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Executive Summary

A Problem Largely Not of Farmers' Making

The authors survey the federal and state regulatory landscape, review the litigation environment as it affects agriculture, and provide guidance for farmers, composters and agricultural communicators.

Per- and polyfluoroalkyl substances (PFAS), often called "forever chemicals," have become one of the most consequential environmental and regulatory challenges facing American agriculture. Farmers, composters and rural communities find themselves at the center of a crisis largely not of their making: agriculture sits downstream from industrial contamination sources, yet farmers and food producers bear disproportionate regulatory, economic and reputational consequences when PFAS are detected in soils, crops, water or food.

The central flaw in current PFAS governance — treating a chemically diverse class of thousands of compounds as a single, uniform hazard — is especially damaging to agriculture. It distorts regulation, amplifies public alarm about food safety and exposes farmers to liability and market consequences poorly calibrated to actual risk.

The presence of PFAS in agricultural soils or food at trace levels does not, by itself, establish meaningful harm. Real-world risk depends on the specific compound, dose, duration and exposure pathway.

Five Core Issues

What Agriculture Needs to Know

The paper identifies five core issues for the agricultural community.

01

The strongest evidence is concentrated in a few compounds

Evidence for adverse health effects is strongest for a small number of well-studied compounds, particularly PFOA and PFOS, and in high-exposure scenarios. The science remains far weaker for most of the thousands of other PFAS.

02

Contaminated inputs are agriculture's main exposure pathway

PFAS reach farms primarily through biosolids, compost, irrigation water and certain feeds — not through farming practices themselves.

03

Governance must be compound-, pathway- and exposure-specific

Sound agricultural governance gives priority to upstream source control and targeted testing rather than blanket restrictions on farming activities.

04

Farmers need practical, science-based tools

Producers need tools to test inputs, interpret results, communicate credibly with buyers and consumers, and avoid regulatory or litigation responses calibrated to industrial polluters rather than agricultural recipients.

05

EPA's biosolids work sharpens the practical question

EPA's 2025 Draft Sewage Sludge Risk Assessment and 2026 draft biosolids guidance treat biosolids as a valuable nutrient source, while calling for source control at wastewater treatment plants, targeted testing, crop- and pathway-specific land-application decisions and clearer public communication.

PFAS Overview

Not One Chemical, but Thousands

PFAS share multiple carbon-fluorine bonds, but the class is chemically diverse. Its members differ substantially in structure, persistence, mobility, exposure pathways and toxicity.

Depending on the definition used, PFAS inventories include thousands to tens of thousands of substances. EPA's CompTox PFAS structure list contains 21,028 in its January 2026 update. No single PFAS definition has been agreed to, including for agricultural purposes — a point with direct consequences when state proposals could sweep fluorinated pesticides into PFAS restrictions without first evaluating exposure, mobility, persistence or agricultural need.

Since the 1940s, PFAS have been used in hundreds of applications because of their resistance to heat, water, oil and chemical degradation — from firefighting foams and nonstick cookware to semiconductors, medical devices and batteries. Some, including certain fluoropolymers, are less soluble and less mobile. Others, including PFOA and PFOS, move readily in water, persist in the environment and have a stronger evidence base for adverse health and ecological effects.

Hazard vs. Risk

Hazard describes a substance's capacity to cause harm under some conditions. Risk depends on how much, how often, for how long and by what pathway someone is exposed. Measurability is not the same as harmfulness: modern analytical tools can detect compounds at concentrations far below many established health thresholds.

What Federal Testing Shows

USDA's Food Safety and Inspection Service has tested 3,199 meat and poultry samples for PFAS, with fewer than 0.1% showing detections. The FDA found no PFAS in 97% of roughly 800 fresh and processed food samples; among seafood specifically, 74% had detectable levels.

Children warrant separate consideration. The same concentration in water or food delivers a larger dose relative to body weight while organ systems are still forming, and early-life behaviors can increase contact with PFAS-bearing dust and materials.

Terminology

Key Terms

Suggested terms and acronyms from the paper.

01

PFAS

Per- and polyfluoroalkyl substances; a broad, chemically diverse group rather than one uniform hazard.

02

PFOA/PFOS

Well-studied legacy PFAS with stronger evidence bases and tighter regulatory attention than most of the broader class.

03

AFFF

Aqueous film-forming foam, a major source of contamination at military bases, airports, fire-training areas and fuel-handling sites.

04

Biosolids

Treated municipal wastewater solids that can provide nutrients but may concentrate PFAS from industrial and household waste streams.

05

Hazard vs. risk

Hazard describes a substance's capacity to cause harm under some conditions; risk depends on dose, duration, pathway and real-world exposure.

06

MCL

Maximum contaminant level, an enforceable drinking-water standard.

07

NASEM

National Academies of Sciences, Engineering, and Medicine; its 2026 USDA/NRCS report frames agricultural PFAS management as decision-making under uncertainty.

PFAS in Agriculture and Food

How PFAS Reach Farms

Farmers are typically downstream recipients of PFAS contamination originating elsewhere, not its generators. The most consequential concern is not background trace detection but localized hotspot exposure.

01Firefighting Foam

Aqueous film-forming foam (AFFF), developed in the 1960s, became a major source of contamination at military bases, airports, fuel depots and refineries. Repeated training, testing and emergency use created many PFAS hotspots. Farms near such facilities have in some cases received contaminated groundwater or irrigation supplies — contamination generated by military or industrial activities, not by farming.

02Biosolids

Biosolids — the treated solid residue from municipal wastewater treatment — are one of the most direct pathways through which PFAS move from industrial and municipal sources into agricultural soils. Wastewater treatment concentrates PFAS in sludge that is then land-applied.

03Compost & Soil Amendments

PFAS are generally not added to compost intentionally. They enter through contaminated feedstocks such as biosolids, mixed municipal or industrial residuals and treated paper fibers, making compost a collection point for PFAS from many scattered sources.

04Water, Air & Legacy Sites

PFAS also reach farms through industrial discharges into waterways, contaminated irrigation water, atmospheric deposition and legacy contamination in soils and groundwater near military or industrial sites.

Where States Look

States that have invested heavily in PFAS investigation — Michigan, Minnesota and Maine — have identified more agricultural impacts, not necessarily because they have more contamination, but because they have looked harder.

Farmers are partners in risk reduction, not convenient downstream targets for contamination they did not cause.

PFAS in Agriculture: Science, Uncertainty, and Risk Communication — CAST, October 2026
The Federal-State Regulatory Landscape

An Evolving National Floor

PFAS regulation in the United States has developed as a layered federal-state system rather than through a single statutory framework. For farmers, the most immediately relevant rules are often state level.

EPA has used the Safe Drinking Water Act to set national drinking-water requirements for some PFAS, the Toxic Substances Control Act to require broad reporting on PFAS in commerce, and CERCLA to designate PFOA and PFOS as hazardous substances, expanding cleanup liability. The federal baseline remains unsettled: EPA retained the 2024 maximum contaminant levels for PFOA and PFOS but in 2025 announced its intent — formally proposed in 2026 — to extend compliance deadlines and to rescind and reconsider standards for PFHxS, PFNA, HFPO-DA (GenX) and the Hazard Index mixture.

States supply much of the implementation detail, especially for soils, biosolids, compost, waste streams and agricultural interfaces. Producers operating across state lines, or selling into multiple state markets, face a patchwork of requirements.

State Approaches

Four States, Four Models

State programs illustrate very different approaches to PFAS governance with direct agricultural implications.

State Approach Agricultural Interface
California Hazard-forward, multi-lane governance, including Proposition 65 chemical-specific listing and warning requirements Listings for PFOA and PFOS create potential labeling exposure for producers selling into California, even where dietary risk is minimal
Minnesota Coordinated, multi-agency approach rooted in early 3M-related disposal-site investigations Since Sept. 1, 2025, biosolids intended for land application must be tested for PFAS, with tiered response actions rather than a blanket ban
Michigan Contamination-driven response that became a statewide framework through the Michigan PFAS Action Response Team The 2025 St. Clair County settlement over PFAS-contaminated compost shows disputes moving beyond drinking water and AFFF sites
Maine Among the most restrictive responses to sludge and septage land-application contamination Farms that accepted biosolids in good faith were severely affected; the state now faces waste streams that can no longer be land-applied

Minnesota's structured testing with tiered responses represents the kind of evidence-based, pathway-specific governance the authors recommend agricultural stakeholders advocate for in other states.

PFAS Litigation

Where Liability Is Heading

PFAS litigation outcomes vary sharply by claim type, exposure pathway and procedural posture. Water treatment-cost claims, property-damage claims and personal-injury suits carry very different evidentiary burdens.

The center of PFAS litigation remains the AFFF multidistrict litigation in the U.S. District Court for the District of South Carolina, focused principally on firefighting-foam contamination. In June 2023, Chemours, DuPont and Corteva agreed to contribute $1.185 billion to resolve PFAS drinking-water claims brought by a nationwide class of public water systems.

Personal-injury claims remain more difficult, because causation often depends on individualized proof of exposure, dose and medical harm. Medical-monitoring claims remain highly state-specific.

Protective Factors for Agriculture

For agricultural defendants, the key protective factors are documented good-faith reliance on regulatory guidance, proactive testing, absence of control over upstream contamination sources and evidence that detected PFAS levels fall below established health thresholds.

Biosolids, Compost and Food Waste

Practical Responses on the Farm

Agriculture and composting sit downstream from multiple contamination sources while facing procurement standards and testing expectations that often move faster than formal regulation.

Composting does not reliably destroy PFAS. The heat and biological digestion that break down many organic contaminants do not reliably break down these chemicals, so source control, feedstock screening and documentation matter more than in earlier contamination episodes. A 2019 study found PFAS in all compost samples it tested.

Farmers also face two sets of rules at once: state regulation sets the legal floor, while private buyer specifications often bind sooner and harder.

EPA's 2026 Draft Biosolids Guidance

The voluntary guidance recommends avoiding land application near fishable waters, drinking-water lakes or reservoirs, or areas with higher groundwater-impact risk; avoiding locations where children under 5 have or may later have access; and favoring lower-exposure crops such as grains, fiber crops or corn for ethanol.

Near-Term Steps for Farmers and Composters

Test higher-risk inputs — especially biosolids, composts, irrigation water, livestock water and certain feeds. Where feasible, shift toward lower-risk nutrient sources and verified clean compost, especially for leafy greens and root crops. Work with Extension, land-grant researchers and certified laboratories to interpret results compound by compound. Participate in baseline soil and water monitoring, and communicate credibly about what was tested, what was found and what steps were taken.

Recommended Actions

Six Action Points for Agricultural Stakeholders

Recommended action points for CAST, land-grant universities and agricultural stakeholders.

Action 01Source Control

Prioritize Source Control

Work upstream with wastewater utilities, composters, industrial dischargers and state agencies before PFAS reach farm inputs.

Action 02Testing

Test Strategically

Focus on higher-risk inputs such as biosolids, compost, irrigation water, livestock water and feeds from industrialized or urbanized watersheds.

Action 03Interpretation

Interpret Results Compound by Compound

Distinguish trace detection from meaningful exposure, and avoid communicating "PFAS present" as if it automatically means "unsafe."

Action 04Documentation

Document Decisions

Preserve records of input sourcing, testing, laboratory methods, buyer communications and risk-management steps so farms are not treated as polluters when they are downstream recipients.

Action 05Policy

Engage in State Rulemaking

Help prevent class-wide or chemically overbroad policies — especially around biosolids, compost and fluorinated pesticides — that could raise farm costs without reducing real risk.

Action 06Communication

Communicate Early

CAST and land-grant universities should prepare plain-language explainers, graphics and talking points before the next PFAS food or farm story breaks.

Conclusion

Risk Communication and Practical Action

A basic distinction must anchor every public conversation about PFAS in agriculture: hazard is not the same thing as risk.

"PFAS detected" is too often reported as "PFAS dangerous," even when a finding is at trace levels and the exposure implications are uncertain or low. When that confusion drives regulatory or market responses, it is farmers — not the manufacturers who created the contamination problem — who bear the cost.

Some legacy PFAS are persistent and will present problems in water supplies and agriculture for years to come. But there is no practical way to remove most of the thousands of PFAS already dispersed through water, soils and waste streams. The goal for agriculture is therefore not elimination but managed, evidence-based risk reduction that protects public health, preserves productive farmland and maintains consumer confidence in the food supply.

Agriculture needs decision tools, not slogans: clear terms, targeted testing, source-aware conservation planning and communication that distinguishes legacy long-chain PFAS and high-exposure pathways from broad, class-wide claims that may have little relevance to actual farm risk.

Disclosure: Thomas Redick, an author of this paper, has advised companies including Cymer (now part of ASML) on PFAS-related waste-management strategy.

Contributors

Authors, Liaison and Reviewers

This paper was written by the following authors and reviewed by the following experts.

Authors

Jon Entine

Founder
Science Literacy Project (Genetic Literacy Project)

Mark McDaniel

Vice President
AlterEcho and TechLaw Consultants Inc.

Thomas Redick

Retired Environmental Attorney
Global Environmental Ethics Counsel LLC

CAST Liaison

John Swarthout

Senior Global Scientific Affairs and Engagement Lead
Bayer Crop Science

Reviewers

John Harding

Senior Counsel
Clyde & Co

Linda Lee

Distinguished Professor, Department of Agronomy
Purdue University

Gregory Jaffe

Founder and President
Jaffe Policy Consulting LLC

Bruce Young

Senior Regulatory Issue Manager
Bayer Crop Science

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PFAS in Agriculture

Complete paper with all findings, state case studies, litigation review and citations. For researchers, policymakers and technical readers.

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Authors Jon Entine, Mark McDaniel and Thomas Redick present the findings, with Redick moderating. Friday, Oct. 16, 2026, noon CT.

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Citation

Cite This Work

DOI-assigned through CAST Publications. Use the DOI for citation in academic and policy documents.

10.62300/krpmdc33