Setting The Pace For PFAS Testing And Analysis
Pace® is the largest American-owned laboratory network and one of the first commercial laboratories to offer PFAS testing services. As regulators push PFAS issues to the forefront, we have accelerated our growth to respond to increasing demand while adopting new methods, processes, and certifications to remain in-step with this rapidly evolving market. In addition to helping our customers protect the environment and the communities they serve, we have also worked with the United States Environmental Protection Agency (EPA) and other agencies to advance the science of PFAS testing and analysis. Highlights of our capabilities and credentials include:
What Are PFAS?
Per- and polyfluoroalkyl substances (PFAS) are a diverse group of synthetic compounds valued for their useful properties, such as heat, water, and oil resistance. For decades, these chemicals have been used to produce hundreds of industrial and consumer products, including non-stick surfaces, textiles, carpets, firefighting foams, electrical components, plastics, and more.
PFAS are bioaccumulative, meaning they build up in the bloodstream and tissue. Research has found links between some PFAS compounds and adverse health effects, such as chronic kidney disease, thyroid issues, low fertility rates, and certain cancers.
How Are PFAS Regulated?
As the concern for the adverse impact PFAS can have on human health grows, so do the number of rules and regulations aimed at assessing and addressing PFAS in the environment. Today, PFAS chemicals are covered by a wide range of state and federal regulations. Many of the primary programs are covered below.
Enacted in 1974, the SDWA grants the EPA the authority to set National Primary Drinking Water Regulations (NPDWR). In 2023, limits were proposed for PFOA, PFOS, PFBS, PFNA, PFHxS, and GenX Chemicals (HFPO-DA).
The EPA issues health advisories for contaminants not yet regulated by the National Primary Drinking Water Regulations (NPDWR). According to the EPA, these health advisories “identify the concentration of a contaminant in drinking water at which adverse health effects and/or aesthetic effects are not anticipated to occur over specific exposure durations (e.g., 1 day, 10 days, a lifetime).” While health advisories are not enforceable, they can be used to inform state and federal PFAS rulemaking, such as the NPDWR.
The CCL is a list of contaminants not currently subject to any proposed or promulgated national primary drinking water regulations but are known or anticipated to occur in public water systems. The Safe Drinking Water Act (SDWA) requires the EPA to publish a new CCL every five years, and this list often provides insights into which compounds the EPA is considering for future rulemaking. CCL6 is expected to include PFAS chemicals, either individually or as a category.
The SDWA requires the EPA to issue a new list of 30 contaminants to be monitored by public water systems every five years. Candidates for the list of contaminants are chemicals and microbes suspected to be present in drinking water, but for which there are no established health-based standards set under the SDWA. In 2023, public water systems serving 3300 or more customers began sampling for 29 PFAS plus lithium under UCMR 5. A randomly selected group of 800 small systems also began sampling as well.
CERCLA, also known as Superfund, gives the EPA broad authority to respond directly to actual or threatened releases of hazardous substances. The EPA intends to classify certain PFAS as hazardous substances under CERCLA. Once this happens, CERCLA grants the EPA the authority to respond directly, e.g., issue cleanup orders, in the event of a release or existing contamination.
As described by the EPA, ELGs (Effluent Limitations Guidelines) are “national, technology-based regulations developed to control industrial wastewater discharges to surface waters and into publicly owned treatment works.” ELG Plan 15 calls for setting PFAS limits on wastewater discharges from landfills (including leachate). Once set, these will be the first ELGs for PFAS. The plan also calls for more studies on PFAS discharges from other sources.
Created in 1972 by the Clean Water Act (CWA), NPDES is a permitting program designed to regulate the discharge of pollutants into the waters of the U.S. (WOTUS). States can petition the EPA to administer their own NPDES program, and most states have received partial or full approval. Tribal Lands are authorized separately. Four states, NH, NM, MD, and MA, as well as most U.S. territories continue to rely on the EPA for NPDES permitting. In 2022, the EPA issued guidance strongly encouraging the addition of PFAS limits in permits covering the discharge of wastewater and biosolids.
Enacted in 1976, RCRA governs the disposal of solid and hazardous waste. While designating PFAS a hazardous substance under CERCLA gives the EPA the authority to mandate cleanup, designating PFAS a hazardous substance under RCRA allows the EPA much greater control over the entire lifecycle of PFAS: manufacturing, transportation, treatment, storage, and disposal. Listing PFAS under RCRA would also automatically designate it as a hazardous substance under CERCLA.
Established under the auspices of the TSCA, the EPA’s significant new use rule grants the agency the authority to approve or reject new uses for potentially hazardous chemicals, including PFAS. Low-Volume Exemptions (LVEs) may be issued for PFAS imported or manufactured in low quantities. The EPA has announced its intention to revisit past LVE decisions and encourage companies to voluntarily withdraw from previously granted exemptions.
The EPA toxicity assessments summarize the potential health effects associated with specific chemicals and identify the exposure levels at which those health effects may occur. These assessments can then be used by the EPA, other federal agencies, state regulators, and local communities to determine when it may be necessary to address potential health risks.
Created in 1986 under the Emergency Planning and Community Right-to-Know Act (EPCRA), TRI tracks toxic chemical releases from industrial facilities into the environment. The first PFAS were added to the TRI industry reporting requirements in 2019, and many more have been added since then.
The TSCA grants the EPA the authority to establish reporting, record-keeping, and testing requirements for chemical compounds. Under the authority granted to the agency by the TSCA, the EPA expects PFAS manufacturers to fund PFAS toxicity studies and has begun issuing testing orders to industry.
Materials Tested By Pace®
Legacy AFFF, the Class B firefighting foam used to fight chemical fires, typically contains PFAS. Newer fluorine-free foams (F3) are not always PFAS-free either. Pace® helps protect communities with testing services for AFFF, F3, and impacted media such as soil, surface water, and groundwater.
PFAS can become airborne in multiple ways, such as waste incineration, stack emissions, and leachate evaporation. Once PFAS is airborne, it can contaminate surrounding communities, impacting soil, groundwater, surface water, and private drinking water wells.
PFAS has been discovered in milk, eggs, deer, fish, and more. When humans consume these products, PFAS can build up in their bloodstream. Testing for PFAS in biota can be challenging, but Pace® has invested in the equipment and expertise to meet our customers’ needs.
Pace® has developed several proven approaches for PFAS testing of consumer and industrial products.
UCMR 5 requires testing of many public water systems in 2023, and regulatory limits on several PFAS in drinking water are due to take effect by the end of 2024. Pace® is an EPA-approved lab for UCMR 5 and credentialed in every state.
Many communities get their drinking water from underground aquifers or surface water, such as rivers, lakes, and reservoirs. Pace® offers several testing services that can analyze PFAS in non-potable waters to support remediation and control efforts by local municipalities and industry.