In today’s webinar, we’ll feature a PFAS Straight Talk panel discussion, featuring a powerhouse panel of nationally recognized PFAS leaders.

With that, I will hand it over to Alana Miller of Regenesis, who will moderate our panel today.

Great. Thank you so much, Jane, for the introduction here.

And I’m pleased to introduce the members of our panel here today, starting first with Taryn McKnight.

She is vice president and PFAS practice leader for Eurofin’s environment testing with over 25 years in the environmental testing.

A PFAS subject matter expert, she contributes to agency and industry work groups and currently co-chairs the NGWA subcommittee developing a white paper on PFAS forensics.

Mary Gady is currently president of Gady Environmental Group LLC and a former senior environmental regulator. Earlier in her career she served as U.S.

EPA Region 5 Administrator, Director of the Illinois EPA under Governor Jim Edgar, and Deputy Assistant Administrator in U.S. EPA’s Office of Solid Waste and Emergency Response. She has also served on the U.S.

Department of Defense Science Advisory Board.

Elizabeth Denley is TRC’s PFAS Initiative Leader and chemistry director and leads the TRC core PFAS team.

She supports PFAS investigations, focused on liability assessments, chemistry, sampling, data interpretation, forensics, QAQC, analytical methods, and has served on the ITRC PFAS team as a section co-leader and trainer.

Rosa Gwyn is the PFAS global leader with ACOM.

She strives to connect global PFAS practitioners on implementing right-sized solutions that immediately protect human health and the environment while stimulating creativity for long-term solutions.

And lastly, Maureen Dooley has over 25 years of remediation experience, including leading treatability studies on biodegradation across contaminants such as chlorinated solvents, petroleum hydrocarbons, explosives, pHs, and pesticides.

At Regenesis, she provides technical leadership for complex soil and groundwater projects across North America, including PFAS treatments.

So with that, I’ll say we only really have so much time here and a lot of topics we’re trying to cover.

So I’m gonna do my best to try to keep us on track here.

A note to our participants and particularly those folks who submitted questions ahead of time, we received a ton of questions and tried our best to synthesize those as best we could.

But if you submitted a question that you find we don’t sufficiently address here today, we’ll do our best to have one of the panelists reach out to you directly offline.

So with that, to start us off here, my first question, I’m going to pose to you, Taryn, first here at least.

Really beginning where a lot of practitioners sort of begin is the investigation and analysis phase of all of these projects.

And that’s really where the PFAS journey begins for a lot of people to try to wrap their heads around the issues that might be present.

So my question to the panel here, how and when do we decide we’ve really achieved a robust enough target analyte list for PFAS analysis?

And how do we know if we have enough information to take action now, or if not, where are some of the gaps of information?

So there’s two big questions there.

And I think with the first one, in terms of robustness, I think it’s time for us to pivot away from thinking about a target analyte list being robust enough.

For many years, the last two decades, we were chipping away, adding a few compounds at a time, six compounds, then 12 compounds, then 20, right?

And it was always just this arms race to add more and more.

And we were feeling insufficient because you keep hearing about how many thousands of PFAS there are, and we’re just adding a few dozen at a time to our target analyte list.

I think it’s time to pivot our thinking and our strategy to are we looking for the right PFAS?

And are we gathering data that’s really going to inform our actions.

So if I provide you data for 100 PFAS, what does that mean to you?

What’s actionable about that?

Is it really PFOA, PFOS, PFH excess, 6.2 FTS?

I mean, is it really just a few that are driving your decision making?

Probably.

So I think it’s not so much about robustness as it is about looking for the right PFAS that influence our decision making.

And we also do need more data on which PFAS are relevant in the environment.

So we test for a lot of compounds right now that we never detect ever at any type of site.

So it would be good to maybe drop some of those, replace them with ones that are more relevant.

I think that’s a component of it as well.

Any other thoughts from anyone else on the panel on that front?

I tend to agree with Taryn definitely on that.

I mean, it’s also, you know, it all depends on what the ultimate use of the data is going to be.

And we only know a little bit about toxicity for several different PFAS chemicals.

But if we’re going to be doing some kind of forensics investigation, you know, then the list becomes a little bit more critical maybe in what we’re looking for and how we use that data.

But I agree there’s, you know, sometimes there’s a lot of hype over these lists and when you detect something and what do you do with that data because there’s no information out there on that particular PFAS and how important is it.

And it’s hard to explain all this to the public sometimes as well, that even if you detect, you know, a trace amount of some obscure PFAS, it doesn’t necessarily mean that there’s an issue here.

Right, more data is not always better, right?

Yeah, no, but that’s great insight.

And I think I have another question that I think sort of piggybacks off of this, which is that, you know, a lot of these ultra short chain PFAS and like TFA in particular appear to be incredibly abundant in the environment.

And I would love to hear from the panelists your thoughts regarding TFA and these ultra-short-chain PFAS and maybe specifically to Taryn first actually any insight on sort of where you’re seeing this analysis take place either by industry or geographically sort of across the world where there seems to be extra attention on this?

Yeah, I think we’re still pretty early on in globally looking at the ultra-shorts.

And you’ve got some folks that have a specific reason to suspect that ultra-shorts are an issue for them.

And they’re probably the first to have started looking at those.

Maybe more emerging is the concern about ultra-shorts in terms of treatment and remediation.

So folks wondering how effective their treatment is on those compounds are starting to look at that.

Maybe very little in terms of human exposure.

So looking at drinking water.

But right now, I think we’re in the early days of just gathering information, presence.

Is it present?

And then we’ve gathered enough information on presence, then we start talking about risk.

whether that’s the path we should be following, that’s the path I see that we’re on.

Yeah, and I think, I just want to add, I mean, we’ve been hearing a lot of hype over TFA in the media, I think maybe even more in Europe than over here.

I’m not convinced it’s something that we should really be focusing on now.

There have been, you know, some studies that have shown TFA can be as persistent as maybe some of the longer-chain PFATs, and it’s pretty mobile, you know, in the environment.

And as we heard, we are seeing it pretty high levels, or higher levels than we are seeing other PFAS.

But first of all, TFA is not necessarily considered a PFAS under some definitions of PFAS.

And although it’s persistent, there are some regulatory limits over in Europe.

I think the Netherlands and Germany, and they’re pretty high.

They’re like, I think, over 2 ,000 nanograms per liter in one and 60 ,000 nanograms per liter in another.

So much higher than we’re seeing with PFOA and PFOS.

So, and TFA doesn’t bioaccumulate in our bodies like PFOA and PFOS.

So I kind of think we should be focusing on the PFAS that we know can be harmful and not necessarily go down this rabbit hole on something that may not really help us in the long run.

So I could make a quick comment because Liz introduced twice now the concept of risk.

It’s unlikely that there’s some unknown yet-to-be-measured PFAS that is as bad for you as, say, plutonium, right?

There’s no plutonium in the PFAS family.

Using the bad actors that we know about as our guide is going to give us a lot of traction really fast, and trying to boil the ocean might just take a lot longer.

I’m an action Jackson.

So, you know, let’s keep rolling, right?

And I couldn’t agree more with Taryn, TFA when you’re testing treatment technologies is on point.

There’s a concept of definitions too, right?

And I do think that’s important that when we are debating how to define PFAS, when you talk about something like TFA, that can be useful if you’re concerned about it, being persistent alone and if you want to turn off the tap.

So you use a definition that includes TFA and product bans and the like, then you address that issue of persistence.

Stop letting it accumulate until it gets to a point it’s accumulated so much that finally it is toxic, right?

So that’s one way of thinking about it.

But for a lot of us that are focused more on environmental cleanup and addressing the risks that already exist, we might use a different definition and focusing like Rosa said on the ones that we know really drive the risk and focusing our resources on cleaning up those.

Well put.

And actually just to piggyback off of what Rosa was saying about things that are actually possible.

Pivoting here a little bit though on maybe switching gears to the regulatory side of things.

You know, we all sort of know that PFAS in so many different ways are unique from how many other chemicals work from a regulatory standpoint fitting into these chemical by chemical approaches.

And that sort of serves as the foundation for a lot of US environmental regulations.

So I’m curious what you all think is possible changes that could be made to our federal environmental regulations and what are possible changes, what are needed changes, given the current state of the union here.

And Mary, if you don’t mind kicking us off on that, I think that’d be great.

Thanks, Alana. As you know, I have very strong feelings on this.

So I think it’s clear that our existing federal laws aren’t up to the task.

I mean, hence we have panels like this and states all over the country are about their putting in place stopgap measures and courts are making decisions by default.

What’s happening is our system doesn’t capture risk to human health and the environment fast enough.

And we end up with words and phrases like ubiquitous, which makes Rosa insane.

So we end up with words like ubiquitous or regrettable substitutions because the chemicals are so widespread and their use is so extensive that regulating or addressing them, their impacts, it’s almost impossible or certainly astronomically expensive.

So, I think the divs need to be significant changes to the U.S.

framework for addressing chemical risk.

And I actually am recommending that TASCAP requires another thorough review like it had in 2016 and an update after the Lautenberg amendments.

With 80 ,000 chemicals in EPA’s inventory and only 1% of them having risk assessments, as I think Taryn was just referencing or Liz, it’s time to see if there’s a better way of doing this.

We should look to other models.

maybe the EU’s precautionary principle model, maybe not.

We should consider whether we’d be better off looking at chemicals by class or characteristics rather than the way we do it one by one, or looking at qualities like bio-accumulative, persistent, and toxic.

We should determine who is best suited to do this.

Is it government or is it industry being supported and overseen by government?

But in the meantime, I think my biggest concern is we need to see that Tosca, which is the existing law, is well-staffed and funded.

And using its existing authorities, like sections four and six, or its recently proposed contaminant candidate list number six, to the max, we need to utilize what we already have.

We don’t have time to wait.

And we need to better fund the research needed from, just better understand the health impacts and the destruction and disposal technologies under a comprehensive government plan to do that research.

The second prong, though, is the one think you were most alluding to, which deals with the inadequacy of our existing media statutes for air, water, and land for addressing PFAS.

As you said, Alana, PFAS is unique, and trying to shoe horn it into these statutes will take forever.

Hence, in the eight years in which the Biden and Trump administrations have been trying to deal with it, we see two PFAS regulated in two statutes, square peg round hole.

So I think Congress should consider an entirely new statute dedicated to PFAS just as it did in 1980 with Superfund for many of the same reasons, distinct liability, thousands of chemicals, lots of unknowns, huge expenses, failure to understand what the appropriate treatment and technologies are.

I think that we need to sort of step back as we are implementing the laws we already have and making progress that way and try and take a more holistic look at this.

And then finally to your last sort of question, which is, is this possible?

Probably not.

or certainly not with the Congress that we have right now.

And I will point out to you that for over three years now, since hazardous people and PFAS were made hazardous substance under CIRCLA, a bipartisan group of legislators in Congress have been trying to pass relief for passive receivers and we still don’t have anything.

So something this comprehensive and dramatic is not gonna happen easily.

And my only hope going forward is that as citizens become more engaged in this and Congress understands better that it has huge health and economic impacts, they will start taking it more seriously and saying there’s got to be a better faster way to do this.

So that’s that. Well put. I feel passionately about it.

We live in an era, luckily for us maybe, unluckily, I don’t know, that things are breaking all around when it comes to government and maybe that’s a perfect opportunity for something like this PFAS Dilemma to show the way in a different way of solving how we want to tackle this.

I think you can tell I’m an optimist at heart if you talk to me personally I might not be so cheerful about it but with a system that’s functioning or not functioning in the U.S.

the way that it is now, this is a prime time to do something differently.

Yeah, that’s a really interesting concept, Mary.

And I echo your feelings about the speed at which the system can respond being a real primary challenge, not just our typical processes, but the speed at which we can enact anything.

We have, on the analytical side, the process for the EPA to promulgate a standard method for us to be able to analyze for PFAS, right?

We’re going on eight years for them to promulgate a method for PFAS in water and soil, and we still don’t have it promulgated.

And when you think about what the APA thought was relevant for PFAS eight years ago, that’s not keeping up with the speed at which things are evolving, the science, the concern.

And private industry has had to fill that gap.

We developed the methods.

we employ them, all of you apply them on your sites, we generate tons of data, and then eventually the EPA takes that method and it’s the basis for promulgating a standard method.

So maybe to Rosa’s point, it’s an opportunity to demonstrate a new way of doing these things that we could do it faster, more efficiently, more effectively.

Sometimes I wonder if the confusion is the point.

But anyway, with that said, you know, you get into, you know, people still have to make decisions.

And when you have confusion, you can feel, you know, how I just keep putting it off, I just keep putting it off.

And at some point, the rubber meets the road.

And I think that’s why the states end up like having to step up in their own individual areas, like you mentioned, Mary, that they have this confusion or not, guidelines that are necessarily giving us what we really need and what we look for, and so you’re trying to fill the gap and fill this vacuum.

So we can hope, but we also have to try to make decisions within this vacuum of sorts you know, for individuals and people have individual responsibility.

And, and I think that’s the challenge, trying to understand how to, how to get through all this and try to make the best decisions for, you know, for your own entity.

A really great point, Maureen.

And it’s something I, I mean, I think a lot of people are really curious about, right, with the federal regulations sort of lagging to, to be, you know, kind about it, but a lot of states being much more proactive on setting standards and actually enforcing fast regulations of their own and taking actions.

I’m curious what you all think some of the consequences are of this and how this directly or indirectly affects the regulated community.

Do you want to start us off on that? I have a lot of thoughts on this.

So I think you know as everybody knows the states are way ahead of regulating PFAS, not just from an environmental contamination perspective, but also from consumer product perspective.

And I guess from the perspective of regulating environmental contamination, the impact of having these state regulations in the absence of federal regulations or having different regulations state to state is not as big of a concern to me.

I think it’s fairly manageable.

But for the most part, I think not always, though.

State regulations pertaining to environmental contamination have been reasonable.

I feel like they’ve been based on science.

They’ve been involved in good thought processes and more collaboration with stakeholders in general.

But from the perspective of the consumer product regulation, I feel the impact is overwhelming.

And frankly, I kind of think it’s unfair to the manufacturers, distributors, retailers who are trying to really navigate this.

I think it’s going be really, really difficult for these entities to navigate these regulations in a cost-efficient manner for their business.

If you think about it, these manufacturers, distributors, and whatnot, they have to come up with strategies for one, for the federal TOSCA PFAS reporting, that 11-year look back and their supply chain.

Two, they have to deal with federal TRI PFAS reporting with no more de minimis amounts allowed for like 190 PFAS.

And then they have to deal with these product bands. And the states have implemented bands of PFAS in different products.

The products regulated in one state may not be regulated in another state. How the states define PFAS in these bands can vary from state to state.

So when you say something’s PFAS-free, whose definition of PFAS are you using?

And recently in New Mexico, they’ve flora polymers from their proposal for PFAS product bands, which in my mind is the most practical approach I’ve seen to date, but most states have not.

How a state even defines, we always hear about intentionally added PFAS. That definition can even vary state to state.

There’s some states like California or Colorado, they include intentional breakdown products of added PFAS and their definition of intentionally added. So that could be much more far-reaching to comply with.

Even Rhode Island’s proposal includes processing aids in their intentionally added PFAS definition, while some states consider processing aids as unintentional PFAS. So very, very tricky to navigate the system of business.

And the other thing, which is also very difficult for these businesses, is that some states have their own reporting or labeling requirements on top of these bans.

And many of us are aware of, you know, Maine, Minnesota’s PFAS reporting requirements and bans.

Connecticut has some new labeling requirements or starting July 1st and very specific, you know, it has to say contains PFAS or made with intentionally added PFAS.

So are all these businesses going to now need to label all of their products like this, even for states that do not require it?

Or is it gonna be cost efficient to follow these rules just for one state?

These businesses are gonna have to do pretty detailed audits their supply chains to see if these labels are even required.

New Mexico has a different labeling requirement.

And then recently the state of Washington came out with this proposed 50 ppm total fluorine as a threshold for whether or not showing something a product has intentionally added PFAS. So that could have a lot of potential complications too.

I’m sure Tamara could even speak to that more about looking at total fluorine versus total organic fluorine and how Total flooring measurements do not necessarily equate to PFAS.

There could be challenges with the analysis of these products because we don’t really have standard validated methods.

And I can see that resulting in a lot of litigation coming down the road.

So the level of due diligence that is really required to comply with these regs by manufacturers, retailers, distributors is extraordinary.

Potential liabilities are also extraordinary.

So we really need to think about, I think, for more, think about this really from a more practical perspective.

Again, maybe we focus on the PFAS we know are harmful.

Maybe we can’t regulate this as a class in every single product and industry, and we need to be unified. I think it’s a country on these rules, even potentially in the world.

It’s going to put a huge financial strain on these regulated entities to maintain compliance with all these different regulations.

Those are my thoughts.

Oh, and you know, we live in a global economy, right?

I mean, mostly, and with Europe driving their reach requirements, let’s say, for PFAS in products and goods and materials and processes and manufacturing and so forth, At least there’s going to be a part of the market that the US and Canada interact with that’s going to have a set of rules that, from what I can tell, but you’re the expert, will be more restrictive than what we’ve seen state by state, with the exception of the labeling requirements, right?

So those are sort of unique and you just have to ask, is this something that just starts at a much higher level, filtering down through the global economy.

And to your point, starting in the simplest fashion for the big actors in the big areas where there’s the greatest amount of potential for exposure either now or through degradation of polyfluorinated compounds, you get the picture.

By the way, I couldn’t agree more with Rosa and Liz about this topic.

I am very, very skeptical and concerned about product bans but I will note that Senator Dick Durbin just introduced a national product ban piece of legislation about two weeks ago. He’s retiring and who knows what will happen with that.

But I’m just saying, at least it would be uniform, Liz, as opposed to like different recognitions all over the place, right?

And potentially adequate funding.

The only thing I want us to take issue with that Liz said is just this, which is, yes, product bans are of serious concern.

And I think the fact that they are handled so differently and forgive me, environmental agencies don’t have the experience to put them into place, so that’s another problem.

But I do say if you are somebody that’s running a state agency and you’re trying to deal with your citizens and your constituents and that you’re right alongside the border of another state that has a totally different groundwater or drinking water standard or biosolids application, land application standard, it’s problematic trying to explain to them why yours is safe or the other is more stringent, but not to worry, whatever, it is very problematic having those different standards in terms of actually communicating public to the public and telling them that they’re safe.

I wonder about the other side of this though when we you hear the phrase turning it off at the tap used a lot when we talk about PFAS product bans right but couldn’t turning it off at the tap also refer to or be represented by controlling emissions? Absolutely. Right? The tap is flowing out via wastewater discharge, waste disposal, air emissions.

So it’s not only the option to stop manufacturing, but it’s the option to control those emissions.

And that you could do rather quickly, you know, putting emission controls in place to ensure that we’re not contaminating the environment, causing a human or eco risk exposure, right?

Well, we figure out how to best implement, you know, eliminating the production because we’re trying to do that so quickly with so little information or the tools.

Like, as you mentioned, demonstrating your product is PFAS free to comply with these bans. That’s a whole nother can of worms.

We don’t even have a good, our arms around how to demonstrate that, which just leads to litigation. Yeah, I think for you were gonna.

Yeah, Rosa, go ahead if you have any insight to add here. I mean, Taryn is absolutely right.

And, you know, we’ve got a lot of cogs moving at the same time here.

If there’s a commitment to to getting PFAS exposures down, part of that starts with the consumer.

The consumer needs to know, so you need to have a label.

It gets complicated really quickly, but we’ve got to pull all of the levers.

And Taryn mentions the controls at the point of creation or use of products and materials that we deem necessary for having PFAS in them.

And that process of deciding what’s absolutely necessary takes time.

I mean, you see the derogations in the REACH program.

So all the levers have to be pulled to kind of stop this crazy runaway train of emitting things that we collectively think are harmful into the environment and exposing human beings and the environment.

I mean, it’s kind of starts with Earth Day, you know, however many years ago, decades ago, we’ve got to stop this crazy train and figure out really, you know, every passenger on the train needs to contribute something. Well put.

I am curious how you all feel about, you know, there’s certainly, you know, we’re talking about product bands and labels and things like that, that are very consumer facing.

And there’s a lot more now very publicly available information regarding PFAS emissions and TRI reporting and all of these things, right?

And I think obviously the environmental practitioners and industry have a responsibility to obviously meet those requirements.

But I’m curious all of your opinions really on how do we effectively communicate to the public these concerns in a way that it really is effective without raising more alarms than than we need to. The alarm was raised.

The alarm was raised. It’s hard to put toothpaste back in the tube.

You know, can the conversation that, you know, created worry, concern, some would even say hysteria, can that be controlled after it started?

It’s a really difficult thing to accomplish.

And there’s a loss of trust with people who, between people who feel unjustly put upon with these issues relating to environmental exposures.

And then there are people like myself who are more eggheady. And you know that there’s no trust in there.

So Alana, if you figure that one out, we’ll all join you and work on it.

But I do think there is a need for a little bit of a reset, if at all possible when we have these conversations, I would like to think that would help.

I have felt strongly that we have done, it’s the hysteria part of it, that we have overplayed what potential negative impacts are, even to the extent that we don’t really know concretely what they are.

And what I have been advocating and have heard others do, people keep saying communication is important.

We need to be more honest about it.

We need to say what we know and what we don’t know, what we are concerned about and we’re not concerned about, and we do not need to keep doing victory laps when we promulgate a law that covers two of many pollutants in our Safe Drinking Water Act, and it’s not effective for five years ago.

Wow, that’s amazing. We should say to the public, this is why it’s going to take so long.

This is why it’s these two. We should be clear on it so the public itself can understand this issue better.

Maybe that, Rosa, that would go some way towards quelling some of the hysteria.

Just some honesty with it, and including this is how far along we are.

And if your issue is a question of your own personal exposure, in the meantime, here are tools for you to do to use to control your exposure.

I mean, the lack of control over a risk is more troubling to people in some instances than the risk itself, right?

People elect to be cigarette smokers.

But they are the ones who are choosing to participate in that, and they are weighing their own risk.

For a pollutant that shows up in your drinking water supply that you thought you had nothing to do with, you know, you’ve lost your control over it, and I think, you know, it’s reasonable to have an emotional response to that.

I think the other piece, too, is the action, and I think it’s interesting, Rosie, you talk about giving people tools.

Well, there was obviously the understanding, a better understanding versus a hysterical response, which we would all have, right?

You don’t understand something.

I don’t want this in my water.

Now what do I do?

But providing tools that you can do, but also just taking some action to make things better.

I think if it’s, okay, this is what we have, this is what we know, and then this is what we can do.

And here’s our actions.

and move it forward and try to at least get some betterment, you know, and move towards a betterment that’s reasonable or it may not be needed.

And I think that’s the flip side, just because something’s there doesn’t mean it’s bad.

Yeah, you got to take action.

People can take personal action.

I think, you know, that’s always an important factor.

And we also have to be reminded that for some of the more costly activities that are required to mitigate PFAS, for example, in large drinking water systems, you can only spend your dollar once, right?

So if you’re trying to figure out what you’ve got to do for that, you don’t get to do a little something now and then magically, four years from now, get another $100 million to do another little something.

You need to do the things.

You need to spend your money commensurate for what you think you can get out of it.

Try to do no harm in the short term, right, and buy yourself time for the long term and start to accumulate those dollars if that’s indeed what’s necessary to do it.

So, you know, now I’m talking about people in the remediation space or drinking water treatment space, which is quite a bit different from the product bands that Liz was talking about.

But maybe the same story is true for manufacturers as well.

what can they justifiably spend their money on now to mitigate the concerns that they’re going to have.

And they don’t even know what’s going to be a concern until Taryn runs their products through a 50 PPM flooring measurement.

Right?

So it’s just all of these cogs are moving at the same time again.

And I also have seen a lot of communities get kind of alarmist about, like, for example, synthetic turf.

will have a lot of people in a community be against the installation of synthetic turf because they believe that there’s PFAS in it, because there was an article about that 10 years ago or something.

But the synthetic turf manufacturers have stopped putting PFAS in their products and were able to demonstrate that it’s still really, really hard to communicate this to the public, they just, you know, there’s just because there’s articles out there saying that this could be in a product, they go through, I mean, the amount of money that is spent sometimes in these communities defending the installation of this product is really incredible to me.

And it’s unfortunate because we’re able to demonstrate with science, with Taryn’s lab, that these materials are okay for use.

And so, so one of the things that’s troubling about this is trying to get the right information out to the public so they can make the right decision.

So Liz, as you said, if people knew that the turf no longer had PFAS in it or whatever analyte that they were concerned about, maybe that would like not forestall them from buying it.

But if you’re a company right now, you’re very worried about getting sued over greenwashing.

So I mean, and lots of companies have been sued over greenwashing over saying something that they think is, well, I don’t have this PFAS, and then somebody finds some other analyte or a trace of something else or whatever.

And so they’re not really green.

And so we’ve got to sort of deal with that issue too, at the same time as we’re trying to deal with these others in terms of transparency and getting out good messaging.

I’m curious if you all as a panel related to this specific topic, have any thoughts or recommendations on, you know, we’ve talked about how the definition of PFAS itself is sort of complicated and varies, place to place and industry to industry, maybe.

How do we come up with either a class-based definition or an analytical tool to be able to substantiate claims that something is PFAS-free?

I mean, I’ll just make my plug for fit-for-purpose definitions.

I don’t think there’s a one-size-fits-all with this complex of a subject.

So I like fit-for-purpose, and it aligns with the same concept we have with data.

The data should be fit-for-purpose.

There’s no one approach to the type or amount of data that you need to answer a multitude of questions.

So if we are trying to prevent continued releases to the environment, that’s maybe one type of definition.

If we are trying to address what’s already in the environment that can pose an exposure risk, that’s maybe another type of definition.

So that I would at least suggest is the starting point that we consider fit for purpose and then debate the guardrails for those definitions.

That’s a really good point, and I think, you know, I’m sensing a lot of themes here from you all, right?

You know, the idea that things need to be both risk-based, but also practical and effective.

And I wonder if you all have any sense of, you know, there’s, Rosa and I know you love using the term that there may or may not be a magic wand for PFAS solutions, right?

And I wonder what you all think are maybe things that can be done, whether it be from the industry side of things or the remediation side of things that are maybe low-hanging fruit in terms of managing PFAS risk. All risk comes with the essential component of exposure.

If you’re not positive shifts.

I’ve worked with teams and looked at a multitude of PFAS treatment technologies, including degradation and destruction technologies.

You start with a great idea and then all of a sudden definitions and emissions and everything we’ve talked about up to now kind of throws a time the public feels exposed.

So one of the shifts that I’ve seen overall in the industry for environmental remediation is focusing on the movement of PFAS.

Where are the PFAS most abundant? The PFAS of concern, I guess I should say, and where are they moving to?

Because the part of the problem is, oh, you know, we thought we had a problem here, now it’s in the right so if you can keep them where you found them and understand them then you know you’re doing a good job and we’d like to keep all of them there but we know that BFES are sneaky and they’re slippery and some can get through but if you can control mass flux you’re gonna be in a better place when the magic wand is identified and I don’t think it’s gonna be one magic wand I think Everybody’s going to have a quiver.

They’re going to pull out their magic wands, and they’re going to solve their fit-to-purpose PFAS solution to their site.

But in the meantime, let’s keep them from moving from A to B.

And keep them where they’re at.

Don’t do any harm.

And I know we’ve got some tools right here, and experts in some of those tools in this phone call today.

So that’s one of the things that we’re promoting.

And I use the rather unsophisticated terminology of when we’re talking about PFAS technologies, remediation technologies, you know, we should settle for Mr. Right Now until we find our Mr. Right.

And when we find our Mr. Right, it will be a fit-for-purpose PFAS solution to the site.

And Mr. Right Now are those technologies that are commercial that you don’t have to have made bespoke for your project or site and that you can use to control mass flux.

And I’m a big fan.

And just, you know, to build on that, Rosa, I mean, I think the thing with some of, you know, the PFAS chemicals themselves have characteristics that are a little different than some of the traditional contaminants we’ve been dealing with, you know, hydrocarbons, chlorinated solvents, and certainly a component of that was degradation or other reactive chemistries and biologies we could apply to it, and that’s a little more evasive with some of these chemicals, and so we can get stuck on this need for destruction, but you can have a betterment without destruction.

You can reduce your risk and exposure without that, and what you’re saying is understanding where it is, how things move, and what modifications can you make to keep it in place or reduce this exposure because that’s ultimately what we’re trying to do is keep it out of people’s drinking water, keep a source where it is, or if you’re a responsible party, keep it on your property and have this betterment.

And there are numerous technologies available today that are being used and your choices are really two.

One is, you can remove things from the environment and dress it up above, or you can inject things into the subsurface and perhaps stabilize things.

But these technologies and these approaches are currently being used and can be used effectively and quickly and make a difference and make a difference.

Well, if you’re a Jane Q public and you are concerned about PFAS moving from a non-residential site that’s close to your residence, the best news you can hear is it’s not gonna come over to my area or towards my drinking water supply.

And we were talking earlier about these product bands.

You know, there is this element of the individual wanting to control his or her own exposure and being able to tell somebody there is a way that we will not have this come to your front door.

That is a benefit.

That is, you know, they, me, I’m part of the public.

I feel the same way, you know, I don’t, I don’t want the PFAS to move to where they shouldn’t be, not just for my sake, but for the whole community.

So for those of you out in the field practicing this, and this makes great sense to me, it reminds me of operable units potentially under super fund or something like that, or non time critical removal, or you’re doing some stabilization efforts.

But are you finding that states and the federal government are receptive to these kind of things rather than a total kind of destruction?

I’ll start and grossly jump in on this.

No, you know more than I do.

Honestly, yes.

I think one of the things is that I think regulators can appreciate an adaptable, adaptive sort of approach to things.

If you’re able to, I’m in the in situ world and we have the injectable materials to stabilize and so I can speak from my own experience, people will ask questions, well, how long is this going to last?

So, we’ll apply a material and keep it from moving offsite in that form.

And so the question is, well, how long will it last?

And so we have a lot of tools to be able to demonstrate to people that, here’s what your longevity is, we can look at your site specific information and in other third party studies have been out there to see that you can have a very robust response that lasts an extended period of time that it gives people some comfort and so they’re willing to move forward with that.

So I would say in general, I can’t think of really situations where we’ve had much pushback.

It’s really been more, let me just understand more and if you can demonstrate what the changes are and you can change the exposure.

You know, this is assuming of course this particular project and all this is appropriate for the approach in technology. We’ve actually had a lot of positive interactions.

And to be honest, most of this has been taking place in states where we have more robust state regulations.

But things are also moving forward in the Department of Defense side, they’re under the circular process.

So many of these sites are moving through the process and that’s a slower process, but it is moving forward.

But I’m sure you’d have something might want to add to that Rosa?

Oh I mean we do have precedence for taking actions for I call them conventional contaminants and then monitoring them over time.

Monitoring their movement by the way which is the whole mass flux component right.

So asking Maureen to tell them that you know putting in a permeable absorptive barrier is going to last forever is kind of a tall order.

We all always have included monitoring in that.

And remember, there’s technology development ongoing, even while we’ve been on this phone call.

And if you can buy some time to get a better solution to find Mr. Right and protect human health in the environment, in the interim, why wouldn’t you like that?

Why wouldn’t you?

And a lot of groundwork was laying for petroleum release sites, which are as old as our environment response programs.

We’ve seen success in absorbing materials.

There is that fundamental difference.

I’m not blind to it, that most PFAS, the perfluorinated compounds, are not degrading, whereas the petroleum products would degrade in the environment naturally, I get it.

I get it that it’s different, but we need to adapt and we need to adapt the tools that we have and develop the tools that we need.

You know, the other thing I was thinking about, you know, think about preparing for this, you know, panel and all is, you know, quite a number of sites have programs ongoing.

And sometimes, you know, if you’re concerned about the potential for PFAS to be part of it or present, and even without having this all-inclusive understanding of where things are, you can sometimes modify a current activity in just a small tweak, and it doesn’t cost a lot of money, and you could create a situation that’s a little more protective of the PFAS component, along with maybe addressing chlorinated solvents or petroleum hydrocarbons.

I always thought sometimes it’s like a twofer, but there’s ways to adapt whatever maybe perhaps existing treatments that may be going on to, again, make it more beneficial.

It may not be, it’s Mr. Right Now, as you say, it may not be the magic bullet, but it can make things better and may be helpful.

And again, it’s going to help with the, you know, the potential liabilities, exposures and all, and, you know, you may be limiting that, you know, future liability by, you know, stopping things from moving off site.

We’re running up on an hour here.

We will continue the conversation for a little bit longer though.

If anyone needs to drop off of the webinar here, there will be a recording that will be distributed following the webinar. All right.

I want to switch gears here a little bit because we got a lot of questions from some of the registrants related to PFAS in biosolids specifically, and I know there’s a lot of expertise here on this panel in this domain.

So, I guess, really, this isn’t even a well-formulated question, but just sort of to all of you, what do you think of as being sort of top-of-mind concerns when it relates to PFAS and biosolids?

Mary, I guess I’ll start with you, pick on you here for this one.

Thanks.

I think that part of the problem is we have biosolids in millions of acres across this country over decades of application and we know so little about them, like where they are or necessarily what’s in them or what contaminate.

And so we don’t actually understand necessarily what all the impacts are going to be.

And I know that Rosa, you share this concern, but one of the things that I think we’re going to have to be really focused on is crop uptake.

What’s happening about things growing on that? What happens to livestock that’s exposed to it?

I’ve been reading about hay that’s sitting on a field and then contaminating 12 feet down the groundwater because of the hay that had been growing on biosolids fields.

So for me, the answer is this is a large problem in this country potentially.

And I’m going to go back to what Rosa said.

Maybe we only deal with it at point of use or maybe we have sort of some limited ways of dealing with it until there’s the magic wand that allows us to spray something over the entire area and have it all remediated.

So that’s my concern.

it’s what we don’t already know so that we can make reasonable judgments about what should be done.

It sure sounds bad to have PFAS in the soil where you’re growing food, doesn’t it?

But we don’t really know enough about what Mary mentioned, crop uptake, and it’s, you know, I’m certainly the opposite of a biologist, you know, different parts of plants We accumulate different types of PFAS in different ways and we eat only parts of plants.

Some we compost or use as silage.

So you know, again, it gets very complicated very fast and you’ve seen some really nice state programs where they, and let’s back up for two seconds, the value of biosolids as fertilizer are essential to the growing of enough food in this country and others for us to live.

I mean, we can’t just throw out the phosphorus that we need because we can’t just get it in the U.S., for example. Okay?

So you don’t want to lose that And some states have adopted what they call tiered approaches because they understand that the doses in the poison, hate to say poison, but there you have it, right?

So how much PFAS are in the biosolids? How much biosolids are applied per acre per year?

It’s all part of this dose response question, and then we also don’t know whether maybe those PFAS, maybe the real bad actors, stay in the biosolids rather than moving into the groundwater or deeper into the veto zone.

I guess what I would say though is I’ve thrown all these wrenches in the works, and I don’t want to imply that we should do nothing because we don’t know enough.

I think that’s also not the response. I’m sort of curious, Liz, what you’ve seen.

You’re closer to Maine than any of us.

You know, Maine had a pretty tough ban on biosolids and it had repercussions. Now Connecticut has something going on. I don’t know what you think.

Well, it has serious repercussions because people don’t know what to do with the biosolids.

One of my concerns, though, really is a little more granular, but the chemistry part of it.

So you’re taking these biosolids, sometimes they have over 90% moisture in them, sending them to a lab.

And the lab only can analyze a very small amount of this sample, like 0.5 grams.

And so we’re making like massive decisions on this very tiny weight that’s supposed to be representative of that biosolids sample. And I have concerns about that.

I don’t think we’re actually, I don’t know, Taryn, you might differ, but I don’t think we’re in a space where we’re necessarily getting the best data on biosolids yet. I feel like that method needs work.

100%, I agree with you.

There’s the representativeness of the sample question for sure, and then there’s what is the risk.

We really do know very little about that, and yet we are chasing very low limits in these samples just to see if anything is there down to the lowest limit possible.

It’s very challenging to do in this matrix and the percent moisture creates a complicating factor and yeah, there’s a lot of work to be done on addressing this one and I’m with you Rosa.

I like to be optimistic. What can we do today? What can we do right now to address things?

And I’m not sure what the solution is on the biosolids front.

I think probably Michigan’s approach is the best at this point.

And Michigan’s approach has set the standard for the upper Midwest and then Virginia came out with something quite similar and it’s a somewhat reasoned approach, you know, instead of being kind of knee-jerk.

And you know, we’re also seeing in Michigan and probably elsewhere a call for industrial pretreatment, right?

So when you think about the PFAS that are going into a wastewater treatment plant that will end up in biosolids and effluent, you have to think about the customer base.

There are some customers, Liz was talking about manufacturers who may be discharging high concentrations of PFAS in our liquid.

And then there’s all our households.

So some studies have shown in certain geographies about 40% of the total fluorinated organofluorine burden coming into wastewater treatment plants is just domestic sources.

You can’t pre-treat that.

It all gets back to the turning off the spigot, right?

So where you can turn it off, where you can intervene and remove those high concentrations.

PFAS into wastewater, municipal wastewater plants, by all means, give it a whirl.

It’s not great news for everybody, but it’s great news at the other end, right?

And then it gets back to this commitment.

If you’re really up in arms about PFAS and biosolids, I think it’s your job to do your due diligence and see what PFAS are coming out of your ***, or maybe coming in is another way to say that.

So in theory, a lot of this could be resolved if EPA put out a risk assessment, finalized some sort of a risk assessment on PFAS and biosolids, but as we know, That’s stymied right now in terms of the EPA review of it.

They got something like 26 ,000 comments on the ones that the Biden administration put out after they reopened the comment period a couple of times.

And it’s only for two PFAS.

But without that, by the way, Rosa, what’s happening in these states is even though they are doing some sort of standards, so at least you have something to react to and sort of put something on that might be safer onto the land application, there are different standards even across state lines.

So Virginia and Maryland just adopted new standards within the last month.

And they’re actually different standards.

So this is back again to the sort of patchwork quilt.

It’s good that they’re doing it.

And a regional approach like that is a good idea.

But it would be nice if we had some sort of uniformity or consistency.

Well, I just am going to say one comment.

And that is I don’t think that a guidance document from the US EPA that is formulated as a risk assessment is actually that uniformity that we need from state to state or regions that are managing this, you know, again, I go back to the sort of practical tiered approach that Michigan kind of started with and the other states have reflected on in their own geographies and their own special ways.

And it’s completely separate from human health risk assessment, right?

It’s coming at it from another angle And we heard earlier people talking about discharge limitations and air emission limitations.

And that’s got almost zero to do with that EPA risk assessment.

So in a way, Mary, I hope that those 26 ,000 comments take 10 years to resolve and that we can figure this out using our other tools.

Yeah, I don’t think that’s what’s going to happen.

But the other thing that’s happening is that even though there is rule 503, which regulates contaminants and biosolids and there has been studies that show over the years every couple of years they’re required to do a study on that that there’s a PFAS regulated in that rule so that there would be at least some sort of consistency and there is also of course a risk assessment associated with that in public comment.

EPA has chosen not to act on those and so they are not putting them in the thing and they’re currently in litigation arguing that they need not do so. So we shall see what happens with it.

So Rosa I agree with you in terms of your sentiment though.