The contamination crisis from the “forever chemicals” known as PFAS is far from over, despite the Biden-Harris administration’s strides implementing its government-wide plan to combat PFAS pollution. EWG has identified steps the next administration should take to build on successes so far.
These steps are priority actions that the Environmental Protection Agency, Department of Defense and others can pursue to reduce PFAS pollution. The plan also includes calls for boosting federal funding to address contamination.
PFAS contamination in the U.S. is widespread, tainting drinking water for millions, and contaminating Superfund sites and the air people breathe. And the health harms from exposure to these chemicals are well known, including testicular, kidney, liver and pancreatic cancer; reproductive problems; weakened childhood immunity; low birth weight; endocrine disruption; and more.
The Biden-Harris administration followed through on many key parts of its PFAS plan, including the landmark April 2024 announcement of drinking water standards for six PFAS, the designation of two notorious PFAS as hazardous substances, a new framework for reviewing PFAS uses, and $10 billion in water grants and loans to address PFAS and emerging contaminants.
But there’s much more that must be done.
What follows are the priority federal actions the next administration can pursue to continue the fight against forever chemicals.
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Environmental Protection Agency
Protecting air, water and food from PFAS
- Double EPA funding for PFAS.
- Protect drinking water from additional PFAS.
- List PFAS as hazardous air pollutants
- Support state control of PFAS emissions into the air.
- Protect communities with environmental justice concerns from PFAS.
- Reduce PFAS discharges into impaired water bodies.
- Update Clean Water Act permits to monitor and prevent industrial discharges of PFAS.
- Strengthen the Effluent Guidelines program.
- Accelerate the development of technology-based limits on industrial sources of PFAS pollution.
- Strengthen protection of waters used as sources of drinking water.
- Enforce compliance by against industrial polluters and federal agencies causing pollution.
- Properly manage the disposal of PFAS waste.
- Stop using PFAS-contaminated sewage sludge as fertilizer.
- Protect fish and wildlife from PFAS.
Eliminating unnecessary PFAS uses
- End imports of PFAS wastes and tighten control over imports of PFAS-containing commercial products.
- Speed up review of PFAS already in use.
- Make sure new PFAS are safe before they enter the marketplace.
- Halt the use of PFAS for oil and gas extraction.
- Ban the use of PFAS in pesticides and containers.
- Ban PFAS in chrome plating using Clean Air Act authority.
- Ban PFAS in fluorinated plastics.
- Expand the Safer Choice program.
Cleaning up historic PFAS pollution
- Strengthen EPA oversight and enforce schedules for PFAS contaminated federal facilities.
- Designate more PFAS as hazardous substances.
- Certify destruction and disposal methods for PFAS.
PFAS science and solutions
- Add more PFAS to the Toxics Release Inventory.
- Make industry identify health harms from PFAS.
- Order industry to report how much PFAS are manufactured, imported and used, as well as their potential risks.
- Expand research on the uptake of PFAS by crops and potential bioaccumulation.
- Identify non-industrial sources of PFAS.
- Conduct research needed to control PFAS in air emissions.
- Significantly ramp up research on PFAS.
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Department of Defense
Protecting air, water and food from PFAS
- Give defense communities safe water to drink.
- Ban incineration of PFAS-firefighting foam and other PFAS wastes until proven safe.
Eliminating unnecessary PFAS uses
Cleaning up historic PFAS pollution
- Double funding for PFAS cleanup.
- Reform the DOD cleanup program.
- Empower communities to engage in DOD cleanups.
- Stop the spread of PFAS from federal facilities.
- Tell the truth about PFAS cleanup costs and time frames.
PFAS science and solutions
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Food and Drug Administration
Protect air, water and food from PFAS
- Fully fund the FDA’s Office of Food Chemical Safety.
- Permanently end the use of PFAS in food packaging.
- Set limits on PFAS concentrations in foods.
Eliminating unnecessary PFAS uses
PFAS science and solutions
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Department of Energy
Science and solutions
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Federal Aviation Administration
Eliminating unnecessary PFAS uses
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Department of Agriculture
Eliminating unnecessary uses of PFAS
PFAS science and solutions
- Investigate the impact on agriculture of PFAS contamination from DOD facilities and other sources.
- Inform farmers about PFAS contamination risks.
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General Services Administration
Eliminating unnecessary uses of PFAS
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Department of Health and Human Services
PFAS science and solutions
- Cover PFAS blood testing through Medicare and Medicaid.
- Update clinician guidance.
- Conduct research to prioritize PFAS based on health effects.
- Study health impacts in pollution hot spots.
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Federal Trade Commission
Eliminating unnecessary PFAS uses
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Department of Veterans Affairs
PFAS science and solutions
Double EPA funding for PFAS. The EPA is severely underfunded for efforts to review PFAS, establish controls on industrial discharges enforce restrictions on pollution, and conduct research necessary to support current and future air and water regulations. Over the next four years, the administration should double the agency’s funding for PFAS, which should be reflected in its funding requests to Congress.
Protect drinking water from additional PFAS. The agency is collecting monitoring data for 29 unregulated PFAS in drinking water from 2023 to 2026. According to early results, many unregulated PFAS have been detected in the drinking water delivered to households. Over the next four years, the agency should develop toxicological profiles for additional PFAS and issue standards to limit the levels of these contaminants in drinking water.
List PFAS as hazardous air pollutants. Hazardous air pollutants, or HAPs, are chemicals known to cause cancer and other serious health harms, such as reproductive and developmental harms, or adverse environmental impacts. There are currently 188 hazardous air pollutants listed under Section 112 of the Clean Air Act. Once listed as a HAP, the EPA and states can take steps under the law to reduce emissions, including implementation of technology-based standards. The agency should list PFAS as HAPs as quickly as possible so that polluting industries will install control technologies to reduce air emissions of PFAS.
Support state control of PFAS emissions into the air. States can regulate air emissions to address PFAS in the absence of federal Clean Air Act rules. Some states have taken or explored actions to address PFAS at specific facilities, including Michigan, New Hampshire and New York. Over the next four years, the EPA should provide guidance, along with funding and technical support, urging states to address PFAS.
Protect communities with environmental justice concerns from PFAS. Pollution hot spots, such as Louisiana’s “cancer alley,” persist for many communities. EPA’s PFAS roadmap stated the agency would use the EJ SCREEN mapping tool to determine if PFAS air pollution disproportionately affects communities with environmental justice concerns and develop options to mitigate the related risks. During the next administration, the agency should identify and institute air emissions controls needed to protect communities from PFAS hot spots. In addition, the EPA and states should take steps to avoid forming more so-called cancer alleys, taking into account all sources of PFAS, including contamination of water supplies
Reduce PFAS discharges into impaired water bodies. Where bodies of water remain impaired because of a pollutant, the Clean Water Act requires states to establish total maximum daily loads, or TMDLs, that calculate the maximum amount of a pollutant allowed to enter a body of water for it to meet, and continue to meet, water quality standards. Over the next four years, the EPA should work with states to prepare for the development of TMDLs as soon as PFAS-impaired waters are identified.
Update Clean Water Act permits to monitor and prevent industrial discharges of PFAS. The EPA has provided guidance to states to begin monitoring and preventing PFAS discharges by using existing Clean Water Act permit authority. Permits are required for any facility that discharges into lakes, rivers and other bodies of water, including sources of drinking water. Over the next two years, the EPA and states should review and update all federally and state-issued permits for industrial sources likely to discharge PFAS, and require industrial pretreatment for PFAS before it is sent into sewer systems or wastewater treatment plants.
Strengthen the Effluent Guidelines program. Technology-based effluent limitation guidelines, or ELGs, are one of the EPA’s and states’ most important tools for limiting pollutants from entering the nation’s waters. The agency’s ELG program is severely underfunded and already behind schedule for establishing ELGs needed to address PFAS. The EPA is due to publish an ELG program plan in January 2025, but before then it should perform a top-to-bottom review of the program, with stakeholder input, to identify funding levels and reforms needed to accelerate the pace of ELG development for PFAS and other toxics.
Accelerate the development of technology-based limits on industrial sources of PFAS pollution. Technology-based effluent limitation guidelines, or ELGs, are one of the EPA’s and states’ most important tools to limit industrial sources of pollutants from entering the nation’s waters. The agency should complete overdue ELGs for PFAS manufacturers and formulators in 2024, for metal finishers by 2025, and by 2026 for landfills, textile manufacturers and other industrial categories the EPA has postponed due to insufficient data. By 2028, the agency should begin to develop ELGs for any other PFAS polluter categories identified by a study on industrial discharges the agency initiated in March 2024.
Strengthen protection of waters used as sources of drinking water. The EPA has committed to publishing by 2024 human health ambient water quality criteria for PFOA and PFOS – two of the most notorious and well-studied PFAS. Meeting this deadline is critically important. The criteria represent specific levels of PFAS in a body of water that are not expected to cause adverse effects to human health, taking into account drinking water and fish consumption. The criteria are needed to develop water quality standards sufficient to protect and restore waters; issue permits to control PFAS discharges; and assess the impact of PFAS pollution on local communities. The EPA should finalize the criteria for PFOA and PFOS in 2024, and over the next four years develop water quality criteria for additional PFAS.
Enforce compliance by againstindustrial polluters and federal agencies causing pollution. The EPA lists “addressing exposure to PFAS” as a top compliance and enforcement initiative. The agency and the Department of Justice should prioritize funding and staffing for this initiative over the next four years. The agencies should coordinate the use of federal legal authorities to hold polluters accountable, as demonstrated by the first PFAS enforcement action under the Clean Water Act, taken against Chemours, in 2023, and action taken under the Safe Drinking Water Act against the U.S. Air Force at the Tucson International Airport site, in 2024. To ensure federal agencies are held to the same standard of accountability as any other entity, the EPA should establish, and make available to the public, legally binding compliance schedules for cleaning up contamination at federal facilities, including Department of Defense facilities.
Properly manage the disposal of PFAS waste. Despite the documented dangers of PFAS, the EPA has not established rules on the disposal of the chemicals. Using its authority under the Resource Conservation and Recovery Act, or RCRA, the EPA has proposed a rule that would include nine PFAS among hazardous constituents for which facilities could be required to investigate and clean up. The agency has also proposed a rule clarifying that corrective action can be taken at waste sites to address emerging contaminants like PFAS, even if they are not yet designated hazardous waste. Within the next year, the EPA should finalize both rules and ensure facility assessments are conducted. Within two years, the agency should finalize listing the nine PFAS as hazardous wastes and begin the process of regulating additional PFAS to ensure the chemicals are subject to RCRA rules for generation, transportation, treatment, storage and disposal.
Stop using PFAS-contaminated sewage sludge as fertilizer. PFAS are known to have contaminated farmland and milk supplies, and may find their way into other foods and crops. PFAS could be contaminating nearly 20 million acres of U.S. cropland, according to an EWG estimate. Contaminated soil has been documented in several states. Th EPA’s assessment of PFAS risks from sewage sludge produced by wastewater facilities is behind schedule. Gaining an understanding of the risks of PFAS to agriculture and the food supply should be a top priority over the next four years. EPA must require tests for PFAS in sewage sludge and work with the Department of Agriculture to inform farmers and wastewater treatment operators about the risks of PFAS in sludge. Sewage sludge containing PFAS should not be used as fertilizer unless proven safe.
Protect fish and wildlife from PFAS. The EPA is overdue in developing aquatic life ambient water quality criteria for PFAS. The water quality criteria help identify levels of PFAS that may harm aquatic life – but this is only a first step. Consumption of PFAS-contaminated fish and wildlife remains a threat to public health. Over the next four years, the EPA must work with other federal agencies to craft a comprehensive strategy for curbing PFAS risks to fish and wildlife and informing consumers, hunters and anglers of these risks.
End imports of PFAS wastes and tighten control over imports of PFAS-containing commercial products. The EPA was forced in late 2023 to “pause” the importation of millions of pounds of PFAS waste from the Netherlands following opposition from North Carolina residents. The agency should end imports of PFAS wastes. In addition, the agency should tighten controls over imports of PFAS-containing products through rulemaking under the Toxic Substances Control Act Section 5(a).
Speed up review of PFAS already in use. Hundreds of PFAS are already used in commerce. The EPA promised in its PFAS strategic roadmap to review previously approved PFAS to address restrictions that are insufficiently protective. To address risks of PFAS still in use, the EPA should set specific goals for completing the review of those uses and update orders under Section 5(e) of the Toxic Substances Control Act. When the EPA learns that certain PFAS are no longer being used or certain uses have been abandoned, the agency should update its significant new use rules under the toxics law to close the door on those PFAS or uses of PFAS.
Make sure new PFAS are safe before they enter the marketplace. The EPA must rigorously review the consequences of allowing any new PFAS or uses of PFAS. In May 2023, the agency proposed a rule under the Toxic Substances Control Act that would improve the approval process and make new PFAS categorically ineligible for low volume exemptions and low release/exposure exemptions, ensuring robust safety review processes in industries using PFAS. It proposed a framework rule in June 2023 that would improve review of PFAS. The EPA must finalize these regulations, with revisions requiring greater transparency and addressing risks to populations historically affected by PFAS exposure. Over the next four years, the agency should conduct a rigorous, class-based review of new PFAS before they are allowed to enter the marketplace.
Ban the use of PFAS in pesticides and containers. PFAS are increasingly used as pesticide ingredients for a variety of household, lawn care, turf, cereal crop and other food crop applications. PFAS in pesticides can pose a risk to agricultural workers, homeowners and downstream water users when pesticides are washed into bodies of water. PFAS can also migrate into pesticides when pesticides are stored in fluorinated plastic containers. The EPA released a new methodology for detecting PFAS in plastic containers in February 2024. The agency should phase out the use of PFAS in pesticides and require the industry to regularly test containers for PFAS.
Ban PFAS in chrome plating using Clean Air Act authority. The Clean Air Act gives the EPA authority to issue national emissions standards for hazardous air pollutants, or NESHAPs , that include steps industries must take to reduce emissions of certain hazardous air pollutants. In 2015, the EPA updated its chromium plating industry standards to ban PFOS from use as a fume suppressant at affected facilities. While some facilities have started using other PFAS to comply with the ban, about half no longer use PFAS as fume suppressants. PFAS are unnecessary for chrome plating, so the EPA should ban all PFAS uses in the chromium NESHAP.
Ban PFAS in fluorinated plastics. In 2022, the EPA informed companies of Toxic Substances Control Act notification requirements for certain PFAS. In 2023, the agency ordered the plastics treatment company Inhance Technologies not to produce PFAS when producing its fluorinated plastic containers. A federal court later scrapped this order based on its interpretation of the toxics law as it applies to new chemicals. Public health advocates in 2024 filed a notice of intent to sue the EPA to stop the manufacture and distribution of plastic containers with dangerous levels of PFOA, citing other provisions of the law. The EPA granted the petition to address three PFAS formed during the fluorination of plastic containers. By granting this petition, the EPA said it would promptly begin to examine the number, location and uses of fluorinated containers in the U.S., alternatives to the fluorination process, and measures to address risk. The EPA should continue using its full authority to stop the manufacture and distribution of plastic containers with dangerous PFOA levels.
Expand the Safer Choice program. The EPA has identified 1,900 products that qualify for its Safer Choice label, which helps consumers and commercial buyers identify products with safer ingredients without sacrificing quality or performance. Government agencies are also increasingly turning to Safer Choice–certified products to comply with new federal acquisition regulations for sustainable purchasing. PFAS are not allowed as ingredients in products that carry the Safer Choice label. Over the next four years, the EPA should allocate additional funding for Safer Choice and greatly expand the categories of products considered for certification.
Halt the use of PFAS for oil and gas extraction.Studies show widespread use of PFAS in oil and gas fracking operations, and disposal of wastewater from such operations may be disproportionately located in areas with higher proportions of people of color and residents living in poverty. While oil and gas operations are not required to disclose the chemicals they use, PFAS are known to be used in mixtures of chemicals injected into the ground to enhance the recovery of oil and gas trapped in rock formations. They are also often used in drilling equipment. Following the example of Colorado and other states, companies should be required to disclose the chemicals used in fracking, and PFAS should be phased out from uses in oil and gas production.
Strengthen EPA oversight and enforce schedules for PFAS contaminated federal facilities. The EPA has authority under the Comprehensive Environmental Response, Compensation and Liability Act to place federal facilities, including those under the jurisdiction of the Department of Defense, on the Superfund National Priorities List, or NPL. The agency’s oversight of NPL cleanups includes authority to make final decisions on cleanup remedies and the ability to enforce cleanup schedules. The EPA should expedite a review of federal facilities with PFAS contamination and place sites with the most serious PFAS contamination on the NPL to strengthen oversight of cleanups.
Designate more PFAS as hazardous substances. The EPA in April 2024 achieved a major milestone by designating two PFAS as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act, or CERCLA. The designation will help jump-start cleanups, require reporting of PFAS releases, and enable the EPA and other agencies to hold polluters accountable. Over the next four years, the EPA should identify additional PFAS for which designation as a hazardous substance is appropriate and complete the designation process. And the agency should treat PFAS that appear with PFOA and PFOS or other hazardous substances at Superfund sites as “pollutants and contaminants” under CERCLA and require those PFAS to be cleaned up as well.
Certify destruction and disposal methods for PFAS. The EPA in April 2024 updated its interim guidance for the destruction and disposal of PFAS. Over the next four years, the agency should build on the guidance by establishing a program for the certification of PFAS disposal and destruction methods that are proven safe and effective.
Add more PFAS to the Toxics Release Inventory. The National Defense Authorization Act for fiscal year 2020 required the EPA to add certain PFAS to the Toxics Release Inventory, or TRI, which requires manufacturers to report on chemical use, release, treatment, and disposal. The law identified a subset of PFAS to be immediately added to the TRI and created requirements for adding additional PFAS. The agency has added 196 PFAS to the TRI since then. The EPA was also required to make a determination on whether to add another subset of PFAS to the TRI at the end of 2021, including all PFAS “used to manufacture fluorinated polymers,” but it has not yet publicly done so. The EPA should make its determination public, add those PFAS to the TRI as soon as possible, and continue adding PFAS to the TRI as required.
Make industry identify health harms from PFAS. The EPA issued a national testing strategy in 2021 to identify and evaluate toxicity associated with PFAS. This identified 24 categories of PFAS that lack sufficient toxicity data to understand the human health effects. Over the next four years, the EPA should accelerate the use of test orders to complete the collection of health effects information for all categories of PFAS that EPA has identified as priority candidates for testing, and complete concrete actions identified in the testing strategy to address data gaps associated with PFAS.
Order industry to report how much PFAS are manufactured, imported and used, as well as their potential risks. In October 2023, the EPA issued a rule under Section (8)(a)(7) of the Toxic Substances Control Act that requires industry to report and retain records of the manufacture or import of PFAS and its uses, volumes, disposal, exposures and hazards. The rule will enable the EPA to better characterize the sources and quantities of manufactured PFAS. Over the next four years, the agency should ensure full compliance with this rule and publish periodic updates on the information reported to the agency. In addition, the EPA should prepare to use the information to guide regulatory priorities for safe management, use and disposal of PFAS, including identifying PFAS for toxicity assessment and identifying priority industries for regulation.
Expand research on the uptake of PFAS by crops and potential bioaccumulation. The EPA has initiated research to better understand the potential uptake of PFAS by crops. But it needs much more funding to examine the variety of crops that may be affected by PFAS contamination of agricultural land and water or other sources of contamination and the types of PFAS involved.
Identify non-industrial sources of PFAS. EWG estimates there could be nearly 30,000 industrial dischargers of PFAS into the environment, including into sources of drinking water.Research shows PFAS sources may also include household products such as toilet paper, PFAS-treated paper, leather products, carpets and other textiles, and even pharmaceuticals. Over the next four years, the EPA and other agencies should design and conduct research to identify and address significant sources of PFAS that may not be traditional “point source” contributors to water pollution.
Conduct research needed to control PFAS in air emissions. While the risks of PFAS in water have been documented sufficiently to support drinking water standards for some PFAS, less has been done to support Clean Air Act, or CAA, regulation of PFAS. Research on PFAS measurement, transport, sources of emissions, emissions from incineration and destruction, and inhalation toxicity is needed to inform monitoring and management of PFAS risks. Within the next four years, the EPA and other agencies should speed up research focused on eliminating gaps in the air research needed to support both CAA regulatory actions and state efforts to control PFAS risks.
Significantly ramp up research on PFAS. The EPA’s regulatory programs are supported by research on PFAS sources, transport, health effects, treatment and control technologies, safe disposal, alternatives, analytical methods and more. Additional funding is needed for EPA’s Office of Research and Development to carry out a PFAS research agenda that is closely coordinated with the agency’s regulatory authorities.
Give defense communities safe water to drink. At least 100 DOD facilities are known to have contaminated both public and private water supplies. The department has not provided alternative water at all facilities where water is contaminated above the EPA’s federal drinking water standards for PFAS. Providing safe alternative water should be an immediate and urgent priority. The military should continuously and actively survey water supplies potentially impacted by PFAS, including private wells, and fast-track the provision of safe alternative sources of water.
Ban incineration of PFAS-firefighting foam and other PFAS wastes until proven safe. The National Defense Authorization Act for fiscal year 2022 placed a temporary ban on the incineration of firefighting foam. The Pentagon subsequently issued a policy that allows such incineration, even though the EPA’s most recent guidance on PFAS disposal and destruction states that “uncertainties remain.” These uncertainties include whether harmful products of incomplete combustion or PFAS air emissions are formed by units operating at lower temperatures. In addition to firefighting foam, the DOD also generates PFAS waste from spent water filters, turnout gear and other military applications of PFAS. All PFAS waste incineration should stop until incineration technology and practices are proven effective at completely destroying PFAS and shown to not create harmful byproducts that could endanger the health of nearby communities.
Protect firefighters from PFAS used in protective equipment. Section 345 of the National Defense Authorization Act for fiscal year 2023 instructs the military not to enter into contracts to procure or purchase personal protective equipment after fall 2026. This includes any equipment that provides protection to the upper and lower torso, arms, legs, head, hands,and feet. The Pentagon should prioritize compliance with this requirement before the 2026 deadline and share its expertise with other federal agencies with firefighting capacity to phase out both government and civilian use of protective equipment containing PFAS.
End the use of PFAS firefighting foam. The National Defense Authorization Act for fiscal year 2020 requires the DOD to stop using firefighting foam containing PFAS by October 2024. In response, the DOD developed new firefighting foam specifications and identified safe and effective alternative foams that meet the new specification. The DOD should finally end the use of PFAS firefighting foam; replace PFAS with safer GreenScreen-certified foams; share its expertise with other federal agencies to end the use of PFAS fire-fighting foam across the government; and help civilian entities to shift to safer foams.
Double funding for PFAS cleanup. The cost of cleaning up the military backlog of contaminated sites is more than $40 billion, even without considering the full costs of PFAS cleanup. At current levels of funding, many installations won’t be cleaned up for 50 years or more. Over the next four years, the administration should double the Pentagon’s PFAS funding which should be reflected in the administration’s funding requests to Congress.
Reform the DOD cleanup program. The department’s Defense Environmental Restoration Program has no published strategy for accelerating PFAS cleanup, and defense communities often lack necessary information and technical assistance to clean up effectively. No final remedy has been approved for PFAS across the DOD’s hundreds of PFAS-contaminated sites. An interagency review of the DOD’s cleanup program should identify bottlenecks in decision-making and contracting processes, ensure cooperation among federal agencies and states to fast-track PFAS cleanup, and establish ambitious multi-year cleanup goals.
Empower communities to engage in DOD cleanups.Communities are legally entitled to participate in decision-making that affects their future well-being and safety. To improve community engagement, Congress in the National Defense Authorization Act for fiscal year 2024 gave the DOD authority to provide community technical assistance for cleanup. Yet the department has not announced the availability of assistance consistent with the new authority. Starting immediately and over the next four years, the DOD should work with EPA, which has an established technical assistance program, to design the program, fully fund such support, and vigorously publicize the availability of the program to help communities effectively participate in DOD cleanups.
Stop the spread of PFAS from federal facilities. Because PFAS are mobile and do not break down, every effort should be made to prevent the spread of PFAS from military installations and other federal sites. The EPA’s policy and practice at non-federal sites has long required early action to contain contaminated plumes of groundwater, even if final remedies have not been determined. The DOD needs to similarly make early actions a priority. The longer PFAS are allowed to migrate, the more it will cost to clean up, and the greater the public health threat. Within one year, the DOD should use a standardized, rigorous process to assess possible early actions to stop the spread of PFAS, set goals and deadlines for implementing interim and early actions, solicit input from regulators, communities and other experts, and publicly report on progress. In addition, the DOD should set aside funds to encourage the implementation of interim and early actions.
Tell the truth about PFAS cleanup costs and time frames. The National Defense Authorization Act for fiscal year 2022 required the DOD to report to Congress the full cost of, and schedule for, PFAS cleanup. The department never produced a report that meets the statutory requirement. Prior to the first term of the 119th Congress, the DOD should provide Congress and the public with a full accounting of PFAS cleanup obligations, including “cost to completion” of cleanup, along with credible estimates of cleanup time frames. Along with this report, the department should publicly commit to specific goals for cleaning up a minimum of 50 installations with the most serious contamination over the next four years.
Assess the health implications of PFAS for military installations and establish a PFAS registry. The National Defense Authorization Act for fiscal year 2019 required the DOD to assess the health implications of PFAS exposure, to include an estimate of the number of service members and veterans exposed to forever chemicals. EWG found the study was incomplete in several ways. The DOD should update the assessment to identify the true extent of PFAS exposure from military service, including consideration of past exposures for service members who served at multiple contaminated installations. It should also establish a registry to provide ongoing medical information and services to those exposed to PFAS.
Fully fund the FDA’s Office of Food Chemical Safety. As part of a reorganization in 2024, the FDA created an Office of Food Chemical Safety, Dietary Supplements, and Innovation. It is an important development in protecting consumers from harmful chemicals like PFAS in their food. But the FDA’s new commitment to review the safety of food and food packaging chemicals will not be realized unless full funding is provided to the office to ensure that chemicals and contaminants in food do not threaten our health.
Permanently end the use of PFAS in food packaging. In February 2024, the FDA announced that food packaging manufacturers have followed through on a commitment to phase out certain PFAS. While this represents a step toward eliminating PFAS, it does not prevent “regrettable substitution” – the use of other PFAS – nor does it ensure that the use of PFAS in all forms of food packaging and other food contact materials is permanently ended. Over the next four years, to prevent the introduction of food packaging and other food contact substances that contain PFAS, the FDA should ban PFAS in food contact substances and implement a program to rigorously review substances that come into contact with food. The FDA should also ban the use of fluorinated plastic containers for food storage. PFAS can form as part of the fluorination process and migrate into food stored in those containers, ultimately exposing people to the chemicals.
Set limits on PFAS concentrations in foods. PFAS can enter the food supply through plants and animals grown, raised or processed in contaminated areas, according to the FDA. In 2022, the FDA tested seafood samples, revealing a significantly higher percentage of detectable PFAS levels and different types of PFAS, compared to previous findings in its Total Diet Study, an ongoing assessment of U.S. consumers’ average dietary intake. The FDA has authority to set action thresholds for contaminants in food, such as toxic metals, but has not set such levels for PFAS. The agency should increase monitoring over the next four years to assess PFAS concentration in food and set action limits for foods known to have high levels of PFAS, such as seafood.
Assess PFAS alternatives for drugs and medical devices. PFAS are used in the manufacturing of FDA-approved drugs and medical devices. The FDA should consider whether safer alternatives are available.
Ban PFAS in cosmetics. Personal care products, such as soaps, lotions and deodorants, are regulated as cosmetics by the FDA, and are covered under the 2022 Modernization of Cosmetics Regulation Act, which granted the FDA more control over these products, introduced recall authority, facilitated registration requirements and improved labeling. The FDA should use the agency’s new power to swiftly ban PFAS from use in personal care products.
Characterize PFAS risks from food. More scientific work is necessary to identify the types and levels of PFAS in food, determine possible health effects and fill gaps in knowledge needed to protect the food supply. Over the next four years, the FDA and the USDA’s Food Safety and Inspection Service should develop a research agenda to address priority research needs, including improved methodologies to identify PFAS in additional foods and expanded testing under the Total Diet Study.
Accelerate research efforts to find replacements for PFAS. The DOE was one of the first federal agencies to adopt a department-wide strategy to address PFAS and institute policies to reduce the purchase of PFAS-containing products. The DOE also published an initial research plan for PFAS. The department should employ its unique research capabilities to support federal PFAS policy responses, such as disposal and destruction technology, in situ treatment, detection and measurement, and PFAS-free alternatives for national energy and national security applications.
Stop using PFAS firefighting foam at civilian airports and for other uses. The DOD has identified effective alternatives for PFAS firefighting foam, and Congress has authorized $350 million to help civilian airports transition to PFAS-free firefighting foam and protect firefighters. Over the next four years, the FAA should use available funding and authorities to complete the transition to safer alternative firefighting foams at civilian airports. Use of GreenScreen-certified foams should be prioritized to avoid regrettable substitution.
Remove PFAS-containing products from USDA’s BioPreferred label and federal purchasing requirements. The BioPreferred Program identifies bio-based products that are given preference for federal purchases. The program has certified more than 2,500 products in 100 product categories, but it does not screen out products that contain PFAS. As a result, the program may be working at cross-purposes with Biden-Harris administration efforts to reduce federal purchases of products with PFAS. The USDA should eliminate PFAS-containing products from its mandatory federal purchasing program, as well as its voluntary labeling program for all product categories in which safer alternatives are available.
Investigate the impact on agriculture of PFAS contamination from DOD facilities and other sources. More research is necessary to understand the potential risks of PFAS to animals and crops, and how farmers can mitigate harm. Section 335 of the National Defense Authorization Act for fiscal year 2021 requires the Pentagon to notify farmers and agricultural operators within a mile downstream of PFAS-contaminated ground water at military installations. The department in July 2023 reported it had notified 3,911agricultural operators. The USDA and the DOD should provide additional funding to expand upon the EPA’s recently initiated study of PFAS risks and mitigation for agriculture.
Inform farmers about PFAS contamination risks. In cooperation with the DOD, the EPA, and states, the USDA should inform farmers of risks to land, animals and crops at locations near PFAS-contaminated military installations and other sources of contamination. Within four years, the agencies should work with states to provide guidance and technical assistance to farmers about mitigating PFAS harm to agricultural operations.
End federal purchases of unnecessary PFAS products. The GSA is eliminating the use of PFAS-containing cleaning products for thousands of federal buildings, and the Department of Defense no longer purchases certain products containing PFAS. These are important steps in the right direction, but represent only a small fraction of overall government procurement. While the Biden administration directed agencies to prioritize the purchase of safe substitutes for PFAS products, many obstacles remain to truly achieving the goal of PFAS-free federal purchasing. Over the next four years, the GSA – working with the EPA as well as the USDA’s BioPreferred program – should eliminate PFAS-containing products from federal purchasing catalogs. The EPA should update federal purchasing guidelines to recommend only PFAS-free products when PFAS-free alternatives are available.
Cover PFAS blood testing through Medicare and M∂edicaid. Populations with contaminated drinking water or living near sources of PFAS often have questions about the extent of their PFAS contamination and potential health risks. PFAS blood levels are an important indicator of exposure, but may be unaffordable for many people. The HHS should take steps to ensure that the costs of PFAS blood tests for wellness screenings and monitoring are covered under Medicare and Medicaid.
Update clinician guidance. In early 2024, the Agency for Toxic Substances and Disease Registry released guidance for clinicians about how to address individuals’ exposure to PFAS. The guidance failed to fully incorporate recommendations from a 2022 National Academies of Science, Engineering, and Medicine report. The agency should expeditiously update the guidance in line with the report’s recommendations.
Conduct research to prioritize PFAS based on health effects. The National Institute of Environmental Health Sciences should increase support of research on PFAS human health risks from individual PFAS or groups of forever chemicals, to help set priorities for federal policy responses, including potential EPA regulations.
Study health impacts in pollution hot spots. The National Defense Authorization Act for fiscal year 2018 required the Agency for Toxic Substances and Disease Control to study the health effects of exposure to PFAS in communities impacted by contamination from military facilities. The so-called PFAS Multi-Site Study, or MSS, should be expanded to include communities harmed by industrial PFAS pollution, such as the Cape Fear region in North Carolina. The study should also consider clusters of illness that may be associated with PFAS from all sources of exposure, including occupational exposure.
Enforce against companies that make misleading claims about PFAS. The FTC should enforce against unfair or deceptive claims about PFAS, such as marketing claims that products are “PFAS free” based on vague definitions of forever chemicals, or testing procedures that aren’t designed to detect low levels of PFAS or all types of PFAS.
Support veterans exposed to PFAS. Because of the DOD’s long history of using PFAS-laden firefighting foam, veterans and people living near military bases are among the most exposed populations to PFAS. The VA should ensure that veterans who develop diseases related to PFAS exposure have access to testing and treatment, as it does with other diseases related to toxic chemical exposure during military service. The VA should establish a “presumption of service connection” for PFAS and certain diseases to ease veterans’ claim filing process.
