Per- and poly-fluoroalkyl substances (PFAS)
Transitioning to fluorine-free firefighting foam
A ban on fluorinated firefighting foams in South Australia came into effect on 30 January 2018 following an amendment of the Environment Protection (Water Quality) Policy 2015 (the Policy) under the Environment Protection Act 1993 (the Act). Legislative requirements are set out in Section 13A of the Policy.
A grace period of 2 years (up to 30 January 2020) was granted to help industry meet the requirements of the ban after which fluorinated foams will be prohibited. Depending on the site and scenario, the transition to fluorine-free foams can be undertaken at an annual service of firefighting equipment, or a longer-term transition plan may be necessary.
Useful information:
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Per- and poly-fluoroalkyl substances, known as PFAS, are man-made chemicals that have been used in a range of industrial and consumer products since the 1950s.
PFAS have been used in domestic and commercial applications including in the manufacture of non-stick cookware, in stain protection for fabrics, furniture and carpet, in food packaging and predominantly in some types of fire-fighting foams.
The two most well-known PFAS are PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid).
For the majority of South Australia, mains water (tap water) is not sourced from groundwater and is safe. In some regional areas where mains water is sourced from groundwater in South Australia,
PFAS contamination is not present.
PFAS in South Australia
South Australia was the first state to ban potentially hazardous fluorinated firefighting foams on 30 January 2018. The ban came into effect following the amendment of the Environment Protection (Water Quality) Policy 2015 under the Environment Protection Act 1993.
This ban effectively negates further environmental and human health risks associated with their use, and provides the community and industry with certainty around the use of these products.
Due to their wide use and persistence in the environment, PFAS can be found in soils, surface water and groundwater in low concentrations in many areas.
Where larger quantities of PFAS have been released into the environment, concentrations may be elevated.
There have been concerns interstate regarding PFAS where they have been found in groundwater which is used for drinking. However, groundwater is not widely used for drinking in SA, so is not considered a major source of human exposure to PFAS in this state.
For the majority of South Australia, mains water (tap water) is not sourced from groundwater and is safe. In some regional areas where mains water is sourced from groundwater in South Australia, PFAS contamination is not present.
Background
In 2009, PFOS and its salts were listed under the Stockholm Convention, which requires participating countries to eliminate or reduce the release of these and other persistent organic chemicals into the environment. Australia is a signatory to the convention and the Commonwealth Government is assessing how to ratify the addition of PFOS.
PFAS are being phased out around the world because they do not break down naturally in the environment and can persist for a long time. Many PFAS chemicals have been shown to bioaccumulate up food chains.
PFAS enter the body through ingestion, not through skin contact. That means you need to eat or drink food or liquids containing PFAS in order for them to enter your body.
The two most well-known PFAS are PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid).
National Environmental Management Plan for PFAS
The Commonwealth, state and territory environment ministers have endorsed Australia’s first PFAS National Environmental Management Plan (NEMP).
The plan provides valuable guidance around storage, reuse and disposal of contaminated material which will facilitate proactive decision making for site contamination management including remediation. It recommends practices to assess sites and address contamination found.
The PFAS NEMP includes a program of future work that is expected to address key gaps by early 2019, as well as other important gaps through longer-term research activities.
Environment Ministers acknowledged the leadership of the Heads of EPA (HEPA) and the Victorian EPA in delivering the plan.
The EPA’s role
The EPA has reviewed historical use of PFAS from firefighting foam in South Australia to identify any areas where further environmental assessment may be required.
This is led to several liable parties entering into voluntary site contamination assessment proposals (VSCAP) with the EPA. A VSCAP details intended work, timeframes and estabilishes standards, and is public available through the EPA Public Register.
Section 83A of the Environment Protection Act 1993, requires owners, occupiers, consultants and auditors to notify the EPA of the existence of site contamination (including PFAS) or in the vicinity of a site, that affects or threatens groundwater. The Act does not apply to Commonwealth land.
The EPA will work with responsible parties of any sites where PFAS are identified to understand the nature and extent of the site contamination and any potential risks on and offsite and ensure appropriate steps are undertaken to minimise any impacts on human and environmental health.
Frequently asked questions
What was PFAS used for?
PFAS have been used in a range of domestic and commercial applications including common household products and specialty applications, including in the manufacture of non-stick cookware, fabric, furniture and carpet stain protection applications, food packaging, some industrial processes, and in some types of fire-fighting foam.
What are the risks?
PFAS are of concern around the world because they are not broken down in the environment and so can persist for a long time. Their widespread use and persistence means that many PFAS are ubiquitous global contaminants. In addition they have been shown to bioaccumulate up food chains.
What are the effects on human health?
Whether PFAS causes health issues in humans is currently unclear, but evidence from studies in animals shows that there is potential for adverse health impacts on humans. Please see Expert Health Panel for PFAS Report.
What should I do if I am a groundwater (bore water) user?
There are many man-made and naturally occurring contaminants that can affect the quality of groundwater. The EPA advises bore-water users to have their bores regularly tested to ensure the water is fit for purpose. In some areas, the EPA advises residents not to use bore water due to other contaminants. Please see ‘Further Information’ below.
Does this ban apply to C8 and ≤C6 type foams, PFOA containing foams, and both per- and poly-fluoroalkyl substances?
The ban applies to all fluorinated firefighting foams (per- and poly-fluoroalkyl substances) including more modern ≤C6 type fluorotelomers.
What do I do with fluorinated products such as firefighting foam on my site?
All fluorinated products must be removed from service by 30 January 2020 and taken to a licenced facility that is authorised to receive that waste. More details can be found in the information sheet on disposal pathways.
Who is responsible for the costs involved in transport, storage, or disposal of fluorinated firefighting foams?
Any costs involved in transport, storage or disposal are the responsibility of holders of the foam or the service provider.
When do I need to use an EPA licenced transporter?
For the transport of small items to a waste facility, such as fire extinguishers or 20-litre drums containing fluorinated firefighting foam products, it is not a requirement to engage an EPA licensed waste transporter. Bulk volumes of fluorinated firefighting foam products (or wash waters from the cleaning of fluorinated firefighting systems) may only be transported by an EPA licensed waste transporter
How do I find an EPA licenced transporter?
Waste transporters can be found in the Yellow Pages. You can check that a waste transporter is licensed by asking for their EPA licence number and searching this against authorisations in the Public Register.
Can I store extinguishers containing PFAS at my site?
No. All fluorinated firefighting foam must be transported to a licensed facility that is authorised to receive that waste for storage or destruction
What happens to the PFAS that leaves my site?
Fluorinated firefighting foam are stored at sites that are authorised to receive PFAS waste and have conditions on their EPA licence to ensure the waste is stored safely. Some facilities are licensed to destroy fluorinated products through a process of incineration at ultra-high temperature
Where can I take PFAS waste?
All fluorinated firefighting foam products must be taken to a licensed facility that is authorised to receive that waste. Again, bulk volumes of fluorinated products (or wash waters from the cleaning of fluorinated firefighting systems) may only be transported by an EPA licensed waste transporter.
How do I add PFAS waste to my waste transporter licence?
Please contact the EPA Waste Tracking Officer on 8204 2039 or email.
How do I know if the firefighting foam I have on site contain PFAS?
You should first check with your firefighting service provider, firefighting foam product MSDS, or other certifications or documentation. All extinguishers and bulk foam containers should be labelled with the type of foam they contain and all fluorine-free firefighting foams should be accompanied by a fluorine-free certification. If you need further clarification, please contact EPA staff on 8463 7811 or 8204 2154.
How do I know if a firefighting foam product is prohibited?
Prohibited firefighting foam products contains a fluorinated organic compound or compounds and they cannot be used in South Australia after January 2020. A fluorinated organic compound is an organic molecule with carbon-fluorine covalent bonds. PFAS are examples of fluorinated organic compounds although there are other chemicals in that category.
A supplier of a firefighting foam product is required to provide certification of the fluorine content (not the fluorinated organic compound content), while the user of a firefighting foam product must ensure that it is not prohibited.
If in doubt, contact the supplier and request confirmation that it does not contain a fluorinated organic compound or compounds by asking:
- What is the total organo-fluorine concentration in the firefighting foam?
- Was fluorine or fluorinated substances used in making the firefighting foam product?
- Was equipment used to manufacture the firefighting foam product, either:
- (a) not previously used to contain or manufacture fluorinated organic compounds? or
- (b) thoroughly cleaned to prevent residual fluorinated organic compounds from being included as contaminants in the firefighting foam product?
Further information
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