Reducing Risk from PFOA AND PFOS in Biosolids: Public Employees for Environmental Responsibility Comments on U.S. EPA Draft Guidance

Download PDF Public Employees for Environmental Responsibility ('PEER') submitted August 26th comments on a document the United States Environmental Protection Agency ('EPA') published on June 29th titled: Draft Guidance for Reducing Risk from Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) in Biosolids ('Draft Guidance'). EPA stated in issuing the Draft Guidance that if finalized, it would provide: The Draft Guidance addressed the Draft Risk Assessment that had been issued by EPA on January 14, 2025, by the Biden Administration. The Draft Guidance argues that EPA has since determined that the Draft Risk Assessment exhibited a number of flaws that caused confusion among the public and the regulated community. EPA sought comments on the Draft Guidance for 60 days following its publication in the July 6th Federal Register. See 91 Fed. Reg. 41020. The August 26th PEER comments request that EPA withdraw its proposed voluntary guidance for the referenced substances in biosolid fertilizers made from sewage sludge and instead issue regulations which would include: The organization argues that the Clean Water Act requires that EPA do so. PEER further argues that the Draft Guidance: In the PEER comments summary, the organization states that the Draft Guidance: The specific arguments made by PEER include: A copy of the PEER comments can be found here.