July 30, 2026

Draft Guidance on Reducing PFOA and PFOS Risks in Sewage Sludge and Biosolids

When domestic and industrial sewage is received by wastewater treatment plants (WWTPs), liquids and solids are separated, producing a semi-solid, nutrient-rich product known as sewage sludge. While the terms “biosolids” and “sewage sludge” are often used interchangeably, EPA specifies that “biosolids” means sewage sludge that is intended to be land applied as a soil amendment or fertilizer and that has been treated to meet Clean Water Act standards found in 40 CFR Part 503. In the United States, approximately 60% of sewage sludge becomes biosolids, 25% is landfilled, and 14% is incinerated.

The two most well-known and well-studied per- and polyfluoroalkyl substances (PFAS) are perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). While domestic production of these two PFAS has mostly been phased out in the U.S., these toxic, environmentally persistent, bioaccumulative chemicals still find their way into WWTPs. Because traditional wastewater treatment technologies do not remove or destroy PFOA or PFOS, these chemicals accumulate in sewage sludge and, in turn, contaminate the ground and waterways when biosolids are land-applied. EPA recently published and is seeking comment on a draft memorandum that provides stakeholders with guidance on reducing potential risks posed by PFOA and PFOS in biosolids. [91 FR 41020]

For WWTP operators, EPA recommends a combination of source identification, pollution prevention, and monitoring to trace the origin of PFOA and PFOS contamination. For the public, individuals can avoid applying biosolids in areas where children have access or in garden beds intended for food crops. The agency suggests several more robust recommendations for bulk land appliers of biosolids, including:

Avoiding land application of sewage sludge near fishable waters, lakes or reservoirs used as a source of drinking water, or areas that may have higher risks for potential groundwater impacts.
Avoiding applying sewage sludge in areas where children under the age of five have access or may have access in the future. Landowners should also be aware other potential sources of PFAS could impact or be present on their land.
Conducting land application on farms with lower-risk crops for human exposure, like farms growing grain, fiber crops, or corn for ethanol production.
Avoiding land application for agricultural practices that have higher risks for human exposures.

This memorandum is non-binding and does not have the force and effect of law. The intent is merely to provide voluntary recommendations for mitigating PFOA and PFOS risks in sewage sludge and biosolids. Comments on the draft guidance may be submitted through September 4, 2026 via Docket ID No. EPA-HQ-OW-2026-2509.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.

Disclaimer

Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.