A Rapidly Shifting Environmental Compliance Landscape
Per- and polyfluoroalkyl substances, commonly referred to as PFAS, have emerged as one of the most significant and fast-moving compliance challenges facing industrial facilities, municipalities, and property owners today. Unlike many legacy contaminants with well-established regulatory frameworks, PFAS presents a moving target. The rules governing detection thresholds, reporting obligations, and cleanup standards are being actively written and rewritten at both the federal and state levels simultaneously.
That means a facility that was in full environmental compliance a year ago may now face new obligations, and the organizations that act proactively are far better positioned than those waiting for an enforcement notice to force the issue. Understanding what PFAS is, where it comes from, and what PFAS remediation looks like is the critical first step.
Miller Environmental Group (MEG) is a national environmental remediation partner with the expertise, equipment, and operational reach to help facilities across the continental United States navigate both discovery and cleanup of PFAS. This post breaks down the science, the regulatory landscape, and the practical steps your organization should be taking now.
What Is PFAS & Why Does It Matter?
PFAS is an umbrella term for a group of thousands of synthetic chemicals that have been used in industrial processes, firefighting foam, non-stick coatings, food packaging, and manufacturing since the 1940s. The chemistry that makes these compounds so useful in industrial applications is also what makes them problematic contaminants.
PFAS compounds are often called “forever chemicals” because the carbon-fluorine bond at the core of their structure doesn’t break down in the environment or the human body. Once released into soil or groundwater, these substances persist and accumulate, creating long-term liability for site owners and serious public health concerns for communities.
Industries and facility types most commonly associated with PFAS contamination include:
- Military installations that have used aqueous film-forming foam (AFFF)
- Airports and fire training facilities with AFFF use histories
- Chemical manufacturers and textile processing operations
- Metal plating and industrial discharge facilities
- Wastewater treatment facilities and landfills accepting PFAS-containing materials
The documented health risks associated with PFAS exposure, including links to certain cancers, immune system effects, and developmental issues, are a primary driver behind the urgency of regulatory action at both the state and federal levels.
“Once released into soil or groundwater, PFAS compounds persist and accumulate, creating long-term liability for site owners and serious public health concerns for communities.”
The Federal Regulatory Landscape: Where Things Stand Now
The federal picture is changing quickly. Key developments include:
- The EPA’s April 2024 National Primary Drinking Water Regulation established the first-ever legally enforceable maximum contaminant levels (MCLs) for PFOA and PFOS at four parts per trillion.
- A May 2025 EPA announcement affirmed PFOA and PFOS limits while proposing to rescind regulations for PFHxS, PFNA, GenX, and the Hazard Index mixture, with compliance deadlines potentially extended to 2031.
- PFOA and PFOS designation as hazardous substances under CERCLA (Superfund), which requires facilities to report significant releases and creates direct liability for site cleanup.
- EPA’s 2026 updated interim guidance on PFAS destruction and disposal, identifying thermal destruction, landfilling, and underground injection as the primary large-scale options currently available.
While proposed federal rollbacks on certain compounds have generated headlines, facilities should not interpret those proposals as reduced liability. State-level activity is running in the opposite direction, with many states moving to fill any perceived gaps with stricter requirements of their own.
State-Level PFAS Requirements: A National Overview
States have broad authority to set PFAS standards that exceed federal minimums, and many have exercised that authority aggressively. For organizations operating across multiple states, this creates a complex patchwork of obligations that requires careful analysis. Notable state-level activity includes:
- New Jersey: Among the strictest PFAS programs in the country, with NJDEP enforcing its own MCLs and expanding PFAS oversight in wastewater and discharge permits.
- New York: Active enforcement through DEC and DOH, plus 2025 legislation banning PFAS in firefighting foam and expanding product restrictions.
- Michigan: An early mover on PFAS groundwater standards, with MCL limits ranging widely by compound.
- California: Proposition 65 warnings required for products containing PFOA, PFOS, and related PFAS compounds, with a textile PFAS ban effective January 2025.
- Maine: One of the broadest PFAS frameworks in the country, including a 2024 agricultural response program addressing PFAS impacts on farmland.
- Illinois: 2025 legislation requiring MCLs for community water supplies and product sales bans effective January 2026.
- Connecticut, Vermont, Washington, Minnesota, and Oregon: Each passed active 2025 legislation addressing product restrictions, disclosure requirements, and firefighting foam bans.
Nearly 350 PFAS bills were introduced across 39 states in the 2025 legislative session alone, with 27 enacted in 13 states. This landscape changes frequently, and facilities should consult with an environmental compliance professional to understand their obligations in each jurisdiction where they operate.
Common Sources of PFAS Contamination at Industrial Sites
For facility managers and EHS professionals conducting a preliminary self-assessment, the following represent the most common pathways through which PFAS contamination is introduced or detected at industrial sites:
- Aqueous film-forming foam (AFFF) used at military bases, airports, and fire training facilities
- Industrial discharge from chemical manufacturing, textile processing, and metal plating operations
- Leaching from landfills accepting PFAS-containing materials
- Contaminated groundwater migrating from adjacent sites
Many facilities discover PFAS contamination not through their own operations, but during routine environmental due diligence or as a result of neighboring site investigations. Waiting for an obvious internal source to trigger assessment may leave organizations exposed to liability they did not create or anticipate.
PFAS Remediation Options That Work
No single approach fits every site, and selecting the right strategy requires a thorough assessment by a qualified remediation firm. The following technologies represent the current primary options, each with distinct trade-offs:
Granular Activated Carbon & Ion Exchange Resins
The most widely used approach for water treatment. Both methods are effective at removing PFAS from groundwater and drinking water, but they transfer rather than destroy the contaminants, generating waste streams that still require proper disposal.
Pump & Treat Systems
An established technology used to contain contaminated groundwater by extracting it for above-ground treatment. This is a proven long-term containment strategy appropriate for many sites, though it requires sustained operation and monitoring.
Soil Excavation & Offsite Disposal
Appropriate for source zone removal where PFAS concentrations in soil are high. This approach is most effective when combined with groundwater treatment to address subsurface contamination that excavation can’t reach.
Thermal Destruction
High-temperature incineration is one of the few technologies that destroys PFAS molecules rather than transferring them to another medium. EPA’s 2026 interim guidance identifies this as a primary large-scale destruction method. Practical application remains constrained by cost and availability.
In-Situ Treatment (Emerging)
Technologies such as in-situ chemical reduction and stabilization are in active development. EPA guidance in this area is still evolving, and organizations considering emerging approaches should work with an environmental remediation partner closely tracking regulatory developments.
“No single approach fits every site. Selecting the right PFAS remediation strategy requires a thorough, site-specific assessment by a qualified environmental remediation services provider.”
What Facilities Should Do Now
Given the pace of regulatory change and the scope of enforcement activity at federal and state levels, EHS managers and facility operators should not treat PFAS as a future concern. The following steps represent practical, defensible actions organizations can take immediately:
- Conduct a PFAS site assessment if your facility has used AFFF, handled fluorinated compounds, or is located near a known PFAS source.
- Review state-specific discharge permits and MCLs for each state in which you operate.
- Document PFAS-containing materials and processes as part of your environmental management program.
- Develop or update your Spill Prevention, Control, and Countermeasure (SPCC) plan to account for PFAS-containing materials.
- Engage a national remediation services provider with PFAS-specific experience before a regulatory inspection or enforcement action forces the timeline.
Compliance isn’t static; achieving and maintaining it requires ongoing attention to a regulatory environment that is changing faster than almost any other area of environmental law. Organizations that build proactive programs around PFAS remediation and environmental compliance now will be better positioned when the next round of updates arrives.
Partner With Miller Environmental Group for PFAS Remediation
Miller Environmental Group is a national environmental remediation partner with the capacity to support facilities across the continental United States and beyond. For more than five decades, we have provided remediation services, hazardous waste transportation and disposal, emergency response, and compliance expertise to federal agencies, Fortune 500 companies, utilities, and industrial facilities of every scale.
We know PFAS is a long-term operational and compliance challenge requiring a partner with the technical depth to assess, plan, and execute across complex regulatory environments. With 24/7 availability for both planned engagements and emergency response situations, MEG is equipped to meet your organization wherever it is in the PFAS remediation process.
In short, we’ll ensure you remain safe and compliant.
Whether your facility is just beginning a PFAS site assessment, navigating a regulatory inquiry, or ready to move forward with a full remediation services program, we can help. Contact Miller Environmental Group today to speak with a PFAS specialist and develop a plan tailored to your site and your obligations.
