The IES and NCLOG welcome PFAS report from the Environmental Audit Committee
The National Contaminated Land Officers Group (NCLOG) and the Land Condition Community (LCC) of the Institution of Environmental Sciences (IES) welcome the Environmental Audit Committee’s report “Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)”.
Published on the 22nd April, the report makes a series of important recommendations on the management of PFAS in the UK. NCLOG and the LCC submitted joint evidence to the inquiry and are pleased to see that many of the issues raised are reflected in the Committee’s conclusions. However, we are concerned that the critical role of Contaminated Land Officers (CLOs) has not been fully recognised in the report. Without appropriate funding, staffing, and technical support of CLOs, there is a real risk that the Government’s ambitions on PFAS will not be delivered in practice.
A welcome challenge to government
The report provides a useful and timely contribution to the emerging understanding of PFAS. The group of contaminants has generated significant public concern, but until recently, the evidence base has been limited and fragmented. The report offers a clear summary of the current position and the scale of the challenge ahead.
Importantly, the Committee acknowledges both the substantial cost of addressing PFAS contamination and the significantly greater cost of inaction, including risks to public health, environmental quality, and long-term economic harm.
NCLOG and the LCC support the report’s central conclusion that the Government’s PFAS Plan, while well-intentioned, does not yet go far enough or fast enough to meet the scale of the challenge. The report’s recommendations strengthen the Government’s proposed actions and highlights key gaps, including resourcing for regulators and wider system capacity for waste treatment and soil remediation; issues that are essential to delivery but currently underdeveloped.
We therefore welcome the Committee’s call for more urgent, better resourced, and more comprehensive action, and support its direction of travel.
Limited recognition of Contaminated Land Officer capacity
Contaminated Land Officers (CLOs) play a central role in addressing legacy PFAS contamination. They are the principal regulators under Part 2A of the Environment Act 1990, and are the lead internal advisers to Local Planning Authorities on land contamination matters. Despite this, there is no dedicated government funding to support this work.
While the report recognises the need to assess PFAS resourcing assessment for the Environment Agency, it does not recommend a resourcing assessment for local authority CLOs.
NCLOG welcomes the Committee’s recommendation for increased funding for local authorities to remediate sites where no responsible party can be found. However, this does not ‘price-in’ the time, complexity and cost of work needed before remediation can begin, including site investigations, analysis, and detailed risk assessments.
With a growing focus and regulatory burden from PFAS, and limited technical guidance, there is a risk that already stretched CLOs will face significant additional pressure. This is particularly relevant given the likelihood of a substantial number of sites where PFAS was not previously considered within previous investigations. Revisiting sites may be emotionally challenging for residents and landowners who have already experienced earlier regulatory processes.
If the EAC’s recommendations are to be effectively implemented and the polluter pays principle meaningfully applied, then a proportionate strengthening and resourcing of the Part 2A framework is essential. CLOs need sufficient funding and clear guidance to deliver the Government’s ambitions on PFAS.
Other areas to be addressed
NCLOG and the LCC would welcome a stronger emphasis on legacy contamination sources. Current regulatory reviews have only assessed a very small proportion of potentially affected sites. Greater focus is needed on high-risk site types, including former airfield fire training areas, military sites, landfills, and wastewater treatment works, where PFAS contamination is most likely to be significant.
As the Government continues to address PFAS, we also need to explore the wider economic and health implications of PFAS, with further research required into high-exposure settings and to estimate the ‘future NHS bill’.
Quotes
Dan Maher, LCC Steering Group member, said “The Environmental Audit Committee report is a positive addition to the PFAS conversation in the UK, asking some important questions and demanding important answers from government. The Committee addresses many of the concerns around the government PFAS Plan that have been echoed in the Land Condition Community since its publication, highlighting the need for more urgency and focus on what is likely to be the biggest environmental and public health issue of the next decade."
~ ENDS ~
Media contact
For further information please contact:
- Ellie Savage ellie@the-ies.org (NCLOG Coordinator)
- IES Office: +44 (0)20 3862 7484
Background
The term Contaminated Land Officers (CLOs) refers to those who are working as land contamination specialists within local authorities. They may also be Environmental Health Officers, Scientific Officers, Technical Officers or have other relevant titles.
The National Contaminated Land Officers Group (NCLOG) brings together over 200 CLOs working across the UK. It acts as the national voice for CLOs in the UK and promotes high-quality and consistent regulation and management of land contamination across the sector. NCLOG provides a home for CLOs to share ideas and knowledge, support members through developing guidance and resources, and provide peer support to individual CLOs, who may be the sole individual dealing with land contamination in their Council.
The Land Condition Community (LCC) connects members to share expertise, shape resources, and drive standards across the sector. The Community leads the annual Land Condition Symposium, runs webinars and discussions, develops professional guidance, and contributes to policy and consultation responses.
NCLOG and LCC are part of the Institution of Environmental Sciences (the IES) family. The IES is at the forefront of uniting the environmental sciences around a shared goal: to work with speed, vision and expertise to solve the world’s most pressing environmental challenges, together. As the global professional membership body for environmental scientists, we support a diverse network of professionals all over the world – and at every stage of their education and careers – to connect, develop, progress and inspire.
Header image credit (c) Peter Togel via AdobeStock