Stephanie Warino P.G., WV LRS, PMP How will PFAS impact the AEC Industry?
There are many drivers in strategic business planning. The competitive environment, labor force conditions, funding cycles, commodity prices, international influences, and regulatory changes are all factors that drive market conditions, among others. Each factor is important and should be evaluated as a component of your strategic business planning market research. Some factors, depending on the markets you serve, can have larger impacts than other factors. One factor that will have significant, widespread impacts in the United States, and will especially affect the AEC industry and our clients, are emerg - ing contaminant groups. Emerging contaminant groups are chemicals – they can be man-made or natural. They are recently discovered, and they are classified as “emerging” because the environmental and overall health risks have not yet been quantified. There are a number of contaminants that the United States Environmental Protection Agency (EPA) classify as “emerging”. The most potentially impactful emerging contaminants under continuing investigation are a group of extensively produced, man-made chemicals called per- and polyfluoroalkyl substances (PFAS). This group of chemicals are extremely pervasive in the environment, are soluble in water, bioaccumulate, and do not break down easily. PFAS can be found in food, household items, in the workplace, in drinking water, and in living organisms. Many of the facilities in which AEC works could be sources, have produced or have utilized PFAS. These potential sources include aviation facilities, car washes, chrome electro - plating, anodizing, and etching services, coatings, paints, and varnish manufacturers, fire-fighting foam manufacturers, landfills, municipal fire departments and firefighting training centers, paper mills, petroleum refineries and terminals, photographic film manufacturers, polish, wax, and cleaning product manufacturers, polymer manufacturers, printing facilities where inks are used in photolithography, textile and carpet manufac - turing, and wastewater treatment plants. AEC and our clients will need to understand the technical and business implications for these emerging contaminants and the levels at which ac - tion could be needed. For chemicals which have been fully assessed and have a known, quantified health hazard, under the Safe Drinking Water Act, the EPA will issue a Maximum Contaminant Level (MCL). Currently, the US EPA is on a path to developing a drinking water standard for two of the most widely studied PFAS – and there are 4,700 PFAS. And the safe threshold right now is incredibly low. Currently, the EPA Health Advisory levels are 70 parts per trillion. Not only that, but specialized sampling methodology and equipment needs to be used to prevent sample contamination - much of the commonly used sampling equipment used to collect samples (tubing, sample containers, and sampling tools) may themselves contain PFAS. Upcoming legislation that seeks to have PFAS designated as a hazardous substance under the Comprehensive Environmental Response, Com - pensation, and Liability Act (CERCLA) would have significant and far-reaching effects in nearly all the markets that we, in AEC, operate within. This legislation, if approved, can result in enormous liabilities for both AEC and our clients. Sources of PFAS are incredibly varied and encompass many of the facilities in which the AEC industry works. Sites should be evaluated for emerging contaminant potential prior to property transfer and subsequent redevelopment. Already over 30 states have PFAS policies of some sort in place, which is predictive of the eventual federal outcome. This is just one group of emerging contaminants, and there are certainly others out there, including but not limited to 1,2,3-trichloropropane, 1,4-dioxane, 2,4,6-trinitrotoluene, dinitrotoluene, hexahydro-1.3.5-trinitro-1,3,5-triazine, and numerous others, including vapor intrusion, which is being investigated as an emerging contaminant (even though it’s really an exposure pathway for various volatile chemicals, and not a specific chemical). But PFAS are by far the most ubiquitous and lasting in the environment, and the most likely to have wide-ranging health effects due to their high rate of use, and their pervasiveness. The most immediate impacts, of course, will be to assess and address groundwaters and surface waters sources for potable water uses, as well as to address wastewater treatment. Both issues have some extremely wide-ranging implications, and it doesn’t stop at finding an unimpacted source of drinking water or designing a wastewater treatment plant to remediate for PFAS. For example, once you determine your existing source is contaminated, then not only is there the issue of finding a new water source, but also the issue of identifying the responsible party. This leads to the issue of investigating, delineating, and remediating the contaminated groundwater. With a re-designed wastewater treatment plant, there will be PFAS-contaminated byproducts that will need proper disposal. And so far, we’ve only talked about water and wastewater. Think about the environmental fate and potential remediation implications of PFAS in soil, in sediment, in landfills, and even as a contaminant in air. Remediation effort costs can range into the millions. For the AEC industry, our involvement in development projects, if there is environmen - tal due diligence, should include attention to this issue. Environmental risk is always manageable to some degree with careful, up-front due diligence – these steps are normally taken in a Phase I Environmental Site Assessment, which is an extremely commoditized task in the AEC in - dustry, so much so that they are sometimes conducted and produced using software. The more commoditized it has become, the more it becomes a sort of “check-the-box” mentality. AEC and our clients have a lot of challenges ahead of us with PFAS regulatory changes likely to be in the not-so-distant future. In addition, strategic market research may also be warranted for your firm to assess the potential business aspects - what clients are we currently serving that may be impacted, and not only how will it affect them and our operations. As a highly innovative industry full of brilliant people, we are up to the challenge - as consultants we can take action now to educate ourselves and our clients, and position both parties for the best possible outcome.
STEPHANIE WARINO is a Strategic Planning Advisor at Zweig Group. She can be reached at swarino@zweiggroup.com.
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June 2021
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