Per- and Polyfluoroalkyl Substances (PFAS)

Per- and Polyfluoroalkyl Substances (PFAS) are a group of several thousand human-made chemicals that are manufactured for their oil and water-resistant properties. Since the 1940s, PFAS have been used in a wide range of consumer products, industrial processes, and in some fire-fighting foams (called aqueous film-forming foam or AFFF). This has resulted in PFAS being released into the air, water and soil.

State Regulatory Actions
Firefighting Foam
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Background and Sources of PFAS

PFAS are made up of chains of carbon and fluorine linked together. The carbon-fluorine bond is one of the shortest and strongest bonds in nature and does not easily break down under natural conditions. For this reason, PFAS are often referred to as “forever chemicals.”

PFAS are mobile in soil and groundwater. These chemicals have been shown to bioaccumulate, or build up, in blood and organs over time, and may pose risks to human health.

The two most common and best-studied compounds in the PFAS family are perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). Although PFOA and PFOS are no longer manufactured in the United States, they have been replaced with other PFAS alternatives such as hexafluoropropylene oxide dimer acid (used in GenX technology), perfluorobutanesulfonic acid (PFBS), 3-perfluoroheptyl propanoic acid (7:3 FTCA), and n-methyl perfluorooctanesulfonamide (NMeFOSA). PFOA and PFOS are still used in manufacturing in other countries so consumer goods imported to the United States may contain PFOA or PFOS.

PFAS are used in many industrial and consumer processes to make everyday items non-stick, or water-, oil-, or stain-resistant.

Food packaging - fast food containers, lunch meat paper, paper straws, disposable plates and bowls, and oil-, water- and grease-resistant coatings on food packaging^*
Commercial household products - non-stick coated cookware (Teflon), cleaning products, waxes, polishes, and adhesives
Clothing and fabric textiles - stain- and water-resistant carpeting and upholstery, water repellant clothing, tents, umbrellas, shoes, and leather goods
Cosmetics and personal care products - shampoos, conditioners, sunscreens, cosmetics, and dental floss
Building and exterior use products - paints and sealants
Industrial use - metal plating and finishing, wire coatings, automotive fluids, and the manufacture of artificial turf
Firefighting foam - aqueous film-forming foam (AFFF)

^* In February 2024, the U.S. Food and Drug Administration (FDA) announced that grease-proofing agents containing PFAS used on paper and paperboard food packaging are no longer being sold in the U.S. This does not include PFAS as an impurity or environmental contaminant introduced during processing of other chemicals.

Given the presence of PFAS in consumer products, disposal of these items into municipal solid waste landfills may be a significant source of PFAS transport into the environment. In the landfill, PFAS can migrate into the liquid waste (leachate) collection system. Leachate is either treated onsite or taken to a wastewater treatment facility to be treated.

Residential wastewater is also a source of PFAS to municipal wastewater treatment facilities. Clothing and textiles treated with PFAS, and personal care products containing PFAS may release PFAS into water washed down residential drains. Wastewater treatment is not currently designed to remove PFAS, and the use of wastewater biosolids, commonly known as sludge, as agricultural fertilizers may distribute PFAS into the environment, leading to the contamination of air, soil, surface water, and groundwater. Private septic systems also contribute through the leaching of PFAS accumulated in septic wastewater from normal household water use (laundry, bathing, house cleaning, etc.) into the surrounding soil, groundwater, and surface water. When released to surface water, PFAS may bioaccumulate in freshwater fish and waterfowl. Likewise, plants, livestock, and wildlife in areas irrigated with PFAS contaminated water or treated with PFAS containing biosolids may take up PFAS, but the amount of uptake varies depending on many factors. PFAS has been found in milk from dairy cows eating silage grown with biosolids containing PFAS or drinking PFAS-impacted groundwater. Studies have demonstrated fruit and vegetables grown using contaminated biosolids as fertilizer or contaminated water can become contaminated with PFAS, with PFAS then taken into the body when eaten.

The production of PFAS, and its use in manufacturing and industrial processes, contributes to the release of PFAS in air, soil and water. PFAS are used both as raw materials to develop, treat or coat products, and as processing aids used in certain activities such as electroplating where it is necessary to reduce harmful aerosols. The release of PFAS from industrial sources can be from direct waste streams from the facility, fugitive emissions to the air, spills, or from disposal of materials containing PFAS.

Aqueous Film-Forming Foams (AFFF) are Class B commercial firefighting foams historically produced with PFOS or polyfluorinated precursors that break down to PFOA or other PFAS. These foams are used at airports, military installations, petroleum refineries and chemical manufacturing plants for fire and flammable vapor suppression as well as for training purposes. AFFF may also be used during the course of normal firefighting operations by fire departments. They have long shelf lives and despite newer products being available, may still be stored and used at these sites. When used, AFFF has the potential to contaminate soil, groundwater, and surface water. Newer products, referred to as “modern fluorotelomer foams,” are available and are not made with PFOS or PFOA precursors, but rather with other PFAS analytes that contain fewer carbon atoms. These modern foams can breakdown to PFAS compounds that may be less toxic.

Routes of Exposure

PFAS has been measured in indoor air, outdoor air, dust, food, water, and various consumer products. Occupational exposure to PFAS for some individuals, such as those working in PFAS manufacturing facilities, installing or treating carpets, or firefighters using PFAS containing firefighting foams, may be higher than the general public. Potential routes of PFAS exposure include ingestion, dermal, and inhalation. Current scientific literature indicates that most exposure to the general public is through ingestion of food and water.

Ingestion

The general population is primarily exposed to PFAS through the ingestion of contaminated food, water, dust, and hand-to-mouth contact with PFAS treated products, such as carpets and textiles or cosmetics and lotions containing PFAS. Infants and toddlers have higher exposure to PFAS due to having a single source of nutrition (breast-feeding or formula-feeding), by hand-to-mouth transfer due to being in contact with treated carpets and furniture, and have greater indoor dust ingestion. Once swallowed, PFAS can enter the bloodstream due to its ability to bind to blood proteins such as albumin, and typically distributes to the liver, kidneys, and blood.

Food grown in water or soil contaminated with PFAS, and food packaging treated with PFAS can cause PFAS to transfer to food, directly exposing people to PFAS upon consumption. PFAS has the ability to biomagnify through trophic levels meaning that its concentration increases as it moves upward through the food chain. This becomes a concern for humans because of the variety of foods that we eat including plants, fish, livestock and wildlife. Ingestion of PFAS contaminated drinking water, including some bottled waters, may be a primary source of PFAS intake into the body.

Dermal

PFAS chemicals are not easily absorbed through the skin; therefore, dermal exposure is considered a less significant route of exposure for the general population. In individuals with high occupational exposures, this may pose a risk.

Inhalation

Both outdoor and indoor air may contain PFAS. PFAS in outdoor air may be attributed to manufacturing releases. Clothing, textiles, and carpets treated with PFAS may result in higher concentrations of some PFAS in indoor air. Some PFAS are volatile chemicals. Toxicity studies conducted to determine levels at which no adverse effect occurs from the inhalation of PFAS have not yet determined a valid concentration for harmful effects from exposure via inhalation.

Ways to Reduce Exposure

Preventing all exposure to PFAS is not practical due to the widespread historic and current use of PFAS, which are commonly used in consumer products throughout the world. Exposure can be reduced by avoiding or limiting exposure with some products, as follows:

Use non-stick coated cookware according to manufacturer guidelines (not all non-stick coatings contain PFAS).
Use stainless steel or cast-iron cookware in place of non-stick coated items.
Avoid oil and water-resistant food packaging.
Avoid stain resistant coatings on carpet, furniture and clothing.
Avoid water repellants on clothing.
Use personal care products without “PTFE” or “Fluoro” ingredients.
Use water filters designed to remove PFAS.
Dust household surfaces with a damp cloth regularly.

The Food and Drug Administration (FDA) recommends consumers eat a varied, well-balanced diet, noting that results from initial PFAS testing in the general food supply did not support needing to avoid certain foods due to PFAS contamination. More information may be obtained from the Food and Drug Administration.

For Private Water Well Users

PFAS does not have any taste, color or odor in drinking water. The only way to confirm the presence of PFAS is through proper sampling and analysis at a laboratory certified to perform validated PFAS analytical methods. Sample collection should be done carefully to avoid contamination from items such as clothing, food and beverage packaging, and personal hygiene products.

If you have a private water well and are concerned with PFAS in your drinking water, contact the Illinois Department of Public Health (IDPH) for assistance with finding a laboratory. IDPH can also provide a health interpretation of your results and provide treatment recommendations.

A searchable list of accredited laboratories is available through the National Environmental Laboratory Accreditation Conference (NELAC).

Home Water Treatment Options

Household removal of PFAS from drinking water requires the use of products such as granular activated carbon, reverse osmosis (RO), or anion exchange filters. These may be point-of-use treatments installed underneath the kitchen sink or countertop pitcher options that are refilled by the consumer as needed; both options require the filters to be changed at regular intervals. For private water well users who do not receive water from a community water supply, certified whole home treatments may be an option. When choosing a treatment, consider water usage, which faucets are used for water for drinking, cooking and making ice, and the type of PFAS identified through testing. Refrigerators with water and ice dispensers may need to be connected to the treatment source.

Treatment options should be tested by an independent third party to show effectiveness of reducing PFAS. NSF International has a list of filtration systems that have been certified to remove PFOA and PFOS. Products can be certified through NSF Protocol P473, NSF/ANSI Standard 53 (filters), or NSF/ANSI Standard 58 (reverse osmosis) to ensure the uniform testing of treatment filters to effectively reduce and remove PFOA and PFOS. Since other PFAS vary in their chemical makeup, they may not be removed as efficiently.

It is important to follow the manufacturer’s recommendations on how to property maintain and change filters for the type of treatment you choose. Used filter material should be disposed according to manufacturer labels.

The cost of treatment depends on the type of treatment chosen. Initial costs can range from $20 - $1,000 with annual media (filter) replacement costs that can vary.

Bottled Water

The U.S. Food and Drug Administration (FDA) is tasked with regulating food, which includes bottled water; however, the FDA has not yet established standards for PFAS in bottled water. Since 2019, the FDA has been testing for PFAS in limited selections of food and water as part of the Total Diet Study. No detections of PFAS have been found in the limited analysis of carbonated and non-carbonated bottled water.

Consumers who choose to buy and drink bottled water should check to make sure they are obtaining bottled water from a supplier who is testing for PFAS in their water supply, or that bottled water is treated through a process to remove PFAS such as reverse osmosis.

The International Bottled Water Association (IBWA) has established the following limits for their members providing bottled water to consumers:

5 parts per trillion for one PFAS
10 parts per trillion for more than one PFAS

Please note that this group does not represent all bottled water manufacturers. Check the bottled water label for information about reverse osmosis or activated carbon filtration methods as they are the two technologies most commonly used for PFAS removal.

Since U.S. EPA has now finalized MCLs for certain PFAS, the FDA must evaluate the appropriateness of PFAS standards in bottled water as required by Section 410 of the Federal Food, Drug, and Cosmetic Act. More information on the PFAS studies being conducted in food and water by the FDA can be found on the FDA PFAS webpage.

Health Effects

General

PFAS are bioaccumulative, meaning they build up in the body over time. They have long half-lives taking anywhere from several months to several years to be eliminated from the body, depending on the particular PFAS. Exposure to PFAS does not necessarily mean that a person will get sick or experience an adverse health effect. Researchers continue working to fully understand the effects on human health. While research on the effects of PFAS exposure on human health is ongoing, current scientific studies have identified possible adverse health effects such as increased cholesterol levels, increased risk for thyroid disease, low infant birth weights, reduced response to vaccines, liver and kidney toxicity, and pregnancy-induced hypertension.

More information regarding the health effects of PFAS exposure can be found on the Illinois Department of Public Health (IDPH), Agency for Toxic Substances and Disease Registry (ATSDR), and U.S. EPA webpages.

Cancer

Several studies of occupational and community exposure of PFAS have been conducted and continue to be researched. The studies have found increases in the risk of kidney and testicular cancers associated with PFOA, and possible links to testicular, breast, and thyroid cancers associated with PFOS. Studies for other PFAS indicate suggestive evidence of a risk of cancer associated exposure. Laboratory studies in animals also suggest an increased risk of pancreatic, liver and thyroid tumors due to exposure from PFAS. PFOA is classified by the International Agency for Research on Cancer (IARC) as Group 1, carcinogenic to humans, and PFOS is classified by the IARC as Group 2B, possibly carcinogenic to humans. Illinois Environmental Protection Agency evaluates chemicals in both these classifications as carcinogens.

More information regarding studies related to PFOA and PFOS carcinogenicity can be found in the IARC and National Toxicology Program (NTP) publications.

For Pregnant & Nursing Women

PFAS can be transported through umbilical cord blood and breast milk to the unborn fetus and infant child. Given the bioaccumulative nature of these chemicals, it is important to minimize exposure before, during and after pregnancy. Pregnant women and women who plan to become pregnant may consider taking steps to reduce their overall exposure to PFAS, which may include using a household drinking water treatment certified to remove PFAS or an alternative drinking water source that is tested for PFAS if sampling indicates that PFAS is present in your drinking water. This step along with those in the Ways to Reduce PFAS Exposure section may reduce overall exposure to PFAS.

The Center for Disease Control (CDC) recommends nursing mothers continue breastfeeding, noting that the benefits outweigh the risks associated with potential PFAS exposure. More information can be found on the PFAS and Breastfeeding webpage.

For bottle-fed infants, if sampling indicates that PFAS is present in your drinking water, consider using a household drinking water treatment or bottled water that has been filtered using reverse osmosis when preparing formula. Bottled water treatment will typically be found on the bottle label.

For Children

Children are more sensitive than adults to the effects of PFAS and have greater exposure. They tend to drink more water relative to body weight than adults. They have higher exposure to contaminated soils and household dusts from playing outside near the ground and on treated carpets, leading to more ingestion from hand to mouth transfer than adults. Children also do not eliminate chemicals from the body as easily as adults, meaning it will take longer to remove the chemical compared to an adult. In addition to the general health effects listed above, animal studies have indicated that PFAS may be linked to growth, learning, and behavior effects.

For Pets & Other Animals

Although most research has been geared toward human health, pets are also susceptible to the health effects of PFAS through the same routes of exposure. It is important to remember that health-based guidance levels are developed based on the average body weight and water consumption rate of an adult human. Pets tend to weigh less and consume more water on a daily basis than the average adult human; therefore, pets may experience these harmful effects at lower doses. It is recommended to use the same precautions for your pets that you are taking for yourself to reduce exposure. Consult with a veterinarian for any concerns regarding the health effects on pets.

Testing Your Blood for PFAS

Most Americans have been exposed to PFAS due to widespread use of these chemicals. A blood test for PFAS can tell how much of each PFAS is in your blood, but it is not able to tell if that exposure has caused your health condition. Many of the health problems associated with PFAS are also linked to a variety of other factors including lifestyle, genetics, and environment. A PFAS blood test is not a routine test and health insurance may not cover the cost of testing. You may need to contact a private laboratory directly to arrange testing.

If you are concerned about PFAS exposure, we recommend that you first consult with a health care professional for further guidance and to better understand risk factors and potential exposures.

Regulatory Status

U.S. EPA Actions to Investigate and Address PFAS

In recent years, U.S. EPA has taken several actions to investigate and address PFAS.

In July 2021, U.S. EPA began releasing PFAS data collected as part of the updated Toxics Release Inventory (TRI). The inventory program tracks the management of certain toxic chemicals that may pose a threat to human health and the environment, including 180 PFAS chemicals for Reporting Year 2022, 189 PFAS chemicals for Reporting Year 2023, and 196 PFAS chemicals for reporting year 2024. Certain industry sectors must report annually how much of each TRI chemical they have released into the environment through air, water, or land disposal and/or managed through recycling, energy recovery, and treatment.

In October 2021, U.S. EPA released a PFAS Strategic Roadmap, committing to a whole agency approach to address PFAS and safeguard communities from PFAS contamination. As stated in the Roadmap, U.S. EPA will use science-based decisions to develop methods to address PFAS, prevent PFAS from entering the environment, hold polluters accountable, and prioritize the protection of disadvantaged communities.

On December 17, 2021, U.S. EPA finalized the fifth Unregulated Contaminant Monitoring Rule (UCMR). Every five years, the Safe Drinking Water Act requires U.S. EPA to release a new list of unregulated contaminants in drinking water to be monitored in public water systems. U.S. EPA has selected a representative set of public water systems nationwide to test for 29 PFAS analytes in drinking water from 2023 to 2026 as part of UCMR 5. UCMR monitoring provides the occurrence and exposure data necessary to protect public health in future regulatory actions. The results of UCMR 5 sampling, including those from selected Illinois Systems, can be found under the UCMR 5 (2023-2026) Occurrence Data, and are updated by U.S. EPA quarterly. More Information on UCMR 5 can be found on the Program Overview Fact Sheet.

U.S. EPA regulates drinking water standards for more than 90 contaminants by setting Maximum Contaminant Levels (MCLs) for the individual contaminants. MCLs are numeric, legally enforceable drinking water standards set as close as feasible to health-based benchmark levels, using the best available analytical and water treatment technologies while taking into consideration costs for treatment. In April 2024, U.S. EPA finalized MCLs for six PFAS chemicals as part of the National Primary Drinking Water Regulation. U.S. EPA notes that the PFAS MCLs are set at specific concentrations that laboratories nationwide are able to measure with high certainty. The PFAS MCLs evaluate chemicals both individually and as a mixture, since research shows that different PFAS chemicals are often found in together in mixtures and can have additive health effects. Evaluating certain chemicals as part of a mixture is done through the calculation of a hazard index. Public water systems will have three years to complete initial monitoring for PFAS and an additional two years to implement solutions to reduce PFAS if needed.

U.S.EPA PFAS MCLs

Table Source: U.S. EPA Fact Sheet for Small and Rural Water Systems

In September 2022, U.S. EPA proposed to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund. On April 19, 2024, U.S. EPA announced that PFOA and PFOS are now designated as hazardous substances under CERCLA. This designation will help protect human health and the environment by allowing faster response and clean-up of PFAS contamination at the cost of the responsible party. More information on the hazardous substance designation may be found on the U.S. EPA’s Superfund webpage.

In April 2024, Illinois Attorney Kwame Raoul joined 11 other state attorneys general in expressing support of the proposed U.S. EPA rule to include nine PFAS analytes as hazardous substances under the Resource Conservation and Recovery Act (RCRA). The letter to U.S. EPA Administrator Michael S. Regan supports the hazardous substance delegation for the following PFAS:

                1. Perfluorooctanoic acid (PFOA);
                2. Perfluorooctanesulfonic acid (PFOS);
                3. Perfluorobutanesulfonic acid (PFBS);
                4. Hexafluoropropylene oxide-dimer acid (HFPO-DA or GenX);
                5. Perfluorobutanoic acid (PFBA);
                6. Perfluorononanoic acid (PFNA);
                7. Perfluorohexanesulfonic acid (PFHxS);
                8. Perfluorodecanoic acid (PFDA) and
                9. Perfluorohexanoic acid (PFHxA)

The designation of nine PFAS as hazardous substances under RCRA would allow Illinois to require corrective action for those PFAS releases into the air, water, and soil at RCRA Treatment, Storage, and Disposal Facilities.

As the single largest purchaser of products and services in the world, spending more than $650 billion each year, the U.S. federal government is taking steps to help purchasers identify products with reduced or no PFAS in certified products. U.S. EPA has compiled a list of standards and ecolabels that restrict the concentration of PFAS chemicals and fluorinated compounds contained in products such as carpet, cleaners, food service wares, furniture, and many other products. Visit U.S. EPA’s Greener Products and Services page for more information.

State Actions

Community Water Supply Sampling

In 2021, the Illinois Environmental Protection Agency completed a statewide investigation into the prevalence and occurrence of per- and polyfluoroalkyl substances (PFAS) in finished drinking water at all 1,749 community water supplies in Illinois. Illinois EPA provided direct notice to each of the community water supplies, and appreciates the cooperation received from community water supplies as part of this important project. The Illinois EPA continues to work with community water supplies where PFAS chemicals were detected to ensure residents are informed and to determine next steps to reduce exposures.

Groundwater Standard Development

35 Illinois Administrative Code (IAC) 620 establishes various aspects of groundwater quality, including method of classification of groundwater, non-degradation provisions, standards for quality of groundwater, and various procedures and protocols for the management and protection of groundwater. On December 8, 2021, Illinois EPA proposed amendments to the Part 620 regulations. The proposed amendments update toxicity data for various listed chemicals; update exposure factors; introduce groundwater quality standards for six PFAS: perfluorooctanoic acid (PFOA), perfluorooctanesulfonic acid (PFOS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic acid (PFHxS), perfluorobutanesulfonic acid (PFBS), and hexafluoropropylene oxide dimer acid (HFPO-DA or GenX); and update other portions of the regulations. The Illinois Pollution Control Board published its Opinion and First Notice of the proposed rule in the Illinois Register on March 29, 2024. Information on the proposed amendments may be found on the 620 Groundwater Quality page. The Board's Opinion and First Notice may be found here.

Class B Firefighting Foam - PFAS Reduction Act (Public Act 102-0290)

Class-B firefighting foam, Aqueous Film-Forming Foam (AFFF), contains Per- and Polyfluoroalkyl Substances (PFAS), a group of chemical compounds that has been associated with serious environmental and human health hazards. The use of AFFF near well fields or surface water bodies has the potential to contaminate groundwater and thus nearby drinking water supplies. Released into a waterway, AFFF may cause injury to wildlife.

The PFAS Reduction Act (Public Act 102-0290), effective January 1, 2022, regulates the use of Class B firefighting foam to minimize PFAS exposure to humans and reduce PFAS releases to the environment. Illinois EPA and the Office of the State Fire Marshal have jointly developed a fact sheet on Firefighting Foam and PFAS which provides information about firefighting foam, PFAS, and the new law.

As of January 1, 2022, any person, unit of local government, fire department, or State agency that discharges or releases Class B firefighting foam that contains intentionally added PFAS chemicals must notify the Illinois Emergency Management Agency (IEMA) within 48 hours of AFFF discharge or release, including use at an emergency incident. To report a discharge or release to IEMA, call 1-800-782-7860.

Pursuant to the PFAS Reduction Act (Public Act 102-0290), Class B firefighting foam must be properly disposed of within 90 days of the expiration date provided by the manufacturer. When considering disposal options, first consult the manufacturer’s literature on the disposal methods for your specific product. Class B firefighting foam must not be disposed of by flushing, draining, or otherwise discharging the foam into a ditch, waterway, storm drain, or sanitary sewer. Unused or unwanted foam should never be dumped or allowed to leak onto the ground.

In April 2024, U.S. EPA published updated interim guidance on the destruction and disposal of PFAS. Two currently available disposal technologies outlined in U.S. EPA’s interim guidance that may be effective for Class B firefighting foam include (i) landfilling of in permitted hazardous waste (Resource Conservation and Recovery Act [RCRA] Subtitle C) landfills and (ii) underground injection in permitted Class I deep wells. The long-term impacts of these disposal methods are not yet well documented. At present, municipal solid waste landfills are allowed to accept Class B firefighting foam, but may choose not to. Contact a waste disposal contractor to determine the specific options available to you based on your location.

U.S. EPA has also identified thermal treatment options as an available destruction technology. However, the incineration of AFFF containing PFAS is prohibited in Illinois. See 415 ILCS 5/22.62.

Interim storage of Class B firefighting foam that is not yet expired may be a reasonable alternative until destruction and disposal technologies become more available and affordable. Any entity storing Class B firefighting foam must ensure proper controls are in place to prevent releases into the environment, conduct an inventory of foam being stored, and keep strict records regarding all Class B foam.

Illinois EPA will continue to monitor revisions to the federal interim guidance, which U.S. EPA has committed to reviewing at least every three years as new technology and information become available.