ACP insights & guidance
When buying land, a potential PFAS issue starts with the site history and the proposed use. The UK Government’s PFAS Plan sets out a programme of work on per- and polyfluoroalkyl substances. For an individual English development site, the Environment Agency’s land contamination risk management approach provides the framework for deciding whether the available evidence is sufficient.
Look for a plausible source and route
Possible prompts for further enquiry include documented use of certain firefighting foams, relevant industrial processes or records showing that potentially affected material was brought to site. A site description alone is weak evidence. Ask for locations, dates, records and the likely nature of the activity before drawing conclusions.
The Phase 1 desk study can bring together historic mapping, records, a site walkover and environmental context. Its conceptual site model considers whether a plausible source could reach a receptor through a relevant pathway. Surface-water drainage, permeable ground and groundwater abstraction may matter for one site. A different use or hydrogeological setting could lead to a different investigation question.
Tie enquiries to the acquisition decision
- Before agreeing terms. Ask what previous reports exist and whether they investigated the part of the site you intend to buy or redevelop.
- When an evidence gap appears. Ask the specialist which uncertainty matters most, who may hold relevant records and whether access is available for further investigation.
- Before specifying sampling. Agree the decision, target media, analyte selection, quality controls and laboratory capability. Discuss interpretation and reporting limits in advance.
- Before relying on a result. Check the purpose and coverage of the evidence. A result describes the analytes, samples and reporting limits used in that investigation.
Illustrative example
Suppose records identify an old fire-training area on one edge of a former industrial site. The first useful questions concern what activities took place, where drainage went and whether the proposed works could disturb affected ground. If a material pathway remains plausible, the specialist can scope a targeted investigation. The records alone do not establish contamination or its extent.
Ask the project team to record acquisition questions separately from planning, remediation or waste management decisions. Different decisions can need different evidence and input from different regulators.
Common question
Does a Phase 1 desk study demonstrate the presence of PFAS?
A desk study assesses available evidence and plausible pathways. Where further evidence is needed, the investigation scope depends on the decision and site conditions.
References and scope
Discuss the project brief
Share the proposed use, historic records and acquisition timetable with the contaminated land team.