Regulatory Alert: EPA Releases Updated Interim Guidance on PFAS Destruction and Disposal
April 23, 2026
Today, the U.S. Environmental Protection Agency (EPA) released updated interim guidance that outlines the latest research on different methodologies used to destroy and dispose of PFAS and PFAS-containing materials, including aqueous film-forming foam (AFFF). This is the third version of EPA’s document, which was first issued in 2020. As with the first two iterations, the guidance primarily focuses on three large-scale technologies available to control and mitigate the environmental release of PFAS: underground injection, landfills, and thermal treatment.
EPA’s updated guidance provides organizations and individuals who manage PFAS-containing materials with a framework for analyzing the safety and effectiveness of available destruction and disposal technologies, including the underlying data to support the guidance. Airport personnel who are planning to transition from AFFF to fluorine-free firefighting foam (F3) agents—or managing other PFAS-containing materials—should consider familiarizing themselves with the updated guidance.
EPA released a fact sheet that explains the updated guidance and will accept public comments for 60 days after the document is published in the Federal Register. We will be working with our PFAS Working Group (WG) to determine whether to file comments.
Background. Under the Fiscal Year 2020 (FY20) National Defense Authorization Act (NDAA), Congress required EPA to publish guidance on the disposal and destruction of PFAS and materials containing PFAS, including AFFF. In developing the interim guidance, EPA was required to consider several factors, including (a) the potential for releases of PFAS during destruction or disposal, including through volatilization, air dispersion, or leachate; and (b) potentially vulnerable populations living near likely destruction or disposal sites. EPA published its first edition of the guidance in December 2020 and the second edition in April 2024.
Updated Interim Guidance Highlights. The updated interim guidance discusses in detail the three main destruction and disposal technologies: underground injection, landfills, and thermal treatment (including incineration). Despite the updated data included in the document, EPA’s key findings regarding each of these technologies remain the same in comparison to the 2024 version of the interim guidance:
- Underground Injection: Certain EPA-permitted injection wells provide “reasonable assurance” that injected fluids will remain isolated and not migrate into nearby sources of drinking water. However, some uncertainty remains over the effectiveness of this method over long timeframes. In addition, the limited number of wells accepting off-site PFAS may limit this method as an option for many organizations.
- Landfills: Landfills permitted under Subtitle C of the Resource Conservation and Recovery Act (RCRA), known as hazardous waste landfills, have been shown to be effective for containing and minimizing PFAS releases into the environment. However, similar to a 2024 finding, EPA states that the latest data continues to show landfilling could result in higher PFAS releases into the environment than previously believed.
- Thermal Destruction: EPA-permitted hazardous waste combustors, such as incinerators, cement kilns, and lightweight aggregate kilns, have been shown to be conducive to destroying PFAS and controlling any leftover chemicals. Similar to a 2024 finding, EPA states that the latest data continues to show thermal treatment as a more effective method than previously believed. However, the agency emphasized that uncertainties remain with these technologies.
In comparison to the 2024 version, the interim updated guidance continues to include (a) a framework for assessing the safety and effectiveness of available PFAS destruction and disposal technologies; and (b) an appendix that provides estimates of costs for management of PFAS materials by thermal treatment, landfilling, and underground injection. However, EPA removed its 2024 guidance on how to evaluate the effects of releases from these technologies on nearby communities, including vulnerable populations.
What’s Next? EPA indicated that the agency will publish the interim guidance in the Federal Register in the near term, triggering a 60-day comment period. In accordance FY20 NDAA requirements, EPA is obligated to revisit and potentially revise the document every three years based on the latest available research. However, last year, EPA Administrator Lee Zeldin indicated that the agency would update the guidance every year. AAAE, through its PFAS WG, will evaluate the interim guidance to determine whether to respond. Any comments submitted would be addressed in the fourth iteration of the document, which will be released in spring 2027.
