On November 14, 2024, EPA issued its third annual progress report on its PFAS Roadmap reporting on the agency’s three years of progress against its overarching goals of restrict, remediate, and research PFAS. The accomplishments highlighted by EPA include:

• Protecting drinking water: EPA reported its accomplishments in protecting drinking water include the establishment of drinking water standards for several PFAS and the ongoing collection of data under the fifth Unregulated Contaminant Monitoring Rule (UCMR5) which will provide data on the frequency of 29 PFAS in drinking water.  In addition, according to EPA, the Bipartisan Infrastructure Law has provided up to $10 billion in investment for the removal of PFAS and other emerging contaminants from water.
• Remediation of PFAS contamination: In 2024, EPA designated PFOA and PFOS as hazardous substances under CERCLA and designated certain PFAS as hazardous constituents under RCRA.  These designations facilitate site remediations and the ability of cooperating parties to obtain contribution from other responsible parties. 
• Advancing chemical safety: EPA reported that it finalized a rule to prevent inactive PFAS from reentering commerce which will prevent companies from resuming the manufacture or processing of 329 PFAS that have not been made or used for many years without a complete EPA review and risk determination.

• Protecting waterways: EPA reported that it finalized water quality criteria for PFOA and PFOS to protect aquatic life and that the agency is working on a proposal to impose technology-based Effluent Limitations Guidelines for PFAS manufacturers. 
• Pursuing enforcement and compliance: EPA reported on its inclusion of PFAS in its National Enforcement and Compliance Initiative for fiscal years 2024-2027.  The key goals of the initiative related to PFAS are to achieve characterization, control, and compliance for PFAS contamination from major manufacturers, federal facilities, and other industrial parties. EPA also issued its PFAS Enforcement Discretion and Settlement Policy which clarifies that the agency’s enforcement is focused on industrial and commercial contributors to PFAS contamination and not on entities like farms or water utilities.

• Research: EPA reported that its National PFAS Testing Strategy will be used to obtain toxicity data and information from manufacturers on categories of PFAS and the agency noted that many of the PFAS on the market have limited or no toxicity data.  
• Reducing PFAS in products and purchasing: EPA reported on its actions to reduce PFAS uses in commerce, including EPA’s action to require EPA custodial contractors to purchase cleaning products that are free of PFAS by joining the General Services Administration program to  cut PFAS from U.S. government custodial contracts.

It is unclear what, if any, changes EPA will make to its PFAS Roadmap under the upcoming Trump Administration. As noted in our prior article, President-elect Trump has nominated former Representative Zeldin to be the EPA Administrator.  While Zeldin is expected to pursue a ‘deregulatory agenda,’ it remains to be seen what that will mean for PFAS, since he has supported PFAS regulation in the past.