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White Paper

EPA Releases Strategic Roadmap for PFAS

By Analise Lindborg, Scientist
Judi L. Durda, Chief Strategy Officer

Outlines Federal Direction for the next three years

On October 18, the U.S. Environmental Protection Agency (EPA) released its most comprehensive plan to date to address per-and polyfluoroalkyl substances (PFAS) in the nation’s water, soil, and air. The Roadmap outlines EPA actions to manage PFAS, including monitoring and regulation, through 2024. It is part of the Biden Administration’s overall plan to develop and implement a coordinated government-wide approach to addressing PFAS.

The Roadmap describes the suite of methods EPA will use to address PFAS, with implications for both the public and private sectors. Of particular note, the Roadmap includes:

Expanded Monitoring

EPA will expand PFAS monitoring and validate the analytical methods needed to be assured of the accuracy of monitoring results. The Fifth Unregulated Contaminant Monitoring Rule released earlier this year includes a suite of 29 PFAS to be monitored in drinking water. This information, along with additional toxicity studies, is expected to inform a national primary drinking water regulation for PFOA and PFOS and drinking water health advisories for GenX and PFBS by 2023. EPA plans to monitor PFAS in effluent through National Pollutant Discharge Elimination System permits and place restrictions on industrial PFAS discharges through Effluent Limitation Guidelines in 2022. EPA will conduct nationwide fish tissue surveys, finalize monitoring approaches for stack emissions and ambient air concentrations of PFAS, and prepare a finalized risk assessment for PFOA and PFOS in biosolids

Toxic Substances Control Act (TSCA) and Related Programs

Several measures related to the manufacture and use of new and banned PFAS will extend review periods, as “new PFAS are subject to rigorous reviews,” restrictions are placed on previously allowed low-volume exemptions, and new uses for previously approved PFAS are limited, subject to new notices and additional reviews. Enhanced reporting requirements will PUBLISHED October 19, 2021

Hazardous Substance Designation

In response to a push to designate PFAS as “hazardous substances,” EPA plans to list PFOS and PFOA as such under the Comprehensive Environmental Response, Compensation and Liability Act. This designation will require facilities to report PFOA Learn more at and PFOS releases that meet or exceed a reporting limit that has not yet been determined by EPA. This designation will increase federal, state, local, and tribal oversight and risk of cost recovery claims from agencies. Notably, EPA does not propose regulating any PFAS as “hazardous waste” under the Resource Conservation and Recovery Act.

No Grouping

Although there is expanded monitoring and proposed regulations placed on various PFAS through this new Roadmap and a plan to further define PFAS categories, EPA still intends to monitor and regulate PFAS individually, rather than as a single group of chemicals. This approach will accommodate consideration of the unique properties of each chemical when evaluating risks and determining management needs

All actions in the Roadmap are listed as “efforts ongoing” or given an expected completion time frame. EPA notes that this work is “subject to the availability of appropriations and other resources” and beyond the time frames, does not provide any prioritization of actions.

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