAS’s complex lifecycle requires a comprehensive response

By Mike Ursin, PG
Team Leader and Senior Project Manager with TRC Companies, Inc.

Per- and polyfluoroalkyl substance (PFAS) chemistry was an accidental discovery by DuPont chemist Dr. Roy J. Plunkett in 1938. His discovery of polytetrafluoroethyelene (PTFE) was used to develop the product Teflon, which would be used worldwide for its nonstick properties on cookware, soil and stain repellency on fabrics and textiles, and as a coating in manufacturing and industrial products for decades. Widespread commercial and industrial use of PFAS began in the 1950s. Since Plunkett’s initial discovery of PTFE, thousands of PFAS compounds have been developed and manufactured with unique physical and chemical properties to repel water, oil, and stains, reduce friction, resist heat and physical and chemical degradation, extinguish chemical and petroleum fires, and impart surfactant properties in a wide range of products and applications.

The effectiveness of PFAS is evident in the myriad product applications. Consumer products such as cosmetics, household cleaners and waterproof boots and outerwear, just to name a few, have contained and some still contain PFAS. The metal plating, firefighting and paper products industries, among many others, have well documented use of PFAS. The list of current and historic applications of PFAS and industries of use continue to expand as the scientific research progresses.  Many products containing PFAS have not been disclosed, partially due to manufacturers’ ability to claim trade secret discretion. This prevents the disclosure of the PFAS compound and amount of PFAS in a particular product.

PFAS in the environment

The properties that make some PFAS desirable and useful in consumer and industrial products also make it challenging to deal with in the environment. Many PFAS have chemical structures that make them incredibly durable and resistant to breakdown, which allows PFAS to persist in the environment. According to the Interstate Technology & Regulatory Council (ITRC), the leading technical resource on PFAS, “the persistence and mobility of some PFAS, combined with decades of widespread use in industrial processes, certain types of firefighting foams, and consumer products, have resulted in their being present in most environmental media at trace levels across the globe.”

PFAS have been discovered in soil, groundwater, surface water, drinking water and air, as well as animal and fish tissue and human blood serum.  As a result of their durability and persistence, once PFAS are introduced into the environment, removal is not always effective easily achieved or economically viable. Some PFAS pose health risks to humans and animals, and some have the potential to build-up or bioaccumulate in organisms over time. The primary exposure risk for humans is through eating or drinking PFAS-contaminated materials, such as contaminated drinking water or food in PFAS-containing packaging.

The durability and persistence of PFAS creates a cycling effect in our environment. Wastewater treatment plants (WWTPs) and landfills are receivers of society’s wastes, and that waste has historically, and continues to, include PFAS due to the products we manufacture and buy.  Even though WWTPs are receivers of PFAS at the “end of the pipe” and are not original sources of PFAS, they are not exempt from regulatory scrutiny for PFAS. There are currently no economically viable treatment options for wastewater treatment of PFAS at the utility scale. If PFAS are received by a WWTP, they will pass through their current treatment systems and have the potential to cycle back into the environment in the effluent discharged by the WWTP. While WWTPs play an important role in introducing PFAS in the environment, they are not the original sources of PFAS.

Past, Present and Future Actions to Address PFAS

Manufactured and used for more than 70 years, addressing the worldwide, human-made problem of PFAS requires complex solutions. PFAS management requires a holistic and broad-based approach. This should include source reduction, phasing out the most dangerous PFAS in non-essential and substitutable products, establishing science-based, media-specific standards (such as a standard specifically for groundwater and one for surface water), and continuing to expand our knowledge through scientific research. Focusing on one industry, removing one product, or establishing one new regulation will not be the silver bullet to single-handedly reduce PFAS discharges into the environment and prevent current and future human health impacts.

There have been successes in the last 20 years to phase out certain PFAS in the United States. Industry voluntarily phased out production of perfluorooctane sulfonate (PFOS) by 2002. In 2006, the U.S. Environmental Protection Agency launched the perfluorooctanoic acid (PFOA) Stewardship Program, which led to the elimination of PFOA by producers from emissions and product content by 2015. As a result of these actions, between 1999 and 2014, concentrations of PFOA and PFOS in human blood (as measured by Centers for Disease Control and Prevention) declined by more than 60% and 80% nationally.  

Some states have already established or are in the process of developing regulations for PFAS, while other states are waiting for the federal government to enact its PFAS Action Plan. There are currently no enforceable PFAS standards for drinking water at the federal level under the Safe Drinking Water Act. The regulations promulgated to date and under consideration only address a fraction of the thousands of PFAS compounds. The Wisconsin Department of Natural Resources (WDNR) is in the process of establishing standards for PFAS in groundwater, surface water, and drinking water. WDNR’s proposed groundwater standards include 18 PFAS compounds. WDNR is also considering creating PFAS standards for biosolids, solid waste and sediment.

On December 16, 2020, Wisconsin published its PFAS Action Plan, which will serve as a “roadmap” for how state agencies address the public health risks of environmental contamination from PFAS in Wisconsin. This PFAS Action Plan includes 25 action items, organized into eight themes, including pollution prevention, research and knowledge, and phase out. The comprehensive nature of the plan is necessary to address the complex issue of PFAS, but it will require effort by many to ensure that it is implemented appropriately and updated frequently to keep up with the ever-evolving science and regulations.

Occupational studies from the 1970s showed potential impacts of PFAS on public health, but meaningful action did not occur until the 2000s with the phase-out of PFOS and PFOA. The rate of scientific research and understanding of PFAS over the last five years is encouraging and rapidly evolving, but hard work remains. We need unwavering leadership from public, industry and government stakeholders to create holistic plans to address the entire PFAS lifecycle and solve this complex problem.

Mike Ursin is a hydrogeologist and Wisconsin-licensed Professional Geologist who has 13 years of environmental consulting experience. His experience includes environmental investigations, emerging contaminants, regulatory agency communication, and building working relationships with clients.