Waste Containing PFAS
The group of chemical compounds referred to as PFAS (perfluoroalkyl and polyfluoroalkyl substances) are found in many types of waste, including firefighting foam, contaminated soil, waste from industrial operations and post-consumer household waste. There are no simple answers on how best to dispose of waste containing PFAS. However, research and regulations continue to develop and evolve, informing best management practices for disposal.
Current state and federal regulations do not prohibit disposal of PFAS-containing waste in a licensed solid waste or hazardous waste disposal facility, nor do they require a facility to accept PFAS-containing wastes.
The Department of Natural Resources recommends that anyone with questions regarding proper disposal of business waste known to contain PFAS consult with an environmental and hazardous waste disposal contractor for current best available disposal options. Additional information is also available from the U.S. Environmental Protection Agency’s Interim Guidance on the Destruction and Disposal of PFAS and Materials Containing PFAS [exit DNR].
Private well owners living near waste disposal sites can learn more about testing well water by accessing the following DNR resources:
What to consider when disposing of waste containing PFAS
The DNR will continue to research, compile and share information to assist waste generators, regulated facilities and the public in identifying disposal options.
Disposal decisions for waste that contains PFAS should be based on the following factors:
- type of waste, such as contaminated soil or industry-generated waste;
- applicable regulations;
- known or potential levels of PFAS contamination;
- available disposal options; and
- whether a facility is approved to accept the waste.
PFAS and hazardous waste
In Wisconsin, the presence of PFAS alone does not characterize a waste as a Resource Conservation and Recovery Act hazardous waste. Wastes must be managed as a RCRA hazardous waste only when they meet specific regulatory listing criteria or exhibit hazardous characteristics, independent of PFAS content.
Current waste management options
Facilities in Wisconsin
Facilities may choose not to accept certain wastes. Contact the facility before transporting any waste known to contain PFAS.
Within the state, and depending on the type of waste in question, disposal facilities that may legally accept waste that contains PFAS include the following:
- Solid waste landfills, such as municipal solid waste, industrial, and construction and demolition landfills.
- Solid waste combustors or incinerators that are processing and treatment facilities designed and operated for controlled burning of solid waste.
- Landspreading facilities where solid waste is deposited, placed or injected in thin layers on or into the ground for agricultural, silvicultural or waste disposal purposes.
Other waste management facilities in Wisconsin that may legally accept and process certain types of waste that contains PFAS, but are not disposal sites, include the following:
- Compost facilities that transform organic solid waste (such as food, yard waste, manure) under controlled conditions designed to promote aerobic decomposition.
- Hazardous waste treatment, storage and disposal facilities that treat and/or store a variety of hazardous wastes. Wisconsin has no active hazardous waste landfills.
- Solid waste processors and materials recovery facilities where solid waste is baled, shredded, pulverized, composted, classified, separated, combusted, or otherwise treated or altered to facilitate further transfer, processing, use or disposal.
Disposal Options Outside of Wisconsin
Waste containing PFAS may also be disposed of by sending it to facilities that do not operate in Wisconsin. The decision to dispose of, process or ship waste containing PFAS should take into account the potential for further release of PFAS compounds into the environment and the possible risks and liabilities associated with the various options.
The listing of an option on this site does not constitute a recommendation for what is an appropriate management approach in any specific scenario.
Facilities outside of Wisconsin that may accept waste containing PFAS include:
- deep injection wells that are used to place fluid underground into porous geologic formations;
- hazardous waste landfills that accept and contain hazardous waste; and
- hazardous waste incinerators that accept and incinerate hazardous waste.
Wisconsin management options by waste type
- Firefighting foam
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Suggestions for disposal:
- Contact the foam manufacturer for disposal recommendations.
- If the foam cannot be returned to the manufacturer, consult with an environmental and hazardous waste disposal contractor for current best available disposal options. They can also assist with characterizing the waste.
Anyone in possession of PFAS foam should plan, train and verify that appropriate storage and containment equipment is available to mitigate PFAS foam discharges in a facility or to the environment.
- Soil and sediment
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Soil and sediment may be managed at a solid waste landfill. Check first with the landfill to determine any special expectations for delivery of soil or sediment. May be managed under the ch. NR 718, Wis. Adm. Code, process for existing sites using a DNR-approved soil management plan.
- Various industry-generated waste
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May be managed at a solid waste landfill or, for some wastes, a construction and demolition landfill. PFAS may be found in waste from processes using polymers, coatings, surfactants, lubricants and waxes, among other industrial processes. Industries can assess the PFAS composition of materials and products and work with distributors and vendors to evaluate the information in material safety data sheets, technical data sheets and environmental documentation before disposal.
- Household-generated waste
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May be managed at a solid waste landfill, solid waste combustor or, for some wastes, a construction and demolition landfill. Many household products contain PFAS coatings or ingredients. According to the Wisconsin Department of Health Services, it is not practical to completely avoid exposure to these chemicals, as they are common and present in the human environment, but DHS offers suggestions to limit contact.
Drinking water filters used by households can be disposed of in household trash to be landfilled, or filter companies may have a mail-back option.
- Food and yard waste
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May be managed at compost facilities. Although composting does not treat or eliminate PFAS compounds, there are many environmental benefits associated with composting, including reducing greenhouse gas emissions and supporting improved soil health. The Wisconsin Department of Health Services also has facts and tips for home gardeners on PFAS and backyard gardening.
The U.S. Food and Drug Administration is working to understand the occurrence of PFAS in the general food supply and packaging by testing for certain PFAS chemicals and reviewing the limited authorized uses of PFAS in food contact applications. The FDA notes on its website that there is no scientific evidence that supports avoiding specific foods because of concerns regarding PFAS contamination.
- Biosolids/waste from wastewater treatment plants
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May be managed at a landspreading facility or solid waste landfills. The DNR is developing additional information on this topic.
