On January 15, 2025, the United States Environmental Protection Agency (EPA) released a Draft “Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS)” for public comment.  EPA recently extended the public comment period and is now accepting comments on the draft risk assessment until August 14, 2025.  EPA said it was extending the deadline in response to stakeholder requests for more time. The National Association of Clean Water Agencies and the American Farm Bureau Federation were among the stakeholders requesting for additional time.

Sewage produced by households, businesses, and wastewater industrial discharges may be conveyed to a wastewater treatment plant, where it can be treated to produce a semi-solid, nutrient rich product commonly known as “sewage sludge” or “biosolids.”  Treated sewage sludge has a variety of uses, such as reclamation groundcover, agricultural fertilizer to feed crops, or other domestic activities such as gardening.  However, according to EPA, PFOA and PFOS may be detected in sewage sludge, even at wastewater treatment plants that only receive wastewater from residential and commercial users.

EPA asserts in its draft risk assessment that there may be some risk to human health associated with land application activities using sewage sludge that contain 1 part per billion (ppb) or more of PFOA or PFOS.  The draft risk assessment, even if finalized, does not contain regulatory thresholds, standards, or screening values, and does not compel action.  However, EPA can use the risk assessment to inform future regulatory decisions, such as whether to regulate PFOA and PFOS in sewage sludge under the Clean Water Act. 

As discussed in  prior posts, EPA’s initiatives regarding PFAS under the current  administration remain unclear.  It is not clear at this time whether EPA will delay or pause any further action on the sewage sludge risk assessment. 

For more on the Trump administration regulatory initiatives, visit our resource page, Trump Administration Initiatives & Executive Orders, or subscribe to our Oval Office Update on LinkedIn.