We first reviewed the U.S. Environmental Protection Agency’s (EPA) PFAS Strategic Roadmap: 2021-2024 in March 2022, and have since posted periodic updates. With the recent conclusion of the 2021-2024 implementation period, we now reflect on accomplishments and speculate about potential future directions.
Some of EPA’s most notable goals for 2021-2024 are described below, as well as the related accomplishments that were achieved.
Office of Chemical Safety and Pollution Prevention
- Completed: Published a National PFAS Testing Strategy document, which is available here: https://www.epa.gov/system/files/documents/2021-10/pfas-natl-test-strategy.pdf.
- Completed: Enhanced PFAS reporting under the Toxics Release Inventory (TRI). This goal was met in October 2023 when the EPA finalized a rule requiring enhanced PFAS reporting to the TRI. This rule designated PFAS as “chemicals of special concern,” which removes many pre-existing exemptions. Details are available here: https://www.epa.gov/newsreleases/epa-finalizes-rule-require-enhanced-pfas-reporting-toxics-release-inventory.
- Completed: New PFAS undergo rigorous review. While this goal was less concrete than some others, steps taken toward its fulfillment included EPA’s framework to keep unsafe PFAS off the market and the addition of seven PFAS chemicals to the TRI. Eleven additional PFAS chemicals were added to the TRI in a rule finalized January 6, 2024, and data collection on these chemicals is expected to begin this year.
Office of Water
- Complete: Expanded drinking water monitoring for PFAS to a national level. The November 2024 update, Three Years of Progress, referenced the Fifth Unregulated Contaminant Monitoring Rule as progress towards this goal. The regulation passed in December 2021 and required roughly 10,000 public water systems to report data for 29 PFAS chemicals. Reporting is expected to be complete in 2026. As of October 2024, approximately 4,180 public water systems had submitted their full results.
- Completed: Established enforceable regulations for Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) in drinking water. The nationwide, legally enforceable drinking water standard was issued on April 10, 2024. The standard set Maximum Containment Level Goals and enforceable Maximum Containment Levels, and it set aside funding to help states and territories achieve compliance.
- Completed: Published a toxicity assessment for five PFAS and two GenX chemicals. The assessment was released in October 2021 and is available here: https://www.epa.gov/chemical-research/human-health-toxicity-assessments-genx-chemicals.
- Completed: Published health advisories on PFBS and GenX chemicals. These advisories were published on June 15, 2022, and are available here: https://www.epa.gov/sdwa/drinking-water-health-advisories-genx-chemicals-and-pfbs.
- Completed: Published national recommended ambient water quality criteria for PFAS. Aquatic life criteria were published in October 2024 (https://www.epa.gov/wqc/aquatic-life-criteria-perfluorooctanoic-acid-pfoa). Criteria for human health were published in December 2024 (https://www.epa.gov/wqc/human-health-water-quality-criteria-pfas).
Office of Land and Emergency Management
- Completed: Proposed PFOA and PFOS hazardous substance designation. The final rule was released on April 2024, and is available here: https://www.epa.gov/newsreleases/biden-harris-administration-finalizes-critical-rule-clean-pfas-contamination-protect.
Office of Air and Radiation
- Ongoing: Conduct research to address PFAS air emissions. Community Multiscale Air Quality (CMAQ)-PFAS was developed to model the emission and transport of airborne PFAS chemicals. More information can be found here: https://www.epa.gov/cmaq/research-highlights#DAmbro_et_al_2021.
Cross Programs Between Different Offices
- Ongoing: Identify PFAS categories. The PFAS National Testing Strategy (released October 2021) outlines progress on identifying classes of PFAS on pages 5 and 6 (https://www.epa.gov/system/files/documents/2021-10/pfas-natl-test-strategy.pdf). Efforts are ongoing. Testing was also ordered on PFAS to aid in further categorization.
- Ongoing: Create a voluntary PFAS stewardship program. This program launched in 2021, and is ongoing: https://www.epa.gov/reviewing-new-chemicals-under-toxic-substances-control-act-tsca/pfas-low-volume-exemption.
EPA also announced future priorities in the November 2024 update, Three Years of Progress, including establishing limits on PFAS discharges from manufacturing operations and continuing to collect data about deposition of PFAS emissions and mitigation of impacts.
Current Status and Prospective Future of PFAS Policy
President Donald Trump signed an executive order (EO) shortly after taking office to withdraw all pending regulations for further review by his new administration, including EPA’s proposal to limit PFAS discharges in industrial wastewater. Such regulatory pauses are common and even expected when a new president is inaugurated, and are not necessarily indicative of future executive decisions or trends in manufacturing practices.
In public statements, President Trump has distanced himself from Project 2025, a political initiative of The Heritage Foundation. On the other hand, the president has selected multiple contributors to the Project 2025 policy agenda for appointed positions in his new administration. Some EOs issued since the president’s inauguration do appear to align with Project 2025 policy aims, but none of these are directly related to PFAS policy (other than a blanket withdrawal of pending regulations). Chapter 13 of the Project 2025 policy document calls for the EPA to “revisit the designation of PFAS chemicals as “hazardous substances” under [the Comprehensive Environmental Response, Compensation, and Liability Act,] CERCLA,” and “revise groundwater cleanup regulations and policies to reflect the challenges of omnipresent contaminants like PFAS.” However, whether the Trump administration will take any interest in pursuing such policies through legislation and rulemaking remains unknown.
Administrative Changes
Lee Zeldin, appointed as Administrator of the EPA on January 29, 2025, will direct the agency’s efforts on PFAS and other regulatory matters. As a politician, Mr. Zeldin’s voting record on PFAS is mixed. He served on the PFAS Task Force when he was a New York Congressman in the U.S. House of Representatives. He voted in favor of the PFAS Action Act and an amendment to the “National Defense Authorization Act of Fiscal Year 2022” titled Taking Action on PFAS Contamination, with both “yea” votes occurring in 2021. However, Zeldin was opposed in 2022 to “Protecting People from Toxic Incineration,” a regulation that would have limited the incineration of PFAS-containing waste. He also voted against an amendment to the PFAS Action Act of 2019 titled Closing the PFAS Clean Water Loophole, an effort to limit the amount of PFAS chemicals that companies could discharge in wastewater. This amendment bears some similarity to a proposed limit that is currently held up by EO for further White House review.
Zeldin said during his Senate confirmation hearings that PFAS are one of his top concerns. However, his plans remain unclear for advancing the testing, classification, and regulation of PFAS chemicals. Other Trump appointees previously served at EPA during Trump’s first administration and have returned to the Office of Chemical Safety, including Nancy Beck (as Senior Advisor) and Lynn Dekleva (as Deputy Assistant Administrator). During the first Trump administration, Beck had a role in rewriting rules concerning tracking health consequences of PFOA, and Dekleva focused on the regulatory process for approving new chemicals. More recently, Beck was the Director of Regulatory Science at Hunton Andrews Kurth LLP and Dekleva was Senior Director at the American Chemistry Council.
In December 2024, Beck indicated her general expectations for the new Trump administration’s potential future directions (i.e., Trump Administration 2.0: What Can We Expect in Chemicals Policy), including decisions that will need to be made about defending legal challenges to the 2024 drinking water standards, setting or revising deadlines for meeting PFAS reporting rules, and expanding the list of PFAS subject to TRI reporting. Over the last several years, she has advocated for certain PFAS policies and classifications, such as the addition of safe harbor provisions in new PFAS regulations. These provisions include an exemption that enables PFAS importers to avoid enforcement if they demonstrate they were unaware their products contained PFAS.
How Can We Help?
Spheros Environmental brings integrated air quality, water resources, and water quality expertise to support clients facing complex PFAS-related challenges. Our scientists use advanced air quality modeling, analysis, and visualization techniques to support air quality management, planning, permitting, compliance, and decision-making in the context of regulatory and legal actions. This work ranges from local to hemispheric scales and includes multi-pollutant impact assessments, atmospheric chemistry and reactions, single-source air dispersion impact analyses, exceptional event demonstrations, policy analyses, and real-time modeling systems.
Our water resources and water quality teams work closely with water utilities to plan for and develop new water supplies, protect the quality and availability of existing supplies, and address emerging contaminants, including PFAS. Spheros conducts PFAS sampling and monitoring programs for water systems across multiple regions, with the expertise to support water quality monitoring, investigate potential sources of PFAS contamination, and develop strategies to help reduce PFAS levels in drinking water.
About the Author
Dana Coe leads Spheros Environmental’s Litigation Services Program, which delivers expert testimony and advisory services to attorneys seeking trusted, unbiased, science-based expertise. Ms. Coe oversees the Program to ensure all litigation support projects clearly communicate complex scientific issues in an accessible, useful, timely, and ethical manner. Much of her 30-year career has been dedicated to assessments of criteria pollutants, toxic air pollutants, and greenhouse gases emitted by a diverse array of sources. She has provided technical support and advice during Clean Air Act enforcement actions and settlement negotiations, including advising a midstream company in a matter concerning fugitive emissions and producing technical content for U.S. Department of Justice’s use in matters concerning motor vehicle emissions and defeat devices. Outside Sonoma Technology, she has consulted on the development of commercial-scale renewable energy projects.