Skip navigation

PFAS Pollution of Food Growing Areas to Continue Under National Environment Management Plan

PFAS (Perfluoroalkyl and Polyfluoroalkyl substances) are synthetic fluorine chemical compounds that are toxic at parts per trillion (one thousandth of a drop of water in an Olympic sized swimming pool)!!! They are arguably the most controversial toxic chemical of our era. Since 'muted alarm bells' alerted people about these chemicals in Australia two decades ago, a plethora of contaminated sites have now been found. PFAS, which is actually an umbrella term for 4000 chemical types, have literally contaminated every person on the planet and have even been detected in rain, ensuring that nowhere is 'untouched' by these chemicals.

PFAS accumulates both in the environment, animals and people. It has been linked to increased risk of kidney, prostate and testicular cancer, thyroid problems, changes in liver enzymes, interference with the body's natural hormones, increased cholesterol levels, reductions in birth weights, increased risk of high blood pressure in pregnant women and developmental delays in children. The sad story sounds similar to the issue of widespread organochlorine pesticide contamination 60 years ago, which helped 'kick-start' the modern day environment movement through the publication of Silent Spring by Rachel Carson. For some reason however, probably because of the enormity (and complexity) of the problem, the PFAS issue has not cut through with the majority of the mainstream public ... yet.

The Department of Agriculture, Fisheries and Forestry are currently taking submissions in regard to the National Environmental Management Plan on PFAS.

Photo: Bushfire at Linton 1998 in what appears to be a pine plantation. This site is probably a contaminated site through the use of Fire Fighting Foam. Fertilisers sourced from biosolids are another source of PFAS contamination in tree plantations. Fire Fighting Foam and contamination from airports has received the most media attention in terms of PFAS contamination in Australia, however media has been reluctant to look at PFAS pollution from the water industry.  Source: Australian PFAS Map


PFAS have been used by industry since the 1940's. Almost sixty years later the US EPA and PFOS manufacturer 3M agreed on May 16 2000, to phase out and find substitutes for PFOS due to its persistence in the environment and its tendency to accumulate in human and animal tissue. The Australian Government's National Industrial Chemicals Notification and Assessment Scheme (NICNAS), published 6 PFAS alerts between 2002 and 2008 including a phaseout of PFAS chemicals in a number of applications including fire fighting foam. The phase out included longer chain PFAS chemicals, to be replaced with the less persistent short chain PFAS types.

However these events did little to stem PFAS pollution events, particularly when other arms of Government suppressed PFAS information.

For instance, in 2003, the Royal Australian Air Force knew about PFAS pollution at Williamtown airbase in NSW, but didn't test for PFAS until 2011 with results released to the local water authority and local council only confidentially in 2012.

As a result of media coverage starting around 2016 regarding pollution and health impacts of PFAS contaminated fire foams and pollution downstream of military bases, Government's around Australia attempted to 'publicly manage' the PFAS issue, which actually had been occurring 'unmanaged and unmonitored' for decades. Two examples, from hundreds of incidents, include contamination of Katherine's drinking water and the West Lakes issue in Adelaide.

The horse had already well and truly bolted by the time the Australian Government published "Per-and Poly-fluroalkyl Substances (PFAS) Information Sharing, Communication and Engagement Guidelines" in 2017. Between 2015-2019, NICNAS also conducted 18 assessments on PFAS chemicals and precursors with no bans implemented. The South Australian Government was actually the first Australian Government to ban PFAS chemicals in fire fighting foams in January 2018, followed by NSW in 2021 (except in fighting catastrophic fires or where there are special exemptions).

In 2004 Australia ratified and became a party to the Stockholm Convention on Persistent Organic Pollutants.  One the most toxic and long lasting of the 4000 types of PFAS chemicals, PFOS, its salts and PFOS-related chemicals were listed on Annex B (restriction) of the Stockholm Convention in 2009. Public consultation was undertaken by the Australian Government in late 2017 on the Regulation Impact Statement of options for the national phase-out of PFOS in the context of the Stockholm Convention. PFOA, its salts and PFOA-related chemicals were listed in 2019, while PFHxS, its salts and PFHxS related chemicals were listed in 2022. PFOS, PFOA and PFHxS however, represent ~0.075% of PFAS chemical types.

Some types of food packaging have also been found to contain high levels of PFAS. (Photo Credit: Consumer Reports). The insidious nature of PFAS chemicals means that they are in a host of 'seemingly innocent' consumer items including fast food wrappers, non-stick cooking wares, carpets, scotch-guard, dental floss and a host of other items. The NEMP does not address current use issues of products containing PFAS.

The NEMP Version 3

The latest attempt by Federal and State Environmental Protection Agencies has been published in the National Environment Management Plan (NEMP). (The first NEMP was published in 2018). The NEMP provides a framework for environmental regulation of PFAS materials and sites and is agreed to by the Heads of EPA Australia and New Zealand (HEPA).

"The PFAS National Environmental Management Plan (NEMP) provides nationally agreed guidance on the management of PFAS contamination in the environment, including prevention of the spread of contamination."

One of its key weaknesses is that it only addresses three types of PFAS chemicals, namely PFOS, PFOA and PFHxS, which are those also listed in the Stockholm Convention. For Australia to be compliant with its international obligations under the Stockholm Convention, PFAS management measures need to be fulfilled with international management standards being implemented. Whilst these three types of PFAS chemicals have been most problematic in terms of persistence, another 4000 PFAS chemicals are not specifically included under the NEMP, or under the Stockholm Convention.

The NEMP also does not address problems current issues relating to current use and management of PFAS containing products, instead suggesting that these issues will perhaps be done by other national (and state?) jurisdictions.

The third version of the NEPM allows for water authorities to continue to sell contaminated biosolids/soil enhancers to farms and other land owners across the country. Biosolids are a big industry and it would appear that the decades old argument promoting the reuse of biosolids, conveniently avoided the issue of PFAS contamination in the biosolids until recently. Whoops!

“Biosolids, commonly known as treated or stabilised sewage sludge, are produced during the biological treatment of sewage. Biosolids contain significant quantities of organic matter, moisture, nutrients and trace elements, and as such are increasingly being viewed as a resource for agricultural and municipal sectors.” EPA Victoria 2004

In 2022 Friends of the Earth researched PFAS levels in biosolids from Victorian waste water treatment plants. Almost all biosolid samples contained PFAS.  <400,000 tonnes of biosolids are produced in Australia each year, with about 280,000 tonnes applied to farmland. In Australia, about 83% of biosolids were used in 2021, down from 91% in 2019 and 94% in 2017. This change is due to the increase stockpiling of biosolids, particularly in Victoria (13% stockpiled in 2021 compared with 5% in 2019).

The NEPM is suggesting PFAS guidelines of 3 criteria categories with three types of safety margins of 5, 2 and 1. The ranges are from 0.22μg/kg to 31μg/kg for PFOS+PFHxS and 1 to 130μg/kg for PFOA. The current Victorian EPA soil guideline is the sum of 0.004mg/kg (4μg/kg).

This graph shows the 12 highest levels of PFAS in individual biosolid samples averaged out from a dozen waste water treatment plants in Victoria. At some locations non PFOS/PFOA/PFHxS detections are higher or equivalent to PFAS types that will be covered under the NEMP, meaning that these biosolids could possibly be used on farms, even though a large portion of the total PFAS amount will not be included in total PFAS calculations under the NEMP. These averages are skewed somewhat by the Melbourne Water data, which unlike almost all of the other water authorities focused their testing namely on only four or five PFAS chemicals (including PFOS, PFOA and PFHxS). Other water authorities tested for 20 or more. Note that 0.2mg/kg = 200μg/kg

In 2020 Queensland produced an End of Waste Code for Biosolids, where trigger values were granted for several PFAS chemicals, including some not included under the NEPM. Monitoring for PFAS was also suggested for Grade A, B and C type Biosolids. It would appear that the NEPM imposes "weaker standards" that what was legally acceptable in Queensland two years earlier.

This graph shows PFAS detections from individual biosolid samples averaged out from seventeen other waste water treatment plants. At most locations non PFOS/PFOA/PFHxS detections are higher or equivalent to PFAS types that will be covered under the NEMP. At some locations the "non-NEMP" PFAS chemicals are 2-3 times higher than combined totals for PFOS/PFOA/PFHxS.

Biosolid data from Mansfield WWTP. The levels of PFOA at this site suggest that biosolids from Mansfield would not be approved under the NEPM due to PFOA levels exceeding 130μg/kg (0.13mg/kg). The other category is "avoided" in the NEPM. How does the water authority now deal with this waste product?

Biosolid data from Kilmore WWTP. The levels of PFOA at this site suggest that biosolids from Kilmore would be approved under the NEPM due to PFOA levels exceeding 60μg/kg (0.06mg/kg) and PFOS/PFHxS levels ~30μg/kg (0.03mg/kg). The "Other" category is "avoided" in the NEPM yet totals over 140μg/kg (0.14mg/kg). What does the NEMP propose happen under this scenario?

From data sourced by FoE under Freedom of Information, approximately 60% of PFAS in Victorian biosolids consist of PFOS, PFHxS and PFOA. It would appear that the remaining 40% of PFAS found in Victorian biosolids (~20 PFAS chemicals) are not included in the NEPM. These chemicals consist mainly: PFHxA, PFPeA, PFDA, PFHpA, PFBA, MeFOSSA and PFBS. At a number of locations these PFAS chemicals have the highest PFAS loads or the second or third highest PFAS loads found in biosolids. This scenario is likely to be the same at numerous locations across Australia.

Biosolids area at Melbourne Water's Western Treatment Plant. The stockpile "Biosolids storage area" at right of screen is ~14 hectares in size. Where is this product ending up and in what volumes? Is it being "diluted" by mixing with other soils and then sent off to farms?

Grampians Wimmera Mallee Water Biosolids stockpile at Charlton. Members of the public can take loads of biosolids for free, after the biosolids have been stockpiled for 3 years. What thought is there for measurement of PFAS contamination of the farm where this "soil" is applied or the contamination of the vehicle transporting the biosolids? What measures are in place to protect the health of the buyer?  Image: GWMWater

SA Water's biosolids at Bolivar Wastewater Treatment Plant north west of Adelaide. It appears that storage capacity at the plant could be an issue. What does the water industry do with stockpiles of PFAS contaminated biosolids when storage capacity is limited? Is this a significant reason behind the need to "dilute" their contaminated product by applying it to farmland?

Water authorities also don't want the responsibility of storing piles of contaminated PFAS biosolids indefinitely or of the costs of sending their biosolids to landfill for further treatment. Are farmers aware that the products they are using could be contaminated with a range of toxins, including PFAS, microplastics and brominated hydrocarbons? Why have testing regimes for other emerging contaminants in biosolids been avoided by the NEMP?

It could be argued that Biosolids contaminated with PFAS (and other chemicals) should actually be classed as Industrial or Hazardous Waste and should be regulated as such. Such moves have been proposed by the US EPA in August 2022 for PFOA and PFOS. Such a move in Australia could see water authorities legally responsible for the clean up costs associated with biosolid contamination. Such an outcome could be vigorously opposed by industry. Biosolids are already being treated, incincerated or landfilled by various water authorities all of which have a number of environmental problems.

“The proposed designation of PFOA and PFOS as hazardous substances is based on significant evidence that PFOA and PFOS may present a substantial danger to human health or welfare and the environment. PFOA and PFOS can accumulate and persist in the human body for long periods of time and evidence from laboratory animal and human epidemiology studies indicate that exposure to PFOA and/or PFOS can cause cancer, reproductive, developmental (e.g., low birth weight), cardiovascular, liver, kidney, and immunological effects.”

The NEMP p9 also states: "noting dilution is not acceptable for example in soil, air, compost or other wastes or products" yet the overarching philosophy with pollution issues for decades was “the solution to pollution is dilution”. The NEMP while saying that such dilution is not acceptable then allows bioaccumulative PFAS tainted biosolids to be used on farmland in a diluted form spread across soil by land owners willing to ‘add value and nutrients to their crops’.

In the near future will farmers wanting to sell their land have to have it tested for chemicals such as PFAS and microplastics? Will detection of PFAS bring down the value of the property or in some cases lead to the closure of the areas on farms where biosolids were applied, similiar to the Dieldrin contamination issue of the 1980's.

Of major concern is that farms have been shut down in the U.S. States of Michigan and Maine due to PFAS contamination from sewage sludge. The Environmental Working Group (EWG) estimate that up to 20 millions acres of US farmland may have been contaminated with PFAS. "EWG estimates 5 percent of all crop fields could be using sewage sludge, or biosolids, as a fertilizer, even though it’s often contaminated with PFAS."

“The arable land is a finite resource, the conditions of which must be able to be used by future generations. If the productive agricultural land is exposed to long-term exposure to hazardous substances and substances that are difficult for nature to break down, this means that the land is polluted during long time, which in the long run can lead to the soil's productivity incapacity is threatened. Furthermore, there is uncertainty about what is happening in the surrounding natural environment as a result of the spreading of sludge containing dangerous substances on arable land…” KEMI Submission (Sweden)

PFAS and food growing

It appears, that most biosolids used for agriculture in Victoria are applied to broadacre farms. Whilst an unknown percentage could make its way into growing food crops, a major hurdle that the biosolid industry face is convincing big food buyers that biosolids are safe.

In 2012 Horticulture Innovation Australia Ltd (now known as Hort Innovation) initiated a harmonisation scheme regarding the food certification of major retailers in Australia. HARPS includes the big food retailers Aldi, Coles, Costco, Harris Farm Markets, HelloFresh, Metcash and Woolworths. HARP are refusing to source food grown with Biosolids.

"Exclusion of Human Effluent and Biosolids: Treated and untreated fertilisers and soil additives made from human effluent or Biosolids shall not be used on growing sites or potential growing sites." p39 HARPS Harmonised Australian Retailer Produce Scheme HARPS Standard Version 2.0 October 2022

Eggs, grains, vegetables, fruits, milk and meats (particularly fish and liver and organ meats) appear to be the highest food risks in terms of food sources grown in contaminated PFAS areas. Lettuce, Zucchini, Tomatoes and Cabbage appear to been of most interest to scientists researching the topic.

Recycled Water

The NEMP remains strangely quiet and vague about PFAS contamination in recycled water from waste water treatment facilities.

On page 169 says “---The use of recycled water requires careful management to avoid contamination of sensitive environments or food webs with repeated applications of persistent substances, including PFAS. The standards and criteria provided in the NEMP and the NWQMS (National Water Quality Management Strategy) for environmental water and water recycling provide the basis for sound management actions---will consider what trials will be conducted before water recycling is rolled out at scale –"

However, it is not clear in this reference to NEMP & NWQMS how they will implement these standards for PFAS. States (EPA's & Health Departments) are currently using the outdated NWQMS National Guidelines to legally approve licenses for reuse of: 1) recycled water to irrigate edible crops, 2) reuse of stormwater on land and 3) recycled water to recharge aquifers.

The health guidelines that jurisdictions are using for non-drinking recycled water are the outdated the 2006 National Water Quality Management Strategy (NWQMS) National Guidelines for Water Recycling: Managing Health and Environmental Risks Phase. These guidelines are yet to be revised and are close to twenty years old.  The States are using these outdated guidelines as an authoritative reference for the supply, use and regulation of recycled water.

Friends of the Earth gained access to Recycled Water contamination concerning PFAS in 2021 and found that the issue was widespread in tested water in Victoria, even though nine water authorities weren't testing for PFAS in recycled water at all. PFAS detections were dominated by PFOS, PFOA, PFHxA and PFPeA.

"Across Victoria over 1800 individual PFAS tests were implemented. PFAS chemicals in recycled water were found in 35.3% of all individual samples and 83.2% of all test regimes."


The NEMP Version 3 also suggests key changes such as additional PFAS monitoring, some amendments to environmental guidelines, additional guidance on remediation and management and disposal to landfill. Guidance is also shared regarding PFAS sampling and analysis. However its major weakness is that it is limited to three PFAS chemicals only and it appears to be attempting to put patches on a system that is inherently flawed to start with. Friends of the Earth acknowledges that re-use of biosolids and recycled water can have environmental benefits, the problem is that these benefits can be outweighed by toxic contamination of those biosolids. This also highlights the shortcomings of a society that has refused to properly acknowledge the inter-generational nature of chemicals such as PFAS used in industrial and everyday household items for decades. The best option would be for Governments, industry and consumers agreeing to ban the use of PFAS chemicals and stop licence agreements allowing industrial sources of PFAS to enter waste water streams.

For more information contact Anthony Amis at FoE: [email protected]

The Department of Agriculture, Fisheries and Forestry are currently taking submissions in regard to the National Environmental Management Plan on PFAS.

Where PFAS is used

It is useful to acknowledge the enormity of the problem we are facing dealing with PFAS chemicals. The following table helps explain how widespread these substances are.

Industry branches and other use categories where PFAS were or are employed. The numbers in parentheses indicate the number of subcategories. No parentheses indicate no subcategories (see: An overview of the uses of per- and polyfluoroalkyl substances (PFAS) Juliane Glüge, Martin Scheringer, Ian T. Cousins, Jamie C. DeWitt, Gretta Goldenman, Dorte Herzke, Rainer Lohmann, Carla A. Ng, Xenia Trier and Zhanyun Wang
Industry branches
Aerospace (7) Mining (3)
Biotechnology (2) Nuclear industry
Building and construction (5) Oil & gas industry (7)
Chemical industry (8) Pharmaceutical industry
Electroless plating Photographic industry (2)
Electroplating (2) Production of plastic and rubber (7)
Electronic industry (5) Semiconductor industry (12)
Energy sector (10) Textile production (2)
Food production industry Watchmaking industry
Machinery and equipment Wood industry (3)
Manufacture of metal products (6)  


Other use categories  
Aerosol propellants Metallic and ceramic surfaces
Air conditioning Music instruments (3)
Antifoaming agent Optical devices (3)
Ammunition Paper and packaging (2)
Apparel Particle physics
Automotive (12) Personal care products
Cleaning compositions (6) Pesticides (2)
Coatings, paints and varnishes (3) Pharmaceuticals (2)
Conservation of books and [thin space (1/6-em)]manuscripts Pipes, pumps, fittings and liners
Cook- and bakingware Plastic, rubber and resins (4)
Dispersions Printing (4)
Electronic devices (7) Refrigerant systems
Fingerprint development Sealants and adhesives (2)
Fire-fighting foam (5) Soldering (2)
Flame retardants Soil remediation
Floor covering including carpets and [thin space (1/6-em)]floor polish (4) Sport article (7)
Glass (3) Stone, concrete and tile
Household applications Textile and upholstery (2)
Laboratory supplies, equipment and [thin space (1/6-em)]instrumentation (4) Tracing and tagging (5)
Leather (4) Water and effluent treatment
Lubricants and greases (2) Wire and cable insulation, gaskets [thin space (1/6-em)]and hoses
Medical utensils (14)  


Continue Reading

Read More