Per- and polyfluoroalkyl substances (PFAS) are a family of manufactured chemicals that never disappear from the environment, which is why they’re called “forever chemicals.” These chemicals are used to make coatings and products resistant to oil and water, or to reduce friction, making PFAS a common ingredient in consumer products.
Unfortunately, studies have shown that some PFAS chemicals are toxic to humans and the environment. In Washington state PFAS have contaminated some drinking water supplies. This contamination has been linked to the use of PFAS in firefighting foam. PFAS have also been detected in surface waters, groundwater, wastewater treatment plant effluent, compost, freshwater and marine sediments, freshwater fish tissue, and osprey eggs in Washington.
We have concluded that PFAS compounds fall under the Model Toxics Control Act (MTCA) and will need to be cleaned up. We are working on setting cleanup levels and developing guidance.
Currently, there are no established federal standards for any PFAS compounds. However, the Environmental Protection Agency issued non-enforceable groundwater health advisory levels for two of the most commonly studied PFAS — perfluorooctanoate (PFOA) and perfluorooctane sulfonate (PFOS).
As part of our efforts to address PFAS contamination, we have reviewed applicable laws and concluded that PFAS compounds are hazardous substances under the Model Toxics Control Act. This conclusion is based on an evaluation of existing regulatory authority which says that compounds considered hazardous substances under the Dangerous Waste Regulations or the Hazardous Waste Statutes are also hazardous substances under MTCA.
PFAS releases into the environment
If PFAS compounds are released to the environment and may pose a threat to human health or the environment, they must be reported to Ecology within 90 days of discovery. As with releases of other hazardous substances, the next step will often be an assessment of whether further action is necessary. If so, follow-up is usually a site investigation and, if needed, a cleanup.
PFAS cleanup levels
The Washington Department of Health recently set State Action Levels (SALs) for five PFAS compounds in drinking water. Using the SALs, we are developing cleanup levels for the same five compounds and expect to release them this spring or summer. Because the SALs are not enforceable, establishing cleanup levels under MTCA using the SALs needs to follow a different process than we usually use, including imposing cleanup levels on a site-by-site basis.
We’re developing detailed guidance that will, among other things, explain how we determined the appropriate cleanup levels and how they apply to individual sites.
Although Washington has made great progress in dealing with PFAS, this is a long-term problem. Efforts to reduce the use of PFAS and to prevent additional releases into the environment will continue to require resources into the future. We are working with other agencies, the public, and stakeholders to figure out the best way to cleanup source areas and reduce exposures.