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Section 3

How Businesses Can Identify and Manage PFAS Risk

From Exposure Pathways to Sampling Best Practices

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Section 3

How Businesses Can Identify and Manage PFAS Risk: From Exposure Pathways to Sampling Best Practices

Why Every Business Needs a PFAS Risk Assessment Strategy

Per- and polyfluoroalkyl substances (PFAS) are everywhere — in the air, soil, water, and even the supply chains that power global industries. Known as “forever chemicals” because of their resistance to breakdown, PFAS are found in thousands of products such as non-stick cookware, food packaging, firefighting foams, textiles, and coatings.

While these compounds offer useful properties like water and heat resistance, they also accumulate in the human body and the environment, creating long-term health and ecological risks. Growing global awareness has sparked a surge in regulations, lawsuits, and cleanup initiatives.

Yet, many organisations still underestimate their exposure, assuming PFAS risks are limited to heavy industry or chemical manufacturing. The truth is, PFAS contamination can touch any business — from the materials it sources to the land it owns or operates.

Proactive risk identification and investigation are no longer optional. They are now essential steps in protecting business reputation, ensuring compliance, and maintaining long-term value.

Understanding Global PFAS Regulatory Expectations

The global regulatory landscape for PFAS is tightening fast. The United States, European Union, Australia, and other regions are imposing strict limits and expanding the list of regulated PFAS compounds.

In the EU, the REACH regulation proposal seeks to ban thousands of PFAS uses, with only a few temporary exemptions for critical industries.
Australia’s PFAS National Environmental Management Plan (NEMP 3.0) provides consistent national guidance for investigating, assessing, and managing PFAS risks across air, soil, and water.
Many individual states and countries now enforce bans on PFAS in firefighting foams, textiles, and food contact materials.

For multinational organisations, this means PFAS compliance must be managed across jurisdictions with differing rules, making due diligence a cornerstone of corporate environmental governance.

Key PFAS Risk Pathways Businesses Must Evaluate

Understanding where PFAS risks exist helps businesses prioritise investigation and mitigation efforts. According to environmental experts, PFAS risks fall into four main categories:

1. Operational and Asset Risk

PFAS may exist at your facilities due to historical industrial activity or the use of PFAS-containing materials such as aqueous film-forming foam (AFFF), coatings, or sealants. These legacy contaminants can lead to expensive remediation, loss of property value, and regulatory liabilities.

2. Supply Chain and Product Risk

PFAS often enter through raw materials, parts, or packaging supplied by vendors. Products containing PFAS can expose companies to compliance violations, recalls, and reputational damage, especially as more jurisdictions adopt product bans.

3. Investment Risk

Investors and holding companies may inherit PFAS liabilities through acquired assets or portfolio companies. Assessing PFAS risk is now a key part of ESG (Environmental, Social, and Governance) due diligence.

4. Reputational and Financial Risk

Public and investor scrutiny of PFAS is rising. Links to contamination can trigger lawsuits, regulatory penalties, and lasting brand damage. Being proactive and transparent in PFAS management builds trust and investor confidence.

How to Begin a PFAS Risk Investigation

Step 1: Assess Properties and Assets

Start by reviewing all owned and leased properties:

Examine historical site records, aerial photos, and environmental reports.
Identify past site uses such as manufacturing, firefighting training, or chemical storage.
Review Phase I/II Environmental Site Assessments (ESAs) for hints of potential PFAS activity.

Even if a property is decades old, historical contamination can persist and remain your responsibility today.

Step 2: Examine Products and Supply Chains

Audit your products and sourcing network:

Check Safety Data Sheets (SDSs) and technical specifications for PFAS ingredients.
Contact suppliers directly to confirm whether PFAS are present in raw materials or components.
Begin with Tier 1 suppliers and expand deeper into your supply chain.

Step 3: Screen Investments

Use environmental data tools and ESG analytics to flag high-risk sectors such as aerospace, textiles, firefighting, packaging, and waste management. Assess whether existing portfolio assets are subject to PFAS liability.

Step 4: Review Internal Operations

Evaluate your own processes and maintenance activities for potential PFAS use — from lubricants and gaskets to cleaning agents and coatings. Engage long-term employees to uncover legacy practices that may have gone undocumented.

Industries Most at Risk from PFAS Exposure

Some sectors have a higher likelihood of PFAS contamination due to historical use or production processes. If your company operates in, supplies to, or owns land previously used for these industries, your risk is elevated:

Aerospace and Defense (firefighting foams, coatings)
Chemical Manufacturing (PFAS production and polymerisation)
Metal Finishing and Plating
Textiles and Apparel (stain- and water-repellent treatments)
Paper and Food Packaging
Plastics and Non-Stick Coatings
Automotive and Electronics Manufacturing
Construction and Infrastructure
Waste Management and Landfills
Firefighting and Emergency Response Facilities
Data Centres and Semiconductor Fabrication
Aviation and Transport

Tools and Resources for PFAS Investigation

A comprehensive PFAS risk review requires coordination across departments and often external expertise. Here’s what you’ll need:

Internal Team: Include representatives from EHS, operations, legal, procurement, and R&D.
Historical Data Access: Gather site histories, permits, and environmental reports.
External Consultants: Engage PFAS specialists for sampling, analytical interpretation, and regulatory advice.
GIS Mapping Tools: Overlay your assets with known contamination sites for spatial risk visualization.
Supplier Questionnaires: Collect PFAS use disclosures to increase transparency.

Digital tools such as chemical screening databases and PFAS inventory platforms can further streamline large-scale investigations.

From Assessment to Action: Building a PFAS Risk Management Framework

Once your investigation is complete, the findings should guide a structured PFAS management plan. This typically involves:

Prioritising High-Risk Sites or Products for deeper assessment or testing.
Conducting Targeted Sampling of soil, groundwater, or materials.
Developing Mitigation Strategies to eliminate PFAS use or control exposure.
Engaging Stakeholders — from regulators to customers — with transparent communication.
Implementing PFAS-Free Alternatives where feasible to reduce long-term liabilities.

Proactive management doesn’t just prevent regulatory penalties — it can position your company as a leader in sustainability and compliance.

Sampling and Measurement: The Backbone of PFAS Management

Accurate data is the foundation of effective PFAS remediation. Sampling and analysis are challenging because PFAS are present at trace levels and can easily contaminate samples during collection.

Key Considerations for PFAS Sampling

PFAS can have multiple sources at a single site, requiring comprehensive planning.
Concentrations can vary dramatically across small distances.
Sampling materials must be PFAS-free — avoid fluoropolymer containers, Teflon-coated tools, and certain waterproof clothing.
Use low-flow sampling techniques (0.1–0.2 L/min) to prevent turbulence and ensure representative results.
Implement strict field quality assurance/quality control (QA/QC) procedures, including trip blanks and field blanks, to detect background contamination.
Maintain samples on ice and within regulatory temperature limits to preserve integrity.

Analytical Measurement Methods

As PFAS testing expands from PFOS and PFOA to thousands of related compounds, labs rely on a mix of analytical techniques. Each method balances selectivity (accuracy) and comprehensiveness (breadth):

Targeted LC-MS/MS (Liquid Chromatography–Mass Spectrometry) for precise quantification of known PFAS.
Total Oxidizable Precursor (TOP) Assay to estimate total PFAS potential by oxidizing precursors.
Extractable Organic Fluorine (EOF) or Total Organic Fluorine (TOF) analysis for overall PFAS mass in samples.

No single method captures all PFAS compounds, so multiple approaches are often combined for a full picture.

Building a Future-Ready PFAS Response Plan

PFAS management requires ongoing vigilance. As science advances and new compounds are identified, regulatory limits will continue to tighten.

By integrating risk identification, accurate sampling, and proactive communication, companies can not only comply with global regulations but also strengthen their brand reputation and investor confidence.

The key takeaway:

“You can’t manage what you haven’t measured.” PFAS risk management begins with investigation — and ends with informed, transparent action.

Updated: 1 December 2025