EPA’s New PFAS Guidance Matters to Utilities
The Environmental Protection Agency is taking another step toward addressing PFAS contamination in wastewater and sewage sludge. In July 2026, EPA released draft guidance focused on PFOA and PFOS in biosolids. The agency also extended the public comment deadline through October 5, 2026. (epa.gov)
For wastewater utilities, this development deserves attention now. PFAS can enter treatment plants from industrial, commercial, and household sources. Conventional wastewater treatment generally does not destroy these persistent chemicals. (epa.gov)
What Is EPA Proposing?
EPA’s draft guidance offers voluntary recommendations for managing PFOA and PFOS in sewage sludge and biosolids. The guidance addresses wastewater operators, landowners, farmers, state agencies, Tribal agencies, and the public. (epa.gov)
EPA has not created a new binding federal biosolids limit through this guidance. However, the recommendations may influence future regulatory decisions and state requirements. Utilities should understand the guidance before additional obligations develop.
Why PFAS Can Become a Wastewater Problem
PFAS often reach wastewater plants through upstream discharges. Sources can include industrial facilities, landfills, commercial laundries, firefighting foam, and consumer products. (epa.gov)
Treatment plants were not designed to eliminate most PFAS compounds. Some PFAS can remain in treated water or concentrate in sewage sludge. That creates challenges for utilities managing biosolids through land application, landfills, or other methods.
Our article on PFAS spreading through fertilizer explains why land-applied biosolids have received increasing scrutiny.
What EPA Wants States to Consider
EPA currently recommends monitoring biosolids for PFAS contamination. The agency also encourages states to identify likely industrial PFAS sources. (epa.gov)
Pretreatment programs may become increasingly important in this process. Controlling PFAS upstream can reduce contamination reaching wastewater facilities. This approach focuses attention on pollution sources instead of expecting utilities to solve the problem alone.
Utilities should also preserve testing, disposal, and source information. Historical records may become important as regulations, cleanup costs, and legal claims develop.
Who Should Pay for PFAS Cleanup?
Wastewater utilities often receive PFAS they did not manufacture or intentionally use. Yet municipalities may face testing, treatment, disposal, and infrastructure costs because of that contamination.
That distinction matters when evaluating responsibility. Communities should carefully investigate where PFAS entered their wastewater systems. Industrial dischargers, product manufacturers, airports, landfills, and other sources may require closer examination.
Our PFAS and water contamination practice addresses legal issues involving municipalities and other parties affected by PFAS pollution.
Why the October 5 Deadline Matters
EPA is accepting public comments on the draft guidance through October 5, 2026. Those comments may help shape final recommendations and future PFAS actions. (epa.gov)
Wastewater utilities have practical experience that regulators need. Their comments can address testing costs, treatment limitations, disposal capacity, source control, and operational realities.
EPA provides additional information through its PFAS sewage sludge and biosolids guidance.
What Utilities Should Do Now
Utilities should begin by reviewing existing PFAS testing and biosolids management practices. They should also identify significant industrial and commercial contributors to their wastewater systems.
You should secure and retain relevant documents. Contracts, sampling data, discharge records, permits, disposal records, and communications may become important later.
PFAS policy continues to change quickly. Municipalities that understand their contamination sources can make better operational, regulatory, and legal decisions.
If PFAS contamination has created significant municipal costs, early evaluation can help identify available options. Stag Liuzza is working with municipalities across the country to hold the chemical companies that polluted water accountable for PFAS remediation costs, and we may be able to help.



