PFAS Compliance

PFAS Is Now a Five-Statute Problem.
Most Facilities Are Only Watching One.

Nine PFAS compounds were designated RCRA hazardous constituents in April 2026. 1,740 facilities now face new corrective action obligations (meaning EPA may require investigation and cleanup of PFAS contamination at your facility). That's on top of CERCLA, SDWA, CWA, and TSCA requirements already in effect. iSi maps your full PFAS exposure across all five statutes — then tells you what to do about it.

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Five Federal Statutes. One Chemical Family. All Active.

PFAS regulation has moved from single-statute (SDWA drinking water limits) to a five-statute framework. Every statute creates different obligations, different timelines, and different regulatory authorities asking questions.

CERCLA

Superfund Liability

PFAS contamination triggers Superfund liability for facilities that released, arranged for disposal of, or transported PFAS waste. Potentially liable parties face remediation costs that regularly exceed $1,000,000 per site.

SDWA

Drinking Water MCLs

Maximum contaminant levels (MCLs) for PFOA and PFOS are final and enforceable. Public water systems must complete initial monitoring by 2027, with full compliance required by 2031. EPA announced in May 2025 its intent to rescind MCLs for four other PFAS compounds (PFHxS, PFNA, HFPO-DA, PFBS) — those limits are under reconsideration. Facilities near municipal water sources face scrutiny over contributions to PFAS levels.

NEW — April 2026

RCRA Corrective Action

Nine PFAS compounds designated as RCRA hazardous constituents. 1,740 facilities with RCRA-permitted or formerly-permitted units now face mandatory PFAS corrective action investigation. This is the most significant new obligation for manufacturers.

CWA

Discharge Limits

Industrial stormwater and wastewater discharge permits are incorporating PFAS limits in states where EPA has issued effluent guideline updates. Facilities discharging to surface waters or POTWs face growing monitoring requirements.

TSCA

Reporting & Testing

PFAS reporting under TSCA Section 8(a)(7) requires manufacturers and importers to report PFAS use and exposure data. Separate TSCA Section 5 requirements apply to new PFAS uses and chemical formulations.

Don't Know Which Apply to You?

iSi's PFAS Screening Assessment determines your facility's exposure under all five statutes — and prioritizes which require immediate action versus monitoring.

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The Industries Facing the Highest Exposure

PFAS regulation isn't evenly distributed. These four sectors face the highest combined exposure across all five statutes.

Fabricated Metals PFAS surface treatments, plating operations, and metal finishing processes create direct RCRA and CERCLA exposure.
Chemical Manufacturing PFAS processing, use as processing aids, or as feedstocks creates obligations under TSCA, RCRA, and CWA.
Petroleum Products AFFF (aqueous film-forming foam) firefighting systems at refineries and terminals create CERCLA and RCRA exposure wherever foam was discharged.
Electronics PFAS-based conformal coatings, photolithography chemicals, and semiconductor processes create TSCA and RCRA reporting obligations.

PFAS Compliance Services

iSi structures PFAS work in three tiers — starting with a screening assessment to understand your exposure before committing to investigation or corrective action.

PFAS Screening Assessment

$5,000–$15,000
  • Five-statute exposure mapping (CERCLA, SDWA, RCRA, CWA, TSCA)
  • AFFF and PFAS use history review
  • Regulatory trigger identification
  • Priority action list with timeline

Ideal for: Facilities uncertain about their PFAS exposure — the screening tells you what applies before you spend on investigations.

Most Common

SWMU PFAS Assessment

$15,000–$40,000
  • Everything in Screening, plus:
  • Site-Wide Management Unit (SWMU) PFAS investigation — the specific area at your facility where RCRA corrective action applies, typically where waste was handled, stored, or released
  • Sampling and analysis program design
  • Regulatory agency communication support
  • RCRA corrective action scope determination
  • Investigation report preparation

Ideal for: Facilities triggered under RCRA corrective action or facing EPA inquiry about PFAS at RCRA-permitted units.

Corrective Action Support

$25,000–$100,000+
  • Everything in SWMU Assessment, plus:
  • Remediation alternative analysis
  • Corrective measures study
  • Regulatory agency negotiation
  • Remedy selection and design support
  • Long-term monitoring program

Ideal for: Facilities with confirmed PFAS contamination requiring formal corrective action under RCRA or CERCLA oversight.

PFAS Compliance Questions

Which PFAS regulations now apply to manufacturers?

As of April 2026, PFAS are regulated under five federal statutes: CERCLA (Superfund liability), SDWA (drinking water MCLs), RCRA (9 compounds now designated hazardous constituents), CWA (discharge limits), and TSCA (reporting and testing requirements). Fabricated metals, chemical manufacturing, petroleum products, and electronics manufacturers face the highest combined exposure.

What does the RCRA PFAS designation mean for my facility?

Nine PFAS compounds were designated as RCRA hazardous constituents in April 2026. This means 1,740 facilities now face new RCRA corrective action obligations (meaning EPA may require investigation and cleanup of PFAS contamination at your facility). Facilities that used AFFF firefighting foam, PFAS-containing coatings, or received PFAS-contaminated waste are most likely affected. RCRA corrective action can require site investigation, remediation feasibility studies, and long-term cleanup — with associated costs starting in the $25,000–$100,000+ range.

How much does PFAS compliance consulting cost?

iSi's PFAS services start with a Screening Assessment at $5,000–$15,000 to determine your facility's exposure across all five federal statutes. SWMU PFAS Assessments run $15,000–$40,000. Full corrective action support starts at $25,000 and scales based on site conditions. Most clients start with the screening assessment to understand scope before committing to investigation costs.

We haven't used AFFF. Do we still have PFAS exposure?

Possibly. PFAS exposure paths include: PFAS-containing surface treatments (metal finishing, electroplating), PFAS as processing aids in manufacturing, PFAS-containing industrial waste received from other facilities, and PFAS in purchased products applied on-site. The screening assessment maps all potential paths — not just AFFF — to give you an accurate picture.

PFAS Compliance Consulting by Market

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PFAS Compliance Is a Five-Statute Problem Now. Get the Full Picture.

iSi's PFAS Screening Assessment maps your exposure under CERCLA, SDWA, RCRA, CWA, and TSCA — and tells you which require action now vs. monitoring. Starting at $5,000–$15,000.

Request PFAS Screening Assessment