American Farmland Trust (AFT) submitted public comments in response to draft guidance from EPA regarding biosolids and the risk of PFAS. The comments express support for the EPA’s goal of providing farmers, ranchers, and the general public with the information they need to make well-considered decisions related to PFAS and biosolids, which is especially imperative in the absence of additional regulation. However, AFT strongly urges the Agency to significantly expand and strengthen its proposed guidance to better protect farmers, farm families, and farmland, as well as the broader environment and the general public, from PFAS.
“PFAS is a serious threat to the health and well-being of farmers, their families, and their livelihoods. We appreciate EPA’s work to address this issue and raise its visibility,” said Emily Liss, AFT’s Farm Viability Policy Manager. “However, PFAS cannot be fully addressed by the actions of private citizens alone. Addressing PFAS will require additional federal leadership to better understand the risks it poses, avoid additional contamination, and provide the resources necessary to address existing contamination.”
AFT is at the forefront of this issue. In 2024, AFT convened the 16-organization PFAS and Agriculture Policy Workgroup, which released a set of federal consensus recommendations in September 2025. These recommendations for Congress and the executive branch include: Provide support and relief to impacted farmers; protect farmers from liability under CERCLA (or Superfund); reduce additional contamination of agricultural land; advance research; and promote federal coordination and communication with farmers and the public.
In July, EPA released draft guidance that includes concise, voluntary recommendations for farmers and ranchers, the general public, and wastewater treatment plants on ways to reduce risk from PFAS present in biosolids. AFT’s comments lay out ways to make the final guidance more detailed and actionable, urging EPA to:
- Provide greater focus on farmers and ranchers in recognition that they face both increased health risks from consistent exposure, as well as unique economic impacts to farm businesses
- Prioritize actions that will prevent additional PFAS contamination of agricultural land, rather than focusing on limiting contamination to farms growing crops with lower risk to consumers
- Include farmer-specific guidance, such as more information about low-uptake crops, developed in partnership with USDA
- Inform farmers about the lack of support for PFAS-contaminated operations as well as the potential impacts of contamination to their land’s future value and production options
- Expand the guidance to include other forms of PFAS (beyond PFOA and PFOS) that are associated with health risks
In addition, AFT’s comments urge EPA to take two key actions to address PFAS, including finalizing the 2025 Draft Biosolids Risk Assessment using feedback provided during the previous public comment period, and conducting a national survey to document the occurrence of PFAS in biosolids. Updating and finalizing this document would provide the information necessary to better understand the risks of PFAS and help direct potential actions such as setting upper thresholds for PFAS in land-applied biosolids.
Background:
PFAS, or “forever chemicals,” are a large class of synthetic chemicals used in many industrial and consumer products. Since they do not break down naturally, PFAS accumulate over time in soil and water, and eventually make their way into crops, animals, and humans. Certain PFAS have been linked to negative health impacts – including various forms of cancer. Farms and ranches have been contaminated through runoff, mostly from military facilities, and the unintentional use of contaminated biosolids as fertilizer. Biosolids are the semi-solid end product of the wastewater treatment system, and frequently contain some level of PFAS.
PFAS came to prominence as an agricultural issue in 2016 after being detected on a dairy farm in Maine. Since then, contamination has been discovered on additional farms and ranches across the nation, including in Maine, Michigan, New Mexico, Texas, and more. Little is known about the scope of contamination since soil testing is not widespread. Although PFAS contamination has led to the closure of some farms, Maine has found that with appropriate financial and technical support, the vast majority can safely remain in production.
