Per- and poly-fluoroalkyl substances (PFAS)

The Commonwealth, state and territory environment ministers have endorsed the second version of the PFAS National Environmental Management Plan (NEMP). This final PFAS NEMP 2.0 was agreed by Heads of EPAs in October 2019.

The plan provides valuable guidance around storage, reuse and disposal of contaminated material which will facilitate proactive decision making for management of sites impacted by PFAS. It recommends practices to assess sites and address PFAS impacts identified.

The PFAS NEMP 2.0 provides new and revised guidance on four of the areas that were identified as urgent priorities in the first version of the NEMP:

1. Environmental guideline values
2. Soil reuse
3. Wastewater management
4. On-site containment

In addition to this new guidance, the PFAS NEMP 2.0 also includes some important clarifications regarding the intent of some of the information contained in the PFAS NEMP 1.0.

PFAS NEMP 2.0 criteria have remained the same as those developed for PFAS NEMP 1.0. The EPA Landfill disposal criteria guidelines were developed based on the PFAS NEMP 2.0 criteria which is consistent with the approach taken by all states and territories.

The statement articulates the shared view of Australian governments that PFAS use should be reduced where practicable, to limit further PFAS releases into the environment and reduce indirect human exposure to these chemicals.

Australian governments have been working collaboratively for several years to consistently and effectively identify and treat existing PFAS contamination in the environment. All agree that more effort should be focused on preventing further PFAS releases into the environment.

It takes time to develop and implement legislation that imposes controls on chemicals like PFAS, so in the meantime Australian governments have developed the Position Statement to start a national conversation about non-regulatory ways to reduce PFAS releases.

There may be some industries that are unaware that their products and processes involve PFAS chemicals. Engaging with industry stakeholders on the Position Statement will:

• Inform industry of the widespread applications of PFAS.
• Prompt investigation into whether certain products contain PFAS chemicals and if PFAS-free alternatives are available.
• Identify realistic, pragmatic and implementable ways to reduce PFAS use.
• Inform government policies and initiatives to better manage industrial chemicals (including PFAS) in Australia and enable us to demonstrate alignment with international agreements.

The Position Statement does not impose regulatory measures or specific timeframes. No regulatory mechanisms will be established without further consultation with industry.

Work is underway to develop the National Standard for Environmental Risk Management of Industrial Chemicals. This will fill a recognised gap in the environmental regulation of industrial chemicals in Australia, by setting a nationally consistent environmental management approach for the use and disposal of industrial chemicals, including PFAS.

Establishing consistent national regulatory controls over PFAS and other chemicals of concern will enable Australia to take actions consistent with international agreements, particularly the Stockholm Convention.

More detailed information on the National Standard and its timeframe for implementation.

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 (EP Act). Legislative requirements are set out in clause 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. Some sites have been issued with exemptions from section 34 of the EP Act in respect of the requirements of 13A of the Policy. In granting these exemptions, the EPA is satisfied that 'environmental harm' as defined under section 5 is unlikely to result from the use of fluorinated firefighting foams at the sites to which the exemptions relate, if operated and managed at all times in accordance with the conditions of the exemptions.

Exemptions that have been issued can be found on the public register, by selecting 'Record Type: Exemption' and 'Record Status: Issued'.

You can email us for more information.

South Australia was the first state to ban 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 PFAS use, and provides the community and industry with certainty around the use of these products.

Due to their widespread use and persistence in the environment, PFAS can be found in soils, surface water and groundwater in low concentrations in many areas in South Australia. 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.

Where larger quantities of PFAS have been released into the environment, concentrations may be elevated. There has been concerns interstate regarding PFAS where they have been found in groundwater which is used for drinking.

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.

If you have not worked with PFAS or visited a contaminated site, you can be exposed to PFOS and PFOA through the air, indoor dust, food, water and various products. For most people, food is expected to be the primary source of exposure to these chemicals.

The main areas where PFAS has been found in South Australia are:

• RAAF Base Edinburgh (including Penfield, Direk, Burton, Salisbury North, Paralowie, Waterloo Corner, St Kilda and Bolivar)
• Adelaide Airport Statement on PFAS
• Parafield Airport Statement on PFAS
• PFAS factsheet for Lefevre Peninsula

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.

If you have not worked with PFAS or visited a contaminated site, you can be exposed to PFOS and PFOA through the air, indoor dust, food, water and various products. For most people, food is expected to be the primary source of exposure to these chemicals.

The two most well-known PFAS are PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid).

The EPA reviewed historical uses 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 persons entering into voluntary site contamination assessment proposals (VSCAP) with the EPA. A VSCAP details intended work, timeframes and standards, and is publicly available through the 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. State EPAs cannot regulate the Commonwealth.

The EPA will work with responsible persons 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.

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 firefighting 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 WasteTracker 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 us 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?

The national Australian Government PFAS website provides easy access to information on PFAS.

• Fire protection service providers’ responsibilities
• Transitioning to fluorine-free firefighting foam
• Expert Health Panel for PFAS Report
• PFAS NEMP (Victorian EPA site)
• PFAS NEMP (Commonwealth)
• SA Health
• Landfill disposal criteria for PFAS-contaminated waste, March 2020
• EPA report on PFAS in the marine environment, March 2017
• EPA media release, 11 June 2016
• Bore and rainwater testing