Be Prepared to Tackle Challenges of PFAS
A big challenge in addressing emerging contaminants is that it’s hard to know how to proceed — or justify expenses — in the absence a cohesive policy and established regulatory limits, such as national drinking water regulations.
Federal agencies and private industry face different pressures as they determine their approach. And whereas the private sector often leads the way on innovation in many areas, some federal agencies have been at the forefront of this particular challenge, especially with regard to the example of per- and polyfluoroalkyl substances (PFAS).
Private industry can benefit from studying some of the developments coming out of the Department of Defense (DOD). The essence of the approach being employed boils down to two key elements:
- Identify the source of any contamination
- Be prepared — know your risks and liability
One common PFAS contamination source is from aqueous film-forming foam (AFFF), an extremely common fire-fighting measure that is often used at airfields. Recognizing this source, the DOD is performing preliminary assessments/site investigations (PA/SI) to differentiate sites that pose little or no potential threat to human health and the environment from those that warrant further investigation. For the latter, they are determining if PFAS has been released to the environment and identifying potential migration pathways.
It is understandable that companies in the private sector might not want to spend money on investigations and remediation when no national regulatory limits have been established. But the price of that attitude is having to go into reaction mode once the Environmental Protection Agency (EPA) sets limits. Those who are less prepared will inevitably have to spend more to catch up.
An investment in understanding the risks, liability and contaminant sources — which in the example of PFAS are numerous and pervasive — offers the promise of smoother process adaptation.
Private industry does not have to approach the challenges of emerging contaminants as they would uncharted waters. By studying the assessment and investigation methods and cutting-edge technologies being deployed by federal agencies at the forefront, the broad array of industries likely to be affected by eventual regulatory limits can follow the Boy Scout motto: “Be prepared.” They will spend less time and money in the long run.
An investment in understanding the risks, liability and contaminant sources offers the promise of smoother process adaptation.