Comments concerning the Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (Docket ID No. EPA-HQ-OW-2024-0504)

A coalition of 42 organizations, including Earthjustice and the NRDC, submitted comments on the EPA's Draft Sewage Sludge Risk Assessment for PFOA and PFOS. The coalition argues that the EPA's assessment confirms that these 'forever chemicals' in sewage sludge pose unacceptable risks to human health and the environment, particularly through land application on farms. They claim the EPA's risk calculations are underestimates because they use low-end concentration models and ignore combined exposure effects. The document calls for the prompt finalization of the assessment, the establishment of numerical limitations and management practices under the Clean Water Act, and the expansion of future risk assessments to include other PFAS, synthetic organic fluorine compounds, and microplastics. Additionally, they advocate for stricter pretreatment standards for industrial dischargers to prevent PFAS from entering publicly-owned treatment works.

• Land application of sewage sludge containing PFOA or PFOS at just 1 part per billion (ppb) can exceed EPA's acceptable thresholds for cancer and non-cancer risks by several orders of magnitude, with children consuming contaminated milk potentially facing a lifetime cancer risk thousands of times above acceptable levels.
• The coalition asserts that the EPA's risk calculations are underestimates because they model risks based on 1 ppb, which is at the low end of measured U.S. concentrations; real-world testing shows PFOA and PFOS are commonly detected at 10 to 100s of ppb.
• PFAS contamination from sewage sludge has caused severe economic and agricultural damage in several states: in Michigan, a cattle farm was shut down and permanently prohibited from agricultural use; in Texas, ranchers stopped sending cattle to market after finding high PFAS levels in a stillborn calf; and in Maine, at least 82 farms have suffered soil, well, or livestock contamination.
• The document argues that the EPA must expand its scope to assess other pollutants in sewage sludge, including short-chain PFAS, synthetic organic fluorine compounds, and microplastics, noting that microplastics can adsorb other pollutants like heavy metals and PFAS.
• The coalition calls for the EPA to establish industry-specific, technology-based pretreatment standards for industrial facilities discharging PFAS to publicly-owned treatment works (POTWs), as traditional wastewater treatment does not remove or destroy PFOA or PFOS.

APA

Earthjustice (2025). Comments concerning the Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (Docket ID No. EPA-HQ-OW-2024-0504). https://earthjustice.org/wp-content/uploads/2025/08/2025-08-14-nrdc_ej-comments-on-pfas-sludge-risk-assessment-final.pdf

Chicago

Earthjustice. Comments concerning the Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (Docket ID No. EPA-HQ-OW-2024-0504). 2025. https://earthjustice.org/wp-content/uploads/2025/08/2025-08-14-nrdc_ej-comments-on-pfas-sludge-risk-assessment-final.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments concerning the Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (Docket ID No. EPA-HQ-OW-2024-0504) |date=14 August 2025 |url=https://earthjustice.org/wp-content/uploads/2025/08/2025-08-14-nrdc_ej-comments-on-pfas-sludge-risk-assessment-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2025comments, author = {{Earthjustice}}, title = {{Comments concerning the Draft Sewage Sludge Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (Docket ID No. EPA-HQ-OW-2024-0504)}}, publisher = {Earthjustice}, year = {2025}, month = aug, url = {https://earthjustice.org/wp-content/uploads/2025/08/2025-08-14-nrdc_ej-comments-on-pfas-sludge-risk-assessment-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }