Let the Buyer Beware – A Cautionary Tale

Let the Buyer Beware - A Cautionary Tale

Ann Marie Gathright

Account Executive

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I remember strolling the streets of New York City years ago and being approached by street vendors furtively peddling knockoff purses and watches conveniently stashed in giant garbage bags. As tourists strolled by, they’d brandish the objects, assigning passersby to each item. “Beautiful lady, you’re a Fendi.”  “Why hasn’t your husband bought you a Rolex, Madame?” All the pitches were similar in nature. Each vendor assured me the items were authentic and that I would never find a better deal. I love a good deal, and against my better judgment, I bought a “Rolex” (I know you’re laughing) for… get ready … $200. You already know how this story ends. I didn’t make it home before the watch died an untimely death.   Those merchants were opportunists, and I was a willing participant. I wanted to believe I was getting quality for the price.

In the environmental industry, a similar scenario is playing out, where per- and polyfluorinated alkyl substances (PFAS) analytical testing is concerned. If you’ve somehow managed to avoid this conversation, PFOA, PFOS, ADONA, and related PFAS compounds, often referred to as perfluorinated chemicals (PFCs, though this term is incomplete and outdated), have been of concern to US EPA for more than a decade. Found in fire suppression foams, pizza boxes, nonstick cookware and popcorn bags (just to name a few), PFAS are pervasive in the environment. A number of fully perfluorinated versions (e.g., PFOA, PFOS) don’t hydrolyze or photolyze in the environment. Unlike with some contaminants, natural degradation doesn’t work with them. PFAS are everywhere … They are difficult to remove from the environment, and the current methods of testing for PFAS are a long way from being foolproof.

Determining which of the PFAS is of interest from an environmental standpoint is in the early stages and complicated by the fact that polyfluoroalkyl substances and larger “precursor” compounds (larger compounds and polymers that contain a perfluoroalkyl functional group) may degrade to PFOA and PFOS or other PFAS of concern. Think polychlorinated biphenyls (PCBs) version 2.0 on steroids – PFAS compounds are of concern at parts-per-trillion levels and are much more easily transported great distances due to their higher water solubility and recalcitrant nature. Those challenges occur, not only in the laboratory, but also during sampling. This is concerning news for all of us, and by that, I mean ALL of US. You. Me. Manufacturers. Industrial Facilities. Military Bases. Ports. ALL of US. They’re everywhere, including in our blood.

Disappointingly, some laboratories are rushing to market, peddling PFAS analyses without the necessary due diligence. Recently, the state of Michigan has seen a number of laboratories popping up offering citizens PFAS home testing kits for the cost of my temporary “Rolex.” A Michigan laboratory manager who has recently entered the PFAS-analysis business, misspoke when he said the possibility of contamination while using a home test kit is low.  His comment is both misleading and untrue. The state of Michigan’s wastewater sampling plan elucidates the myriad ways that a Sampling Team could contaminate a PFAS sample. Sunscreen, cosmetics, fabric softener, hand cream, aluminum foil are only a few of the bad actors on the contamination list.

Here’s the difference between my embarrassing “Rolex” purchase and selling PFAS analysis for the relative cost of my junk timepiece. I knew better. My concern is that those procuring PFAS home testing kits are going to wind up just like me- with a product that is neither accurate nor precise. Keep in mind that current published laboratory methods address only about two dozen analytes out of the thousands of different PFAS chemicals that are present in environmental media. Laboratories are using different versions of these published methods, different extraction practices, and there are differences in the available standards including an absence of many isomers.

In addition, PFAS are not yet regulated by the US EPA, nor are the laboratories performing the testing accredited by the US EPA. Disturbing, right?

But, here is some good news:  The US EPA is hosting public meetings in every region to confer with stakeholders in order to gain feedback on how best to address PFAS contamination and to share its intentions on future steps towards rulemaking.  We can all agree that the formalization of any cleanup standards or drinking water standards must be based on solid science. More information can be found here.

Like any complex issue, there isn’t one right answer. No silver bullet. To avoid buying a garbage-bag “Rolex,” you can take some precautionary steps:

  • Implement a robust quality assurance/quality control Sampling and Analysis Plan and engage independent Chemists and Geoscientists who understand each of these issues and can develop a program for your objectives.
  • Ensure you sampling procedures are specifically for PFAS.
  • Audit your Sampling Team.
  • Vet (audit) your laboratories’ analytical capabilities.
  • Validate the data prior to any use.
  • Understand the value of independent technical consultants in this highly visible arena.

Let the Buyer Beware - A Cautionary Tale

I remember strolling the streets of New York City years ago and being approached by street vendors furtively peddling knockoff purses and watches conveniently stashed in giant garbage bags. As tourists strolled by, they’d brandish the objects, assigning passersby to each item. “Beautiful lady, you’re a Fendi.”  “Why hasn’t your husband bought you a Rolex, Madame?” All the pitches were similar in nature. Each vendor assured me the items were authentic and that I would never find a better deal. I love a good deal, and against my better judgment, I bought a “Rolex” (I know you’re laughing) for… get ready … $200. You already know how this story ends. I didn’t make it home before the watch died an untimely death.   Those merchants were opportunists, and I was a willing participant. I wanted to believe I was getting quality for the price.

In the environmental industry, a similar scenario is playing out, where per- and polyfluorinated alkyl substances (PFAS) analytical testing is concerned. If you’ve somehow managed to avoid this conversation, PFOA, PFOS, ADONA, and related PFAS compounds, often referred to as perfluorinated chemicals (PFCs, though this term is incomplete and outdated), have been of concern to US EPA for more than a decade. Found in fire suppression foams, pizza boxes, nonstick cookware and popcorn bags (just to name a few), PFAS are pervasive in the environment. A number of fully perfluorinated versions (e.g., PFOA, PFOS) don’t hydrolyze or photolyze in the environment. Unlike with some contaminants, natural degradation doesn’t work with them. PFAS are everywhere … They are difficult to remove from the environment, and the current methods of testing for PFAS are a long way from being foolproof.

Determining which of the PFAS is of interest from an environmental standpoint is in the early stages and complicated by the fact that polyfluoroalkyl substances and larger “precursor” compounds (larger compounds and polymers that contain a perfluoroalkyl functional group) may degrade to PFOA and PFOS or other PFAS of concern. Think polychlorinated biphenyls (PCBs) version 2.0 on steroids – PFAS compounds are of concern at parts-per-trillion levels and are much more easily transported great distances due to their higher water solubility and recalcitrant nature. Those challenges occur, not only in the laboratory, but also during sampling. This is concerning news for all of us, and by that, I mean ALL of US. You. Me. Manufacturers. Industrial Facilities. Military Bases. Ports. ALL of US. They’re everywhere, including in our blood.

Disappointingly, some laboratories are rushing to market, peddling PFAS analyses without the necessary due diligence. Recently, the state of Michigan has seen a number of laboratories popping up offering citizens PFAS home testing kits for the cost of my temporary “Rolex.” A Michigan laboratory manager who has recently entered the PFAS-analysis business, misspoke when he said the possibility of contamination while using a home test kit is low.  His comment is both misleading and untrue. The state of Michigan’s wastewater sampling plan elucidates the myriad ways that a Sampling Team could contaminate a PFAS sample. Sunscreen, cosmetics, fabric softener, hand cream, aluminum foil are only a few of the bad actors on the contamination list.

Here’s the difference between my embarrassing “Rolex” purchase and selling PFAS analysis for the relative cost of my junk timepiece. I knew better. My concern is that those procuring PFAS home testing kits are going to wind up just like me- with a product that is neither accurate nor precise. Keep in mind that current published laboratory methods address only about two dozen analytes out of the thousands of different PFAS chemicals that are present in environmental media. Laboratories are using different versions of these published methods, different extraction practices, and there are differences in the available standards including an absence of many isomers.

In addition, PFAS are not yet regulated by the US EPA, nor are the laboratories performing the testing accredited by the US EPA. Disturbing, right?

But, here is some good news:  The US EPA is hosting public meetings in every region to confer with stakeholders in order to gain feedback on how best to address PFAS contamination and to share its intentions on future steps towards rulemaking.  We can all agree that the formalization of any cleanup standards or drinking water standards must be based on solid science. More information can be found here.

Like any complex issue, there isn’t one right answer. No silver bullet. To avoid buying a garbage-bag “Rolex,” you can take some precautionary steps:

  • Implement a robust quality assurance/quality control Sampling and Analysis Plan and engage independent Chemists and Geoscientists who understand each of these issues and can develop a program for your objectives.
  • Ensure you sampling procedures are specifically for PFAS.
  • Audit your Sampling Team.
  • Vet (audit) your laboratories’ analytical capabilities.
  • Validate the data prior to any use.
  • Understand the value of independent technical consultants in this highly visible arena.

Ann Marie Gathright

Account Executive

Sign up for our newsletter, The Standard!