In recent weeks, the U.S. EPA’s announcement outlining the agency’s priorities has dominated the PFAS news. In this post, we share our take on highlights from the announcement and what they may mean for our clients.
U.S. EPA Sets the Stage for 2025-2028
Released on April 28, EPA’s press release is worth reading because the take from online commentators has differed wildly. Some argue the announcement lacks substance. Others have read specific intent behind some of the statements, although some of the inferred intentions may be skewed by the actions commentators would like to see taken.
Our take is somewhere between the two views. We expected PFAS to remain a top priority due to civil litigation, public pressure, existing science, and the appointment of Lee Zeldin as EPA administrator, a former Congressman with a track record of supporting PFAS legislation. There’s also the fact that EPA’s PFAS Action Plan was released in 2019 under the first Trump administration. Of course, the agency administration is different, but we took that as a sign that the White House would be open to prioritizing PFAS-related issues.
That said, we agree that many details are so vague as to be almost impossible to predict what actions fulfilling these priorities will entail. At best, the agency set the stage with this announcement, but we don’t yet know how the story will play out over the next four years.
What We’re Watching
At the risk of reading EPA’s announcement with our own hopes in mind, we decided a few priorities were worth calling out. If achieved, they could advance the state of the science to the advantage of those who produce/use PFAS in their operations and those concerned with ensuring a toxin-free environment. Here are some of the priorities we’ll be watching closely:
Priority: Provide more frequent updates to the PFAS Destruction and Disposal Guidance—changing from every three years to annually—as EPA continues to assess the effectiveness of available treatment technologies.
Our take: The increased frequency is good and needed, provided the updates are substantive. Definitive guidance needs to be based on sound science, and that can take time. For our part, Pace® is helping clients evaluate PFAS treatment options through our PFAS Treatability Studies Center of Excellence.
Priority: Ramp up the development of testing methods to improve detection and strategies to address PFAS.
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Our take: Last year saw several significant advancements in PFAS testing, including the finalization of EPA 1633 and 1621. Pace® was involved in the validation of both of these test methods as well as ASTM D8421/D8535. Even so, there are limitations to currently available test methods, such as the ability to detect total organic fluorine or specific categories of PFAS, such as short-chain PFAS and fluoropolymers. While it’s too early to say what EPA has in mind here, we’re eager to continue to work with them on the next phase of test method development.
Priority: Develop effluent limitations guidelines (ELGs) for PFAS manufacturers and metal finishers and evaluate other ELGs necessary for reduction of PFAS discharges.
Our take: We’re assuming EPA will finalize the ELGs planned for landfills. This priority was announced in Effluent Guidelines Program Plan 15 and affirmed in Preliminary Plan 16. The above priority also leads us to believe that EPA is likely to proceed with the proposed Information Collection Request (ICR) and perhaps expand it to include data collection from more Publicly Owned Treatment Works (POTWs). Our on-demand webinar, US EPA Information Collection Rule (ICR) for PFAS and NPDES, takes a deep dive into the ICR if you’re looking for more details.
Priority: Implement section 8(a)7 to smartly collect necessary information, as Congress envisioned and consistent with TSCA, without overburdening small businesses and article importers.
Our take: The way this statement is worded leads us to believe there may be some reporting exemptions added. A few days ago, the agency also announced a proposed extension to the reporting deadlines. It’s not yet clear if the agency intends to take additional action to decrease the reporting burden. TSCA reporting doesn’t typically require PFAS testing, so my team isn’t usually involved. Nevertheless, our Regulatory and Compliance team does work with TSCA clients, so they are watching this one closely.
Priority: Finish public comment period for biosolids risk assessment and determine path forward based on comments.
Our take: Biosolids have already received a lot of attention from state legislators in 2025. This priority seems to recognize that biosolids can be a critical contributor to PFAS contamination. We’ve been testing PFAS in biosolids for several years, so we’re very interested in seeing what direction EPA takes after they finalize the report.
Update: While we didn’t comment on EPA’s review of the National Primary Drinking Water Regulations, the agency has since announced their intentions. The Maximum Contaminant Levels (MCLs) for PFOA and PFOS will remain as is; however, the limits for PFHxS, PFNA, HFPO-DA and the Hazard Index will be rescinded and reconsidered. The full announcement can be found on the EPA’s website.
A First Step
No matter how vaguely worded, we believe this announcement moves the ball forward. At a minimum, we now know that the current administration isn’t planning to bury PFAS, metaphorically speaking at least. Under the Biden administration, the agency took what started as the PFAS Action Plan in 2019 and turned it into a PFAS Strategic Roadmap. Leveraging what had been learned in two short years, this document included more detail and more specific priorities and objectives, giving those impacted by the agency’s actions a heads up on what to expect. Our hope is that the current EPA administration will take a similar path.
