Farm Production and Conservation Business Center | Farm Service Agency | Natural Resources Conservation Service | Risk Management Agency

Per-and Polyfluoroalkyl Substances (PFAS)

PFAS

Per-and polyfluoroalkyl substances (PFAS) are a class of 

chemical compounds that are highly resistant to 

degradation and easily bioaccumulate in the environment. 

They are found in a broad range of products ranging from 

food packaging, non-stick cookware, water-proofing 

sealants, and fire-fighting foams used at public and 

military airfields. There are thousands of chemical 

compounds in the PFAS family, but perfluorooctane 

sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA)

have been the most widely studied. The study of PFAS is

ongoing, but lab and epidemiological studies have found 

possible human health risks to PFAS exposure. 

In 2016, the U.S. Environmental Protection Agency

(EPA) published a Lifetime Public Health Advisory

(LHA) for PFOS and PFOA in drinking water at 70 parts 

per trillion (ppt). The EPA is currently evaluating new 

rules for PFAS under the Safe Drinking Water Act

(SDWA) and potential designation as a hazardous 

substance under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA). 

Department of Defense Notifications

As part of the 2021 National Defense Reauthorization 

Act (Section 335), Department of Defense (DoD)

installations are required to notify any agricultural 

operation located within one mile downgradient of a

military installation where PFAS has been detected in 

groundwater above advisory limits. These notifications 

include PFOS and PFOA at 70 ppt, individually or in 

combination, and Perfluorobutanesulfonic acid or PFBS 

(a related PFAS compound) at 40 parts per billion (ppb).

Notifications are being sent even though DoD is still 

assessing the nature and extent of PFAS contamination 

at its installations. The notifications are to ensure 

transparency as DoD continues its PFAS assessments.

Frequently Asked Questions and Answers

If a producer receives a DoD Notice does that mean their

farm or ranch water supply is contaminated?

No, it only means there is a potential that their groundwater 

is contaminated. There are many factors that influence if a 

particular property is impacted. These factors include the 

type and concentration of PFAS, climate, hydrogeology, 

geology, and environmental conditions. The only way to 

determine if a water supply is contaminated is to sample 

water from the well(s) on the property.

What is the health advisory for PFAS?

The EPA LHA for the most common PFAS compounds, 

PFOS and PFOA, is currently 70 ppt, individually or in 

combination. At or below this level, no adverse health 

effects are anticipated to occur. DoD has issued guidance to

its installations for PFAS, including PFBS at 40 ppb, and 

some states have promulgated their own PFAS limits.

What if FSA becomes aware of a notice related to a 

property that is being considered for a farm loan?

The loan application and agency review process should 

proceed as normal. The Farm Service Agency (FSA) must 

conduct due diligence and complete an Environmental Risk 

Assessment (Form FSA-851) on real property being offered 

as basic or additional security and certain loan servicing 

actions per FSA guidance. Currently, there are no published 

Maximum Contaminant Levels (MCLs) under the SDWA

and no PFAS compounds are listed as a hazardous 

substance under CERCLA. If identified, PFAS should be 

treated as a “non-scope” contaminant, like asbestos and 

mold, and documented on the Form FSA-851. If PFOS or 

PFOA contamination at the property exceeds the current 

LHA of 70 ppt, then the appraisal and market value should 

appropriately reflect the environmental condition of the 

property.

USDA is an equal opportunity provider, employer, and lender.

July 2021
FAQs Continued...

What are the next steps in this process and will a 

producer’s wells be sampled?

FSA, the Natural Resources Conservation Service 

(NRCS), and the Risk Management Agency (RMA)

should continue delivering USDA services to producers 

as normal. DoD is in the process of assessing PFAS 

contamination at its installations and will determine if 

groundwater wells outside the installation require 

sampling as part of their assessment. Each assessment

and the next steps in the process are specific to each

DoD installation that provided the notification. The best 

source of information about the assessment is DoD’s 

point of contact that was identified in the notification 

letter. The letter also provides websites where producers

can get more general information about DoD’s 

Environmental Program and PFAS in the environment. 

Your state regulatory agency may be another source of 

information about PFAS contamination at DoD 

installations.

Additional Resources

DoD webpage with information on PFAS

https://www.defense.gov/Explore/Spotlight/pfas/

EPA webpage providing general information on PFAS

https://www.epa.gov/pfas/

EPA Fact Sheet, PFOS and PFOA Drinking Water 

Health Advisories

https://www.epa.gov/sites/production/files/2016-

06/documents/drinkingwaterhealthadvisories_pfoa_pfos_up

dated_5.31.16.pdf

Food and Drug Administration (FDA) webpage on PFAS

https://www.fda.gov/food/chemicals/and-polyfluoroaklylsubstances-pfas/

NRCS Science and Technology Webinar Portal

For webinars concerning PFAS in water and agricultural 

production, search for “PFAS”.

www.conservationwebinars.net/previous-webinars

PFAS - JULY 2021

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