On April 28, 2025, the U.S. Environmental Protection Agency (EPA) announced "major EPA actions to combat PFAS contamination." EPA Administrator Lee Zeldin said that he has "long been concerned about PFAS and the efforts to help states and communities dealing with legacy contamination in their backyards. With today's announcement, we are tackling PFAS from all of EPA's program offices, advancing research and testing, stopping PFAS from getting into drinking water systems, holding polluters accountable, and providing certainty for passive receivers. This is just a start of the work we will do on PFAS to ensure Americans have the cleanest air, land, and water."
Some have read these words as portending a major rollback of federal PFAS regulations. The announcement last week was mostly short on specifics about what EPA might do about PFAS beyond the many actions taken in the past 3 1/2 years. But, given the many things that have been done – and increasing clarity about the difficulties some of those things present for states, municipalities and industry – one might consider whether some deliberation now about EPA's next steps would make sense in any administration.
One specific change EPA does promise is that it will provide annual updates to its PFAS Destruction and Disposal Guidance. We should welcome that change. If PFAS are the "urgent public health and environmental issue" that EPA has said they are, identifying cost-effective and sustainable ways to dispose of them should be a high priority.
But until last week the PFAS Destruction and Disposal Guidance was due to be updated only every three years. To make matters worse, the last PFAS Destruction and Disposal Guidance – in April 2024 – didn't provide guidance regarding any of the technologies that have emerged to treat or dispose of PFAS. EPA said it was "neither recommending nor discouraging the use of any emerging technology for managing PFAS-containing materials." That may have been an appropriate position for EPA to take at the time, but we will all be better off when EPA approves any of the technologies that have been developed for disposing of or destroying PFAS.
In 2024 the U.S. Department of Defense (DOD) reported that there were 715 facilities at which PFAS releases have been or are being investigated. The DOD estimated that its bill for addressing these PFAS releases would be $7 billion, but that estimate has already gone up. Of course, the hundreds, if not thousands, of sites at which the DOD is not the only responsible entity aren't included in this number, so cost-effectiveness and sustainability are essential.
Fortunately, EPA's 2024 PFAS Destruction and Disposal Guidance included a detailed framework for the evaluation of PFAS destruction and disposal technologies. Consistent with Administrator Zeldin's commitment to advance PFAS research and the promise of annual PFAS Destruction and Disposal Guidance updates, hopefully EPA will soon use that framework to evaluate the many PFAS destruction and disposal technologies that have been developed over the past few years and make recommendations regarding the use of those technologies.
