EPA investigation into firefighting foams – Expert Reaction

Firefighting foams containing banned chemical PFOS have been found at 17 sites across New Zealand by the Environmental Protection Authority (EPA).

PFOS foams were excluded from the Firefighting Chemicals Group Standard in 2006, meaning they could no longer be imported into New Zealand. In 2011, all PFOS products were completely banned and strict controls were set to manage their storage and disposal.

The EPA investigated 166 sites, including airports, ports, refineries, petrochemical storage sites and ships. They found firefighting foam containing PFOS at several regional airports, four sites controlled by Shell Taranaki Ltd, two tug boats, and at a tyre company. Foam containing lower levels of PFOS was also found at other sites, most likely due to contamination. All foams detected appeared to have been imported prior to 2006.

The SMC asked experts to comment on the report. Please feel free to use these comments in your reporting.

Associate Professor Deborah Read, Environmental Health Indicators Programme, Massey University, Wellington, comments:

“There is no public health risk from the PFOS that has been found in the EPA investigation as the foam was within equipment that was labelled and securely stored. It is, however, important that this banned substance is safely removed and disposed of to prevent any future exposure of people or the environment.

“PFOS belongs to a group of man-made substances, perrfluoroalkyl or polyfluoroalkyl substances (PFAS) produced since the 1950s. Their chemical properties led to a wide range of uses including in firefighting foams so their presence in the environment is widespread. Sources of exposure include air, water, soil, food, indoor dust and PFAS-containing consumer products. PFAS are very persistent in the environment and bioaccumulate. As a result, all New Zealanders have some background exposure. Studies have investigated many human health effects but to date the evidence is inconclusive between PFOS and any specific health effect.”

Conflict of interest statement: I have no conflict of interest relating to the EPA investigation and report.

Dr Arindam Basu, Senior Lecturer, Environmental and Occupational Health, School of Health Sciences, University of Canterbury, comments:

Were the sites discovered by the EPA endangering staff or the surrounding environment?

“The EPA found contaminants in the following sites:

  • Airports: Gisborne, Palmerston North, Hawkes Bay (Task Protection Services Ltd being contracted to undertake firefighting services for these three airports), Nelson (plus Nelson Airport Fire Services Ltd), Kapiti Coast and Chatham Islands
  • Four sites controlled by Shell Taranaki Ltd,
  • one vessel owned by Marine Services Auckland Ltd and
  • another by Lyttelton Port Company, and
  • at TRS Tyres in Whanganui.
  • Auckland International, Queenstown, and New Plymouth airports, and
  • Air New Zealand hangar in Auckland.

“Considering where the EPA found the contaminants were all occupational settings (ports, airports, fuel storage sites, etc), and that relatively high concentration of exposure for the exposed workers who may or may not have been equipped with personal protection devices to minimise exposure.

“Even if there were environmental contamination over a long period of time through leaching in groundwater, we would not know now, but the population in the surrounding regions need to be followed up with by investigation of their groundwater and drinking water.

“It is possible that people would have occupational exposures, but these would need to be followed up. As health effects are largely long term, immediate health effects may not occur.”

Was the process carried out by the EPA sufficient to find all PFOS-containing firefighting foam?

“Considering that PFOS-containing firefighting foams would only ever be used only in Type B firefighting foams meant for fighting fires due to fuels, the process that EPA followed is sufficient and adequate. As EPA stated in the mandate, their mandate was to conduct investigations at the airfields where these were commonly used and likely to be found.

“Investigation of water levels of PFOA near the contaminated sites to assess the possible community exposure levels was beyond the mandate of this examination, but EPA may consider this for a future investigation. As for identifying all PFOS-containing firefighting foam, the process the EPA adopted was appropriate, and necessary. However, testing of public water systems for PFAS may have been beyond the mandate of this investigation and it was not clear from this report.”

What are PFOS and PFOA and where are they used?

“Perfluorooctanoic acid (PFOA) and perfluorooctane sulphate (PFOS) are two of the most used and studied organic chemicals (“perfluoroalkyls”). These are part of a larger group referred to as perfluoroalkyl substances (PFAS). They are also known as ‘C8’ and are used in firefighting foams (only Class B, now discontinued), carpets, clothing, fabrics for furniture, cookware etc that are resistant to water, grease or stains.”

What dangers to human health and the environment does PFOS pose?

“While there is a wide variation as to the lowest acceptable levels that are compatible with human safety, New Zealand (NZEPA) has established health advisory levels for drinking water at 100 parts per trillion (ppt) and the United States EPA has established the health advisory levels at 70 parts per trillion for PFOA and PFOS.

“Perfluoroalkyls are very stable in the environment and are resistant to biodegradation, photoxidation, direct photolysis, and hydrolysis, and they have very low volatility so they persist for a long time in nature, being virtually ‘indestructible’.

“But they can leach into groundwater and so humans are exposed to these through groundwater and drinking contaminated water and inhaling air where these are present.

The Agency for Toxic Substances and Disease Registry in the US has identified, on the basis of epidemiological studies (mostly cross-sectional studies), that the following conditions are associated with exposure to perfluoroalkyls:

  • Pregnancy-induced hypertension/pre-eclampsia (PFOA, PFOS) Liver damage, as evidenced by increases in serum enzymes and decreases in serum bilirubin levels Increases in serum lipids, particularly total cholesterol and low-density lipoprotein (LDL) cholesterol (PFOA, PFOS, PFNA, PFDeA)
  • Increased risk of thyroid disease (PFOA, PFOS)
  • Decreased antibody response to vaccines (PFOA, PFOS, PFHxS, PFDeA)
  • Increased risk of asthma diagnosis (PFOA)
  • Increased risk of decreased fertility (PFOA, PFOS) and low birth weight
  • The International Agency for Research on Cancer concluded that PFOA is possibly carcinogenic to humans (Group 2B)
  • Increases in testicular and kidney cancer have been observed in highly exposed humans.

“As for New Zealand, according to the Ministry of Health, a 2013 study found that New Zealanders generally had PFOS levels in their blood that were lower than those found in the blood of people in the USA, Canada, Germany and Australia and PFOA levels were similar or lower.

“In the present investigation, all sites exceeded the maximum threshold and recommended level for recreational water quality. All non-compliant foams were 1-10% above these levels, at exposure levels that could lead to potential health effects. These were unsafe exposure levels.

“However, note that NZ EPA has mandated 100 ppt as an acceptable maximum level of contamination. This level is higher than the United States EPA issued advice on 70 ppt based on environmental health risk assessment

“We would not know long-term effects of exposure without further studies and analyses from these exposed individuals; none of the health effects were acute as that would need exposure to toxic levels of high exposure that does not seem to occur.”

Conflict of interest statement: I do not hold any share or any other interest in any companies that deal with firefighting foams in any form