Our View of EPA’s New Guidance on PFAS in Biosolids

Conversation Shifts to Data-Driven Understanding of Risk

On June 29, 2026, the United States Environmental Protection Agency (EPA) released draft guidance (pdf) on managing risks associated with PFOA and PFOS in biosolids, offering an important clarification of its January 2025 Draft Risk Assessment.

That earlier assessment sparked significant concern across the wastewater, biosolids, and agricultural sectors, as it suggested the potential for elevated human health risks from land-applied biosolids based on a conservative test case. But in this newly released guidance, EPA explicitly acknowledges that the assessment lacked clarity and created confusion for both the regulated community and the public.

This new guidance does not walk back concern around PFAS. Instead, it provides needed context for how risk should be understood, communicated and managed going forward.

Reframing the Risk Conversation

This recent guidance shifts how biosolids risk is characterized. EPA makes clear that the earlier assessment relied heavily on conservative, higher-risk hypothetical scenarios that did not represent most real-world land application practices or true exposure risks to most Americans.

In doing so, the agency also acknowledges what was missing in the 2025 draft: a national survey of PFOA and PFOS in biosolids, an evaluation of how often higher-risk scenarios occur, and a broader assessment of how the public is exposed to biosolids-related pathways.

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Without this context, the earlier draft created a perception that all biosolids use poses an unacceptable risk. The new guidance directly addresses that misconception. It reinforces that biosolids risk depends upon site conditions, exposure scenarios, and the presence (or absence) of PFAS sources within a given system.

This distinction matters. It shifts the conversation away from broad generalizations and toward a more nuanced, data-driven understanding of risk.

Balancing Risk With the Value of Biosolids

While much of the public discussion has focused on potential risks, EPA’s new guidance also reaffirms the importance of biosolids as a resource. The agency continues to support beneficial reuse and land application as a critical component of wastewater management.

That support reflects both practical and environmental realities. Biosolids provide nutrients and soil-conditioning benefits, reduce dependence on synthetic fertilizers, and offer a cost-effective residuals management option for utilities — particularly in regions where landfill or incineration capacity is constrained.

At the same time, EPA acknowledges that biosolids management exists within a broader system of tradeoffs. Limiting or eliminating land application without viable alternatives can introduce new environmental impacts and significantly increase costs for utilities and customers.

In this context, the agency’s message is clear: biosolids remain a viable and valuable management option — but one that must be informed by better data, clearer communication, and more proactive risk management. EPA also notes that some land application scenarios may warrant greater scrutiny than others, particularly where opportunities for human exposure are higher, further reinforcing the need for site-specific decision making.

Regulations Remain Undefined

One of the most notable aspects of the guidance is the absence of criteria. EPA does not propose numeric PFAS limits for biosolids, revisions to 40 CFR Part 503, or a timeline for future rulemaking.

Instead, the agency suggests a more incremental approach that relies on continued data collection, stakeholder input, and state-led initiatives to inform future decisions. Across the country, states have moved forward with their own approach to managing the PFAS risks from the land application of biosolids, ranging from monitoring requirements to pretreatment strategies and, in some cases, restrictions on land application. Several state programs have also demonstrated that industrial source control and pretreatment initiatives can significantly reduce PFAS loadings to wastewater treatment plants (WWTPs), reinforcing the value of upstream risk reduction as part of a broader biosolids management strategy.

The result is a regulatory environment that is both active and uncertain. Federal direction is still evolving, while state-level actions continue to expand and diversify. For utilities, this creates a challenging but familiar dynamic: the need to plan ahead in the absence of fully defined future requirements.

Although federal standards do not currently exist, the expectations of regulators, stakeholders, and communities do. Utilities are being asked to better understand PFAS in their systems, to demonstrate responsible management of biosolids, and to communicate clearly about what is known and what is still evolving.

What Utilities Should Be Doing Now

The EPA is asking for comments on this guidance, so the immediate action is to provide your feedback by Sept. 4, 2026. In addition, there are several actions you can take to position your utility for future impacts of PFAS and manage your risk. Those include: 

• Track federal and state PFAS regulatory developments and evaluate potential impacts on biosolids management.
• Develop and implement structured PFAS sampling and analysis plans to establish baseline conditions, trends and concentrations in biosolids and plant effluent.
• Assess and strengthen pretreatment programs to better identify and control industrial PFAS sources (pdf).
• Evaluate biosolids management practices, including land application strategies and alternative disposal options. 
• Build clear, proactive communication strategies for regulators, customers, agricultural partners and the public.
• Monitor technology advances for PFAS reduction at WWTPs to inform viable and sound roadmaps for future implementation.  
• Engage with peer utilities to share data, lessons learned and emerging practices. 
• Develop a proactive and specific biosolids master plan that addresses equipment age and condition, energy recovery, alternative end-use options and future PFAS risks. Following a comprehensive plan will guide progress with biosolids management and reduce the risk and costs of future compliance.

The utilities that understand their data, engage their stakeholders, and define a clear strategy will be best positioned to adapt when regulations are confirmed. At HDR, we see this new guidance as an opportunity to address PFAS in our wastewater systems and to help utilities approach risk, communication, and residuals management in an increasingly complex regulatory environment.

Need help getting started? Contact Brian.Bakke [at] hdrinc.com (Brian Bakke) at or connect on LinkedIn.