two firefighters using firefighting foam to extinguish a fire

Protecting the workforce from PFAS

Author: Tim Fagan, Senior Legal Editor

PFAS – it is an acronym that is seemingly everywhere. It stands for per- and polyfluoroalkyl substances (PFAS), a class of thousands of complex synthetic chemicals that have been used in industrial and consumer products since the mid-1900s.

PFAS repel water, oil, and other liquids and are extremely durable, temperature resistant, and reduce friction. These properties make PFAS beneficial in many products and applications, such as stain- and water-resistant fabrics, food packaging, nonstick cookware, paints and other coatings, insulation, fire-fighting foams, personal care products, personal protective equipment, construction materials, and industrial processes.

PFAS are persistent in the environment and may take thousands of years to biodegrade, which is why they are often referred to as “forever chemicals.” The chemicals get into water supplies and can be taken up by plants and can bioaccumulate as they progress up the food chain, meaning they build up in the bodies of animals and humans with each exposure, and without any way of being removed.

Due to the widespread production and use of these chemicals, their persistence in the environment, and bio accumulative properties, most people in the United States have been exposed to PFAS and have PFAS in their blood. Research into the toxicity of PFAS is ongoing, but current evidence shows that increased PFAS exposure can lead to increased risk of heart disease, liver damage, birth defects, pregnancy complications, suppressed immune function, and higher rates of kidney and testicular cancer.

Protecting workers

PFAS exposure can vary by occupation and work activities, with chemical manufacturing, firefighting, the aerospace industry, construction, and electronics manufacturing being among the most likely to result in exposure. In addition, there are multiple pathways of exposure, with inhalation and skin contact being the more common paths of occupational exposure. The potential for PFAS exposure should be considered when conducting job hazard analyses.

While there are no generally accepted best practices, actions employers can take to protect workers from PFAS exposure and the potential adverse health effects, include:

  • Identifying the sources of PFAS exposure at your facility, and regularly reassessing. Many companies are unaware that there are substances and products that contain PFAS present in their facility and within their supply chain. Take the time to assess the products, materials, equipment, processes, and wastes at your facility for the presence of PFAS.
  • Considering alternatives to PFAS-containing products, materials, and equipment.
  • Assessing potential contamination of the soil and drinking water onsite. If necessary, provide bottled water to employees.
  • Ensuring workers have access to appropriate personal protective equipment (PPE) to provide adequate protection from PFAS hazards.
  • Providing workers with training on PFAS hazards, their risk of exposure, and actions that can be taken to mitigate exposure.
  • Properly destroying or disposing of PFAS materials according to EPA’s 2024 Interim Guidance on the Destruction and Disposal of PFAS.

Learning more about the problem

The EPA launched a multi-pronged campaign to address PFAS hazards, and facilities need to take actions to protect their workers. However, one of the challenges to effectively addressing the problem is limited knowledge and information, but actions are being taken to expand our knowledge and acquire more information about PFAS.

Research into the toxicity of these chemicals and new methods of destruction and disposal is ongoing. In addition, the EPA finalized the following:

  • A rule under the Toxic Substances Control Act (TSCA) requiring any person that manufactures or has manufactured PFAS or PFAS-containing articles in any year since January 1, 2011, to electronically report information about PFAS uses, production volumes, disposal, exposures, and hazards. This information, which must be submitted between November 12, 2024, and May 8, 2025, will allow the EPA to get a full understanding the scope of the PFAS problem by identifying and characterizing the sources and quantities of PFAS manufactured in this country.
  • The EPA added certain PFAS substances to the Toxic Release Inventory (TRI) report, under the Emergency Planning and Community Right-to-Know Act (EPCRA) and these chemicals are not eligible for the de minimis exemption. This will provide more information on releases and how wastes containing these chemicals are managed.

More information will help EPA determine the necessary actions to clean-up PFAS in the environment and limit future releases. It will also inform OSHA and employers on how employees may be exposed to PFAS and guide them to appropriate actions to ensure worker safety.