Presentation Outline

Safety Moment

Overview of PFCs

International Regulatory Emergence

and Trends

Managing PFC related contamination

Future Challenges

Page 2

Safety Moment – Skin Cancer

• Two out of three Australians develop some form of skin cancer in their lifetime (Similar in NZ???)

• It kills more than 1,800 Australians each year

• Get to know your skin

• Talk with your GP about any spot that has changed in size, shape, colour

• Use Protection

• Have regular check-ups

• Cancer Council Helpline

Overview of Per-Fluoro-Compounds (PFCs)

Persistent, Bio-accumulative and Toxic (PBT)

Synthetic linear long-chain halogenated organic polymers with a

functional end - complex chemical behaviour (perfluorinated

compounds and polyfluorinated compounds)

Globally ubiquitous

Two predominant manufacturing processes

Eruption of research over the last 5 to 10 years

Used as surface treatment and coatings.

November 12, 2013 PFCs 101 Page 5

History

• Commercially available from 3M between 1948 and 2002 (although 3M started to phase out manufacture of PFOS in 2000)

• AFFF was developed by 3M incorporation in conjunction with the US Defence Force in the 60s for Class B fires

• DuPont and a couple of other companies still manufacture PFOS/PFOA salts in Europe, Japan and China

• 3M manufacturing facility in Minnesota, two disposal sites and one landfill where manufacturing wastes were historically disposed are being remediated

• Ansulite is the AFFF currently being endorsed by ICAO/CASA.

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Commercial Uses of PFCs

Fabric coatings

Carpet and paper coatings

Computer processors

Floor polish

Alkaline cleaners

Denture cleaners

Shampoos

Non-stick cookware (Teflon)

Gore Tex® (breathable stain resistant all weather clothing)

Fire-fighting foam (greatest volumes used for AFFF) 3% and 6% Light Water AFFF

Also used in sprinkler systems within hangers (fire suppression)

Aviation hydraulic fluid

Mining/oil well surfactant

Acid rust suppressant

Metal plating

Electronic etching bath

Ant/roach insecticides

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Summary of PFOS Chemical Properties

• PFOS is moderately soluble, whilst PFOA is extremely soluble

• Non-flammable

• Thermally stable

• Non volatile

• PFOS will not tend to hydrolyse or photolyse.

• Has a high potential to adsorb to substrates although also has a potential to desorb under certain environments

• The C-F covalent bond is extremely strong and therefore appears to result in the persistence of the PFOS/PFOA compounds in the environment. It is believed that PFOS has a life time of up to 3-4000 years. Although humans can eliminate PFOS between 3 and 21 years

• Another interesting point is the PFOS may mobilise other contaminants such as organic and heavy metals.

Toxicity

• Initially thought to be biologically inert and eliminated fast from the body because they are lipophilic (i.e. not stored in fat). No longer the case.

• PFOS can be toxic via inhalation, ingestion, ocular and dermal exposure

• It is not likely absorbed through the skin and ingestion is the only significant exposure pathway (i.e. ingesting contaminated water and/or fish)

• It is estimated that PFOS has a half life of between 3 and 4 years in humans

• Large epidemiological studies (e.g. C8 Panel, DuPont Case in Washington – 69,000 residents) demonstrated positive correlation between PFOA and kidney cancer, testicular cancer and thyroid disease.

International Regulatory Emergence

• 1999 - 3M submitted internal information to US EPA

• 2002 – US EPA investigation/OECD Hazardous Assessment

• 2003 - National Industrial Chemical Notification and Assessment Scheme (NICNAS) in Australia issued a PFOS alert

• 2004 – UK Environmental Risk Evaluation Report

• 2006 - US EPA 2010/2015 PFOA Stewardship Program

• 2006 - US EPA Review of alternative chemistry under TSCA new chemical program

• 2006 – EU Directive 2006/122/EC (effective 6/27/08) - Restricts PFOS use and semi-finished products containing PFOS.

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International Emergence Continued...

• 2006 – UK Environment Agency: Policy on the Disposal of Firewater Containing PFOS (Policy No. 32-06)

• 2006 – Canada: “Perfluorinated carboxylic acids (PFCAs) and precursors: A proposed action plan for assessment and management

• 2007 - Germany: threshold values for drinking water and sewage sludge

• 2007 – DuPont eliminating need to make, buy or use PFOA by 2015

• 2007 – UK: Drinking Water Screening Thresholds revised downward

• 2008 – Canada: Started regulating and prohibiting the manufacture, use and importation of PFOS products

• 2009 - Stockholm Convention: PFOS, its salts, and perfluorooctane sulfonyl fluorides (PFOSF) were added to Annex B, subjecting them to restrictions on production and use.

November 12, 2013 PFCs 101 Page 11

International Emergence Continued...

• 2009: Risk Assessment (Chemical Safety Report) according to REACH-TGD prepared by consortia of Miteni and DuPont, submitted by German Ministry of Environment to EU-Commission

• 2010 – OECD Survey of Product Content and Environmental Release Information on PFCs

• 2010 – US EPA “Perfluoroalkyl Acids (PFAA)” Symposium

• 2010 - Canada: risk management scope for PFOA: goal phase out of PFOA and precursors

• 2011/2012 - Australian Federal Government (SEWPaC) Regulatory Impact Statement – Ratification of PFOS listing on Stockholm Convention.

November 12, 2013 PFCs 101 Page 12

Emergence in Australia

• Defence has been evaluating AFFF use since 2003 with assistance from CRC CARE since 2005

• June 2007 – Defence released Environmental Guidelines for Management of Fire Fighting Aqueous Film Forming Foam (AFFF) Products – use by Defence Environmental Managers and Users – promote use of Ansulite AFFF

• A national fire fighting agency has been investigating PFC contamination at their sites since 2007/2008

• Fire fighting agencies in Australia have moved away from AFFF to fluorine-free foams

• 2009 National survey on PFC importation (PFCs not manufactured in Australia) by NICNAS. Two major importers – fire fighting agencies (AFFF) and metal plating industry (mist suppression).

Page 13 November 12, 2013 PFCs 101

Emergence in Australia Continued…

• Sept 2011 National Forum/Workshop on "Fire Fighting Foams and the Environment“ at CleanUp 2011 Conference:

– attended by diverse stakeholders including Fluorine Free Foam Manufacturers.

– Position Paper Pending on use of Class B AFFF

– Considerable debate over environmental risks vs. societal benefits

• SEWPaC currently evaluating cost/benefit of PFC importation and use in industrial applications – results expected in 2-3 months

• HH and Environmental guidelines have not been established

• State EPA regulators likely awaiting SEWPaC report before establishing governance approach

• International Standards adopted or site-specific risk assessments performed; reluctance to adopt conservative existing Standards.

Page 14 November 12, 2013 PFCs 101

Emergence in Australia Continued…

• NICNAS Guidance - “Options for Disposal of PFOS Waste”; although States/Territories are not yet adopted

• Fire Fighting Foams with PFCs – Environmental Review by Dept. of Environment and Conservation Western Australia

• Off-site disposal of PFC impacted materials is restricted and regulatory preference is to treat/incinerate materials

• Conservative regulation of tradewaste discharge and disposal of PFC impacted materials

• Lack of approved waste disposal options has resulted in accumulation of wastewater at some sites (e.g. 20 – 30 10KL tanks which is a logistical nightmare

• Increasing use of mobile wastewater treatment trailers.

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• EPA’s approach has been to mitigate exposures at the source

Significant New Use Rules (SNURs) on Perfluoroalkyl Sulfonates (PFAS)

2010/15 PFOA Stewardship Program – 8 companies participating

Long-Chain Perfluorinated Chemicals (LCPFCs) Action Plan

• August 2003, USEPA PFOA screening level was 150 µg/L now, then reduced to 0.5 µg/L in 2006 and was further reduced to 0.4 µg/L

• May 2012, US EPA requires public drinking water suppliers to test for PFOS/PFOA

Expected to reveal presence in drinking water systems

Increased awareness of persistence of PFCs

• Minnesota Pollution Control Agency – Soil criteria for different land uses

• Minnesota Dept Health – Drinking water and fish consumption guidelines.

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US EPA Regulation

Summary of Current Regulatory Trends

- A number of hazardous assessments of PFOS and PFOA conducted by international bodies

- Source Control - Prohibition on manufacture, importation and use by many countries (US, Germany Canada etc.), including fire fighting foams

- Discharge restrictions and licence agreements – conservative

- Decrease in human health screening values.

November 12, 2013 Page 17

Current Guidelines Regulator/ Country PFOS PFOA

SOIL

US EPA – Residential 2.1 mg/kg 2.1 mg/kg

US EPA – Recreational 2.5 mg/kg 2.6 mg/kg

US EPA – Industrial 13 mg/kg 14 mg/kg

MHD – Residential 2 mg/kg 2 mg/kg

MHD – Industrial 14 mg/kg 13 mg/kg

Groundwater

US EPA – drinking water 0.2 µg/L 0.4 µg/L

MHD – drinking water 0.3 µg/L 0.5 µg/L

UK DEFRA – drinking water 0.3 µg/L 10 µg/L

Germany – drinking water 0.1 µg/L 0.1 µg/L

Surface Water

MHD – Site Specific 0.006 µg/L – 0.0122 µg/L 0.61 µg/L – 0.72 µg/L

Challenges

Breakdown products (metabolites)

Complex and undiscovered chemical transformation products

Dramatic new developments in analytical chemistry and ever lower detection limits (impact to reliability of analytical results)

Costly analytical fees ($270 - $350 per sample)

Complex and inconsistent regulatory requirements

Insufficient long term HH impact information/studies

Insufficient ecological toxicology information/studies

Contamination issues (PFCs penetrate and adhere to infrastructure).

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Challenges

Ecological Impact – biota sampling and comprehensive understanding of ecological systems (including food chain) are required

Soil/Sediment – Disposal? Capping? Incineration?

Groundwater:

• High water solubility = large dilute plumes which may be comingled with other contaminants

• Difficult to remediate….

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Remediation

- Remediation technologies are in their infancy and are not yet proven in the field:

• High energy remedial technologies (ultrasonic and/or mechanical degradation)

• reduction by elemental iron under high temperatures

• Advanced oxidation – caution must be taken because polyfluorinated compounds may degrade to carboxylates (e.g. PFOA)

• MNA – Possible for Polyfluorinated Compounds not Perfluorinated Compounds

• The longevity of immobilisation products have not been demonstrated.

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Future Trends

• Increased awareness by the general population and Regulatory Agencies regarding the legacy of PFC’s

• Tighter regulatory control of impacted sites and hopefully regulatory consistency

• Risk based approach to assessing and remediating PFC impacted sites

• Fate and transport approach to discharge of PFC impacted wastewater

• Increase in R&D – Remedial technology and field screening.

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PFOS/PFOA Web Resources

• http://www.fluoridealert.org/

pesticides/pfos-pfas.2005.pubmed.htm

• http://www.statesassembly.gov.je/documents/propositi

ons/30624-25008-19102004.htm

• http://www.pops.int/documents/meetings/cop_1/cheml

isting/Default.htm

• http://www.lanuv.nrw.de/veroeffentlichungen/fachberic

hte/fabe34/fabe34.pdf

• www.oecd.org

• www.ewg.org

• www.epa.gov/oppt/pfoa

• www.pca.state.mn.us/programs/p2-s/toolkit/index.html

Additional Resources

OECD Portal on Perfluorinated Chemicals http://www.oecd.org/site/0,3407,en_21571361_44787844_1_1_1_1_1,00.html

•Stockholm Convention http://chm.pops.int/Implementation/NewPOPs/The9newPOPs/tabid/672/language/en-US/Default.aspx

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Difficulties in Managing Persistent Organic Pollutants, such as PFOS and PFOA, under Emerging Regulation Internationally Prepared by Rachael Casson and Presented by Ross McFarland

Thank You

Rachael Casson and Ross McFarland

AECOM