PFAS - the Bureaucracy and Hierarchy of Decision-Makers
SEE NO EVIL HEAR NO EVIL SPEAK NO EVIL
vic Epa failing the people
The Victorian government webpage notes how the PFAS coverup is facilitated by the Victorian Environmental Protection Authority (VicEPA) and enabled by federal government guidance frameworks.
Even though the EPA is a science-based regulator they have deliberately chosen not to apply the science!!!
Worst, VicEPA do not even apply current state of knowledge that other international environmental regulators do.
Even though the EPA is a science-based regulator they have deliberately chosen not to apply the science!!!
Worst, VicEPA do not even apply current state of knowledge that other international environmental regulators do.
- To have a regulator that selectively applies the rules is dangerous
- To have a regulator that lies is even worst.
- both cannot be correct when one states virtually no level of PFAS is safe.
- both cannot be right if one has a higher standard than the other.
- both cannot be protective of human and environmental health.
how is epa protecting the people - they're not!
This page is dedicated to who is accountable at the VicEPA and who is not protecting the public from PFAS exposures.
- The CEO (administers the Authority), Chief Environmental Scientist (provides advice to the Authority/Minister and ) and the Governing Board (governance, strategic planning and risk management) are answerable to the Environment Protection Act 2017 as are ALL staff.
- Can we assume, if ALL work to cover for the minister's lack of backbone, that no one is working to protect the people as evident by the following snip.
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Exasperated comments from PFAS impacted farmers when the greatest threat of exposure comes from ingestion of PFAS contaminated food, water, soil and air, “how can we avoid it when we work in the dust every day. It’s our workplace. What do EPA expect - wash our lungs out.”
As for checking ingredients to avoid products containing PFAS, there are no labelling and no disclosures so people don’t know they are being exposed to PFAS when, how and where. While the functions and duties of EPA under PART 12.2 of the Act appear to be arrogantly IGNORED BY ALL maybe section 356(2)(c) could be better utilised by the people,
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red flags to be aware of
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VicEPA are doing a really bad job of covering up the coverup.
The full truth and transparency about PFAS levels in our environment and their forever expanding movement around defence bases, airports, ESSO gas plant in Gippsland, wastewater plant's biosolid stockpiles all over Australia, etc would really stuff up the averages. Keeping the truth from the people is political. Someone in VicEPA is complicit with that decision. |
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No transparency & lack of rights
- Across Victoria, public have no access to industry's nasties for soil, air and water quality testing other than FOI that is also not transparent. E.g. 2022 Investigation by Victorian Ombudsman into VicEPA decisions on West Gate Tunnel Project spoil [PFAS] disposal - We sought to examine whether the EPA had proper regard to the principles set out in its Act –including ‘Accountability’ – and to human rights.
- Conducting contaminant studies would have more credibility if they actually tested highly contaminated areas near industry impacted food producers not creeks long way from industry pollution like Latrobe Valley coal mines and paper mill. E.g Emerging and legacy contaminants across land-use gradients and the risk to aquatic ecosystems. Imagine if they had put resources into some real testing and monitoring of highly exposed areas. As it was PFOS concentrations ranged from below the laboratory limit of reporting (LOR) (<2 ng/L) to 100 ng/L. So where did the PFOS move from and where is the PFOS moving to?
- Health-based guidelines remained unchanged and out of step with international standards. E.g. The EPA and Victoria’s water sector take a proportionate, risk-based approach to understanding and managing potential risks associated with emerging contaminants in recycled water...Emerging contaminants still need to be better understood and are largely unregulated. Aka - farmers can still irrigate with PFAS contaminated recycled water without any disclosures. How are VicEPA getting away with not regulating PFAS for irrigation? Read their webpage on recycled water.
- And this irresponsible comment, There is no consistent evidence that PFAS are harmful to human health, or cause any specific illnesses, even in the case of highly exposed occupational populations.
- This EPA page is a shocker. Apparently it is our fault yet nothing about PFAS labelling, disclosures, removal of PFAS from point source with non-essential uses, better EPA enforcement... The source of the emerging contaminants in wastewater is us – the chemicals, medicines, and products we use travel down the drain and into wastewater treatment plants. EPA’s role is to regulate how businesses and industry use, store and dispose of their waste, but we can all make a difference by reducing our pollution and waste.
- May 2023 EPA Designation – Classification of PFAS-impacted soil used as fill with a total concentration not exceeding 0.004 mg/kg. Yet the opposite for biosolids used for fill and fertilisers for food producing areas and backyard vegie gardens with allowable PFAS content 50mg/kg.
- PFAS and Human Health - Most of us are exposed to low levels of PFAS. This may be from using products that contain PFAS compounds, or from eating food or drinking water with PFAS in it. This is unlikely to be harmful to our health. Recent studies show people's exposure to PFAS in the general environment is reducing. Where is EPA's referenced links to prove this because highly exposed areas are still greatly exposed to long-chain PFAS with more people now exposed to short chain PFAS. This is showing up in pooled blood which VicEPA are very much aware of but clearly not saying this publicly rather condone this comment off Australian PFAS portal - However, not all PFAS have these properties. For example, PFAS with short carbon chains are generally of lower concern than the long chain PFAS like PFOA, PFOS and PFHxS.
- Updated international literature is full of the global ecological crisis of PFASs in drinking water and products gradually shifting from long-chain to short-chain PFASs. E.g. Despite the phase-out of some legacy PFAS due to their environmental persistence and adverse health effects, alternative, short-chain and legacy PFAS mixtures will continue to pollute water and air and adversely influence women’s health and this link In summary short chain PFAS and other alternative PFAS were more potent gene inducers, and potential health effects of replacement PFAS should be critically evaluated in humans.
- VicEPA are just not prepared to protect the people when all studies presented to the public downplay the extent of high PFAS concentrations yet random information can be found in other reports or new articles. Here are just a few examples. To be noted in the following snip that new drinking water thresholds set by the USEPA for PFOA and PFOS is 4.0 parts per trillion (ppt).
- How does drinking water at the Avalon airport become so contaminated when it was a known site for past use of PFAS firefighting foam - A spokesperson for Airservices Australia said the threshold for safe levels for drinking water was 70 ppt, and that levels detected in the tower and station were at 5,800 ppt and 3,080 ppt respectively.
- In 2021 PFOS concentrations in surface water from 19 wetlands in duck hunting locations across Victoria had PFOS concentrations ranged from below the laboratory LOR (<2 ng/L) to 490 ng/L (location near the air base). Toxicant default guideline values for aquatic ecosystem protection PFOS in freshwater Technical brief May 2023
advice already presented to vicepa & acknowledged
Challenged VicEPA on,
- lack of use on current state of knowledge.
- problems with relying on a national PFAS framework that is undermining the seriousness & ongoing extent of PFAS mobilisation and contamination that is not reducing our PFAS exposures rather increasing them.
- defaulting to federal frameworks and quoting FSANZ and acceptance of their connected studies supposedly using updated state of knowledge science while referencing outdated guidelines is testament to deliberate inaction is in conflict to VicEPA quoting the precautionary principles. See FSANZ information page here
- Know that short-chained PFAS has increased in the general population’s blood samples highlighting increasing exposures. While long-chain PFAS has decreased in the same general population, this cannot be said for highly exposed communities.
- The fact dedicated testing of food samples in these areas which supply significant food produce for human consumption is ‘avoided’ due to suspect risk assessments is either-
- with the knowledge of the probability of harm or,
- with a conscious and reckless indifference to the probability of harm.
- If PFAS is increasing in the general population and domestic sewerage then wastewater treatment plants become a risk to the health of our waterways if they cannot reduce PFAS which in turn would reduce many other emerging contaminants.
- EPA is the regulator who allows release of these chemicals from cumulative industries and are responsible for poor river health.
- EPA are condoning poor risk assessment/hazards in the wastewater industry due to outdated guidelines with EPA the go-to authority for all human health.
- Dilution is not a solution to pollution
- How to address the point source of PFAS getting into domestic sewerage wastewater treatment cycle?
- How EPA reviews recycling, reuse and the GED to manage the risks?
- Would EPA be non-compliant with their own Act and could this be tested in court of law.
- What is the duty of the suppliers of recycled water to test the chemistry of the end product and to the suitability?
- What declaration should they make, legal disclosures, disclaimers to the receivers of the product chemistry (including fertilisers) in the event the recycled water contaminates land and water outside of their management/ownership.
- VicEPA to give priority to identifying all sources emerging contaminants that are contributing to increased exposures of PFAS impacting the health of our waterways and those communities that use them.
- VicEPA challenge the Commonwealth for their lack of responsible PFAS management and lead on updating guidelines to reduce industry impacts on surface and groundwater.
- review discharge licence conditions to waterways, identifying chemicals in use and how much each licence is allowed to be discharged into waterways.
- become stronger enforcers of facilities dumping pharmaceuticals into stormwater & sewerage system.
- give public access to the types of chemicals that industry is licenced to discharge into waterways.
- prevent wastewater being injected into groundwater.
- industry get-out clause, ‘as far as reasonably practicable’, be reassessed in decision-making in relation to human rights charter and full cost analysis to human health and environment.
- VicEPA must become a stronger regulator and protector of the people and our environment that we all interact with.
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This page last updated 17 October 2023
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