The United States Environmental Protection Agency (EPA) released draft guidance on managing risks associated with PFOA and PFOS in biosolids on June 29, offering an important clarification of its January 2025 Draft Risk Assessment.

That earlier assessment sparked significant concern across the wastewater, biosolids and agricultural sectors, as it suggested the potential for elevated human health risks from land-applied biosolids based on a conservative test case. But in this newly released guidance, EPA explicitly acknowledges that the assessment lacked clarity and created confusion for both the regulated community and the public.

This new guidance does not walk back concern around PFAS. Instead, it provides needed context for how risk should be understood, communicated and managed going forward. The agency also encouraged public comment on this draft by Sept. 4 so that future actions are informed by widespread industry and customer perspective.

Reframing the risk conversation

This recent guidance shifts how biosolids risk is characterized. EPA makes clear that the earlier assessment relied heavily on conservative, higher-risk hypothetical scenarios that did not represent most real-world land application practices nor true exposure risks to most Americans.

In doing so, the agency also acknowledges what was missing in the 2025 draft: a national survey of PFOA and PFOS in biosolids, an evaluation of how often higher-risk scenarios occur, and a broader assessment of how the public is exposed to biosolids-related pathways.

Without this context, the earlier draft created a perception that all biosolids use poses unacceptable risk. The new guidance directly addresses that misconception. It reinforces that biosolids risk depends upon site conditions, exposure scenarios and the presence (or absence) of PFAS sources within a given system.

This distinction matters. It shifts the conversation away from broad generalizations and toward a more nuanced, data-driven understanding of risk.

Balancing risk with the value of biosolids

While much of the public discussion has focused on potential risks, EPA’s new guidance also reaffirms the importance of biosolids as a resource. The agency continues to support beneficial reuse and land application as a critical component of wastewater management.

That support reflects both practical and environmental realities. Biosolids provide nutrients and soil conditioning benefits, reduce dependence on synthetic fertilizers and offer a cost-effective residuals management option for utilities — particularly in regions where landfill or incineration capacity is constrained.

At the same time, EPA acknowledges that biosolids management exists within a broader system of tradeoffs. Limiting or eliminating land application without viable alternatives can introduce new environmental impacts and significantly increase costs for utilities and customers.

In this context, the agency’s message is clear: biosolids remain a viable and valuable management option — but one that must be informed by better data, clearer communication and more proactive risk management. EPA also notes that some land application scenarios may warrant greater scrutiny than others, particularly where opportunities for human exposure are higher, further reinforcing the need for site-specific decision making.