[00:00:00] Liz Bothwell: Hi everyone, welcome to Waste360's NothingWasted! Podcast. On every episode, we invite the most interesting people in waste recycling and organics to sit down with us and chat candidly about their thoughts, their work, this unique industry and so much more. Thanks for listening and enjoy this episode.
[00:00:26] Liz: Hi everyone. This is Liz Bothwell from Waste360, I'm with Anne Germain, Vice President of Technical and Regulatory Affairs from the NWRA. Hi, Anne, thanks for being on the show again.
[00:00:38] Anne Germain: Hi Liz, thanks for including me.
[00:00:41] Liz: We want to talk about PFAS, and there's been so much talk about these chemicals lately, you're the perfect person to give our audience a PFAS-101 type of overview. Could you begin by sharing with us what exactly PFAS is? And where it fits into the waste industry?
[00:01:00] Anne: Sure. Obviously, nobody in the world can know everything about PFAS, so I am just scratching the surface when I say anything. Certainly, there's opportunities to continue talking long after we're done, but to start PFAS stands for Per and Polyfluoroalkyl Substances, they represent man-made fluorinated organic compounds, so none of these chemicals occur in nature. They represent a class of chemicals that, at last count, there's about 4,600 of these chemicals. Certainly, a huge number.
Initially invented early part of first half of the 20th century and used by some of the major U.S. manufacturers, such as DuPont and 3M in various products such as Teflon or Scotchgard. It's used in food packaging, used in just various materials to numerous even to mention. Two of these chemicals, PFOA, P-F-O-A and PFOS, P-F-O-S, grew the attention of the public probably early part of this century as potentially problematic.
Generally, people talk about PFAS as a class of chemicals, but often the attention is focused on PFOA and PFOS. I can tell you what those stand for, but most people just refer to those by their acronyms. At any rate, the US's manufacturers voluntarily agreed to eliminate PFOA and PFOS from their manufacturing back in 2010 to 2015, however, there was no restriction, this is a voluntary agreement so there is no regulatory or legislative restriction from manufacturer, nor was there any restriction on any of materials containing those substances.
The use has declined, and when I say the use is the use of those two. Those manufacturers went towards using other PFAS chemicals and away from those. Back in 2009, the US EPA came up with an initial draft to health advisory for both PFOA and PFOS. Then, in 2016, they finalized their health advisory at 70 parts per trillion for each of those, which generated a huge amount of attention because a health advisory doesn't contain any legal, regulatory or legislative restrictions, it just says that if you're exposed to that on a routine basis, there might be some health implications.
Certainly, a lot of attention was focused on drinking water across the country, and as drinking water be gained a lot of attention, people started focusing on, "Where else could these substances be found?", and attention start focusing on wastewater, landfills, groundwater and other areas.
We, of course, receive tons of materials that have PFAS in it, lots of consumer products. You have lots of it in your life, your carpeting, cleaning products, food packaging, furnishing, cosmetics, outdoor gear, I could just go on and on. There's so many different products that contain PFAS, so as a result, the landfills, of course, are receiving lots of different materials that also have PFAS in it because it is so ubiquitous.
Some landfills have been asked to test their leachate just to get a measure but, of course, landfills do treat their leachate and generally that's at wastewater treatment plants. There's no direct discharge that is implicated for exposing the public, it's generally through wastewater treatment plants but, of course, wastewater treatment plants as they're looking at stuff, they're starting to look upstream at their industrial contributors, so it becomes everybody looking at everybody else. That's part of the reason why it's gaining so much attention right now.
[00:06:06] Anne: That makes sense. Anne, what are some of the alleged health environmental implications of PFAS?
[00:06:12] Liz: First of all, I want to say I have no experience as medical professional or science in epidemiology or anything like that, I'm just repeating here what some of the presentations papers out there have said. There's a whole host of implications for health. They're primarily for much higher exposures than might be from any landfill source but nonetheless, they do include thyroid functionality, cholesterol, there's been implications for pregnancy-induced hypertension, birthweight.
Generally, when epidemiologist look at this, they try and look at the most vulnerable population when setting the levels. Even if the levels can be tolerated at a much higher level for adults, generally, they're looking at it for babies because they're the most sensitive population. As such the levels that might result in immunological effects, might be fairly high -I don't know what those levels would be, but they might be much higher- but they're not looking necessarily at that person and their exposure, they're looking at who the most vulnerable population is. Again, that would generally, be infants.
Then, for the environment, obviously, we see lots of other animals, as I said, they're completely man-made. As they make their way out into the environment, we do see them starting to show up in various animals, so it's been implicated in different fish populations. I think New Jersey has found it in the fish and I think Michigan has found it in deer, so as it gets out there, there's potential implications even as we start to buy some of these wild-caught fish, or if you're a hunter and you're starting to eat deer and you're thinking, "Oh, I might not have any exposure to these man-made chemicals because there's no food packaging or anything like that", there still could be potentially exposure implications there.
[00:08:35] Liz: Okay. You mentioned the number more than 4,000 types out there, it's just amazing how much we don't know and that it's not regulated it. Do you think is there a push for nationwide standards? Because it seems like the states are on their own now. Some like New Jersey, for example, seem to be making decisions and moving in a direction and they don't seem to be waiting. What do you think?
[00:08:59] Anne: That's a very good question. Part of what has happened is because the EPA did come out with their health advisory, but then they didn't actually come out with what we call an MCL, Maximum Contaminant Level that establishes a similar limit for drinking water or anything like that, because EPA didn't, a lot of states have taken it upon themselves to move forward and establish various rules. Certainly, New Jersey but we also have California, we have Vermont, New Hampshire. There's a bunch of different states, Michigan, Pennsylvania, New York, that are all looking at it.
I think even within the federal government there's also different actions that are going on. EPA did release their action plan earlier this year where they are planning on looking at it further. But even as we established some of these limits, there are also other implications with respect to there's not approved sampling protocols for a lot of these materials. When I talk about 4,500 different PFAS, there's test methods for very few of them.
Then other people are just looking at totals fluorinated compound, which is a whole even larger group than PFAS, it would implicate many more chemicals. There's so much more that it gets implicate very quickly. Even sampling materials, the EPA has not established sampling protocols. Michigan has established sampling protocols and they get very complicated very quickly because these PFAS are so ubiquitous, you don't want to contaminate the sample and have the sampler contaminate the sample, so when they do their collection, they're supposed to be very careful and cognizant of the sunscreen that they're using, the bug spray that they're using because they could have PFAS in it.
They even talked about what kind of rain gear that they're using or the waterproof notebooks could have PFAS in it. Or if you're using post-it notes or sharpies, there's all sorts of things where you have to be very aware when you're even doing the sampling to avoid cross-contamination.
[00:11:41] Liz: It really is everywhere.
[00:11:43] Anne: It's everywhere. That's part of the reason why when we are looking at PFAS from a landfill perspective, we acknowledge that, of course, landfills are getting PFAS and, of course, our leachate does have PFAS in it. But we do want the general public to also understand that their exposure to PFAS is not from the landfills, their exposure to PFAS is from the foods that they're eating, from the air that they're breathing, from the water that they're drinking. It's not coming from the landfills, the landfills are actually a reflection of what they're sending to us.
[00:12:26] Liz: Right, that's a great way to say it. What can the landfill owners and operators do?
[00:12:32] Anne: The only thing we can really do is educate the public. There are pretreatment technologies that are used for water, and if regulations get put into effect for pretreatment or something like that, that might be something that ends up happening down the road. As of right now, we're still at the infancy and still at such an exploratory phase, but it's continuously being generated and people are focused on where it's ending up, but they're less focused on where it is in their homes. If people are truly concerned about exposure, then they should look at their primary routes of exposure. That's what we want people to focus on.
Washington State did pass a rule that requires the Department of Ecology to go back and look at if there's safe alternatives for PFAS in food packaging, and if there is, then they're supposed to ban it. That's something that they're going to be looking at. I haven't followed the progress of that, but that's going to be something to consider in the future.
We also have to look at this and the implications for, as we look at composting more of our food and trying to divert material from the landfill, that these items are also going to have PFAS in it.
[00:14:09] Liz: Right, exactly. Soil and it's just so many implications, it's crazy. Waste360 just shared that eight states were granted six million dollars in funding by the EPA to research PFAS in the waste stream. Do you think academia can help us better understand and manage this issue?
[00:14:28] Anne: Yes. I think already there's been a lot of research that has gone into it. Definitely this research funding will certainly help as we start to decline in use PFOA and PFOS, looking at the newer landfills and trying to see if there's a decline in that, making it through to the leachate which PFAS end up being sequestered in the landfill. Because, of course, some of it isn't very mobile, just because you put it in the landfill doesn't mean it automatically comes out of the landfill, some of it is sequester and the landfill does act as a sink for some of these materials, so we're going to get a better understanding of when that happens, why it happens, tons of research that we can certainly benefit from.
[00:15:23] Liz: Okay, good. Now, did you go to the ERS PFAS event in Michigan?
[00:15:27] Anne: I did, yes. I thought that was a really good effort to get all the landfill folks to talk about it from leachate, but it was really focused on leachate. Some of the other things that we're talking about with respect to potential ramifications for compost, that because it was so targeted at leachate, it didn't cover some of these other areas. But for the leachate side, it was an excellent primer on what the state of PFAS and leachate is.
[00:16:05] Liz: Good. Did you get a sense that people are bracing for this or being proactive? What was the sense you got from it?
[00:16:14] Anne: I think we're actually up to speed on it, the questions are whether legislation is going to run ahead of the science because I think, as you said, there's so much attention right now and some of the science just isn't available. We see the way some of these laws are being written, they're actually trying to make affirmative declarations on what the status of some of these chemicals are before there's any science to support it.
I think we are trying to make sure that we're up to speed as an industry on what the potential issues are, but at the same time, not encourage people to say that all PFAS are exactly the same, that necessarily one PFAS chemical reacts the same as another because, obviously, we already know that they behave very differently and what their health implications are, what their environmental implications are, are certainly going to vary based on which chemical it is.
[00:17:32] Liz: Right, good point. Have you watched The Devil We Know on Netflix?
[00:17:38] Anne: No, I haven't seen that. I have told my husband but he's less interested in what- [laughs] I just have to find a night when he's in a good mood because, generally, we're watching shows together, that's part of the reason why it gets put lower on the list every time. I do have to watch that.
[00:18:05] Liz: [laughs] Okay, let me know what you think. I watch it the other night and it's mind-blowing, it really is. I'll be curious to hear what you think.
[00:18:13] Anne: Yes. Obviously, I think that generates even more attention to the issue. It's got such a fluid society just because the US makes certain changes, we have to think about imports and what other materials [unintelligible 00:18:34]. I remember the first time I had Teflon pan, I was amazed at how great it was not having to clean that pan and everything just slips right off, it was fantastic.
[00:18:49] Liz: Right, of course. Like we talked about, it's in so many things I didn't even realize, dental floss and all of these other conveniences like you're saying. Our world of convenience, definitely, has made us more prone to this, but who knew, right?
[00:19:07] Anne: Exactly.
[00:19:08] Liz: You've done a great job of really intertwining this issue with the waste industry. I guess big-picture questions, who's going to pay for all of this if we do have to, different processes for the leachate and isolating that? Is it going to go to the landfill owners? Will it go to the facilities? Is it just going to be across the board? Will it be consumers and manufacturers or we just don't know yet?
[00:19:34] Anne: That's a very good question. I think, obviously, the drinking water agencies are trying to tackle some of that. Cape Fear in North Carolina experienced this firsthand where they were outlining some of the costs that they had to undergo because they had PFAS showing up in their drinking water. The costs that they had to increase for their ratepayers was substantial, but they also said besides the cost, they also experienced a significant decline in public trust. All for issues that they rightly don't feel that they were the cause of it.
I think we, in the landfill industry, feel the same way, we don't [inaudible 00:20:35] we don't use these materials, and yet there's the potential implication that we're going to have to be holding the bag on it and also, the public trust is important for us to maintain as well. These are all factors considered. I don't know if we're going to be able to get all the funding, be able to be supported by the original manufacturers or who's going to end up having to support some of this stuff. That's part of something that we should think about as we continue to utilize these materials and as we continue to manufacturing them.
[00:21:23] Liz: Okay. Anything else we should be watching out for around PFAS?
[00:21:27] Anne: Well, obviously, there's a tremendous amount of legislations and regulations that are cropping up and they're covering all aspects of PFAS. We're looking at new trends in states and they're enacting of MCLs, or even just doing their initial testing so we're going to continue to focus on this into the future. Hopefully, we are able to work together with our wastewater treatment plant partners and come up with good plans on how to manage our materials.
[00:22:08] Liz: Okay, sounds good. Well, it's something we're all paying attention to, even more now that it's tipped into the mass media. Thank you so much for this awesome overview and I'm sure we'll be tapping your brain soon to hear even more.
[00:22:27] Anne: Okay, great.