October was a slow month at the EPA due to the current government shutdown in D.C. However, that gives me a chance to catch up on actions taking place in states across the country. Even though the majority of state legislatures have recessed for the year, some are still in session while others passed laws granting authority to state agencies to carry on the work of addressing PFAS contamination.
FEDERAL PFAS ACTIONS
Before we get into the state PFAS action, here’s one quick federal development that was automatically implemented despite the shutdown.
EPA Adds PFHxS-Na to Toxic Release Inventory
On October 7, the EPA announced the addition of PFHxS-Na (CASRN 82382-12-5) to the Toxic Release Inventory (TRI). This PFAS compound was automatically added due to the finalization and publication of its toxicity value in the Integrated Risk Information System (IRIS) database. PFHxS may be found in certain fire-fighting foams, waterproof/stainproof textiles, metal plating operations, and cleaning agents.
KEY STATE PFAS ACTIONS
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Maine has been at the epicenter of concerns over PFAS in agriculture. To help the state’s cattle farmers preserve their business, the Maine CDC has introduced an interesting new tool. This online resource provides practical guidelines and actionable steps for identifying potential sources of PFAS on farms, implementing best management practices, and reducing the risk of chemical exposure in livestock.
Illinois
Last month we reported that HB 2516 was signed by the Governor. Starting in 2032, this new law prohibits intentionally added PFAS in several product categories, including cosmetics, dental floss, juvenile products, menstrual products, intimate apparel, food packaging, and food contact products. At the same time, the Governor also signed HB 2409, banning the manufacture, distribution, and sale of Personal Protective Equipment (PPE) intended for firefighting in which PFAS was intentionally added as of January 1, 2027,
New York
Last year, New York passed legislation prohibiting the sale of new apparel containing intentionally added PFAS as of January 1, 2025. This legislation gave the NY Department of Environmental Conservation (NYDEC) until January 1, 2027, to define those limits. In August, NYDEC held a stakeholder meeting to consider a proposal to limit individual PFAS analytes added to apparel to 25 to 1000 parts per billion (ppb) and all PFAS to 50 parts per million (ppm) as measured in total organic fluorine (TOF). Comments on the proposal were due September 25, 2025.
Only a couple of states have set limits for PFAS as measured in TOF. In part, that may be because of method challenges and limitations to using TOF as a representation of total PFAS in consumer products. If you have questions or concerns about analyzing for TOF, feel free to reach out to us. We’d be happy to walk through your project/compliance requirements to help determine the best approach.
North Carolina
The North Carolina Department of Environmental Quality recently mandated an expansion to private well testing eligibility under a program funded by Chemours. According to reports, this opens up funds to around 14,000 additional homeowners.
Massachusetts
Massachusetts, one of the few state legislatures still in regular session, is currently considering H136, a bill that would regulate the land-application of biosolids from a wastewater treatment plant in agriculture. Although its legislative session ends in Mid-November, Massachusetts allows bills to be carried over into next year’s session.
California
In the era of increased regulatory attention to PFAS, Governor Newsom is one of the few state governors to veto PFAS-related legislation. On October 13, Newsom vetoed SB 682, which would have banned PFAS in a variety of consumer products, citing concerns about affordability and rapid market shifts.
Wisconsin
In October, the Wisconsin Department of Natural Resources held a public meeting on its proposal to establish state standards for PFAS in drinking water that match those enacted by the U.S. EPA in 2024. This means that, if the national primary drinking water regulations are rolled back to only include PFOA and PFOS, water systems in Wisconsin will still need to comply with the 10 parts per trillion (ppt) individual limits for PFNA, PFHxS, and GenX chemicals as well as the Hazard Index limit for these three compounds plus PFBS. As we’ve reported, the EPA intended to issue a Notice of Proposed Rulemaking in September, but the government shut down has stalled the agency’s progress.
PFAS NEWS OF INTEREST
New study calls for scienced-based regulation of fluoropolymers
Wastewater study says domestic wastewater is a major contributor to PFAS levels
A legal look at how PFAS is being addressed in Phase I ESAs
A look at Phase II ESA data at dry cleaners, car washes, airfields, and warehouses
Detection & quantitation of PFAS in sea foam vs bulk water samples
An analysis of PFAS levels in U.S. meat, poultry, catfish, and eggs
Wisconsin duck and fish advisories
PFAS WEBINARS & VIDEOS
Webinar: Comprehensive Overview of Core Discrete Fracture Network (COREDFN): A High-Resolution Approach to Bedrock Investigations Involving VOCs and PFAS – This webinar will be conducted in two parts. The first session (Nov 12th, Noon ET) will focus on an overview of COREDFN and its application to VOC-contaminated sites. A follow up session (Dec 10th, Noon ET) will focus on the adaptation of COREDFN to sites with potential PFAS contamination. Both sessions will be highly informative for those focused on PFAS detection, particularly in Environmental Site Assessments, CERCLA compliance, and remediation-related projects. Register here.
On-demand Webinar: Biosolids Analysis for PFAS: Challenges, Considerations, and Options Analyzing PFAS levels in biosolids presents unique challenges. In this webinar replay, Nick Nigro, Pace® PFAS Product Manager, provides considerations and alternatives to ensure you are getting analytical data that meets your project objectives. Watch the webinar.
On-demand Webinar: Mastering the Challenges of Sediment and Biota Analysis – This on-demand session examines the challenges of sample prep, extraction, and cleanup for the analysis of various compounds, including PFAS, in sediment and plant/animal tissue. Watch the webinar.
Forever Ends Here The Future of Water: The World’s Leading Tech to Eliminate PFAS Forever Chemicals – I recently had the pleasure of talking about our role in validating the results from Invicta Water’s development of PFAS destruction technology. You can watch the video on YouTube.
Reach Out with Your Questions
If you have any questions about PFAS testing and analysis, please don’t hesitate to contact us. We’re always happy to connect and help you find the information or resources you need. Looking forward to hearing from you!
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