PFAS0121
Prepared by Professor Paul Nathanail, Dr Ken Scally, Matthew Lawman, Michael Lunn and Peter Atchison
The Environmental Industries Association (EIA) warmly welcomes the Environmental Audit Committee (EAC) inquiry into Understanding the threats and benefits from using Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Our submission draws on the expertise of members of our Remediation of Land and Groundwater Working Group and the Environmental Analysis and Testing Working Group Group. These two groups represent a very broad spectrum of contamination specialists and technical experts from toxicologists and risk assessors, to remediation consultants and contractors. Over the course of several meetings our Members have discussed and agreed upon the following response to the EAC inquiry.
PFAS have been used in industry and consumer products since the 1940s. Their use is based on their chemical stability and surface-active properties - the same properties that makes them an environmental concern and their being referred to, inaccurately, as "forever” or more usefully as “lingering” chemicals".
A very wide range of fluorinated organic substances, including alkyl (PFAS) and aromatic compounds, are used in the chemical, pharmaceutical, personal care, medical, food, electronics, defence, textile, optical and other industrial sectors.
UK environmental regulators are generally poorly equipped to understand the risks posed by PFAS. They need training and a support network by professional experts to allow them to make decisions with confidence. EIA members have delivered high level training on PFAS to every Welsh local authority and introductory level training to many across England and Scotland.
The absence of regulatory thresholds for PFAS (beyond the environmental quality standard (EQS) for PFOS) in surface water impedes risk assessment and screening of PFAS. There is no publicly available position emerging in the UK regions. Clear guidance on the approach that the EA / SEPA / NRW and NIEA expect would be welcome.
Defra set up a contaminated land expert panel to advise local authorities between 2012 and 2018. Similar support for PFAS could be an effective and efficient option. EIA would be pleased to explore in oral evidence how this could be set up and operate.
Most of the large body of PFAS research is conducted in the United States, primarily funded by federal agencies such as the Department of Energy (DoE), Department of Defense (DoD), and the Environmental Protection Agency (EPA). These bodies have driven significant advancements in understanding PFAS toxicity, environmental fate, remediation technologies, and analytical methods, particularly in the context of large-scale contamination at military and industrial sites.
In contrast, the UK’s research base on PFAS, while growing, is relatively limited in scale and scope. Research activities are distributed across a number of academic institutions, public agencies, and government-funded bodies such as the Environment Agency, and the Health and Safety Executive. However, sustained and coordinated national funding for PFAS-specific research has not yet reached the scale seen in the US or parts of Europe.
Analytical laboratories can measure concentrations of a small number of individual (“targetted”) PFAS compounds where there is a Certified Reference Material or, but with less confidence, a digital library. Other PFAS (“non-targeted”) can only be tentatively quantified.
UK capabilities in analytical technology are reasonably mature, with several laboratories equipped with LC-MS/MS analysis that can target specific PFAS compounds. Method development for non-targeted screening and total organic fluorine approaches is ongoing but remains limited to a small number of centres of excellence. The regulatory framework is also still evolving, with current monitoring efforts largely focused on a subset of regulated PFAS (such as PFOA and PFOS), while emerging PFAS and short-chain alternatives remain poorly characterised.
The investment needed to allow laboratories to expand both capacity and capability in PFAS analysis is considerable (ca £250,000 for liquid chromatography and £500,000 high resolution mass spectrometry for non targeted analysis) but can only be justified if there is a definite market for such analyses - which, as previous experiences show, will only grow slowly - too slowly.
Laboratory capacity and capability to perform high-quality, validated PFAS analyses should be unblocked by supporting investment to expand accredited laboratory throughput, standardise methods, and ensure consistency across inter-laboratory proficiency testing (PT) studies. Encouraging the development and uptake of robust analytical protocols will improve confidence in data quality and support timely decision-making across both the regulatory and commercial sectors
EIA would be pleased to explore how the UK government could help unblock this bottleneck and enable more detailed and reasonable assessment of PFAS in soil and water.
That said, recent policy and regulatory momentum, driven by the UK REACH programme and growing public awareness, has catalysed increased interest and funding in PFAS research in products and feed materials. Cross-sector collaborations between academic researchers, water utilities, environmental consultancies, and commercial laboratories are beginning to coalesce around knowledge gaps in environmental occurrence, fate and transport modelling, human health risk assessment, and development of remediation technologies.
The UK also participates in European and global knowledge-sharing networks, including for example EIA member involvement in the European NICOLE PFAS Working Group and collaboration with recognised leaders in PFAS research and policy from Scandinavia, Netherlands, USA, Australia and China.
Knowledge is pretty low - at least in part deliberately so. There needs to be a clear differentiation between PFAS polymers, such as the inert PTFE tape widely used in domestic plumbing, and other PFAS and also uses where PFAS are essential versus desirable or optional.
The use of “forever” as a nickname for PFAS is unhelpfully inaccurate in formal documents.
Repeated media stories that presence or detection of PFAS is equivalent to risky levels are inaccurate and unhelpful. Action on PFAS in food at levels that exceed scientific concern should be taken before if not alongside action on PFAS detected in environmental media.
In the UK there are only TWO PFAS manufacturers but many businesses use PFAS in their products. Their use spans all geographies and socioeconomic groups across the UK. They are de facto unavoidable although alternatives are or may become available for many uses whilst other uses could be considered non essential and PFAS use should not be permitted in such cases.
Considerable resources have been given to the EA and to a lesser extent other UK regulators and research institutions in recent years however the return on that investment is not always either clear or realised. Greater investment targeted to better risk based understanding of PFAS in environmental media by both public and private sectors should be encouraged. Despite the present focus on record levels of housebuilding with an emphasis of previously developed (brownfield) land and grey belt sites the budget and associated statements do not address the friction caused by PFAS in soil and waters.
Current technologies for treating PFAS contamination can be broadly categorised into removal and destruction, or containment approaches. Each method varies significantly in efficiency, cost-effectiveness, and risk profile depending on the specific PFAS compounds present, concentration levels, and matrix (e.g., water, soil, sediment).
EIA members have experience showing that typical PFAS remediation costs are at the higher end of the scale compared to other persistent organic pollutants.
EIA would encourage publicly funded PFAS site investigation, risk assessment and remediation projects to be made publicly available to raise awareness and levels of good practice. Privately funded projects should be encouraged to do likewise - perhaps by highlighting existing research and development tax credits.
The UK has an excellent risk based framework that can deal with fugitive PFAS through planning and environmental protection laws but a much weaker and slower approach to dealing with PFAS in the supply chain and in particular the end of life stage.
The regulatory regime for dealing with historic releases of PFAS into the environment is fit for purpose. Both the planning regime and Part 2A of the Environmental Protection Act 1990 (as amended) are chemical agnostic and provide narrative criteria for when remediation is needed. It should be borne in mind that perfectly reasonably they trigger remediation at different levels of risk - not safe or suitable for use and a significant possibility of significant harm respectively.
Planning on PFAS Impacted Sites (Q2, Q6, Q7) is facing a potential blockage created by Planning Authorities responding to issues regarding PFAS raised by technical advisors (including the Environment Agency and Land Contamination Officers). From experience, the blockage can be generated by an unwillingness to accept risk assessments and remedial strategies in light of the increasing range of PFAS that can be detected in environmental media, the lack of regulatory standards for these compounds and level of understanding of toxicity/fate in the environment and health/environmental implications coupled with societal concerns about the detection of PFAS.
A key indicator of this potential development restriction could be the number of GQRA/DQRA and remedial strategies where PFAS has been identified that have been approved under the planning process by land use type i.e. infrastructure, commercial/industrial and residential that have been approved when PFAS is present.
It is recommended that this is routinely reviewed, especially as significant residential developments are proposed at airfields, including Cambridge East, Dunsfold Park, RAF Abingdon where PFAS is widely known to have been used historically.
Only a few PFAS have been registered under UK REACH and the regime cannot move fast enough to accommodate new substances. A faster screening process to focus on those PFAS likely to represent the greatest hazard should be encouraged to allow limited HSE resources to focus on PFAS of most concern.
Government support to expand UK laboratory capacity to analyse more individual targeted PFAS is needed alongside support to analyse non targeted PFAS for which no reference material is available.
The cost of a weak regulatory regime for the use and disposal of PFAS is being borne by current efforts to develop land affected by contamination for housing. Taking the 1.5 million homes target over the life of this parliament and assuming ⅔ are on land potentially affected by PFAS contamination and 1 soil sample being tested per house would require 1,000,000 samples at a rough cost of £350 per sample - a total of £350,000,000 just for the soil analysis - no allowance made for water pollution or risk assessment let alone remediation or the extra effort to avoid cross-contamination and to decontaminate between sample locations that adds 25% to the time for a site investigation.
Government support for standardised method statements for sampling and analysis - especially for empirical methods such as leaching and the PFAS specific TOP Assay - would help ensure consistency.
A precautionary approach for new entries into the UK market is essential to prevent future health and environmental impacts. However a more rigorous approach to risk-benefit regulation is needed for the large number of products that include PFAS. Neither blanket bans nor a lax hands off approach serve the UK well enough. Greater accountability for the businesses that choose to use PFAS in their products is needed. This could be achieved by taking a similar approach to the one adopted for health and safety at work legislation.
The risk based approach for contaminants in environmental media applies to PFAS and should be reinforced by regulators and government. The societal awareness resulting from mainstream and social media articles highlighting the detection of PFAS in various media, including consumer products and foods, should be welcomed as an opportunity to raise understanding of the ability of the planning system to deliver land that is safe and suitable for its intended use. Knee jerk or politically driven approaches, including recent U-turns, seen in some influential jurisdictions should be noted and avoided.
There is huge inconsistency in how PFAS are regulated across the UK - and particularly WITHIN individual countries. This reflects the variable level of knowledge among individual regulators. However the generic Land Contamination Risk Management (LCRM) guidance is implemented across all parts of the UK and is a common framework. Recent guidance from CIRIA (authored by an EIA member) shows how LCRM should be applied for PFAS in soils and water.
Both the EU and the US (at Federal level) have chosen not to follow strictly science based approaches to regulation. Playing to the gallery has resulted in examples of laws that are simply unenforceable and bring the jurisdictions into disrepute.
Treating PFAS is costly, long term and not always necessary. The UK can learn from the experiences of countries with more mature regulatory frameworks and established PFAS monitoring and remediation programmes, particularly the United States, the Netherlands, Sweden, Australia, and Canada. These jurisdictions have adopted proactive, ostensibly risk-based, and adaptive strategies that can help inform but not drive the UK’s approach to PFAS management.
UK legislation is workable and substance agnostic whereas in some jurisdictions, chemicals must be individually listed if they are to attract regulatory attention.
The main lesson is to avoid scientifically invalid standards such as those adopted by the US EPA or proposed by the EU for so-called “total” PFAS. In addition, overly cautious protocols, such as those adopted in parts of Australia for example, can hinder the investigation of PFAS pollution or endanger worker health and safety.
The UK funding is very limited and most new technologies are imported from abroad. A specific area where the UK, in the form of the British Geological Survey, has a global lead is in the development of laboratory tests to estimate bio-accessibility - a very useful parameter for human health risk assessment as demonstrated by the pioneering work of SME Land Quality Management Ltd.. No such tests exist for PFAS.
The introduction of new technologies by commercial laboratories requires considerable expenditure. Support to enable this from government - whether in the form of revolving loans or early signposting of new requirements to justify private sector investment is needed to allow the UK to benefit from techniques such as high-resolution mass spectroscopy and organic fluorine analysis.
UK legislation on land contamination is substance agnostic - it applies to all and any substances avoiding the regulatory loopholes seen in some international jurisdictions. There is therefore no need for PFAS specific legislation - that in any event would be slow to enact and open to wide interpretation.
PFAS are a high-profile group of substances whose toxicity and behaviour in the environment are imperfectly understood but known to vary greatly from substance to substance and therefore regulatory focus should reflect the hazard represented by an individual substance.
The UK approach to land contamination is flexible and robust enough to allow precautionary decisions on land management and reuse to be made even as our knowledge base continues to improve.
Both public and private sector initiatives - such as the Environment Agency multi-phase PFAS programme and CIRIA’s guidance on PFAS in soil and water - are to be celebrated.
The UK government could help accelerate this by supporting investment in analytical facilities to allow analysis of more individual PFAS compounds in more media (e.g. concrete, bricks, wood) and with high precision in the form of lower limits of reporting.
May 2025
EIA commends the following to the Environmental Audit Committee for consideration:
EIA members would welcome the opportunity to support the EAC Inquiry by presenting oral evidence and answering any questions committee members may have. In this regard EIA offers lead author Professor Paul Nathanail.
HSE and EA (2023a) Analysis of the most appropriate regulatory management options (RMOA) poly- and perfluoroalkyl substances (PFAS), Health and Safety Executive, London, Environment Agency, Bristol, UK https://www.hse.gov.uk/reach/assets/docs/pfas-rmoa.pdf
HSE and EA (2023b) Analysis of the most appropriate regulatory management options (RMOA), Annexes. Poly- and perfluoroalkyl substances (PFAS), Health and Safety Executive, London, Environment Agency, Bristol, UK https://www.hse.gov.uk/REACH/assets/docs/pfas-rmoa-annexes.pdf
NATHANAIL, P, WILLIAMS, G and NATHANAIL, J F. 2024. Good practice guidance: some per- and polyfluoroalkyl substances (PFAS) in soil and the water environment, C819, CIRIA, London, UK (ISBN: 978-0-86017-965-8)
NATHANAIL, P. 2025. PFAS Uncovered: What You Need to Know About These Lingering (Not Forever) Chemicals. The Chemnical Engineer, 25 February 2025. https://www.thechemicalengineer.com/features/pfas-uncovered-what-you-need-to-know-about-these-lingering-not-forever-chemicals/