TRENDING TOPIC
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The enduring impact of PFAS chemicals
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After more than 80 years of use across many industries around the world, the impact of forever chemicals present a major concern to the insurance industry. Liberty’s risk engineering guide brings you up to speed on what these chemicals are, where they are used, why they are a concern and the current state of legislation and litigation activity.
PFAS is an umbrella term for Per- and Polyfluoroalkyl substances. These are a class of over 5,000 human-made chemicals (though the number can vary depending on the definition) that have been used in a wide range of consumer products and industrial applications since the 1940s. Today they are found in everything from contact lenses to lipstick, guitar strings, x-ray films, and the infamous firefighting foam that is the subject of landmark litigation. The carbon-fluorine bonds in PFAS lead to very stable substances, however, this also makes the ultimate breakdown products of PFAS extremely persistent in the environment and in the human body. This is why they are often referred to as “Forever Chemicals”.
Where are PFAS found?
PFAS are used in a wide range of applications. While there is no comprehensive source of information on the many individual PFAS substances, and their functions in different applications, a study completed by the Royal Society of Chemistry in 2020 was able to demonstrate “that PFAS are used in almost all industry branches and many consumer products”. The study identified more than 200 use categories and subcategories for more than 1400 individual PFAS.
Environmental Sources
Drinking water:
Why are PFAS an issue?
Food:
Consumer Products
Non-stick cookware:
Cosmetics:
Other Sources
Industrial sites:
Drinking water infrastructure:
Contaminated through industrial sites, wastewater treatment plants, landfills, firefighting foams, and PFAS-containing infrastructure.
Soil:
Contaminated through firefighting foams, waste disposal, and biosolids used as fertiliser.
Can be found in fish, meat, dairy, eggs, fruits and vegetables, and processed foods due to packaging, contaminated soil or water, and farming practices.
Air:
Released from industrial facilities, landfills, and fire-fighting activities.
Used for their hydrophobic and oleophobic properties.
Found in some makeup, sunscreen, and personal care products.
Used for stain and water resistance.
Waterproof clothing:
Food packaging
Used for water resistance properties.
Used to prevent grease and water absorption.
Carpets and furniture:
Manufacturing facilities, military bases, fire training facilities and landfills.
Firefighting foam:
A major source of environmental contamination in areas like airports, petrochemical plants and military bases.
Some pipes, fittings, and storage tanks may contain PFAS materials.
Given the long history of PFAS (in use for around 80 years), the number of different substances involved (over 5,000 chemicals) and pervasiveness (used in household and consumer products, industrial processes, and fire protection) there are several key reasons why PFAS are a major emerging risk:
In insurance terms, an emerging risk refers to a risk that is either entirely new, or one that's evolving in a way that increases its potential impact. Because the risk is new or evolving there’s a lack of complete understanding, so it can be challenging to assess the risk in terms of likelihood or potential consequences.
1. Persistence and bioaccumulation
PFAS have been used in a vast array of products and industrial processes, leading to widespread environmental contamination. They have been detected in drinking water, food, soil, air, and even wildlife.
PFAS have not been proven to cause any specific illnesses in humans, however, due to their persistence and bioaccumulation, human exposure to these chemicals should be minimised.
With over 5,000 individual PFAS chemicals and variations in their properties and potential health effects they are a growing concern for regulators and litigators.
Addressing PFAS contamination involves significant costs for clean-up, remediation, and litigation.
Overview of uses
2. Widespread contamination
PFAS are extremely persistent in the environment and in the human body. They disintegrate very slowly, meaning they can accumulate over time and reach potentially harmful levels.
Once absorbed, they can remain in the body for years, increasing the potential for adverse health effects.
3. Potential health risks
4. Regulatory complexity
5. Economic and societal costs
Several studies (including studies where large doses of PFAS have been administered to laboratory animals) have linked PFAS exposure to various health problems, including effects on the immune system, liver, reproduction, development and benign (non-cancer) tumours.
A few studies show a link between PFAS exposure and health effects. Some show limited, and some no evidence of human disease accompanying these health effects.
Regulation presents a complex challenge that will require further research and harmonisation of international efforts.
The potential impacts on public health and healthcare systems will add to the financial burden.
PFAS chemicals have found use in a wide range of industries and consumer products.
The Royal Society of Chemistry study identified “more than 200 uses in 64 use categories” for more than 1400 individual PFAS. In addition to previously known use categories such as textile impregnation, fire-fighting foam, and electroplating, the study demonstrated that the use of PFAS substances was far more extensive than generally accepted. For example, PFAS were found to be used in ammunition, climbing ropes, guitar strings, artificial turf, solar collectors and photovoltaic cells, windmill blade coatings, drilling fluids and soil remediation. Some specific uses of PFAS have been identified as currently being essential to health, safety, or the functioning of today's society for which alternatives so far do not exist. Essential use categories may have to remain in place until safe, viable alternatives have been found.
Ongoing research and development efforts are focusing on safer alternatives to PFAS for various applications, but commercial viability and widespread adoption haven't fully materialised yet. In summary, the current level of use is a complex situation with continued PFAS use alongside growing awareness and regulatory efforts.
However, some countries, like India and Russia, have increased their use of PFAS compounds, while certain industries still rely heavily on PFAS, including:
What is the current level of use?
The PFAS of most concern are perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). Many countries have phased out, or are in the process of phasing out the use of PFOS and PFOA due to concerns about the persistence, bioaccumulation and potential toxicity of these chemicals.
Key science findings
Exposure pathways
"An overview of the uses of PFAS substances" by Royal Society of Chemistry
Aviation / refineries / petrochemical manufacturers: firefighting foams for site safety.
Semiconductors: etching processes in chip manufacturing.
Medical: X-ray films, MRIs surgical drapes and gowns, filters, tubing and many other medical devices and equipment.
2. Association with health concern
Numerous studies have shown associations between PFAS exposure and various health problems, including:
What is science telling us about health effects of PFAS exposure?
While the “smoking gun” of causation has yet to materialise, science increasingly paints a concerning picture of potential health effects from exposure to PFAS chemicals. More research (beyond animal studies) is needed to fully understand the risks.
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Summary of key science findings:
3. Dose-dependent effects
Like other hazardous chemicals, the severity of health effects will likely depend on the level and duration of exposure – the higher the dose and the longer the exposure the greater the risk.
4. Individual factors
Genetic susceptibility, underlying health conditions, and other environmental exposures can influence how individuals respond to PFAS exposure.
5. Research challenges
Distinguishing PFAS effects from other environmental factors and lifestyle choices in observational studies presents challenges. Additionally, research on newer PFAS alternatives is still limited. Overall, the science points towards a strong need for caution and proactive measures to reduce PFAS exposure and mitigate potential health risks. Public health initiatives, stricter regulations, and responsible manufacturing practices are essential to address this ongoing environmental and health challenge.
1. Classification
The US EPA has classified PFOA and PFOS as "likely to be carcinogenic to humans." However, the EPA is still evaluating the scientific evidence on PFAS health effects.
While the evidence of potential PFAS harm is strong, causality has not yet been definitively established. Further research is needed to fully understand the specific risks associated with PFAS exposure and to determine the exact mechanisms by which it may impact human health. Regardless, this classification is significant because it carries weight for public health agencies and regulatory bodies around the world. The IARC classification is likely to influence future regulations and public health initiatives related to PFAS. It could also lead to increased litigation against companies that manufacture or use PFAS.
It's important to note that the IARC classification system focuses on the potential for a substance to cause cancer, not the risk of cancer in any specific individual. The risk of developing cancer from PFAS exposure depends on several factors, including the level of exposure, duration of exposure, and individual susceptibility.
Mechanistic evidence – in simple terms, this is evidence that helps explain how something works, not just that it does. It is evidence that gives us a clearer picture of the inner workings of a system or process. In the cases of PFAS studies, mechanistic evidence provides insights into how PFAS might interact with cells and biological processes, that may potentially lead to cancer developing. While mechanistic evidence is not conclusive evidence it does strengthen the case for potential harm even though conclusive data from human studies may still be limited.
Increased cancer risk
Thyroid dysfunction
Reproductive issues
Immune system suppression
Developmental effects
Other concerns
The International Agency for Research on Cancer (IARC) recently classified the two major PFAS chemicals in November 2023:
PFOA was classified as “carcinogenic to humans” (Group 1) based on “sufficient” evidence for cancer in experimental animals and “strong” mechanistic evidence in exposed humans.
PFOS was classified as “possibly carcinogenic to humans” (Group 2B) based on “strong” mechanistic evidence. The evidence for cancer in experimental animals was “limited” for PFOS, and the evidence regarding cancer in humans was “inadequate”.
Increased cholesterol levels, obesity risk, and even liver damage are also among the potential health effects under investigation.
Potential impacts on children include delayed cognitive function, behavioural changes, and impaired bone development.
Studies suggest PFAS may weaken the immune system, increasing susceptibility to infections and reducing vaccine response.
Reduced fertility, pregnancy complications and lower birth weight have been linked to PFAS exposure.
PFAS exposure has been associated with hypothyroidism, autoimmune thyroid disease, and altered thyroid hormone levels.
Evidence suggests potential links to kidney, testicular, prostate, and pancreatic cancers, though conclusive proof is still under investigation.
Consumer products that contain PFAS (such as non-stick cookware, waterproof /stainproof clothing and carpets, cosmetics and personal care products, food packaging etc.) can be another source of exposure.
What are the exposure pathways?
Workplace exposure to PFAS can occur to people who are involved in the manufacture, or use of PFAS. Outside of the workplace, exposure to PFAS can occur from food, water (ground and surface water) and various consumer products.
Drinking water is often the primary pathway of exposure, especially in areas with contaminated water sources.
While inhalation isn’t considered a primary route, PFAS can be released into the air from various sources, including the burning of PFAS-containing materials.
Ingestion is another primary pathway of exposure as PFAS can accumulate in the food chain, with higher levels found in fish, shellfish, and livestock.
Dermal (skin) contact with PFAS is not considered a significant exposure pathway.
Primary exposure pathway
Secondary exposure pathway
PFAS Legislation and Regulation
The following provides an overview of the EPA’s efforts to address the challenges posed by PFAS so far:
Regulations in the US
Regulatory authorities, driven by increasing public interest in these chemical compounds, have focused their efforts on banning or further restricting the use of PFAS substances over the last few years. The U.S. Environmental Protection Agency (EPA) on April 10, 2024, officially designated PFOA and PFOS as hazardous under the Comprehensive Environmental Response, Compensation, and Liability Act, or CERCLA. At the same time, it finalised a proposed new rule aimed at reducing the level of six PFAS substances in drinking water. This is the first enforceable federal drinking water regulation for PFAS.
Protecting communities from PFAS in drinking water:
Key EPA Actions to Address PFAS | US EPA
Reducing PFAS exposure through enforcement and regulations:
Guidance on Destroying and Disposing of PFAS:
The EPA has updated its Interim Guidance on destroying and disposing of certain per- and polyfluoroalkyl substances (PFAS) and PFAS-containing materials. This guidance focuses on non-consumer products and includes firefighting foam. It also identifies promising new technologies for PFAS destruction.
Regulations outside the US
Read next
Per- and Polyfluoroalkyl Substances (PFAS) | US EPA
Back
The final rule requires public water systems to monitor for these PFAS. They have three years to complete initial monitoring, followed by ongoing compliance monitoring.
The public water systems have five years to implement solutions that reduce these PFAS if monitoring shows that drinking water levels exceed the final rule MCLs.
The EPA also finalised health-based, non-enforceable Maximum Contaminant Level Goals (MCLGs) for these PFAS.
The EPA finalised a National Primary Drinking Water Regulation (NPDWR) establishing legally enforceable levels, called Maximum Contaminant Levels (MCLs), for six PFAS in drinking water (PFOA, PFOS, PFHxS, PFNA, and HFPO-DA as contaminants with individual MCLs, and PFAS mixtures containing at least two or more of PFHxS, PFNA, HFPO-DA, and PFBS using a Hazard Index MCL).
The EPA also finalised a rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERLA), also known as Superfund.
In addition to the final rule, EPA issued a separate CERCLA enforcement discretion policy that outlines that EPA enforcement will focus on parties who significantly contributed to the release of PFAS chemicals into the environment.
Under CERCLA, the government and other parties can sue for contributions to cleanups and to recover costs related to those actions.
Regulation around PFAS substances is increasing outside of the US as well. The following is a non-exhaustive list of restrictions implemented across the world:
The EU has restricted PFOS for more than 10 years under the EU’s Persistent Organic Pollutants (POPs) Regulation, while PFOA, its salts and PFOA-related compounds have been banned since July 2020. In February 2023, the European Chemicals Agency (ECHA) published a proposed updated to the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as it relates to PFAS. The update considers PFAS as "Substances of Very High Concern” and is the most significant regulatory measure targeting the chemical class in any jurisdiction to date.
ECHA publishes PFAS restriction proposal
Japan’s Environment Ministry banned the manufacturing and use of PFOS in 2010 and PFOA in 2021 and banned the production and importation of PFHxS and its salts, as well as the import of ten (10) product types containing them. In 2020, the government also set a safety limit of 50 nanograms per litre for drinking water for the first time, though it is “provisional” and not legally binding. In February 2024 the Food Safety Commission of Japan released a draft report on the “tolerable daily intake” (TDI) of PFOA and PFOS through food. The draft report specified a TDI of 20 nanograms each of PFOA and PFOS per kilogram of body weight per day. South Korea has included PFOS, its salts and PFOS-Fluoride as restricted substances under the Persistent Organic Pollutants Control Act. Under the Act, any manufacture, import, export and use of PFOS, its salts and PFOS-F are restricted except for specific exemptions and acceptable use in the Stockholm Convention.
There are limited national regulations and both countries are relying on existing chemical safety frameworks to address PFAS concerns. PFAS management in Australia has primarily been led by the Heads of EPAs Australia and New Zealand (HEPA) with the publication of the PFAS National Environmental Management Plan (NEMP) in 2018. A revised PFAS NEMP Version 2.0 was published in January 2020. Australia has not ratified the listing of PFOS and PFOA under the Stockholm Convention. Some states, like Queensland in Australia, have implemented specific PFAS bans for food packaging and firefighting foams. New Zealand’s EPA recently released a draft proposal to ban all PFAS in cosmetic products by 2025, which aligns with EU regulations. In addition, all PFAS fire-fighting foams will be completely banned in NZ from December 2025.
Europe
Asia
Australia & New Zealand
In April 2022, South Korea’s Ministry of Food and Drug Safety updated its ‘Regulations on the Safety Standards etc. of Cosmetics’ to include 7 PFAS compounds as prohibited cosmetic materials. Thailand’s Food & Drug Administration (FDA) has drafted a proposal to ban 13 types of PFAS for use in cosmetics. On 1 November, 2023, Thailand’s Department of Industrial Works (DIW) tabled draft amendments to the List of Hazardous Substances under the Hazardous Substances Act for public comment. The DIW proposes to list PFHxS, its salts and PFHxS-related compounds as Type 3 hazardous substance China’s Ministry of Environmental Protection (MEP) issued an announcement in 2014 In 2014, banning “production, transportation, application, imports and exports of PFOS, its salts, and PFOS-F, except for specific exemptions and acceptable use.” In general, most Asian countries lack comprehensive PFAS regulations, although awareness and concern are growing.
FAQs | Australian Government PFAS Taskforce
PFAS are forever – a complicated chemical family | EPA
Global organisations
At an individual country level, Germany, Denmark, Sweden, and the Netherlands have taken independent steps to restrict or ban specific PFAS applications.
There are limited national regulations and both countries are relying on existing chemical safety frameworks to address PFAS concerns. PFAS management in Australia has primarily been led by the Heads of EPAs Australia and New Zealand (HEPA) with the publication of the PFAS National Environmental Management Plan (NEMP) in 2018. A revised PFAS NEMP Version 2.0 was published in January 2020. Australia has not ratified the listing of PFOS and PFOA under the Stockholm Convention. Some states, like Queensland in Australia, have implemented specific PFAS bans for food packaging and firefighting foams.
New Zealand’s EPA recently released a draft proposal to ban all PFAS in cosmetic products by 2025, which aligns with EU regulations. In addition, all PFAS fire-fighting foams will be completely banned in NZ from December 2025.
China
Japan
South Korea
Thailand
Thailand’s Food & Drug Administration (FDA) has drafted a proposal to ban 13 types of PFAS for use in cosmetics. On 1 November 2023, Thailand’s Department of Industrial Works (DIW) tabled draft amendments to the List of Hazardous Substances under the Hazardous Substances Act for public comment. The DIW proposes to list PFHxS, its salts and PFHxS-related compounds as Type 3 hazardous substances.
South Korea has included PFOS, its salts and PFOS-Fluoride as restricted substances under the Persistent Organic Pollutants Control Act. Under the Act, any manufacture, import, export and use of PFOS, its salts and PFOS-F are restricted except for specific exemptions and acceptable use in the Stockholm Convention. In April 2022, South Korea’s Ministry of Food and Drug Safety updated its ‘Regulations on the Safety Standards etc. of Cosmetics’ to include 7 PFAS compounds as prohibited cosmetic materials.
Japan’s Environment Ministry banned the manufacturing and use of PFOS in 2010 and PFOA in 2021 and banned the production and importation of PFHxS and its salts, as well as the import of ten (10) product types containing them. In 2020, the government also set a safety limit of 50 nanograms per litre for drinking water for the first time, though it is “provisional” and not legally binding. In February 2024 the Food Safety Commission of Japan released a draft report on the “tolerable daily intake” (TDI) of PFOA and PFOS through food. The draft report specified a TDI of 20 nanograms each of PFOA and PFOS per kilogram of body weight per day.
China's regulations around PFAS substances have evolved significantly in recent years, but still lack comprehensive bans. In 2014, the production of PFOS and PFOA was banned except for specific exemptions. In 2023, PFHxS was added to the List of New Pollutants for Priority Management, but these regulations are not yet mandatory across all industries. Building on these measures, China prohibited the import and export of PFOS, PFOA, PFHxS, and other persistent organic pollutants in 2024. This step aims to limit the flow of these harmful substances across borders and reduce their presence in the environment. Prior to this, in April 2023, Hygienic Standards for Drinking Water for Domestic Use came into effect in China, which define the upper limits for PFOA and PFOS in drinking water. Prior to this, a series of specifications were issued to regulate the measurement of substance in drinking water and feeding materials.
Global organisations:
The Stockholm Convention on Persistent Organic Pollutants (POPs) is a global treaty to “protect human health and the environment from chemicals that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of humans and wildlife, and have harmful impacts on human health or on the environment”. PFOS, PFOA and their precursors are listed under the Stockholm Convention. This means that the production and use of these substances are restricted or eliminated in the countries that are parties to the treaty. The Stockholm Convention is also involved in the assessment of alternatives to PFOS, PFOA, PFHxS and their related compounds.
Overview of PFAS at Stockholm Convention
The Organisation for Economic Co-operation and Development (OECD) has established the Global Perfluorinated Chemicals (PFC) Group. The Group “brings together experts from OECD member and non-member countries in academia, governments, industry and NGOs as well as representatives from other international organisations”. Their work involves developing guidance and recommendations for PFAS management and regulation.
OECD Portal on Per and Poly Fluorinated Chemicals
Key trends:
Voluntary agreements
Limited knowledge and capacity
International momentum
Focus on specific applications
Litigation in the US
There is a global shift towards stricter PFAS regulations, with many countries following the EU's lead.
While complete bans remain rare, restrictions are often targeting specific applications with readily available alternatives (e.g. fire-fighting foams).
Some countries are working with industry to phase out PFAS through voluntary agreements and incentives.
Many developing countries lack the resources and scientific expertise to tackle PFAS effectively.
There are more than 15,000 claims that have been filed nationwide against DuPont (and its spinoffs Chemours and Corteva) along with 3M, the major manufacturers of PFAS in the US. A handful of smaller PFAS companies are also facing suits. So far DuPont, Chemours, Corteva and 3M have paid a total of nearly USD11.5 billion in damages for PFAS contamination. In June 2023, DuPont, Chemours, and Corteva reached a USD1.185 billion settlement with 3000 local water systems that had sued the companies for the costs of cleaning and filtering their wells and aquifers. In July 2023, 3M reached a tentative agreement to pay USD10.3 billion to $12.5 billion to a multidistrict litigation coalition made up of 300 different water providers. Previously, in 2018, 3M settled a lawsuit with the state of Minnesota for USD850 million. The Minnesota Attorney General sued 3M in 2010 alleging that PFAS chemicals produced by the company had damaged drinking water and natural resources in the state.
In addition to the chemical manufacturers being sued for contaminating land and drinking water, there’s an increasing trend of lawsuits being brought against a broader array of defendants who have allegedly exposed people to PFAS, including via fire-fighting foams, biosolids, food packaging, apparel, and personal care products. As result, several manufacturers have stopped producing PFAS-containing products, and several retailers have stopped selling products that contain PFAS to mitigate future liability In 2018, a US firefighter filed a class action lawsuit against a number of PFAS manufacturers to fund an independent investigation of links between exposure and health impacts of the entire class of PFAS substances. Overall, US PFAS litigation demonstrates growing public concern about these chemicals and their potential health risks. It reflects evolving legal strategies and increasing efforts to hold polluters accountable for environmental contamination and related health impacts.
Legal liability PFAS chemical lawsuit
Litigation outside the US
While still not as widespread as in the US, PFAS litigation is gaining traction globally. Listed below are some instances of legal action against PFAS use and contamination outside the US:
Australia:
Commonwealth settles $132.7 million class action over PFAS contamination across Australia
Europe:
What's next for PFAS litigation?
Summary
While claims in Europe are lagging those in the US, litigation concerning alleged PFAS groundwater contamination is on the rise and it’s generally expected that there will be increase in such claims, together with personal injury/property damage claims. In Sweden, Kallinge residents are claiming that groundwater was contaminated with PFAS due to firefighting foam from nearby military bases and are seeking compensation. In March 2023, a number of municipalities from the southwest of Lyon launched group litigation for compensation in relation to PFAS contamination of the Rhône. In Belgium, public prosecutors investigated the potential criminal liability of 3M for PFAS contamination of the Scheldt River. In 2022, the Flemish government announced a EUR571 million agreement with 3M for the remediation of the alleged PFAS contamination of the river.
In 2020, the Australian government reached a settlement with three communities for AUD212 million that had alleged their groundwater had been contaminated with PFAS due to use of fire-fighting foam at air force bases. This was followed in 2023 with another AUD132 million class action settlement between the government and 30,000 landowners that alleged property value loss and distress due to PFAS contamination. While still not as widespread as in the US, PFAS litigation is gaining traction globally. As awareness and understanding of PFAS risks increase, legal action likely will continue to evolve and play a role in shaping policy and public health responses to these persistent chemicals.
There is still a long way to go before PFAS exposure evaluations are completed. Chemical research studies are a lengthy and complex process with a lot of unknowns and variables. Due to the large number of chemicals that fall under the PFAS family, it may be a long time before we fully understand their impact. Even after evaluations are complete there will be challenges with introducing safer and as effective replacements. PFAS free products are being introduced to eliminate existing aqueous film-forming foams (AFFF) containing PFAS used to extinguish fires. Until then, health and environmental exposures will need to be considered individually as part of the consultation process between underwriters, brokers and clients.
Liberty’s global Casualty Risk Engineers have studied and tracked PFAS since it became a problem. We use our knowledge of the principles of chemical safety and current understanding of PFAS chemicals to support brokers and clients to understand and evaluate the known risks that PFAS currently present.
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Angelo Maniatis
Author:
Last updated 22 May 2024
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About Liberty Specialty Markets
This document is intended to broadly illustrate the kinds of exposures a business can face from use of PFAS. It is not a comment on insurance coverage available from Liberty. You should not rely on this information without first obtaining professional advice. This information is current as at 22 May 2024. Liberty means Liberty Specialty Markets, a trading name of Liberty Mutual Insurance Company, Australia Branch (ABN 61 086 083 605; AFSL No. 530842 (for claims handling and settling services only)) incorporated in Massachusetts, USA (the liability of members is limited); Liberty Specialty Markets Hong Kong Limited (UBI 66395065); Liberty Specialty Markets Singapore Pte Limited (UEN 201538069C); and Liberty Specialty Markets Singapore Pte Limited, Labuan Branch (Company No. LF12903), a licensed insurer under the Labuan Financial Services and Securities Act 2010 (Licence No. IS2016162).
Vice President Risk Engineering Casualty & Professional & Financial Risks, Asia Pacific E: angelo.maniatis@libertyglobalgroup.com M: +61 474 259 456
Melbourne, Australia
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