UK Focus xiii
FOREVER CHEMICALS: NAVIGATING THE PFAS CHALLENGE IN THE UK WATER INDUSTRY
PFAS (per-and poly fl uoroalkyl substances) is a chemical family consisting of many thousands of individual substances. They are sometimes referred to as ‘forever chemicals’ because of their persistence in the environment.
PFAS are favoured for their durability and useful properties such as in non-stick, water repellence and anti-grease applications.
They also have many and widespread uses in industry, including in fi refi ghting foam. The properties of these substances mean that they are very resistant to biodegradation.
Industrial and commercial activities may result in the inadvertent release of various pollutants including per- and polyfl uoroalkyl substances.
The issue of PFAS contamination has even made it into the cultural sphere. The Hollywood fi lm ‘Dark Waters’ tells the real-life story of Rob Bilott, the lawyer who took on chemical giant DuPont after discovering that the company was polluting drinking water with PFOA (a type of PFAS) in the US.
Drinking water
The Drinking Water Inspectorate (DWI) has just announced that new guidance on PFAS will be issued to water companies later in the summer (2024). There are four key changes that will likely be announced:
1. The DWI has a list of 47 individual chemical parameters of interest, but new requirements will include measuring 6:2 fl uorotelomer sulfonamide alkylbetaine (FTAB) from January 2025.
2. Its risk-based three-tier system for detecting PFAS will also be applied to any PFAS chemicals detected in raw and fi nal water where it is not treated.
3. Water companies will also be required to inform the DWI if they detect any PFAS chemicals that are not listed or identifi ed at concentrations less than 0.01 micrograms per litre (µg/l).
4. Guidance which applies to PFOS and PFOA will be expanded to apply to all PFAS chemicals listed in Annex C of the The Water Industry (Suppliers’ Information) Direction 2019 (referred to as the Information Direction).
Currently the Drinking Water Inspectorate requires that drinking waters be regarded as “wholesome”. This means that they must not contain any substance at a level which would constitute a potential danger to human health (as well as meeting the other requirements of the Regulations).
The Environment Act, passed in 2021, incorporates the main tenets of environmental protection into UK law, including the ‘precautionary principle’, the ‘prevention principle’ and the ‘integration principle’ which must consider environmental protection within law making. This is the mechanism the UK can use to impose standards like the levels of PFAS within drinking water.
This swift change in guidance follows hot on the heels of the US when, in April 2024, the US Environmental Protection Agency (EPA) announced national legally enforceable drinking water standard for six individual PFAS along with a $1B investment to address PFAS in drinking water. This is the fi rst time that drinking water standards have been fi nalised for a new chemical under the Safe Drinking Water Act since it was updated in 1996.
The EU currently sets environmental limits on PFAS. The Drinking Water Directive limits total PFAS in drinking water to 0.5 µg/l and levels for 20 individual PFAS to 0.1 µg/l.
Wastewater
The behaviour of PFAS in the environment means they tend to pollute groundwater, and this can lead to contaminating the drinking water supply. PFAS leak into the soil, water, and air
from sources such as industry, fi refi ghting foams and waste infrastructure. Existing water treatment methods do not remove PFAS due to it being diffi cult and costly. Because they break down slowly, if at all, they can build up in the environment, leading to the greater likelihood of them passing into drinking water and the food chain.
The Environment Agency (EA) in England may soon be proposing limits on PFAS discharge levels. It has identifi ed additional monitoring programmes and projects (which started in 2021) to expand its existing evidence base on PFAS, to include:
• Groundwater • Surface water (fresh and saline) • Freshwater fi sh (PFOA and PFOS only) • Marine fi sh • Landfi ll leachate
• WWTW effl uent and sludge (through CIP3) PFAS are commonly found in infl uents, effl uents, and sludges from wastewater treatment works (WWTW) globally. In the UK, PFOS and PFOA are monitored under the Chemicals Investigations Programme (CIP), now being expanded to include sampling for PFAS in effl uent, sewage sludge and groundwater. The 2014 review of the Groundwater Directive (2006/118/EEC) led to a 2015 initiative to identify emerging pollutants, including PFAS, for a voluntary Ground Water Watch List (GWWL). Eleven Member States provided data on PFAS. If suffi cient EU-wide data is available, Annex I and/or II of the Directive could be amended to include at least 10 PFAS, with potential future updates to cover all known PFAS.
Conclusion
The widespread use and persistence of PFAS present signifi cant environmental and public health challenges globally. Known as ‘forever chemicals’ due to their durability and resistance to degradation, PFAS have infi ltrated various industries and products, from non-stick coatings to fi refi ghting foams, resulting in inadvertent environmental contamination.
The absence of specifi c regulatory standards for PFAS in drinking water in England and Wales highlights a critical gap in current legislation, albeit mitigated by the requirement that water remains “wholesome” and free from substances posing potential health risks. In contrast, the United States has taken a proactive stance with the establishment of enforceable drinking water standards for six individual PFAS, accompanied by substantial fi nancial investments for remediation—a signifi cant step forward in safeguarding public health. The EU similarly has taken action and set limits on PFAS in drinking water.
Looking ahead, the UK may follow suit with potential updates to its regulatory framework under the Environment Act 2021, refl ecting growing concerns and advancing scientifi c understanding of PFAS contamination. The Environment Agency’s expanded monitoring programs underscore efforts to gather comprehensive data on PFAS presence in groundwater, surface water, and wastewater treatment works, essential for informed regulatory decisions and effective environmental management.
As PFAS continue to pose complex challenges due to their persistence and wide-ranging environmental impacts, international collaboration and robust regulatory frameworks will be crucial in mitigating their spread and protecting both ecosystems and human health from these enduring pollutants.
Read more in our whitepaper here:
https://www.adlerandallan.
co.uk/knowledge/white-paper/comprehensive-exploration- business-relevant-pollutants
Author Contact Details Bill Atkinson, Chief Scientifi c Advisor • Adler and Allan • Address: 80 Station Parade, Harrogate, HG1 1HQ, UK • Tel: 0800 592827 • Email:
sales@adlerandallan.co.uk • Web:
www.adlerandallan.co.uk
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