On October 18, 2021, the U.S. Environmental Protection Agency (EPA) announced a strategic roadmap to address per- and polyfluoroalkyl substances (PFAS). EPA Director Michael S. Regan announced that the roadmap focuses on a “lifecycle approach to PFAS in order to make meaningful progress.” The roadmap emphasizes three central directives:
- Research using the best available science
- Proactively prevent PFAS from entering air, land, and water
- Remediate, broaden, and accelerate the cleanup of PFAS contamination
As a leader in addressing PFAS issues in air, water, soil, and biosolids, Barr has summarized the announcement with the following eight takeaways:
- Sources are the focus. While EPA’s PFAS roadmap outlines multiple priorities, the agency’s intended focus is on PFAS sources. This includes PFAS prevention, lifecycle considerations, release accountability, and historic and ongoing release tracking. Affected industries include:
- PFAS manufacturing
- Metal finishing
- Textile manufacturing
- Pulp and paper
- Municipal drinking water and sewage treatment facilities
- Carpet manufacturing
- Facilities that have used aqueous film forming foam (AFFF), including airports
- Buildout of regulatory frameworks. The roadmap focuses heavily on EPA’s regulatory mechanisms and environmental authorities used to address PFAS contamination. This includes RCRA, CERCLA, TSCA, CAA, and NPDES permitting. While formal regulation development is ongoing, the roadmap shows EPA’s intention to increase reporting and compliance through regulatory requirements. For questions on regulatory developments, contact one of Barr’s PFAS consultants.
- Multi-media focus. While ground and surface water has been the primary medium for PFAS research and containment, soil and air will receive greater attention moving forward. For example, EPA plans to research the fate and transport of PFAS air emissions, an area where Barr is a recognized expert.
- Standard setting. The roadmap outlines standards for testing methodology. Throughout 2021, EPA has updated and validated analytical methods that will carry through multiple media. Barr has contributed to the method development and evaluation for some media as part of our current projects.
- Disadvantaged community protection. The roadmap incorporates broader environmental justice (EJ) implications for potential and contributing PFAS sources. As more entities evaluate their EJ and environmental, social, and governance (ESG) PFAS implications, business decisions will likely transcend beyond just regulatory framework.
- The permanence of PFAS. Addressing PFAS will likely take decades, and EPA’s roadmap outlines both current and future actions and priorities. Therefore, the regulated industrial community needs to understand their PFAS-related exposure and risks. For example, the plan outlines a short-term consideration to monitor PFAS at NPDES-permitted facilities, with a long-term consideration of seeking to require mandatory reporting of PFAS through the Toxic Release Inventory (TRI), likely at a lower threshold than currently established.
- State involvement stays. While the roadmap outlines federal actions, its timeline gives states the ability to develop their own strategies.
- Taking action. Many states have been waiting for federal action to address PFAS. EPA’s roadmap shows a clear plan for federal involvement and leadership. Although the complexities of PFAS has slowed regulatory development, the future of awareness and risk assessment is now. Current attention is on the eight-chain chemical bonds, but future regulation is inevitable, because PFAS includes more than 4,000 compounds. It’s critical to work with an experienced consultant that understands the complexities of PFAS and takes a holistic approach to address site-specific solutions.
Since the early 2000s, Barr has developed and implemented highly effective multi-media PFAS detection, monitoring, remediation, and treatment solutions for industrial clients and municipalities. For an overview of recent projects, visit our PFAS Innovation & Insights page.
We will continue to monitor PFAS developments at the federal level and across North America. For more information, contact us at PFAS@barr.com.
For more information on EPA’s PFAS strategic roadmap, see the following resources: