Where New Hampshire Stands on PFAS in Biosolids

Taking the pulse?

New Hampshire is steadily tightening its oversight of PFAS in biosolids, commonly referred to as “sludge”. Right now, the state requires PFAS testing, and regulators are working toward numerical “screening values” that would help determine whether a biosolids product is suitable for beneficial use such as land application. Numeric threshold values don’t exist yet for PFAS in NH Sludge Management Rules, Env-Wq 800 – but regulators indicate they are on the way.

What is in place today?

Under the draft updates to Env‑Wq 800, PFAS have been added to the list of parameters required for sludge quality certification, initial testing of soils, and facility beneficial use. Testing uses a broad, 40‑compound list based on EPA Method 1633, and results are reported in nanograms per gram. In practice, this means PFAS data are now part of the normal quality‑certification process, ensuring that sludge is routinely assessed for these compounds.

PFAS are also indirectly regulated through groundwater standards. Env‑Wq 808 links PFAS detections in leachate or groundwater to the state’s existing Ambient Groundwater Quality Standards (AGQS) in Env‑Or 603, which means regulated PFAS exceedances trigger the same corrective‑action framework used for other contaminants.

What is coming next?

NHDES has been requiring PFAS monitoring in biosolids since 2019 and recently completed a study with the U.S. Geological Survey to understand PFAS concentrations in soils across New Hampshire, in groundwater near AFFF sites and at an active biosolids land application site. Building on that research, the agency is working to develop a model of how certain PFAS compounds move from land-applied biosolids through soil to groundwater. Results from the modeling will help define numeric PFAS screening values for beneficial use of biosolids.

During testimony, NHDES said it expects the modeling work to wrap up and be peer‑reviewed by fall 2026. After that, the agency plans to propose formal PFAS screening standards for biosolids under Env‑Wq 800.

What does this mean now?

For the moment, biosolids generators who wish to beneficially use their product must continue monitoring PFAS and comparing results against groundwater and other environmental standards, but there’s no pass/fail limit in Env‑Wq 800 like there is for metals, and other contaminants.

Once the state adopts numeric PFAS threshold values, New Hampshire will move from simply tracking PFAS in biosolids to actively regulating it — setting a clear ceiling for beneficial use and providing more predictability for everyone involved in biosolids management.