AMWA Submits Comments On PFAS Biosolids Risk Assessment

On August 14, AMWA submitted comments to EPA on its draft sewage sludge risk assessment for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). EPA’s draft risk assessment reflected the Agency’s estimation of the potential risks to human health posed by PFOA and PFOS in biosolids that are applied on land, disposed in a landfill, or incinerated. 

AMWA’s comments identified significant methodological gaps in the draft assessment and urged EPA to revise the assessment before any final publication. AMWA’s concerns about the assessment’s methods include its reliance on unrealistic exposure assumptions, limited evaluation of exposure routes, and lack of contextual comparison to other PFAS sources. The letter cautions that these limitations could overstate risks in some cases, while not acknowledging the many biosolids management practices that can minimize risks, and lead to misinformed regulatory responses.

The letter urged EPA to incorporate statistical approaches that incorporate uncertainty and variability in conditions, use more representative data, and provide clear interim guidance on biosolids management while formal rules are developed. The letter also reiterated AMWA’s broader call for PFAS control strategies, focusing on preventing contamination at the source and coordinating across federal agencies to reduce exposure from consumer products, food packaging, and other pathways. 

AMWA worked with the regulatory subcommittee to develop comments and worked with partnering organizations to ensure that the Association’s letter reflected the need for holistic PFAS management that does not unfairly burden passive receivers of PFAS.