The problem here is the disconnect between science and law.
Risk management and knowingly exposing PFAS communities to elevated levels of PFAS
is totally different to deliberately focus on the general population.
Both have different roles.
One is to establish causation via evidence.
The other is to manage risk to people via a duty of care and statutory obligations.

PFAS - food safety CON

"You are producers, we'll just set the levels [PFAS] and you will be right for ever and a day. It will always be safe", stated a well-known toxicologist at a very public Queensland meeting to impacted farmers fearful about their livelihood and ability to sell their livestock at market. It is very concerning that PFAS levels have remained irresponsibly higher than other countries. But to state the levels can be manipulated to suit a desired outcome reveals our food safety laws are open to abuse. Further reading puts the integrity of Food Standards Australia New Zealand (FSANZ) in question and whether political influence is infiltrating our food standards codes? 
UPDATE March 2025 - My PFAS Inquiry submission finally uploaded after Committee review on controversial comments I made about FSANZ & their response. 
Go to Submissions page to see my feedback to drinking water regulations and PFAS Inquiry
UPDATE October 2024 - Australia is finally updating drinking water guidelines and PFAS fact sheets. Opportunity to provide feedback here. Unfortunately what's proposed is underwhelming.
See PFAS Drinking water webpage. 
​PFOA - carcinogen or not?

australia's position on pfas

February 2024, enHealth releases it most updated health PFAS guidance factsheet.
It is using the same 27th FSANZ diet study, a non-credible ANU health study and outdated drinking water guidelines continuing the same coverup from 2019 with PFAS lifetime exposure levels unchanged since 2017.
See the FOI 4238 release exposing reviewing & 'tweaking' of the ANU Health Study by departments to best represent a desired outcome for the Australian Government. Pages 13 & 14 are enlightening.
​It appears FSANZ only just assessed PFAS in food and water since 2021, with enHealth providing the health advice establishing an Expert Health Panel to advise the Australian Government in 2017.
Previous to this toxicologists set the TDIs from toxicology studies on the express objective to limit the amount of PFAS exposures from what you eat and drink. That is what we were led to believe.
However, The Saturday Paper exposed this conflict of interest where 'consultants paid millions by Defence helped revise chemical safety standards that could shield the department from multiple compensation claims. The April 5 workshop set “tolerable daily intake” levels for both chemicals at 75 times higher than acceptable limits in the United States. Safe drinking water limits were set at more than 78 times the US level. At the workshop were Golder Associates, a global environmental consultancy; Newcastle-based CRC Care, part owned by the Defence Department; and the Melbourne company ToxConsult.'
ToxConsult were also engaged by ESSO with the Gippsland PFAS scandal in Victoria at their Longford Gas plant where ESSO breached their EPA discharge licence causing PFAS contamination to vast areas around their onshore site.
The article from 2016 was damning and rightly so stating - ​
The relaxed guidelines could help defence reduce potential legal liability for contamination and clean-up costs, lawyers say. This is a serious issue for the Defence Department.
​I challenged the FSANZ Board on 20 February 2023 giving them an opportunity to reset their inexcusable position stance on PFAS. Their quick response, 2 March 2023, is the evidence of their updated position - dangerous and irresponsible when we know that state and federal governments are not collating any evidence that would warrant updating.
Read the following complaint letter sent to the FSANZ Board challenging lack of protections for human health and their response on 9 March 2023.
The FSANZ response noted their own 2021 review of the Immunomodulation potential of PFAS peer reviewed by an unknown external expert in epidemiology to back up their inaction.
A new and far more credible review, 'Consideration of pathways for immunotoxicity of per- and polyfluoroalkyl substances (PFAS)' was available on 22 February 2023 being the most updated health information for immune effects which highlights FSANZ's attempt to undermine the small number of health studies as petty.
I have been privileged to elicit a further counter response from FSANZ challenging my claims to the PFAS Inquiry.

why is fsanz on the nose?

FSANZ develops food standards and sets Tolerable Daily Intake (TDIs) for chemicals and PFAS in foods and beverages common to the Australian diet to ensure no deceptive conduct and that food purchased is safe to consume. 
In developing standards, FSANZ also needs to genuinely consider other matters including:
  • ensuring our standards are based on risk analysis using the best available scientific evidence
  • promoting consistency between domestic and international food standards​
CoM challenges:
  • the 'dietary modelling' techniques used for PFAS are not credible
  • known health-based guidance value are not based on updated peer reviewed international science rather using Australian 'experts' to discredit studies
  • ability of FSANZ to reduce the level of risk to the ENTIRE population from increasing PFAS exposure​
TDIs are also used as an apparent safe end point for human risk assessment triggers in the absence of evidence PFAS is safe.
The accompanying technical documents for the 27th Australian Total Diet Study PFAS substances reveals:
  • ​the study is useless for heavily exposed individuals wanting to know targeted information about the food and water sourced in their local regional area. There are no studies so huge data gaps.
  • it is just a collation of statistics using means and average analysis for the general population which says more about diluting facts on PFAS.
​Our Australian TDIs are not based on up-to-date science, ignoring legacy PFAS which is expanding because FSANZ says PFAS in the general diet is low.
​The trickle-down effect then allows other agencies to use FSANZ TDIs as a default position so PFAS contaminated livestock and food produce using PFAS contaminated water or feed stock can be sold or determined is safe to consume which would be way above international levels.
All the while the individual is being deceived and misled about what they are consuming.
​Agriculture Victoria continues the best example of PFAS misinformation dished out by a government entity.
​​This has implications for Australia export trade for red meat, eggs and derived products.  ​
As of March 2025, Australia is still not proposing any changes, any new rules for labelling, new updates for wastewater treatment or how to reduce PFAS at the source origin.

How does Australia compare to EU & USA?

There are cattle raised for human consumption all around Australia in areas contaminated by Defence, ESSO, CFA, Waste Water Treatment Plants and numerous industries that government are doing nothing about yet the PFAS plumes are expanding, some rapidly. Worst is government undermining the extent of PFAS hotspots.
Our food safety laws are compromised along with the bureaucrats and self interest entities facilitating the coverup
Just to confuse with another unit of measure, a Department of Health representative in NSW gave a figure to a farmer that 19 nanograms per millilitre of blood (19ng/mL =19ppb =19000ppt) is what they model for livestock  which equated to the farmer being told not to eat any more than 200grams of his own beef per month because his cattle's PFAS blood levels were around 180ng/mL (180,000ppt) to 390ng/mL (390,000ppt) just for PFOS so the sum total was over 500,000ppt.
Read the story here, Exclusive: Beef stock raised near RAAF base contaminated from toxic foam
The farmer was told you can ON-SELL for some other person to consume.
That one piece of beef over the month does not account for all the other exposures of PFAS from drinking water, other food products, PFAS residues from unlabelled household and personal consumer products through to ingesting the dust the farmer works in. 
These figures are way too high but important to note this is the only time a measurable figure has been noted.
As a comparison -
The EU have amended their Maximum Residue Limits (MRL) of PFAS in certain foodstuffs.
The food commodities lists with MRL can be found here which have been set to ensure a high level of human health protection from imports.
Australia need to ensure red meat exports are below these levels but continue not to declare MRLs.
As an example,
  • Meat of bovine animals, pigs and poultry alone, the EU's MRL for the sum of PFOS, PFOA, PFNA and PFHxS is 1.3μg/kg (1.3ppb =1300ppt), sheep is 1600ppt.
  • Maine in USA, which is known for its dairy farms has set MRL for beef of 3.4 ng/g (3.4ppb =3400ppt)
We know of cattle in Australia with PFAS blood serum levels around 1500ng/ml (1,500,000ppt) which the Australian Government, by virtue of sale yards and abattoirs, National Vendor declaration has declared is fit for human consumption by its inaction.

​Tracking PFAS contaminated food

Our health is the sum of food and water we consume but without disclosures or origins we don't know what we are feeding our families. For the general population, the main route of exposure to PFAS is through food and the consumption of contaminated drinking water. 
*Note Blue Mountains PFAS contaminated drinking water. For the population in PFAS hotspots, exposure increases.
CoM provided a submission ​into the 2018 Inquiry into the management of per- and polyfluoroalkyl substances (PFAS) contamination in and around Defence bases. Shocking that a federal inquiry on PFAS was limited to defence sites for two reasons:
  1. media-based stories centred around Defence sites only rather than other industry PFAS contamination sources
  2. complicates how the rest of Australia with state based regulatory frameworks could respond and coordinate management between agencies of the Commonwealth Government. 
That inquiry goes to the heart of major livestock authorities burying their heads in the contaminated dirt, namely Dept of Foreign Affairs & Trade, SafeMeat, Meat & Livestock Australia, Dairy Australia, insurance liability and Occupational Health & Safety. 
CoM did get a quote noted in the final report with subsections noted on this webpage link.​
  • 6.10  Tracey Anton [CoM], of the Latrobe Valley in Victoria, similarly raised concerns that either the Government was allowing PFAS contaminated agricultural produce to be exported, or it was being distributed in the domestic market while ‘denying a person a right to choose between contaminated and non-contaminated foodstuff’.
  • 6.11 The Victorian Government submitted that a ‘lack of nationally regulated maximum levels for PFAS in foods complicates the provision of defensible advice to agriculture producers, including livestock producers and meat processors’. However, it noted that the health-based guidance values developed by Food Standards Australia New Zealand had provided some clarity and consistency across jurisdictions.​  
What we are left with are Australian toxicologists and state agricultural Chief Veterinarians providing outcomes why contaminated livestock can be sold at market for human consumption in conflict with Food Acts.
​This issue is also dealt with on the PFAS Livestock page.

​what is acceptable

Chemicals are the hazards to human health but the risk is the probability of harm. You can't have zero risk as every chemical presents a risk starting at negligible risk.
As an example,
  • sugar presents a negligible risk to human health.
Polluters like ESSO and Government pay consultants  and research universities to conduct health studies in major contaminated areas concluding:
  • PFOS/PFOA contamination presents a low risk to humans.
Whereas, science from other countries has already declared: 
  • PFOS/PFOA presents an unacceptable risk to human health.
Hazard vs Risk
The more exposure the greater the risk therefore companies like ESSO and government, including state EPAs are being deliberately deceptive!!!

Why Victoria is noteworthy

​​Victoria had the Fiskville Inquiry in 2015 where a lot was exposed to uncover what should be happening with our food safety but isn't.
What happened in this inquiry is entirely relevant to other sites around Victoria and Australia.
There is an established hierarchy of responsibility overseeing heavily PFAS contaminated sites from state based EPA appointed auditors, consultant companies conducting human health assessments, toxicologists, etc., to determine the risks to the person, environment and a business.  A toxicologist can't look at evidence without understanding the latest research so when overseas countries says it's a problem and their TDIs are so much lower, how can Victoria, Queensland, NSW and others say it is not a problem here and rate risk as low potentially allowing polluters to be absolved from liability and compensation?
State of knowledge if applied responsibly is powerful. Pleading ignorance in court just won't cut it.  

who is pulling the strings of our food safety code

​​If you are buying a product that the relevant state and territory Food Act is saying is safe to eat - then it should be backed up by the Federal Food Safety Code. To note, these codes and Acts are the law of the land and are in place for a reason and what the Australian Government should be complying with but is not.​
Victorian FOOD ACT 1994 - SECT 4E - Meaning of unsuitable food:
 (1)     For the purposes of this Act, food is unsuitable if it is food that--
   (d)     contains a biological or chemical agent, or other matter or substance, that is foreign to the nature of the food.
 (2)     However, food is not unsuitable for the purposes of this Act merely because--
   (d)     it contains any matter or substance that is permitted by the Food Standards Code.
​I am not aware of any part of the Food Safety Code that states one, or any number of PFAS compounds, are permitted by the Food Safety Code in any food group therefore the levels of any PFAS compound for consumption should be ZERO.
This is backed up with transcripts from the 2015 Fiskville Inquiry when Dr Brendan Tatham from PrimeSafe was asked the following questions.
This PrimeSafe transcript from the Fiskville Inquiry needs to be read in total (8 pages- 70KB) to highlight mismanagement at the highest level.
The CHAIR—Are you aware if there are any standards in respect of perfluorinated chemicals such as PFOS or PFOA?
  • Dr TATHAM—The standards which PrimeSafe utilises and makes codes under the Meat Industry Act, the two which are relevant here are 4696, an Australian standard for the hygienic production of meat for human consumption, and then the food standards code. Under the food standards code there is a list of maximum residue limits for a range of chemicals. They are listed within the food standards code. The technical detail is described in my statement. PFOS is not one of the chemicals listed in the food standards code, which means that in order for compliance to be demonstrated by an abattoir for the food standards code, there should be zero or at the not detectable limit for that chemical, if it is not listed as an MRL in the food standards code.
The CHAIR—So if it is not listed in the standard, then it should not be present?
  • Dr TATHAM--Correct.
The CHAIR—Just on that, the food standards code says that these are the things that can be in livestock and at these levels, if they are going to be consumed by humans, and PFOS is not one of them and therefore it should not be in the livestock. In this case, PrimeSafe is aware that there is PFOS in these animals but it takes no action even though it should not be there. It seems a bit of a contradiction in responsibilities or legislation.
  • Dr TATHAM—I understand the issue that you have identified. When non-compliance is suspected or detected with regard to issues of public health, PrimeSafe seeks advice from the chief health officer around: is there a public health risk, and therefore should PrimeSafe put in place any regulatory action which is over and above what the standards require? So in a way the standards are just looking after what happens on a day-to-day basis and if an issue—--
The CHAIR—So do you know why this chemical is not on the food standards schedule or the code?
  • Dr TATHAM—No, I do not know the answer to that question. I would have thought that given that there is now data being produced around the chemical and that is an increasing amount of data over time, that it might be something that the food standards code and the national agency that sets those limits would be wanting to consider.
Mr RICHARDSON—Following on from that, why then is it not listed on the standards?
  • Dr TATHAM—Again, I cannot answer that question. The standards are controlled by FSANZ, Food Standards Australia New Zealand. It is a commonwealth body, and is informed by science and risk assessment people at the national level.
 > all paths lead back to FSANZ