Aug 1, 2025
PFAS (per- and polyfluoroalkyl substances) are synthetic chemicals that have become a growing concern due to their persistence in the environment and potential health risks. In the context of Phase I Environmental Site Assessments (ESAs), PFAS are now more prominently considered due to recent regulatory changes. Under the updated ASTM E1527-21 standard, PFAS are categorized as "emerging contaminants." While they were previously considered outside the scope of Phase I ESAs unless specifically requested, the EPA’s designation of certain PFAS (like PFOA and PFOS) as hazardous substances under CERCLA in 2024 means they must now be evaluated as part of the standard assessment process.
This change requires environmental professionals to investigate whether PFAS were used, stored, or disposed of on a property, especially in industries like manufacturing, firefighting, or plating. Including PFAS in Phase I ESAs helps identify potential contamination early, informs property transactions, and protects buyers and lenders from future liability. If PFAS contamination is suspected, a Phase II ESA may be necessary to confirm and address the issue. Overall, the inclusion of PFAS in Phase I ESAs reflects a shift toward more comprehensive environmental due diligence.