Q&A: Evolving PFAS Regulatory Guidance
As PFAS regulations expand, what are the impacts on previously overlooked industries?
The scope of PFAS regulations is expanding to involve industries that initially may not have been considered to pose concerns. For example, sectors such as agriculture (e.g., PFAS in biosolids or other plant operations), food packaging, and textiles are now facing regulatory scrutiny. This underscores the importance of vigilance and proactive measures across a broader range of industries. Legislative changes may require adjustments in manufacturing processes, waste management practices, and product formulations to reduce PFAS usage and emissions, making it essential for industries to stay informed and adapt to these requirements.
How is Langan educating clients about PFAS regulatory compliance?
Monitoring and Reporting: Langan’s dedicated subject matter experts and PFAS practitioners monitor technical and regulatory developments and guidance. The team shares updates with Langan practice leads and clients to keep everyone up to date about potential business implications and new PFAS regulations, thus enabling informed decision-making and compliance.
Industry Advocacy: Langan is heavily involved in industry stakeholder groups and PFAS committees, which provide input, advocacy, and practical experience regarding PFAS regulations and guidance.
Innovative Tools: Langan provides an interactive state guideline map to help clients navigate the varying PFAS action levels in each state.
Langan is committed to tracking regulatory changes and providing clients with proactive measures to address these challenges and anticipate the expanding scope of affected industries.
Why are PFAS such a concern from a regulatory perspective?
PFAS are widely used in industrial applications and consumer products for their resistance to heat, water, and oil. If discharged, PFAS are resistant to conventional water and soil remediation methods, making it challenging to cost-effectively address them in the environment. PFAS precursors can further degrade based on environmental conditions, contributing to their persistence and complicating their fate and transport in the environment.
Why is it important to proactively consider PFAS regulations?
PFAS chemicals are complex at the molecular level, and relevant regulatory guidance continuously adapts to new data, research, and laboratory methodologies. By staying ahead of these anticipated changes, you can proactively respond, confirm compliance, and minimize risks.
EPA’s guidance on addressing PFAS and their potential impacts on human health and the environment is currently in flux until more data can be obtained and examined. Once addressed, updates may include:
- Additions to the regulatory PFAS analytes list
- Standardized analytical methods
- Hazard index adjustments
- Action levels modifications
- Reporting requirements
- Increased focus on air emissions
- Limits to usage and disposal
- Navigation of state-specific regulations
While some states follow EPA’s PFAS guidelines, others have established their own regulations. For clients with project sites nationwide, Langan monitors and updates its PFAS Navigator Pro database, which can be accessed to confirm compliance with each state’s unique regulations and standards.
Learn more about Langan’s PFAS analysis and consulting services.
Diane Escobedo is a Senior Staff Geologist in Langan’s Santa Barbara office with experience delineating PFAS and developing Conceptual Site Models. Her work encompasses due diligence, environmental investigation, site characterization, remediation, management consulting, and strategy. She is also well-versed in federal, state, and local environmental regulations.