PFAS Investigations: What Property Owners and Developers Need to Know

PFAS Investigations for Property Owners & Developers

Per- and polyfluoroalkyl substances, commonly known as PFAS, have become an increasingly important consideration in contaminated land investigations across Australia.

For property owners and developers, potential PFAS contamination can affect more than a site’s environmental condition. It may influence property transactions, development approvals, construction programs, waste disposal options and overall project costs.

Understanding the potential risks early can help stakeholders make informed decisions and reduce the likelihood of unexpected costs and project delays.

What are PFAS?

PFAS are a broad group of manufactured chemicals that have historically been used because of their resistance to heat, water, grease and stains. They have been found in products including firefighting foams, industrial coatings, textiles and other commercial applications.

These chemicals can remain in the environment for extended periods and may move through soil, surface water and groundwater. As a result, PFAS contamination may extend beyond the original source area or property boundary.

The presence of PFAS does not automatically mean that a site presents an unacceptable risk. By gaining an understanding of the extent of contamination, potential exposure pathways, risks can be understood and managed.

Which properties may be at greater risk?

PFAS contamination is often associated with sites where PFAS-containing firefighting foams were historically stored, handled or used. Other higher-risk locations may include:

  • Airports and aviation facilities
  • Defence properties
  • Fire training grounds and emergency service facilities
  • Industrial and manufacturing sites
  • Fuel storage and processing facilities
  • Landfills and waste management facilities
  • Wastewater treatment sites

Historical incidents may also be relevant when assessing PFAS risk. Recent Australian research into two historical petrol tanker fires found that PFAS contamination associated with firefighting foam remained undetected for more than two decades following the original incidents. This highlights the importance of considering not only a site’s routine operations, but also historical accidents, emergency responses and other one-off events that may have involved PFAS-containing firefighting foams. 

There are typically low levels of PFAS contamination in inner urban industrial area soils.  This can occur by being a neighbouring property where PFAS has been used and the PFAS has migrated via aerosols, groundwater, surface water, drainage systems or the transport or relocation of contaminated soil.

A property does not necessarily need to have directly used PFAS for an investigation to be appropriate. Its location, surrounding land uses and historical activities may also need to be considered.

Why PFAS matters during property transactions and development

Undetected PFAS contamination can create significant commercial and operational challenges.

During a property transaction, potential contamination may affect environmental due diligence, contractual negotiations, financing arrangements and asset value. For development projects, PFAS can influence planning conditions, excavation strategies, dewatering, soil classification, off-site disposal and environmental management requirements.

Contaminated land can also limit how a property is used or increase development costs. Identifying PFAS risks after construction or excavation has begun may result in project delays, additional testing and unplanned management expenses.

What does a PFAS investigation involve?

A PFAS investigation will generally begin with a review of the site’s history and surrounding land uses. This may form part of a preliminary site investigation, pre-purchase environmental due diligence assessment or broader development planning process.

Where a potential source or contamination pathway is identified, further work may include:

  • Developing a conceptual site model that shows where the PFAS is located in, such as soils, sediment groundwater.  The potential migration pathways and how people, and ecosystems maybe be exposed to the PFAS
  • Preparing a targeted sampling and analysis plan to confirm the extent of contamination
  • Collecting soil, groundwater, surface water or sediment samples
  • Assessing potential human health and environmental risks
  • Recommending management, remediation or monitoring measures

The scope of the investigation should reflect the site conditions, proposed land use and relevant regulatory requirements.

An evolving regulatory environment

Australia’s PFAS National Environmental Management Plan provides nationally consistent guidance for assessing and managing PFAS contamination. The guidance has continued to evolve as scientific understanding, investigation criteria and management approaches are updated.

Property owners and developers should also consider the requirements of the relevant state or territory environmental regulator, planning authority and waste disposal framework.

Managing PFAS risk early

Early PFAS risk assessment can provide greater certainty when purchasing, selling, redeveloping or managing land. It allows potential issues to be incorporated into project planning, approvals, budgets and construction methodologies before they become more difficult or costly to address.

Agon Environmental supports property owners, developers and project teams with contaminated land assessments, environmental due diligence and targeted PFAS investigations. By identifying potential risks early and providing practical, risk-based advice, Agon helps clients understand the implications for their site and make informed decisions about appropriate next steps. 

If you are purchasing, developing or managing a property that may be affected by PFAS, contact Agon Environmental to discuss an appropriate, risk-based investigation strategy.