In the last days of the Biden administration in January 2025, the United States Environmental Protection Agency (EPA) published its Draft Risk Assessment for Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) (Draft Risk Assessment), leaving state regulators, the public, municipalities, and biosolids recycling companies to figure out the practical implications of EPA’s draft conclusions. Central to some of the confusion and misinformation stemming from the Draft Risk Assessment has been EPA’s conclusion that biosolids containing PFOA and PFOS at a low concentration of one parts per billion (ppb) may exceed EPA’s extremely protective criteria for remote health risks under implausible, unrealistic long-term exposure scenarios. Though EPA acknowledged that these long-term exposure scenarios are largely inapplicable to the vast majority of the population—acknowledging that the Draft Risk Assessment “does not model risk for the general public,” confusion ensued,
