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Defence Estate Quality Management System (DEQMS) BSI Certification

Environment Compliance Element Environmental Management

Defence PFAS management during maintenance and construction projects

Defence is committed to the effective management of per- and poly-fluoroalkyl substances (PFAS) contamination when undertaking maintenance and construction programs of work.

Legacy firefighting foam, containing perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) as active ingredients, was used at Defence bases for emergency firefighting situations and training. Perfluorohexane Sulfonate (PFHxS) is also commonly found in the legacy firefighting foam as an impurity in the manufacturing process. PFOS, PFOA and PFHxS belong to the PFAS group of chemicals.

In 2004, Defence commenced phasing out its use of the legacy firefighting foam, 3M Light Water, containing PFOS and PFOA as active ingredients and transitioned to a more environmentally safe product called Ansulite for use on the Defence estate. Furthermore, Defence has made changes to the way it uses firefighting foam to ensure that the risk of releasing the product into the environment is minimised.

Guidance material is available to support Defence staff in making informed risk based decisions when planning and executing maintenance and construction related work. 

For information relating to the PFAS Investigation and Management Program please use the following link.


Where can I find Information related to contamination on the site?

Information can be sought from the GEMS EFM-CSR, from published PFAS Investigation reports on the Defence National PFAS Website, or through consultation with the PFAS Investigation and Management Branch site Project Team.

Who does the testing for PFAS on behalf of Defence during construction and maintenance works?

All investigations should be undertaken by engaging an experienced and qualified consultant.

Samples should be sent to an appropriately qualified NATA accredited laboratory for analysis.

How many samples should be taken?

Adequate funding for appropriate PFAS sampling needs to be considered in the Initial Business Case Approvals and Pre First Pass Approval. Appropriate sampling should be conducted on the proposed sites in accordance with standard testing regimes before commencement of any work if there is a possibility that historic PFAS contamination may be present.

A state and territory environmental regulator administers the laws for their state/territory. In most states and territories, the regulator will be an Environment Protection Authority (EPA). Each state/territory will have guidance on the appropriate nominated requirements for undertaking in-situ or stockpile sampling.

Which contaminants should I be testing?

  • PFAS - must include the standard laboratory suite as per Appendix C of the framework with laboratory reporting limits of 0.005 mg/kg (5 µg/kg);
  • PFAS samples must also be analysed for leachable levels using the Australian Standard Leaching Procedure (ASLP ) for use in evaluating on-site re-use/management options;
  • Where landfill disposal is to be considered, Toxicity Characteristics Leaching Procedure (TCLP) tests for PFAS may be required by the jurisdictional regulator (currently Queensland and New South Wales) and Total Oxidisable Precursor Assay (TOPA) may also be required (currently Queensland);and
  • Other identified site specific potential contaminants of concern.

Chemical Compound CAS No
Perfluorobutanoic acid (PFBA) 375-22-4
Perfluoro pentanoic acid (PFPA or PFPeA) 2706-90-3
Perfluoro-n-hexanoic acid (PFHxA) 307-24-4
Perfluoro-n-heptanoic acid (PFHpA) 375-85-9
Perfluoro-n-octanoic acid (PFOA) 335-67-1
Perfluoro-n-nonanoic acid (PFNA) 375-95-1
Perfluoro-n-decanoic acid (PFDA) 335-76-2
Perfluoro-n-undecanoic acid (PFUnDA) 2058-94-8
Perfluoro-n-dodecanoic acid (PFDoDA) 307-55-1
Perfluoro-n-tridecanoic acid (PFTriDA) 72629-94-8
Perfluoro-n-tetradecanoic acid (PFTeDA) 376-06-7
Perfluorobutane sulfonic acid (PFBS) 375-73-5
Perfluoro-n-hexane sulfonic acid (PFHxS) 355-46-4
Perfluoro-n-heptane sulfonic acid (PFHpS) 375-92-8
Perfluoro-n-octane sulfonic acid (PFOS) 1763-23-1
Perfluorooctane sulfonamide (PFOSA) 754-91-6
N-Methylperfluoro-1-octane sulphonamide (N-MeFOSA) 31506-32-8
N-Ethylperfluoro-1-octane sulphonamide (N-EtFOSA) 4151-50-2
2-(N-Methylperfluoro-1-octane sulphonamide)-ethanol (N-MeFOSE) 1691-99-2
1H,1H,2H,2H-Perfluorooctanesulfonic Acid (6:2 FTS) 27619-97-2
1H,1H,2H,2H-Perfluorodecanesulfonic Acid (8:2 FTS) 39108-34-4

What do the laboratory reports mean?

The Certificate of Analysis is the report produced by an accredited laboratory containing all results for the PFAS compounds tested from the samples taken.

The Certificate of Analysis may show that sample results are below the limit of reporting (<LOR). This either means that there is no PFAS in the sample or the amount of PFAS is too small for the laboratory to measure with any degree of certainty.

The sampling and analysis process involves quality control checks, which is a process conducted by the laboratory to ensure the results are accurate.

What do I do with the data I have received?

Results should be compared to the guideline values as provided within the relevant sections of the framework for decision making to determine appropriate management actions. This may be undertaken by the consultant who can assist in providing recommendations for management of the material in accordance with the framework.

What is a risk assessment and how do I conduct one?

A risk can be assessed on the basis of its suitability for current or realistic future use and the risk that use may pose to human health and/or the environment.

A risk assessment should take into account factors relevant to the environmental value of the resource such as the proposed and realistic future uses, physicochemical and bioavailability characteristics of the particular contaminant(s) and the distribution of the contamination. In this approach, the potential receptor, either human or ecological, determines the level of protection required.

How should a stockpile be designed to manage PFAS contaminated spoil?

The primary principle which should be adhered to is that a stockpile should be impervious to reduce the risk of PFAS leaching into the environment. This is achieved through the stockpile design and work procedures limiting the risk of stockpiled materials becoming wet.

Further specifications for project planning and stockpile design activities are available in the Defence PFAS Construction and Maintenance Framework or the Defence Engineered Stockpile Facility Performance Specification guidance document.

Is PFAS-contaminated spoil able to be disposed at an offsite waste disposal facility?

The option to dispose of contaminated spoil at a licensed waste disposal facility is determined by relevant state/territory based environmental legislation and regulations.  Approval should be sought by the civil contractor’s environmental consultant to transport and dispose of the spoil or water from the relevant Environmental Protection Agency.  Opportunities may exist to transport spoil/water at facilities in a different state of origin. Paperwork outlining the level of contamination, EPA approval, transport certificates and disposal facility letters of acceptance forms/documents should be provided to Defence.

What approach should be adopted to applying the Framework to active projects?

The Framework should be provided to Contractors and their environmental consultants who should undertake an impact assessment to identify if changes need to be made to project scopes to meet the intent of the Framework. If there is an impact on scope which affects the project’s Environmental Clearance Certificate, the relevant Regional Environmental Officer/Regional Environment and Sustainability Officer should be consulted. If required a risk assessment may need to be undertaken to identify pragmatic solutions which enable the Framework to be applied while not overtly impacting on project scope or viability.

Where do I access further information?

Advice can be sought from the PFAS Investigation and Management Branch via email to The Estate Management Team within PFAS Investigation and Management Branch will either resolve your enquiry or refer it to a relevant Branch policy expert.

When lodging a request, stakeholders should include:

  • Reference to the affected property and program/project IDs;
  • Specific required actions or questions which require advice;
  • Any pertinent background information or previous advice provided by PFAS Investigation and Management Branch; and
  • The date which the advice is required.

Version Control
Version No: 1.3 | Last Updated: Jul 20
Technical Authority: ASPFASIM | Subject Matter Expert: ASPFASIM