Per- and poly-fluoroalkyl substances (PFAS)

The Commonwealth, state and territory environment ministers have developed a third version of the PFAS National Environmental Management Plan (NEMP). This PFAS NEMP 3.0 was agreed to by Heads of EPAs and released on 23 September 2022 for public consultation.

The plan provides valuable guidance around storage, reuse and disposal of contaminated material which will facilitate proactive decision making for management of sites impacted by PFAS. It recommends practices to assess sites and address PFAS impacts identified.

The draft PFAS NEMP 3.0 provides new and revised guidance on 6 of the areas that were identified as urgent priorities in the second version of the NEMP:

1. PFAS family (grouping of PFAS)
2. Guidance on ambient monitoring data collection
3. Nationally consistent criteria for PFAS in biosolids
4. Guidance on PFAS behaviour in soils
5. Guidance on managing PFAS in resource recovery
6. Site-specific guidance for sediments, construction water management and principles and approaches to remediation.

In addition to this new guidance, the draft PFAS NEMP also includes some important clarifications regarding the intent of some of the information contained in the PFAS NEMP 2.0.

PFAS NEMP 3.0 criteria have remained the same as those developed for PFAS NEMP 2.0. The EPA Landfill disposal criteria guidelines were developed based on the PFAS NEMP 2.0 criteria which is consistent with the approach taken by all states and territories.

The consultation draft and supporting documents for the new criteria are available.

The statement articulates the shared view of Australian governments that PFAS use should be reduced where practicable, to limit further PFAS releases into the environment and reduce indirect human exposure to these chemicals.

Australian governments have been working collaboratively for several years to consistently and effectively identify and treat existing PFAS contamination in the environment. All agree that more effort should be focused on preventing further PFAS releases into the environment.

It takes time to develop and implement legislation that imposes controls on chemicals like PFAS, so in the meantime Australian governments have developed the Position Statement to start a national conversation about non-regulatory ways to reduce PFAS releases.

There may be some industries that are unaware that their products and processes involve PFAS chemicals. Engaging with industry stakeholders on the Position Statement will:

• Inform industry of the widespread applications of PFAS.
• Prompt investigation into whether certain products contain PFAS chemicals and if PFAS-free alternatives are available.
• Identify realistic, pragmatic and implementable ways to reduce PFAS use.
• Inform government policies and initiatives to better manage industrial chemicals (including PFAS) in Australia and enable us to demonstrate alignment with international agreements.

The Position Statement does not impose regulatory measures or specific timeframes. No regulatory mechanisms will be established without further consultation with industry.

In 2009, PFOS and its salts were listed under the Stockholm Convention which requires participating countries to eliminate or reduce the release of these and other persistent organic chemicals into the environment. Australia is a signatory to the convention and the Commonwealth Government is assessing how to ratify the addition of PFOS.

Work is underway to develop the National Standard for Environmental Risk Management of Industrial Chemicals. This will fill a recognised gap in the environmental regulation of industrial chemicals in Australia, by setting a nationally consistent environmental management approach for the use and disposal of industrial chemicals, including PFAS.

Establishing consistent national regulatory controls over PFAS and other chemicals of concern will enable Australia to take actions consistent with international agreements, particularly the Stockholm Convention.

More detailed information on the National Standard and its timeframe for implementation.

The EPA is South Australia’s independent environment protection regulator. The Environment Protection Act 1993 does not apply to Commonwealth land. State EPAs cannot regulate the Commonwealth.

The EPA regulates the use of PFAS-containing fire-fighting foams (see section on Transitioning to fluorine-free fire-fighting foam), assesses site contamination (see below), and regulates the disposal of PFAS-contaminated wastes (see Landfill disposal criteria for PFAS-contaminated waste).

The EPA reviewed historical uses of PFAS from fire-fighting foam in South Australia to identify any areas where further environmental assessment may be required. 

This is led to several liable persons entering into voluntary site contamination assessment proposals (VSCAP) with the EPA. A VSCAP details intended work, timeframes and standards, and is publicly available through the public register.

Section 83A of the Environment Protection Act 1993, requires owners, occupiers, consultants and auditors to notify the EPA of the existence of site contamination (including PFAS) or in the vicinity of a site that affects or threatens groundwater.

The EPA will work with responsible persons of any sites where PFAS are identified to understand the nature and extent of the site contamination and any potential risks on- and off-site and ensure appropriate steps are undertaken to minimise any impacts on human and environmental health.

South Australia was the first state to ban all fluorinated (PFAS-containing) fire-fighting foams, which have been a key source of PFAS contamination around the world due to inadvertent releases to the environment during fire-fighting responses. This ban effectively minimises further environmental and human health risks associated with PFAS use in fire-fighting foams, and provides the community, industry and emergency services with certainty around the prohibition of these products.

The ban on fluorinated fire-fighting foams in South Australia came into effect on 30 January 2018 following an amendment of theEnvironment Protection (Water Quality) Policy 2015 under the Environment Protection Act 1993. Legislative requirements are set out in clause 13A of the Policy.

Due to their widespread use and persistence in the environment, PFAS can be found in soils, surface water and groundwater in low concentrations in many areas in South Australia. PFAS are being phased out of many industrial processes and consumer products around the world because they do not break down naturally in the environment and can persist for a long time, and they can bioaccumulate up food chains.

Where larger quantities of PFAS have been released into the environment, concentrations may be elevated. There has been concerns interstate regarding PFAS where they have been found in groundwater which is used for drinking.

For the majority of South Australia, mains water (tap water) is not sourced from groundwater and is safe. In some regional areas where mains water is sourced from groundwater in South Australia, PFAS contamination is not present.

Even if you have not worked with PFAS or visited a contaminated site, you can be exposed to low concentrations of PFOS and PFOA through the air, indoor dust, food, water and various consumer products. For most people, food is expected to be the primary source of exposure to these chemicals. For further information about PFAS and your health, please visit the SA Health website.

The main areas where PFAS has been found in South Australia are:

• RAAF Base Edinburgh (including Penfield, Direk, Burton, Salisbury North, Paralowie, Waterloo Corner, St Kilda and Bolivar)
• Adelaide Airport
• Parafield Airport
• Le Fevre Peninsula
• CFS State Training Centre at Brukunga

The ban on fluorinated fire-fighting foams came into effect on 30 January 2018, and a grace period of 2 years to 30 January 2020 was granted to help industry meet the requirements of the ban. Since this time fluorinated foams have been prohibited.

Some sites have been issued with exemptions from section 34 of the Environment Protection Act 1993 in respect of the requirements of 13A of the Environment Protection (Water Quality) Policy 2015. In granting these exemptions, the EPA is satisfied that 'environmental harm' as defined under section 5 is unlikely to result from the use of fluorinated fire-fighting foams at these sites, if operated and managed at all times in accordance with the conditions of the exemptions.

Exemptions that have been issued can be found on the public register, by selecting 'Record Type: Exemption' and 'Record Status: Issued'.

You can email us for more information.

What was PFAS used for?

PFAS have been used in a range of domestic and commercial applications including common household products and specialty applications, including in the manufacture of non-stick cookware, fabric, furniture and carpet stain protection applications, food packaging, some industrial processes, and in some types of fire-fighting foam.  

What are the risks?

PFAS are of concern around the world because they are not broken down in the environment and so can persist for a long time. Their widespread use and persistence means that many PFAS are ubiquitous global contaminants. In addition they have been shown to bioaccumulate up food chains.  

What are the effects on human health?

Whether PFAS causes health issues in humans is currently unclear, but evidence from studies in animals shows that there is potential for adverse health impacts on humans. Please see Expert Health Panel for PFAS Report.

What should I do if I am a groundwater (bore water) user?

There are many man-made and naturally occurring contaminants that can affect the quality of groundwater. The EPA advises bore-water users to have their bores regularly tested to ensure the water is fit for purpose. In some areas, the EPA advises residents not to use bore water due to other contaminants. Please refer to the section on bore water.

FAQs specific to the ban on fluorinated fire-fighting foams

Does this ban apply to C8 and ≤C6 type foams, PFOA containing foams, and both per- and poly-fluoroalkyl substances?

The ban applies to all fluorinated fire-fighting foams (per- and poly-fluoroalkyl substances) including more modern ≤C6 type fluorotelomers.

What do I do with fluorinated products such as fire-fighting foam on my site?

All fluorinated products must be removed from service by 30 January 2020 and taken to a licenced facility that is authorised to receive that waste. More details can be found in the information sheet on disposal pathways.

Who is responsible for the costs involved in transport, storage, or disposal of fluorinated fire-fighting foams?

Any costs involved in transport, storage or disposal are the responsibility of holders of the foam or the service provider.

When do I need to use an EPA licenced transporter?

For the transport of small PFAS-containing items to a waste facility, such as fire extinguishers or 20-litre drums containing fluorinated fire-fighting foam products, it is not a requirement to engage an EPA-licensed waste transporter. Bulk volumes of fluorinated fire-fighting foam products (or wash waters from the cleaning of fluorinated fire-fighting systems) may only be transported by an EPA-licensed waste transporter.

How do I find an EPA licenced transporter?

Waste transporters can be found in the Yellow Pages. You can check that a waste transporter is licensed by asking for their EPA licence number and searching this against authorisations in the public register.

Can I store extinguishers containing PFAS at my site?

No. All fluorinated fire-fighting foam must be transported to a licensed facility that is authorised to receive that waste for storage or destruction

What happens to banned fluorinated fire-fighting foam once a licensed waste transporter removes it from my site?

Waste fluorinated fire-fighting foams may be sent to a disposal facility that is authorised to destroy the waste, usually through a process of high-temperature treatment or incineration.

While awaiting disposal, the waste may be stored at sites that are authorised to receive PFAS waste and have conditions on their EPA licence to ensure the waste is stored safely.

Where can I take AFFF-related PFAS waste?

All fluorinated fire-fighting foam products must be taken to a licensed facility that is authorised to receive that waste. Bulk volumes of fluorinated fire-fighting foam products (or wash waters from the cleaning of fluorinated fire-fighting systems) may only be transported by an EPA-licensed waste transporter.

How do I add PFAS waste to my waste transporter licence?

Please contact the EPA WasteTracker Officer on 8204 2039 or email.

How do I know if the fire-fighting foam I have on site contain PFAS?

Prohibited fire-fighting foam products include those that contain a fluorinated organic compound or compounds. A fluorinated organic compound is an organic molecule with carbon-fluorine covalent bonds. PFAS are examples of fluorinated organic compounds although there are other chemicals in that category.

You should first check with your fire-fighting service provider, fire-fighting foam product MSDS, or other certifications or documentation. All extinguishers and bulk foam containers should be labelled with the type of foam they contain and all fluorine-free fire-fighting foams should be accompanied by a fluorine-free certification.

If in doubt, contact the supplier and request confirmation that it does not contain a fluorinated organic compound or compounds by asking:

• What is the total organo-fluorine concentration in the fire-fighting foam?
• Was fluorine or fluorinated substances used in making the fire-fighting foam product?
• Was equipment used to manufacture the fire-fighting foam product, either:
  • not previously used to contain or manufacture fluorinated organic compounds?
    or
  • thoroughly cleaned to prevent residual fluorinated organic compounds from being included as contaminants in the fire-fighting foam product?

If you need further clarification, please contact the EPA at 8204 2004 or email.

The national Australian Government PFAS website provides easy access to information on PFAS.

• Fire protection service providers’ responsibilities
• Transitioning to fluorine-free fire-fighting foam
• Expert Health Panel for PFAS Report
• PFAS NEMP (Victorian EPA site)
• PFAS NEMP (Commonwealth)
• SA Health
• Landfill disposal criteria for PFAS-contaminated waste, March 2020
• EPA report on PFAS in the marine environment, March 2017
• EPA media release, 11 June 2016
• Bore and rainwater testing