Environmental Due Diligence

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PFAS IN BITS AND BYTES: The Changing Landscape of PFAS data and Phase I Environmental Site Assessments

LightBox Profile
LightBox Insights
October 11, 2022 3 mins

LightBox recently hosted a LinkedIn Live discussing how the industry is incorporating per- and polyfluoroalkyl substances (PFAS) into environmental site assessments, based on a LightBox survey of leading environmental professionals and a study of PFAS data available from federal and state sources. Paul Schiffer, vice president of product management at LightBox EDR®, and Alan Agadoni, general manager at LightBox EDR®, discussed the large and ever-growing universe of data published by state and federal environmental agencies, with a look at the trends and patterns that might help EPs use PFAS data when conducting environmental site assessments. This was the first in a series of presentations on this topic. Below are the questions asked in the survey and a highlight of the responses.

  • “Do you currently address PFAS risk as a standard part of a Phase I ESA?” Seventy-one percent of respondents said no, while 29% said yes.
  • “Do your organization’s Phase I ESA reports typically include a section on PFAS?” Six percent said they always do, 32% said only when a PFAS issue is identified, and 54% said they don’t have a PFAS section.”
  • “What criteria do you use to determine the likelihood of PFAS impacting the subject property?” Eighty-three percent said government records, 61% said file reviews, 69% said local knowledge interviews, and 20% said “other.”
  • “When assessing potential PFAS contamination, what types of site uses may be viewed as high PFAS risk?” The answers were 93% fire training facilities; 78% heavy industrial facilities; 68% properties that had a fire; 62% auto/rail/air accidents; 50% light industrial facilities.

Further insight was provided based on the LightBox team’s study of data sources of PFAS information:

  • Local knowledge and interviews are very important, which is consistent with what LightBox has seen in the marketplace and in reports.
  • Growth in PFAS information is tied to three sources: Google search, academic programs, and government record databases. Google searches have grown substantially, and while the government is involved in generating PFAS data, so are research institutions. The amount of data being created is growing very quickly—more than a 100% compound growth rate per year.
  • In 2018 there were few databases, but we’ve seen a steep climb. States are typically leading the way—they have a longer history of enforcement, and generally release more data frequently. There’s a natural center of gravity around databases with known and suspected PFAS, while federal data is focused on potential PFAS. States have less bureaucracy and can get information out quicker.
  • There’s a fair amount of variety surrounding data and a wide variety of collection methods, source definitions, and record counts. The counts aren’t necessarily indicative of levels of contamination.
  • Data provided varies substantially by state, which may be a function of multiple factors—various states of legislative activity, enforcement activity, or quantity of high liability sites. Sometimes PFAS data will reside in other hazardous waste databases. It’s crucial to know where your state is on the continuum of regulatory, enforcement, and data-tracking activity. Keep in mind that just because a state doesn’t have a great PFAS database doesn’t mean it’s not tracking; it’s about finding the right database.
  • The federal government is moving more slowly with respect to releasing PFAS specific databases, but demand for that data is significant. In response, the government released the National PFAS Dataset in February, though it’s mostly an extraction from previously existing data.
  • Federal database sources include spills, federal sites, superfund sites with known PFAS detections, PFAS manufacturers and handlers, facilities in industries that may handle PFAS, manifests (based on a keyword search of RCRA e-Manifest shipments), Clean Water Act discharge monitoring, toxics release inventory, drinking water testing (UCMR and state), and ambient environmental sampling for PFAS.
  • Much of the information provided in the federal file is not geolocated and is somewhat difficult to associate with locations because it wasn’t intended or collected for that purpose.
  • Additional in-depth survey coverage will be forthcoming. We continue to evaluate and load PFAS databases in our products—we currently have 59 databases covering 49 states. In October, LightBox will launch federal PFAS databases and in the coming months, we will be releasing new data, so stay tuned.

The LinkedIn webinar is available here

Please contact Alan (aagadoni@lightboxre.com) or Paul (pschiffer@lightboxre.com) with any questions or feedback.

Information on a range of topics—including survey data and other presentations—are available at https://www.lightboxre.com/insights/.

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