EPA Releases PFAS Strategic Roadmap

On October 18, 2021 EPA released its PFAS Strategic Roadmap that includes a comprehensive and ambitious plan for addressing the potential risks associated with PFAS. A copy of the document is available at: PFAS Strategic Roadmap: EPA’s Commitments to Action 2021—2024. 

EPA Administrator Michael Regan formed an EPA Council on PFAS comprised of members from numerous offices within EPA Headquarters and Regions who were instrumental in developing the Roadmap – Radhika Fox, Assistant Administrator for Water, and Deb Szaro, Acting Regional Administrator, Region 1, co-chair the EPA Council on PFAS .

The Roadmap provides a detailed outline of the key actions EPA plans to undertake to address PFAS with proposed time lines for each action. A summary of the key actions and target dates is provided below.

National PFAS Testing Strategy

• Issue test orders to PFAS manufacturers
• Require PFAS manufacturers to conduct and fund testing (Expected by end of 2021)

TRI & TSCA Reporting

• Expand TRI reporting for PFAS (Spring 2022)
• Finalize new PFAS reporting rule under TSCA Section 8 (Winter 2022)

Drinking Water (DW)

• Monitor PFAS in DW (Fall 2021)
• Develop DW standard for PFOS & PFOA (Proposed - Fall 2022 & Final – Fall 2023

Revise ELG for PFAS discharges to POTWs

• Proposed rule for organic chemical, plastics, and synthetic fiber manufacturers can release into water (Summer 2023)
• Proposed rule for Metal Finishing (Summer 2024)

Water Discharges

• Use NPDES permits to reduce PFAS discharges into waterways (Winter 2022)
• Develop water quality criteria for PFAS
  • Aquatic life criteria (Winter 2022)
  • Human health criteria (Fall 2024)
• Monitor fish tissue for PFAS (Summer 2022) and issue fish advisories (Spring 2023)

Waste Management and Remediation

• Finalize risk assessments for PFOA and PFOS in biosolids (Winter 2024)
• Designate PFAS as hazardous substances under CERCLA (Proposed Spring 2022 & Final Summer 2023)
• Update guidance on destruction and disposal of PFAS (Fall 2023)

Air Emissions

• Build technical foundation to address PFAS air emissions (Fall 2023)

Technical Research and Development

• Finalize and lab validate analytical methods for PFAS (Winter 2022)
• Continue to assess human health and environmental risks for PFAS
• Evaluate and develop technologies for reducing PFAS in the environment

Enforcement & Compliance

• Address Environmental Justice concerns in communities impacted by PFAS (Fall 2021)
• Use enforcement tools to address PFAS releases at facilities
• Establish a PFAS Voluntary Stewardship Program (Spring 2022)

Public Outreach

• Educate the public about the risks of PFAS
• Issue Annual Reports on progress to address PFAS (Winter 2022)

One broad area of concern is EPA’s repeated reference to PFAS generally as a class as opposed to specific PFAS compounds (with a few exceptions). NASF as well as its industry partners continue to oppose the regulation of PFAS as a broad class, advocating that each individual PFAS compound should be assessed on its own merits and potential risks to the environment and human health.

In addition, EPA identified a schedule for developing the PFAS wastewater discharge limits for the metal finishing industry sector.  EPA has targeted Summer 2024 for a proposed rule. 

While it is favorable news that the surface finishing industry will have additional time for the rulemaking, The Policy Group on behalf of NASF has initiated recent discussions with EPA officials on this new rulemaking and has begun gathering data to inform the process.  If you have any questions about the PFAS wastewater discharge rulemaking or the EPA PFAS Strategic Roadmap, contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.  

This update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.