MiMfg Magazine December 2017 | Page 7

December 2017 and a growing public perception that “no risk” is acceptable from chemicals, there may even be public pressure to address conditions even when concentrations are below regulatory limits (e.g., public water supplies). • Since there are only a few technologies that appear effective in treating PFAS, finding a cost-effective method to treat and clean up these contaminants will be challenging. What can industry do? 1. In the absence of institutional knowledge, consider conducting a preliminary assessment (PA) of your current and former operations to evaluate whether you may have used PFAS. Make sure you keep good records. 2. Review the historic material safety data sheet or current safe ty data sheet of materials used in your operations. If you are using PFAS, consider whether an alternative non-PFAS containing material can be used instead. 3. Understand the specific fate and transport mechanisms for each location possibly impacted. 4. Monitor the activities of MPART, develop standards and consider commenting on rules and regulations, either on your own or through organizations such as the MMA. The state has created a website, michigan.gov/pfasresponse, where developments can be monitored. MiMfg Magazine 5. In some instances, it may be advisable to investigate in order to evaluate whether potential environmental liability issues require additional attention or document that no liability exposure exists based on the PA. 6 Todd Fracassi is a partner at Pepper Hamilton LLP. He may be reached at 248-359-7304 and [email protected]. Pepper Hamilton is an MMA Associate member. Visit online: www.pepperlaw.com. James Colmer is vice president of operations at BB&E. He may be reached at 248-489-9636 x309 and [email protected]. BB&E Inc. is an MMA Associate member. Visit online: www.bbande.com. 7