The U.S. Environmental Protection Agency (EPA) recently released draft guidance outlining voluntary recommendations for reducing potential risks from perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) in sewage sludge and biosolids. The guidance is intended for wastewater treatment plants (WWTPs) and related facilities, landowners and farmers, state and Tribal water agencies, and the public. The guidance focuses specifically on PFOA and PFOS; broader references to per- and polyfluoroalkyl substances (PFAS) in the context of biosolids should be used carefully unless discussing the larger class of compounds or related source-reduction efforts.
Biosolids are sewage sludge that has been treated by a WWTP and managed to meet applicable requirements under the Clean Water Act (CWA) Part 503 regulations for land application, surface disposal, or incineration. EPA has historically recognized land application of biosolids as beneficial, providing nutrients/organic matter to soil, restoring/enhancing soil quality, as well as providing cost-effective residuals management for wastewater facilities.
Rather than discouraging beneficial reuse, EPA’s draft guidance discusses risk-reduction practices intended to help stakeholders make more informed, site-specific decisions about land application. The recommendations address various practices, management of sewage sludge through other pathways, and steps that WWTPs can take to identify and reduce PFOA/PFOS before they end up in in residual solids or pass through the treatment system via effluent.
Why EPA Is Revisiting PFOA and PFOS Risks in Sewage Sludge
EPA’s latest guidance follows the 2025 Draft Risk Assessment that evaluated potential human health impacts associated with PFOA/PFOS in sewage sludge. After reviewing stakeholder feedback, EPA identified limitations that created uncertainty and confusion about how the preliminary findings should be interpreted. In particular, EPA noted that the assessment focused on higher-exposure hypothetical scenarios, did not estimate how frequently those scenarios occur nationwide, and did not include a national occurrence survey sufficient to characterize the range, frequency, and geographic distribution of PFOA/PFOS in sewage sludge. EPA also clarified that the use of 1 part per billion (ppb) was not intended to represent a universally safe or unsafe threshold for biosolids.
The exposure pathways included migration to groundwater and farm ponds, uptake into crops, transfer to livestock, potential accumulation in milk, meat, eggs, or fish, and human exposure through drinking water or food-chain pathways. These pathways are important, but the associated risks depend heavily on chemical concentrations, cumulative loading, site conditions, land use, crop selection, and receptor behavior.
The new guidance shifts the focus to practical risk-reduction measures that can be implemented, while EPA continues to evaluate occurrence data, exposure assumptions, and potential future regulatory or administrative actions. This approach better reflects the site-specific nature of biosolids management and the need to consider source and end-use controls.
Recommended PFAS Risk-Reduction Practices for Land Application of Biosolids
EPA’s draft guidance identifies several practices for reducing potential exposure to PFOA/PFOS, while allowing stakeholders to evaluate whether continued beneficial use is appropriate based on local requirements, management practices, site-specific exposure pathways, and available alternatives.
Although much of the draft guidance focuses on land application, EPA is also seeking feedback on surface disposal and incineration. This broader context is important because utilities may need to evaluate multiple management options, including land application, landfill disposal, surface disposal, or incineration based on capacity, cost, permits, local acceptance, residuals characteristics, and PFAS-related release pathways. Incineration should not be presented as a simple solution because technical questions remain regarding destruction efficiency, air emissions, incomplete combustion products, residual ash management, and monitoring requirements.
While EPA has not concluded that all land-applied biosolids result in unacceptable risks, agricultural and environmental investigations highlight the potential for PFAS accumulation in soil. EPA’s guidance encourages WWTPs and other sewage sludge generators to consider source identification, pollution prevention, and monitoring. These practices can help facilities to identify significant sources of PFOA/PFOS entering the wastewater system and evaluate opportunities to reduce them.
For bulk land application, EPA recommends avoiding areas near fishable waters, drinking water sources, and locations with greater potential for groundwater impacts. The agency also recommends avoiding playgrounds, schools, parks, and residences, while favoring uses associated with lower potential for human exposure, such as grain, fiber crops, and corn grown for ethanol production.
For biosolids used in homes and communities, EPA recommends researching the supplier and avoiding application in locations where children may come into contact with treated soil. The guidance also advises against using biosolids in garden beds for edible produce with greater potential to take up PFOA/PFOS, including leafy greens and root vegetables, or in areas accessible to egg-laying hens.
State Source Reduction Strategies Limit PFOA and PFOS in Wastewater Systems
Because traditional wastewater treatment does not remove or destroy PFOA/PFOS, these substances can accumulate in sewage sludge to varying degrees during treatment. EPA’s draft guidance points to source reduction as one of the control methods limiting the amount of PFOA and PFOS entering wastewater systems and ultimately accumulating in biosolids.
Several states have implemented programs to identify significant sources of PFAS entering sewer systems and reduce discharges from industrial facilities. EPA highlights programs in Michigan, Wisconsin, Minnesota, Colorado, Maryland, and Virginia based on a tiered approach that uses PFOA/PFOS levels as indicators of significant contributors and measures for controlling land application. Other states are mulling similar approaches that involve monitoring/studies, source identification, and/or targeted reductions/prohibitions, although specific requirements, concentration thresholds, and rule/guidance adoption mechanisms vary. Two states, Connecticut and Maine, have banned land application altogether.
How EPA’s Biosolids Guidance Fits Within the Broader PFAS Regulatory Landscape
Agency’s actions on biosolids are not taking shape in a regulatory vacuum. EPA’s multifront approach to PFAS intersects with additional aspects of the Clean Water Act(CWA permitting, guidance, ambient water quality criteria [final for aquatic life and draft for human health], and effluent limits), as well as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA hazardous substance final designation), Resource Conservation and Recovery Act(RCRA proposed listing has hazardous constituents), Safe Drinking Water Act (SDWA drinking water standards), Toxic Substances Control Act (TSCA notifications, reporting, and recordkeeping), Federal Food, Drug, and Cosmetic Act (FFDCA monitoring), and Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA ingredients and containers). The multiple regulatory pieces in motion, plus pending legal challenges, add notable complexity to biosolids management. This matters because biosolids stakeholders are evaluating not only technical risk, but also regulatory uncertainty, potential future standards, and liability concerns associated with generation, transport, land application, disposal, and long-term residual management.
What Wastewater Utilities, Farmers, and Landowners Should Do Next
As the regulatory approach to PFOA and PFOS in biosolids continues to develop, wastewater utilities, landowners, farmers, and other stakeholders should evaluate how EPA’s recommended practices may apply to their operations, how state or local requirements may differ, and whether source-control, sampling, communication, or alternative-management strategies are warranted.
EPA is accepting public comment on the draft guidance through September 4, 2026. The agency is seeking feedback on the draft recommendations, additional risk-reduction practices, existing state and local approaches, and potential next steps for the 2025 Draft Risk Assessment.
