What's My PFAS Responsibility?

Thanks to high-profile lawsuits and growing public awareness, many manufacturers and industry leaders are assessing their liability. Here's what you need to know.

Industry and Manufacturing



PFAS are a diverse group of compounds, which are resistant to heat, water, and oil. These properties have made PFAS ideal for use in hundreds of industrial applications and consumer products, including certain paper food packaging, firefighting foams, carpeting, apparel, and upholstery.

Download the Infographic: Sources of PFAS Contamination

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PFOA and PFOS get the most attention, but as of June 2020, at least 19 PFAS compounds are regulated or monitored across 23 states, 9 countries, and the European Union. The Interstate Technology & Regulatory Council (ITRC) maintains a table of water and soil values by state and country. This table is updated every couple of months as new rules are proposed or passed.


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Perfluorooctanesulfonic acid (PFOS)



PFAS can enter the local water supply, ground and surface waters, soil, vegetation, and animal tissue through a variety of industrial sources.


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Air Emissions

EPA researchers have found that point and non-point emissions can be a significant source of PFAS.

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Discharges from industrial and municipal wastewater treatment plants can contaminate surface water.

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Unlined and lined landfills have separate sources of PFAS concerns from direct contamination to leachate management issues.

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Aqueous Film-Forming Foam (AFFF) is great for putting out chemical fires, but it is a major documented source of PFAS contamination.

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More than half of the domestic sewage sludge produced in the U.S. gets applied to agriculture as bio-solids.



Currently the EPA has only finalized test methods for drinking water, however, test methods for non-potable water and solids (soil, biosolids, plant and animal tissues, etc.) are under development.

Learn More

PFAS Test Methods 2

Targeting Non-Targeted PFAS

Every day brings news of new litigation against PFAS chemical producers and those who use PFAS compounds in their operations. Even while they seek to mitigate the damage, industry leaders need to bear in mind that the chemicals commonly named in these lawsuits are less than 0.1 percent of the 4,700+ CAS-registered PFAS compounds.

Although toxicity levels have yet to be determined for the vast majority of PFAS compounds, it is generally recognized that PFAS all share a similar structure and that the health risks associated with one PFAS are expected for other PFAS as well. This means that manufacturers of PFAS compounds, as well as those using PFAS chemicals in their production and operations, could be facing ever-increasing litigation as public awareness of the PFAS problem grows.

Test methods, such as TOP Assay and TOF, can be used to detect a wide range of non-targeted PFAS. Learn more about these methods on our PFAS Test Methods page.

Targeting Non-targeted PFAS


Wastewater regulators issue wastewater discharge permits under the National Pollutant Discharge Elimination System (NPDES) permit program.

This program has been around since the early 70s, but only recently have some states started to add PFAS to the permit requirements. The best way to stay abreast of changing NPDES requirements is to visit the applicable environmental regulatory agency's website for the latest information.

Learn More About Our Wastewater Testing Program

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Although no US regulatory criteria have been established for PFAA precursors, concerns regarding their migration and transformation into PFAAs are growing. PFAA precursors can include compounds that originated in the original PFAS formulations or are polyfluorinated intermediate transformation products. The number of PFAA precursors quantifiable with commercially available analytical methods using LC/MS/MS is very limited.

To address this problem, the Total Oxidizable Precursor, or “TOP” Assay, was developed to better understand, and to a certain extent quantify, the mass of precursors that may be in an environmental sample. This test includes subjecting a sample through a strong bench-top oxidation step to mimic natural degradation processes and analyzing the sample pre- and post-oxidation. The mass balance is used to quantitate the amount of precursors in the sample.

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Pace has a long history of sampling stack emissions and ambient air for a wide range of contaminants. We've leveraged our expertise to develop reliable methods for sampling and testing air and emissions for PFAS compounds.

The most common examples of air emissions testing for PFAS involve incinerator stack emissions from manufacturing and industrial sites. This requires specialized sampling equipment to be placed in the stack by qualified personnel. Samples are then tested using traditional PFAS by LC MS/MS Isotope Dilution methods. Not all labs that offer PFAS test methods are equipped to test stack emissions for contamination.

Learn More About Our Stack Emissions Testing Program

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The EPA's Toxic Release Inventory (TRI) program tracks the management of chemicals that may pose a threat to human health and the environment. As of January 1, 2020, 172 PFAS compounds were added to the program. The full list is available online.

The Pace Analytical® Regulatory Services team can provide assistance with TRI or other regulatory reporting requirements.

Learn more

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With lawsuits proliferating, estimates for total industry liability run into the billions of dollars. Even if the contamination happened years ago, you could still be held liable as PFAS compounds do not break down naturally. A judge recently settled a lawsuit against a shoe manufacturer for nearly $70 million for PFAS contamination stemming from the 1960s.

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For more insight on the latest issues related to PFAS, check out our Blog.

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Take The Next Step



Pace Analytical® offers the only certified mobile lab in the industry capable of analyzing PFAS in the single digit, parts-per-trillion range. We can often provide same-day results and fully defensible data at a lower cost than expedited services at other labs.

Download our PFAST® data sheet to learn more about our mobile lab capabilities.

PFAS Mobile Lab

4 Reasons to Choose Pace®

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Pace Analytical® has been an industry leader in persistent organic pollutant testing for over three decades, and we were one of the first commercial laboratories to analyze for PFAS compounds.

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Pace maintains certifications and accreditations in every state that offers or requires them. We're also certified/accredited by NELAC, ISO, the Department of Defense (DoD), and the Department of Energy (DOE).

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Rapid Response

The Pace Rapid Response Team can quickly respond to any emergency. Our team will coordinate sample container delivery, assist with technical information needed onsite, and ensure samples are delivered as quickly as possible to the appropriate Pace laboratory. In many cases, we can provide PFAS results in as little as 24 hours.

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Our mobile lab is the only certified mobile lab in the industry capable of analyzing PFAS in the single-digit, parts-per-trillion range. This lab can identify PFAS plumes and source areas and provide fully defensible data, often with same-day results and at a lower cost than expedited services at other labs.