Understanding PFAS Compliance: Regulations and Effective Management

Posted on October 31, 2023

PFAS are a group of synthetic poly- and perfluoroalkyl chemicals that are extremely resistant to degradation. Due to their widespread use and very slow degradation, some of them have been  found nearly everywhere in our environment today—in the soil, water, air, in many food products, and even in the blood of humans and animals.

Despite several of the compounds being potentially linked to a range of negative health effects by the EPA and CDC, many PFAS continue to be used in industrial and manufacturing processes and do not have many regulations governing their use and disposal.

Why and how are PFAS used?

Developed in the 1930s and first used commercially in the 1940s, PFAS have been implemented in thousands of consumer products, industrial processes, and military applications over the past 90 years. They continue to be developed and used to this day because of unique properties that make them versatile and useful:

  • Temperature resistance
  • Repel oil, water, and other liquids
  • Friction reduction
  • Increase the stability and durability of other materials

Those properties have led to PFAS being used in a wide variety of industrial applications since the 1940s:

  • Coating and insulation for wire manufacturing
  • Surface coatings on paper products to repel grease and moisture
  • Preventing corrosion and reducing wear on metal plating and etching
  • Creating stain resistant carpet and waterproof outerwear in the textile industry
  • Food packaging and non-stick cookware
  • They are a key ingredient in many industrial surfactants, resins, molds, and plastics
  • Photoresists, top and bottom anti-reflective coatings, and etchants in the semiconductor industry

The problem with PFAS

There are thousands of different PFAS that have been synthesized and, because they break down so slowly, they have built up in our environment. People encounter these chemicals in a multitude of ways, and some leave the body slowly over time, leading to accumulation in our bodies. According to the CDC, some studies have identified a potential relationship between certain PFAS and harmful health conditions or side effects. The bottom line is that it is very easy for PFAS to enter the water supply, soil, and other parts of the environment, but they can be difficult to remove.

The regulatory situation around PFAS compliance

In general, there are few rules currently governing the use and disposal of PFAS. PFAS are also not presently designated as a hazardous waste by the EPA. However, the EPA and many states are beginning to take steps to control the release of these chemicals into the environment.

Many current and proposed regulations deal with PFAS and water. The Clean Water Act established the National Pollutant Discharge Elimination System (NPDES), including guidelines that apply to manufacturers, formulators, and metal plating facilities that discharge materials that may be harmful to human health or aquatic life. Under this regulation, USEPA and the states could soon regulate PFAS in wastewater discharges and treatment residuals.

In addition to the Clean Water Act, here are some updates on regulations that may come into effect over the next couple of years:

  • In March 2023, the EPA proposed maximum contaminant levels (MCLs) for six different PFAS in drinking water. This regulation is expected to be finalized in early 2024.
  • In May 2024, a proposal is expected to revise effluent limitation guidelines for industrial sectors that manufacture PFAS and discharge to surface water or sewage treatment plants.
  • On August 26, 2022, the EPA proposed to designate PFOS and PFOA as hazardous substances under CERCLA, or Superfund. The final ruling is expected in February 2024.
  • A ruling is scheduled for August 2023 to determine whether four PFAS compounds are considered hazardous constituents under RCRA.
  • The USEPA is expected to update guidance on disposing of materials containing PFAS by December 2023.

How we can manage PFAS

There are steps we can take to remove these chemicals from water, prevent further introduction into the environment, and adhere to current PFAS regulations. There are several options for treating PFAS found in water:

  • Granulated activated carbon filters that catch contaminants for removal
  • Ion exchange resins that attract and hold contaminants
  • Reverse osmosis and nanofiltration use pressurized membranes
  • Other absorbents, electrochemical oxidation, foam fractionation, plasma, and UV radiation are alternative proposed methods that may be effective at removing harmful chemicals from water

Besides treating PFAS in  water, the primary action we can take to protect our environment is to dispose of these compounds properly.  Under current regulations in most states, PFAS when present in waste do not yet require special disposal practices.

However, to ensure that wastes containing PFAS are properly contained,  we can use methods like deep well injection, which places contaminated waste far underground beneath aquifers that supply drinking water; solid waste Subtitle D, or hazardous waste Subtitle C landfills; or they may be treated in incineration or fuel blending units permitted for RCRA hazardous waste.

Remember PCBs

Although the regulation and management of PFAS is in its early stages, it is likely to accelerate quickly. Our current situation is remarkably similar to the PCBs in the 1970s. Just like PFAS, PCBs and dioxins were widely used in a variety of products and industrial processes between the 1920s and 1970s.

Once it became known that PCBs and dioxins were linked to potential harmful side effects and just how concentrated they were in the environment (they were found in the ground, water, and living things from major cities to the arctic, and everywhere in between), public opinion turned rapidly against them. Regulators then moved quickly to ban the use of these chemicals in 1979.

PCBs and dioxins are regulated under CERCLA, they are banned from being manufactured, and the EPA has required reporting, record keeping, and testing. What this tells us about the current PFAS situation is that you need to act sooner rather than later. Industries and operations that use PFAS should get out ahead of the situation, take steps to limit their use, and implement safe ways to dispose of them, before they are forced to do so quickly by a rapid change in opinion and laws.


The information contained in this statement is based on the Veolia group's understanding and know-how of the scientific and technical fields discussed herein as of the time of publication. Statements that may be interpreted as predictive of future outcomes or performance should not be considered guarantees of such, but rather reasoned assessments of the possible evolution of the technologies described. As this document is based on the state of the Veolia group's scientific, technical, and regulatory knowledge at the time of its publication, the completeness and accuracy of the information contained herein cannot be guaranteed. Descriptions contained herein apply exclusively to those examples and/or to the general situations specifically referenced, and in no event should be considered to apply to specific scenarios without prior review and validation.

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