PFAS are a group of chemicals with industrial, commercial and home uses. They’ve been around since the 1930s and started being produced in quantity in the 1950s. Since then they’ve gotten into every corner of our lives, and many processes produce large quantities of PFAS-contaminated waste.
PFAS build up in the food chain, leach into the environment easily, and cause health problems in animals and humans. Thus the EPA is seeking more stringent regulations to control their production, use and disposal. This includes seeking to have new PFAS placed on the list of banned substances, seeking to establish maximal safe levels of common PFAS in drinking water, and working to mitigate the effects of dumping PFAS.
In this post we will examine what PFAS are, how they are regulated and how they should be disposed of.
What does PFAS mean?
Skeletal structure of PFOS
PFAS stands for Per- and Polyfluoro-Alkyl Substances. Technically, they’re synthetic, organofluorine compounds made by attaching fluorine atoms to an alkyl chain. They’re extremely difficult to break down, and most are resistant to heat, water, oil, and many chemical agents. This means they tend to persist — where they’re used, where they’re dumped, and where they escape into the environment, including into animals and humans.
Common PFAS include:
- Perfluorooctanoic acid (PFOA)
- Perfluorooctane sulfonate (PFOS)
- Perfluorohexane-1-sulfonic acid (PFHxS)
- GenX — hexafluoropropylene oxide dimer acid (HFPO-DA)
PFAS are divided into two groups, long chain and short chain, and long-chain PFAS are regarded as more dangerous. They’re being phased out and replaced with short-chain analogs which are themselves in the crosshairs of various regulatory agencies in the USA, Canada and elsewhere.
Where does PFAS show up?
PFAS don’t tend to break down in the environment because their chemical bonds are too strong. As a result, they accumulate in the food chain, in wildlife and in groundwater and surface water, and in humans. They’re commonly found in dumps, and in the products they’re originally used in.
What is PFAS used in?
PFAS gets used in fire-retardant household goods like couch covers, in fast food wrappers and in industrial applications. In operation their resistance to breakdown is a major selling point: they’re used to make couch cushions less easy to ignite because they have such strong chemical bonds already that they don’t oxidize easily. On fast food wrappers, they provide resistance to grease, water, and acids, so you don’t get food all over your hands and less packaging is required. PFAS are useful in a wide range of applications, meaning that since their introduction in the 1950s, they’ve been added to a growing list of consumer and industrial products.
What products contain PFAS?
Commercial household products like stain-resistant and water-repellent fabrics, nonstick cooking and household products like Teflon contain PFAS. So do polishes, waxes, paints and cleaning products. Although they’re not used in firefighting foams anymore, they were for a long time and any legacy firefighting foams are likely to contain them.
PFAS are FDA-authorized in food contact uses like food wrappers, popcorn wrappers and pet food packaging. They’re also used in the manufacture of other food-contact products like industrial food production machinery.
Outside the home, they’re common in business applications like chrome plating, electronics manufacturing and oil recovery — dirty work that involves grease or oil, chemical reactions or heat often relies on PFAS to reduce friction literally and metaphorically.
In other words… they’re everywhere, and it’s a growing problem for the environment and human health, as well as for the waste disposal industry.
PFAS in the environment
PFAS are found in groundwater and drinking water, usually if it comes from close by a facility that uses or handles PFAS, like a landfill, wastewater treatment plant or a firefighter training facility that’s still using legacy firefighting foam containing PFAS.
They also occur in food that’s grown on soil or irrigated with water that’s contaminated with PFAS, packaged using PFAS, or processed with equipment that contains PFAS.
And most worryingly, PFAS show up in fish and animals, building up in tissues because animals lack the capacity to break down or excrete them. Just like lead or mercury, the higher up the food chain an animal is, the more PFAS you find. Because humans are at the top of the food chain, PFAS concentrates with humans, leading to health problems.
What does PFAS do to humans?
PFAS have been linked to health issues in both humans and animals.
In humans, they’re thought to be linked with:
- Liver problems like enzyme disruption, cholesterol issues and changed distributions of fat through the liver
- Immunological issues like asthma and decreased vaccination responsiveness
- Developmental effects including lowered birthweight
- Endocrine effects including thyroid disease, altered hormone production and decreased fertility
- Cardiovascular problems including pregnancy-induced hypertension
- Cancer, especially of the testicles and kidneys, though these are linked only to the specific PFAS PFOA.
A 2007 study by the CDC estimated that PFAS could be detected in the blood of 98% of Americans.
What regulations apply to PFAS?
Since their danger was recognized, there has been increasing effort to regulate PFAS. Long-chain PFAS were phased out of production and lost FDA approval in 2011 over concerns about their environmental and health effects. They were replaced with short-chain PFAS like PFBA, which have shorter molecules with fewer carbon atoms. As such they’re less chemically stable and more easily excreted so they don’t build up as much in the food chain. However, some of these short-chain PFAS are now being phased out by the FDA too, specifically those containing 6:2 FTOH.
Safe levels of chemicals in drinking water are set by the EPA and regulated under the Safe Drinking Water Act (SDWA). The SDWA empowers the EPA to set and enforce Maximum Contaminant Levels (MCL), but there is currently no MCL for PFAS. The EPA has begun the process to set MCLs, and has issued a Drinking Water Health Advisory for the PFAS PFOA and PFOS.
However, the EPA hasn’t added a new toxic chemical to the SDWA since 1996, when it — rather than Congress — became responsible for adding chemicals to the list, and a higher burden of proof of harm was required.
These efforts form part of the EPA’s PFAS Action Plan, which includes efforts to reduce human PFAS exposure through stricter water regulation, cleanups of contaminated sites, and using other federal agencies, cities, states and tribes to address legacy PFAS contamination at Superfund sites and other federal cleanup sites. This includes using the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to investigate sites and seeking to have PFOA and PFOS designated hazardous substances under CERCLA.
States have implemented their own regulations on drinking water contamination with PFAS — in California, it’s 5.1 parts per trillion (ppt) for PFOA, 6.5ppt for PFOS — and the resultant ‘patchwork of regulations and standards… present[s] significant challenges to impacted industries.’
How should you dispose of waste that contains PFAS?
There aren’t any federal regulations on disposal of PFAS — yet. In the meantime, and with regulations on the horizon, there are sound business reasons to move toward best practices as quickly as possible, to be ready for regulations when they arrive.
The Stockholm Convention on Persistent Organic Pollutants indicates PFAS waste should be either stored in a controlled landfill that protects against leaching to the environment, or thermally destroyed at a minimum 1,100°C/2,012°F. Similar advice is given in the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal for wastes containing more than 50 mg/kg of the long-chain PFAS PFOS.
The EPA’s Interim Guidance on Destroying and Disposing of Certain PFAS and PFAS-Containing Materials That Are Not Consumer Products explains the EPA’s position and explores three options: incineration, landfill, and deep well injection.
The EPA’s opinion on PFAS disposal methods
Incineration may cause the release of Products of Incomplete Combustion (PICs), meaning incineration might work to spread PFAS further if it isn’t done right. Incinerators need to be specialized, very-high-temperature systems with waste scrubbers, and there are few of them. Canada has incinerators, but has begun to refuse to accept PFAS-contaminated waste.
The EPA is collecting data on the technical aspects of PFAS high-temperature incineration, and in the meantime recommends sequestration in landfills regulated under Subtitle C of the Toxic Substances Control Act (TSCA), which are for hazardous waste. There are just 21 of these in the USA, so safe transportation of PFAS-contaminated waste to them may not be cost-effective.
The EPA’s Guidance also considers Subtitle D Municipal Solid Waste Landfills (MSWLFs) intended for nonhazardous waste. There is good evidence that the technology used to prevent them leaching into soil and water is not fully effective, but it does mitigate the release of PFAS into the environment, and there are 1,908 MSWLFs in the continental USA, making them a far more accessible option than Subtitle C sites.
Finally, deep well injection is considered the least uncertain method of safely disposing of hazardous PFAS waste, but is only available for liquid wastes and only at a restricted number of sites. For the majority of PFAS disposal, MSWLFs will continue to be the destination of choice for the foreseeable future.
Locating an appropriate site for PFAS disposal can be difficult, but it doesn’t have to be. You can use our Site Locator to find a waste disposal expert in your area that knows how to deal with your PFAS waste.