A Timeline of US Federal Actions on PFAS

The US Environmental Protection Agency (EPA) has made great strides with its research and regulation of per- and polyfluoroalkyl substances (PFAS) since 3M notified the Office of Toxic substances that perfluorooctanesulfonic acid (PFOS) might bioaccumulate in May of 1998. Within the last year, the EPA has rolled out a Strategic Roadmap to which they commit to broader and bolder polices to protect public health and the environment. With this Roadmap, the EPA is working to safeguard communities from these “forever” chemicals, to provide new data on the contaminants that have impacted drinking water systems, and to facilitate mitigation for corrective action. We have compiled the timeline below to help you understand the PFAS regulatory journey, and the landmark studies and rules that have brought us to the present day. If you have any questions regarding PFAS investigation, treatment, or remediation, we encourage you to reach out to us.

US Federal Actions on PFAS

May 1998

PFOS Build Up in Blood

3M alerts EPA that PFOS can build up in blood, as a precautionary measure.

December 1998
Rat Study Data

Rat Study Data

3M sends EPA rat study data, showing liver damage from PFAS exposure.

June 1999

Audit Agreement

3M enters into a comprehensive Audit Agreement with EPA under the EPA Self-Disclosure Policy, committing to a comprehensive audit. The audit occurred April 24, 1999 until April 24, 2000.

March 2002
SNUR: Manufacture or Import of 13 PFAS Chemicals

Significant New Use Rule (SNUR): Manufacture or Import of 13 PFAS Chemicals

EPA publishes a SNUR which required manufacturers to provide EPA with notification about the manufacture or import of 13 PFAS chemicals.

Action conducted under:
Toxic Substances Control Act (TSCA)

December 2002

SNUR: Manufacture or Import of 75 PFAS Chemicals

EPA publishes SNUR which required manufacturers to provide EPA with notification about the manufacture or import of 75 PFAS chemicals.

Action conducted under: TSCA

December 2005

Case Against DuPont

EPA settles perfluorooctanoic acid (PFOA) case against DuPont for largest environmental administrative penalty in agency history, $10.25 million, regarding use of PFOA.

January 2006
Global Stewardship Program

Global Stewardship Program

EPA invited 8 major leading companies in the PFAS industry to join in a global stewardship program.

Action conducted under: TSCA

October 2007

183 PFAS No Longer Manufactured

EPA finalized a SNUR on 183 PFAS believed to no longer be manufactured (including imported) or used in the US.

Action conducted under: TSCA

January 2009

Health Advisories

EPA publishes provisional health advisories for PFOA and PFOS.

December 2009

Long-Chain Perfluorinated Chemicals (PFCs) Action Plan

EPA publishes Long-Chain PFCs Action Plan (the agency’s first PFAS action plan).

May 2012

Third Unregulated Contaminant Monitoring Rule (UCMR 3)

EPA published the UCMR 3, requiring monitoring for 6 PFAS.

Action conducted under:
Safe Drinking Water Act (SDWA)

October 2013

PFOA-Related Chemicals in Carpets

EPA issued a rule requiring companies to report all new uses of certain PFOA-related chemicals as part of carpets.

Action conducted under: TSCA

January 2015
SNUR: Manufacturers and Importers

SNUR: Manufacturers and Importers

EPA proposed a SNUR to require manufacturers and importers of PFOA and PFOA-related chemicals to notify EPA at least 90 days before starting or resuming new uses in any products.

October 2015

EPA Method 537

EPA developed a laboratory method for measuring PFOS, PFOA, and 12 other PFAS in drinking water (EPA Method 537).

Action conducted under: SDWA

May 2016

Drinking Water Health Advisories

EPA released drinking water health advisories for PFOA and PFOS (70 ng/L each or combined).

Action conducted under: SDWA

May 2018

PFAS National Leadership Summit

EPA hosts PFAS National Leadership Summit (May 22–23, 2018).

June 2018
Communities Impacted by PFAS

Communities Impacted by PFAS

Following leadership summit, EPA conducted multiple events with communities impacted by PFAS.

November 2018

November 2, 2018—GenX

EPA expanded the current drinking water Method 537 to include GenX and additional PFAS.

Action conducted under: SDWA

November 14, 2018—Toxicity Assessment for GenX

EPA published the draft toxicity assessment for GenX.

November 21, 2018—Toxicity Assessment of Perfluorobutane Sulfonic Acid (PFBS)

EPA released the human health toxicity assessment of PFBS.

February 2019

February 14, 2019—PFAS Action Plan

Andrew Wheeler, EPA administrator, announces PFAS Action Plan.

February 27, 2019—Impacts to Agriculture and Rural Economies

EPA publishes directive to prioritize federal research on impacts to agriculture and rural economies in EPA’s PFAS Action Plan.

April 2019
December 2019

National Defense Authorization Act (NDAA)

Congress passes the NDAA, which phases out the use of aqueous film forming foam (AFFF) at all military sites owned by the federal government by October 1, 2024, and forbids training exercises with the use of any AFFF releases.

February 2020
PFAS Action Plan: Program Update

PFAS Action Plan: Program Update

EPA publishes the PFAS Action Plan: Program Update.

February 20, 2020—PFAS in Surface Coatings

EPA proposed a supplemental SNUR to ensure EPA is notified before anyone begins or resumes the import of long-chain PFAS as part of surface coatings.

Action conducted under: TSCA

July 2020

Long-chain PFAS

EPA issued a final rule requiring notice and EPA review before the use of long-chain PFAS that have been phase out in the US could begin again.

Action conducted under: TSCA

November 2020

Recommendations from the PFAS National Pollutant Discharge Elimination System (NPDES) Regional Coordinators Committee

EPA publishes a memo: Interim Strategy for Per- and Polyfluoroalkyl Substances in Federally Issued National Pollutant Discharge Elimination System Permits.

Action conducted under:
Clean Water Act (CWA)

February 2021

PFAS in Drinking Water

EPA re-proposed and began developing the final fifth Unregulated Contaminant Monitoring Rule (UCMR 5) to provide new data on 29 PFAS in drinking water.

Action conducted under: SDWA

April 2021

Toxicity Assessment for PFBS

EPA published an updated toxicity assessment for PFBS.

April 27, 2021—EPA Council on PFAS

EPA Administrator Regan called for the creation of a new EPA Council on PFAS.

April 27, 2021—Low Volume Exemptions for PFAS

EPA announces changes to low volume exemptions for PFAS entering the US market.

June 2021
Hazardous Substances Designation

Hazardous Substances Designation

EPA restarted the process to designate PFOA and PFOS as hazardous substances.

June 10, 2021—EPA Data Rule

EPA proposed a rule to require all manufacturers and importers of PFAS in any year since 2011 to give EPA a wide range of data.

June 10, 2021—July 2020 SNUR

EPA withdrew a compliance guide related to EPA’s July 2020 SNUR, and the July 2020 SNUR continues to be in effect.

Action conducted under: TSCA

July 2021

2020 Toxics Release Inventory (TRI) Reporting

EPA released preliminary data for TRI reporting, including the first ever reporting on PFAS.

Action conducted under: TRI

August 2021
Health Hazards for PFBA

Health Hazards for Perfluorobutanoate Acid (PFBA)

EPA released a draft assessment of the human health hazards for PFBA for public comment and external peer review.

October 2021
Another Stop on the PFAS Strategic Roadmap Announced

Final Toxicity Assessment for GenX

EPA published a final human health toxicity assessment for GenX.

PFAS National Testing Strategy

EPA announced that they are developing a National PFAS Testing Strategy to require PFAS manufacturers to provide information on PFAS.

Action conducted under: TSCA

October 18, 2021—PFAS Strategic Roadmap

EPA announced the PFAS Strategic Roadmap.

October 26, 2021—Resource Conservation and Recovery Act (RCRA) Corrective Action Process

EPA announced steps towards evaluating the existing data for four PFAS under RCRA and strengthening the ability to cleanup PFAS contamination through the RCRA corrective action process.

Action conducted under: RCRA

November 2021

Science Advisory Board

EPA asked the Science Advisory Board to review 4 draft scientific documents including recent scientific data and new analyses that indicate that negative health effects may occur at much lower levels of exposure to PFOA and PFOS.

December 2021


EPA publishes the UCMR 5.

Action conducted under: SDWA

January 2022

Reporting on Releases and Waste Management

EPA requires reporting on releases and other waste management of certain PFAS, including PFBS.

March 2022

National PFAS Datasets

EPA posts National PFAS Datasets.

Action conducted under: SDWA

March 16, 2022—Safer Chemicals Ingredients List

EPA sends TSCA compliance letters to the industry and removes PFAS from its Safer Chemicals Ingredients List.

April 2022
A water resources worker wearing PPE crouched next to a stream performing water sampling.

CWA Drafts Aquatic Life Criteria for PFOA and PFOS

Drafted Aquatic Life Criteria for PFOA and PFOS.

Actions conducted under: CWA

EPA Issues Memo

EPA issued a memo on minimizing PFAS contamination to surface water via NPDES permitting.

Actions conducted under: CWA

Draft Absorbable Organic Fluorine Method

Draft Adsorbable Organic Fluorine Method that can broadly screen for the presence of chemical substances that contain carbon-fluorine bonds, including PFAS.

Actions conducted under: CWA

May 2022

May 18, 2022—Five PFAS Added to RSLs and RRMLs

Five PFAS added to Regional Screening Levels (RSLs) and Regional Remedial Management Levels (RRMLs) to help EPA determine if response or remediation are needed.

Action conducted under: CAA

June 2022
National Testing Strategy Announced

National Testing Strategy Announced

National testing strategy announced that will require PFAS manufacturers to provide the agency with toxicity data and information on categories of PFAS to inform future regulatory efforts.

Action conducted under: TSCA

Interim Drinking Water Health Advisories for PFOA and PFOS

Drinking water interim health advisories proposed under the Safe Drinking Water Act (SDWA).

Action conducted under: SDWA

August 2022
Healthcare compliance and assurance solutions

August 26, 2022—PFOA and PFOS Proposed as Hazardous Substances under CERCLA

Action conducted under: CERCLA

December 2022

December 5, 2022—EPA Proposal made to Improve PFAS Reporting

EPA proposed a rule that would improve reporting PFAS to the Toxics Release Inventory (TRI).

Action conducted under: TRI

December 5, 2022—EPA Issues Companion Memo on the CWA’s NPDES

EPA issued a companion memo providing guidance to states on how to use the Clean Water Act’s NPDES permitting program to reduce harmful PFAS pollution.

Action conducted under: CWA

January 2023

EPA Releases New Interactive Webpage, PFAS Analytic Tools

The EPA released a new interactive webpage, called the PFAS Analytic Tools, which bring together multiple sources of information on PFAS in one place.

EPA Releases Final Effluent Limitations Guidelines (ELGs) Plan 15

EPA released its final Effluent Limitations Guidelines (ELGs) Plan 15, including a determination that revised ELGs and pretreatment standards are warranted for reducing PFAS in leachate discharges from landfills.

Action conducted under: CWA

EPA Proposes Preventative Ruling

EPA proposed a rule that would prevent anyone from starting or resuming—without a complete EPA review and risk determination— the manufacture, processing, or use of an estimated 300 PFAS that have not been made or used for many years, known as “inactive PFAS.”

Action conducted under: TSCA

February 2023

February 13, 2023—EPA Announces the Availability of $2B from Bipartisan Infrastructure Law

EPA announced the availability of $2B from President Biden’s Bipartisan Infrastructure Law to address emerging contaminants, including PFAS, in drinking water with grants to public water systems in small or disadvantaged communities in states and territories across the country.

March 2023
Water engineer with survey equipment kneeling by a stream collecting data

March 14, 2023—EPA Proposes Maximum Contaminant Levels (MCLs) for six PFAS

EPA proposes Maximum Contaminant Levels (MCLs) for six PFAS in drinking water. The proposed MCLs are the first legally enforceable levels for PFAS.

Action conducted under: SDWA

April 2023

EPA Issues an Advance Notice of Proposed Rulemaking (ANPRM)

The EPA issued an Advance Notice of Proposed Rulemaking(ANPRM) asking the public for input regarding potential future hazardous substance designations of PFAS under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.

Action conducted under: CERCLA

July 2023

EPA Method 1633 Finalized for Aqueous Matrices

Method prepared by the EPA Office of Water.

Apex Associated Press (Apex AP) represents contributions from various authors within the Apex professional community.


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