PFAS Analysis in an Evolving Regulatory Landscape

The best way scientists can address the challenges in dealing with PFAS and the changes in regulation is by talking to each other—communicating. We tend to stay in our lab, in our office, talking to our friends and colleagues that are working on the same field as us. If you’re an environmental scientist, most likely you are not going to be talking to a materials scientist characterizing new materials contained in PFAS. By working together, we can address the challenges from upcoming regulation. I also think it is very important to inform legislators, to ensure that regulations incorporate the latest science.

How are we going to close the mass balance of PFAS? We have current analytical regulatory matters that cover around 40 to 70 PFAS—that is less than 1 or 2% of the total PFAS that we know is out there. We are only at the tip of the iceberg.

You can't manage what you can't measure. If we don't have reliable measurement techniques for a vast amount of these, PFAS management becomes a difficult issue then, as well. Specifically, looking at high resolution mass spectrometry tools to identify some of these new PFAS is a big step forward. We also need to make sure that we continue to develop routine methods for some of our new PFAS matrices, like air, and we increase our scope in drinking water and wastewater so we can get more occurrence data that gives us a more accurate picture of how much PFAS is out there.

If you look at Europe, we've actually seen quite a lot of work completed around testing for PFAS contamination with the European Safety Authority setting maximum levels for a number of selected PFAS in certain food types. Due to the health effects from consuming food with PFAS contamination, I do expect similar regulations or discussions to follow in North America for food and also for food packaging that can be a source of PFAS materials. We did recently (February 2024) see an update from the FDA about imported foods and the presence of PFAS contaminants. These are some of the activities that will drive more awareness to PFAS contamination and I believe accelerate the adoption of a more proactive PFAS testing framework and program in the food and beverage supply chain industry.

Doing routine analysis of PFAS in labs, there's definitely a learning curve that we have to go through. There are a lot of peculiarities to handling samples. Make sure you don't contaminate the sample stream or do anything negative to the samples you're handling. Once you've kind of gone past that learning curve for a lab, it gets a little bit easier. In this case, I think, as time goes on and the labs adopt these methods, it'll be easier to meet future regulations.

There's a lot of work going on by the U.S. EPA. They have an extensive fast action plan, as they call it, that deals with a number of different things, including the monitoring and testing of PFAS, but also remediation and then strategic and scientific communication to the public. I think when we look at it from our testing perspective, it's fair to say that the EPA is looking into methods to add additional PFAS to their drinking water and wastewater methods, but they're also looking at new methods to come out on the air testing side, as well. I think these are things we can expect in the next 12 to 18 months.

We should see soon, with expanded regulations, more of a focus on solid matrices. The new method 1633 covers soil samples, solids and biosolids, in addition to water testing, and the fact that those have been released show that there's a push and a need for understanding and controlling PFAS exposure in those matrices—especially bio solids, which are applicated on farmland and can be taken up by food. In addition to those matrices, the EPA and ASTM have been working on standards and methods for PFAS testing in air, both for industrial output and ambient air sampling. I see those matrices being a potential target for further regulation down the road. Moving away from environmental testing, the FDA is also expanding its PFAS target list and eventually I feel that the U.S. is going to follow the lead of Europe and put more focus on food and food packaging.

We've seen clear messaging from the EPA that they want to hold polluters accountable and also work on projects to help remediate any contaminants, exposures or sources. I expect a lot of attention will be placed on the industrial market and potentially around the areas where people may or may have been discharged. They've already taken steps to regulate forced discharges from industrial sources and I expect more in the coming years. I also see the U.S. government having an opportunity to further strengthen the regulations to control and reduce policies that were released from all industrial processes, such as water cleanup or consumer manufacturing.

In a similar manner, I see short chain PFAS compounds that are actually volatile in the air getting more attention and regulatory exposure because of how they can be transported within the environment. They're going to have a big impact because of how they get into the environment, outside of industrial settings. I think developing regulations for air monitoring will be addressed with a collaborative approach from regulatory agencies, industry and technology providers.

The best step that labs can take for future-proofing their laboratories is to control their PFAS background. That's the biggest problem I see labs having, especially as the PFAS compound list expands more—that background becomes more of a potential issue. Labs looking to future-proof themselves need to make sure they are capable of meeting future lower limits and new compounds, and can isolate their PFAS laboratories and screen materials coming in to make sure they have very good control over their background. They need to deliver high results.

In addition, the sheer number of PFAS compounds that aren't being tested for means as PFAS compounds become more of an interest and have required testing, labs will need to be flexible and quick in adapting new methods or additions to existing methods. Having experienced staff on hand that are good with method development, having tools that can help with method development, and then also having a lot of expertise and flexibility in terms of sample prep to handle new matrices as they arrive, are all going to be critical for making sure that a PFAS lab can work very well into the future.

We are seeing incredible growth in the PFAS testing market with a lot of laboratories needing to test a high volume of samples faster. To ensure they are future-proofed, I really encourage establishing a collaborative relationship with the technology providers that are investing to develop and support these fast PFAS workflows, reach out to them at the local and remote support-level to understand what options they have or can suggest for a lab’s unique requirements. This comes down to understanding the time you're looking to test these samples in—is it days, is it weeks, is it longer? Also, to what scope are you following a specific method or do you have more research focuses in mind?

Another area is automation. More and more samples will be coming into these labs so the use of sample preparation automation platforms is going to be critical. Understanding the options available today and how those support one of the mass spectrometry workflows is an very popular topic.

PFAS in air will be critical in the future. Air is something that we cannot discriminate because everyone breathes air—24 hours a day. Knowing the concentrations of PFAS in air is important, especially for sensitive populations. That's a big area we have to look into.

The other area we really need to be focusing on is closing the mass balance of PFAS—or measuring other PFAS that are not on our regulatory target list. We need to understand how prevalent they are and try to get a holistic picture of how much PFAS is really out in the environment.