What every municipal utility should know about PFAS monitoring plans

In what’s been cited as a “public health disaster,” moves have been made by both the EPA and state agencies to implement PFAS monitoring plans.


A physical sample of PFOA, appearing as a white solid as seen here in a relatively pure form. It is commonly referred to as the main harmful PFAS chemical and PFOA is responsible for many of the negative health effects commonly associated with PFAS. A physical sample of PFOA, appearing as a white solid as seen here in a relatively pure form. It is commonly referred to as the main harmful PFAS chemical and PFOA is responsible for many of the negative health effects commonly associated with PFAS.

Earlier this year, the U.S. EPA reported that more than 158 million have drinking water contaminated by what’s known as “forever chemicals” — or PFAS.

In what’s been cited as a “public health disaster,” moves have been made by both the EPA and state agencies to implement PFAS monitoring plans. That way, municipal utilities can better understand how the chemicals enter water systems and accumulate within them, while informing remediation efforts.

At the same time, the EPA has announced $1 billion in funding to help public water systems implement PFAS testing and treatment, alongside support for private well owners to address PFAS contamination.

All of these initiatives tie back to a broader conversation: PFAS is present in the majority of the U.S water supply and efforts must be made to combat it.

The PFAS focus

Formally known as per- and polyfluoroalkyl substances, PFAS are a group of human-made chemicals that have been in use since the 1940s. You can find them in a range of products, from non-stick cookware to food packaging.

Why are they called “forever chemicals?” It goes back to the fact that PFAS are persistent in their environment, with a strong resistance to heat, water, and oil. This also means they aren’t easily broken down in the human body.

Research estimates 98% of the U.S. population has detectable levels of PFAS in their blood — a nod to how pervasive these chemicals have become. With their connections to harmful health effects, that’s reason for ample pause and concern.

As the Minnesota Department of Health reports, studies have consistently shown associations between PFAS exposure and decreased vaccination responses, heightened cholesterol, and lower birth weight. Associations have been made between long-term PFAS exposure and kidney cancer, too.

The current rulings around PFAS monitoring

In April 2024, the EPA issued their final PFAS National Primary Drinking Water Regulation (NPDWR), which sets standards for six PFAS chemicals in public drinking water systems. Here’s a breakdown of what the timeline looks like:

  • By 2027, water systems must start initial monitoring at all their distribution system’s entry points. (Monitoring frequency varies based on both the water source and the size of the system.)
  • Beginning in 2027, impacted systems must start ongoing compliance monitoring, including data in annual Consumer Confidence Reports (CCRs) and notifying the public of monitoring or testing violations. 
  • By 2029, systems are required to be fully compliant with maximum contaminant levels (MCLs) for regulated PFAS.

Quarterly PFAS monitoring continues beyond this point. If water systems show consistently low PSAF levels, they may be able to move to annual or triennial monitoring.

The NPDWR outlines that sampling must be performed by a state-certified laboratory or approved by the EPA. It also doesn’t permit any composite sampling — or monitoring waivers — for accuracy and to account for potential cross-contamination.

Prior to the EPA rulings, some states had rolled out their own mandates.

In 2020, Michigan adopted enforceable MCLs for seven PFAS compounds. The EPA’s MCL for PFOA and PFOS is 4 parts per trillion (ppt); Michigan’s limits are 8 ppt and 16 ppt, respectively. The state also regulates the compound PFHxA.

New Jersey, meanwhile, boasts some of the country’s strictest PFAS standards, with regulations that apply to all public water systems. The state’s MCLs are 14 ppt for PFOA and 13 ppt for PFOS and PFNA.

Practical takeaways from these frameworks

Many municipal utilities across the country have already begun PFAS monitoring in response to state-level regulations or guidance, particularly in states that moved early to address PFAS contamination. Some utilities may have testing protocols in place, established lab partnerships, and experience communicating results to the public. 

However, for other systems, the EPA’s NPDWR is the first formal roadmap they must follow. While EPA’s guidance is clear, there’s a slew of logistical, financial, and public engagement challenges that it brings up for utilities.

While EPA funding aims to reduce burdens, other measures can do the same.

Leverage existing data where possible

If previous PFAS monitoring was conducted with EPA-approved methods—EPA Methods 533 and 537.1— the results could count toward initial monitoring requirements. A state primary agency can confirm the eligibility of data, and if so, reduce costs and legwork.

Designate a PFAS compliance lead or team

PFAS monitoring requires careful coordination, from where samples are collected, to how they’re analyzed, to how data is tracked and reported on. Appointing a point person or a cross-functional team early on guarantees that all compliance elements are properly addressed, even as requirements evolve.

Develop a public communication strategy early

Given heightened public awareness and concern around PFAS exposure, transparency is important. Municipal utilities should be ready to explain what PFAS are, remediation plans, and how compliance efforts are being funded. Clear messaging now can manage public expectations and reduce confusion.

Coordinate with neighboring utilities or regional partners

For smaller or rural water systems, forming coalitions or entering into shared-service agreements can make PFAS monitoring less resource intensive. Joint procurement of lab services, unified public communications, and even a shared treatment infrastructure can save costs, simplify compliance, and improve consistency in how PFAS is addressed regionally.

The costs are high, but so are the stakes

PFAS monitoring is a substantial lift for municipal utilities, but one that carries a lot of weight.

The EPA estimates that the removal of PFOA and PFOS could save $1.5 billion in annual healthcare costs. That’s a result of fewer cancers, heart attacks and strokes, and birth complications.

With thoughtful planning, coordination, and communication, water systems can meet the moment and secure healthier, safer water for decades to come.

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