oEPA

United States
Environmental Protection
Agency

EPA's PFAS Strategic Roadmap:
Three Years of Progress

November 2024


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Introduction

PFAS, the common term used for per- and
polyfluoroalkyl substances, are an urgent threat to
public health and the environment. Communities
across the nation are discovering these chemicals
in their air, land, and water. The science is clear:
exposure to certain PFAS poses significant risks
to human health, including cancer, even at very
low levels. That's why, in 2021, EPA Administrator
Michael Regan established the EPA Council on PFAS
and multiple offices within the EPA developed the
Agency's PFAS Strategic Roadmap. The Roadmap is
our commitment to the American people to confront
PFAS contamination head on—by following the
science, leveraging all available tools and authorities,
holding polluters accountable, and investing historic
resources to protect communities. The Roadmap is
structured around three overarching goals:

RESTRICT

Pursuing a comprehensive approach to
proactively prevent PFAS from entering air,
land, and water at levels that can adversely
impact human health and the environment.

REMEDIATE

Broadening and accelerating the cleanup of
PFAS contamination to protect human health
and ecological systems.

RESEARCH

Investing in research, development, and
innovation to increase understanding of PFAS
methods, human health and environmental
risks, and technologies.

In the Roadmap, the EPA committed to issuing an
annual public report on progress toward the Agency's
PFAS commitments. The EPA followed through on this
commitment through progress reports in November
2022 and December 2023. This report synthesizes the
Agency's progress addressing PFAS under the Biden-
Harris Administration, and sets the stage for future
priority actions to protect communities from PFAS.

The EPA acknowledged in 2021 that the Roadmap
itself would not solve all of the nation's PFAS

challenges overnight, but that its actions would help
turn the tide by harnessing the collective resources
and authority across federal, Tribal, state, and local
governments to empower meaningful action. Under
the Biden-Harris Administration, under the PFAS
Strategic Roadmap, and in coordination with federal
partners in the Interagency Policy Committee on
PFAS. the EPA has taken unprecedented steps to
safeguard human health and protect the environment
from PFAS:

Protecting Drinking Water: Under the PFAS
Roadmap, in April 2024, the EPA took a signature
step to protect public health by establishing the first
federal, legally enforceable drinking water standards
for several PFAS individually and in mixtures. The EPA
estimates the final rule will reduce PFAS exposure
for approximately 100 million people and prevent
thousands of premature deaths, tens of thousands of
serious illnesses, including cancers and liver and heart
impacts in adults, and immune and developmental
impacts to infants and children. And since early 2021,
the EPA has been undertaking the largest nationwide
effort to understand the frequency that PFAS is found
in drinking water, and at what levels, under the fifth
Unregulated Contaminant Monitoring Rule (UCMR).
Under this program, the EPA is collecting and making
publicly available data on 29 different PFAS in drinking
water at approximately 10,000 water systems. These
data will help the Agency make determinations about
future actions to protect public health under the
Safe Drinking Water Act, as well as supporting water
systems' implementation of the new PFAS standards.

Cleaning Up PFAS Contamination: Through science,
policy, and regulation, the EPA has catalyzed the
cleanup of PFAS contamination by federal agencies,
states, and responsible parties to protect people,
communities, and the environment. The EPA finalized
the designation of PFOA and PFOS as hazardous
substances under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA,
or Superfund) in 2024. Finalizing this critical
regulatory tool enables the EPA to use cost recovery
and enforcement authorities to address PFOA
and PFOS releases, which ensures that polluters
pay for investigations and cleanup. The EPA has
continued to integrate peer-reviewed science into its
site assessments and decision-making, rescinding
outdated groundwater cleanup guidance for PFOA
and PFOS in 2023 and continuing to update its

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April 2024 - EPA Administrator Michael Regan, White House Council on Environmental Quality Chair Brenda Maiiory,
North Carolina Governor Roy Cooper, and state and community leaders in Fayetteville, NC to announce the first
enforceable drinking water standards for certain PFAS.

contaminated site screening level tables with new final
toxicity values for these and other PFAS. In April 2024,
the EPA also synthesized significant new research and
issued updated guidance that describes approaches
for managing the destruction and disposal of PFAS-
containing materials and recommends practices
associated with these technologies that minimize
PFAS releases to the environment. And in early 2024,
the EPA laid the foundation for final PFAS action under
the Resource Conservation and Recovery Act (RCRA)
to designate certain PFAS as hazardous constituents.
ensuring that PFAS can be cleaned up at facilities that
handle waste using RCRA corrective action. Through
this work, the EPA has broadened and accelerated
the cleanup of PFAS contamination to protect human
health and ecological systems.

Advancing Chemical Safety: Since January 2021,
the EPA has taken dozens of actions to harness the
authorities of the Toxic Substances Control Act and
other laws to protect people from PFAS and account
for risks to vulnerable subpopulations, like children.
For PFAS for which manufacture and processing
has ceased, the EPA issued a Significant New Use
Rule (SNUR) to prevent resumed manufacture or

processing of hundreds of inactive PFAS without a
robust up-front EPA safety review. The EPA has also
issued SNURs to ensure that existing protections
imposed on submitters of PFAS through the
EPA's Toxic Substances Control Act (TSCA) new
chemicals program are more broadly applicable to
ail future manufacturers and processors of those
chemicals. And to ensure adequate review of new
PFAS, or chemicals not previously in commerce, the
EPA announced policy changes in April 2021 and
proposed regulations in May 2023 to close premarket
review exemptions for PFAS and other persistent,
bioaccumulative, and toxic chemicals. And to guide
the EPA's review of new PFAS before they are made,
the Agency released a framework in June 2023 to
ensure rigor and consistency in its reviews, and, as
necessary, to ensure these chemicals are effectively
managed to protect against risk to people's health or
the environment.

Safeguarding our Waterways: Since early 2021,
the EPA has put critical building blocks in place
for understanding and addressing PFAS in our
nation's waters under the Clean Water Act. The EPA
finalized two critical methods, EPA Methods 1621

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and 1633. for measuring PFAS in a range of different
environmental media. The EPA released two sets of
recommendations for how EPA Regions and states
can use key Clean Water Act permitting authorities
to collect information on PFAS discharges, consider
and incorporate PFAS-reduction measures, and set
technology-based effluent limits, with rules to be
proposed that codify final analytical methods and
require PFAS be disclosed in Clean Water Act permit
applications. The EPA is working to propose the first-
ever technology-based Effluent Limitations Guidelines
for PFAS manufacturers, and expects proposed
rules for metal finishers and landfills to follow. The
EPA in October 2024 finalized recommended water
quality criteria for the protection of aquatic life from
the effects of PFOA and PFOS as well as water
quality benchmarks for other PFAS, and released a
recommended list of PFAS to monitor for in state and
Tribal fish and shellfish advisory programs. And in
the coming months, the EPA expects to release draft
recommended water quality criteria for the protection
of human health from the effects of several PFAS as
well as a draft risk assessment of PFOA and PFOS in
biosolids to inform future Clean Water Act steps.

EPA scientist Sarah Kadlec performs experiments to
evaluate the effect of PFOS and other substances on
aquatic organisms. In October 2024, the EPA published
Aquatic Life Criteria for certain PFAS.

Catalyzing Infrastructure Investments: Just one
month after Administrator Regan released the PFAS
Strategic Roadmap, President Biden signed the
Bipartisan Infrastructure Law (BIL). Through the
BIL, the Biden-Harris Administration is supporting
transformational investments in our nation's water
infrastructure with an unprecedented more than $50
billion to invest in drinking water and clean water
infrastructure around the country. Of those funds,
$10 billion are dedicated to assist communities
and water systems impacted by PFAS and other
emerging contaminants, with billions more in general
funds also available to support progress on PFAS.
Many of the programs delivering this funding are part
of the President's Justice40 Initiative, which sets
the goal that 40% of the overall benefits of certain
federal investments in climate, clean water, and other
areas flow to disadvantaged communities that are
marginalized by underinvestment and overburdened
by pollution. The BIL uses both existing and new EPA
water finance programs to provide communities with
funding for emerging contaminants, and more than
half of that $10 billion must be provided as grants
or forgivable loans. This funding has provided a
tremendous opportunity to advance the research and
policy actions in the Roadmap with financial resources
to protect people and the environment from PFAS
contamination. These BIL investments are already
helping communities from Tucson, AZ, to North
Attleboro, MA, and from Yukatat, AK, to Darlington
County, SC, to make transformative investments
to protect drinking water, pilot wastewater capture
solutions, and reduce PFAS levels in people and the
environment.

Pursuing Enforcement and Compliance: PFAS
contamination is personal for many communities
across the country and has imposed significant costs
on state and local governments, water systems, and
individuals. Addressing and redressing decades of
contamination by the manufacturers and users of
these chemicals will rely on key actions the EPA has
put in place during the last three years. The EPA's
final designation of PFOA and PFOS as CERCLA
hazardous substances is a centerpiece of this effort
- enabling the EPA to use the full suite of available
CERCLA authorities to address more contaminated
sites, take earlier action, and expedite eventual
cleanup. Additionally, the EPA's PFAS Enforcement
Discretion and Settlement Policy Under CERCLA
reinforces the EPA's laser focus on the significant

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contributors to the PFAS contamination challenge
- and not on entities where equitable factors do not
support seeking response actions or costs under
CERCLA, such as farms where biosolids are applied
to the land, community water systems, or publicly
owned treatment works. And the EPA's addition
of Addressing Exposure to PFAS as a National
Enforcement and Compliance Initiative will ensure
the Agency continues to build upon its goals to take
enforcement actions to protect public health. For
example, in November 2022, the EPA announced a
Safe Drinking Water Act emergency order requiring
3M to sample, test, and treat the drinking water
around its Cordova, Illinois, facility to address PFAS
contamination.

Advancing our Understanding of PFAS: Data on
PFAS are essential for improving our understanding
of this large, diverse class of chemicals. As we learn
more about the potential risks to human health and
the environment from PFAS, we can do more - at
all levels of government - to reduce these risks.

Since 2021, the EPA has leveraged its research and
regulatory programs to collect and generate more
data on PFAS. This includes the EPA's previously
mentioned nationwide drinking water monitoring
program, UCMR5; finalizing a regulation under TSCA
that will generate the largest-ever dataset of PFAS
manufactured and used in the United States; and
significant improvements to Toxics Release Inventory
PFAS reporting that have eliminated exemptions
that previously allowed facilities to avoid reporting,
by regularly adding PFAS to the TRI list as science
evolves, and by proposing a rule in October 2024 that
would require reporting on 16 individual PFAS and 15
categories of PFAS, representing over 100 individual
PFAS. The EPA has leveraged its authorities under
TSCA to develop, implement, and refine the Agency's
National PFAS Testing Strategy, which is building
the available information on categories of PFAS that
lack adequate data to inform future decisions. And to
provide a transparent and accessible resource to the
public on PFAS manufacture, release, and occurrence,
the EPA released its PFAS Analytic Tools in January
2023. These tools bring together multiple sources of
information in one spot with mapping, charting, and
filtering functions, allowing the public to see where
testing has been done and what level of detections
were measured. Finally, the Agency has continued
to pursue a rigorous research agenda focused on
developing new methods to detect PFAS in the

environment, advancing the science needed to assess
the human health and environmental risks from PFAS,
and testing technologies for reducing PFAS in the
environment. Results from this research have already
informed both federal and state actions on PFAS and
will continue to serve as the scientific foundation for
future decision-making.

Reducing PFAS in Products and Purchasing:

Reinforcing the EPA's regulatory efforts to prevent
PFAS releases to the environment, the EPA has
taken significant action to reduce PFAS uses in
commerce, in coordination with federal partners and
complementing significant efforts by several states.
Following through on Executive Order 14057 on
federal sustainability, the EPA has developed and
refined a number of online resources to educate
purchasers and other users on which ecolabels and
sustainability standards restrict or eliminate PFAS
from their products. The EPA has ensured that its
information and tools focus on removing PFAS as a
class of chemicals rather than only a few chemicals
at a time. The EPA has removed PFAS from the Safer
Choice program's Safer Chemical Ingredients List
and is ensuring that PFAS are not intentionally added
to Safer Choice-certified products. The EPA has
taken action to remove 12 PFAS from the list of inert
ingredients approved for use in nonfood pesticide
products. And the EPA has taken significant steps
alongside the General Services Administration (GSA)
to ensure the most widely used procurement tools
across the federal government - the largest consumer
of goods and services in the world - are highlighting
the products that do not contain PFAS. In addition,
the EPA and GSA successfully updated GSA's
National Custodial specification to ensure all cleaning
products being used to clean federal buildings do not
contain PFAS.

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Key Accomplishments: 2024

Protecting Drinking Water

Safe drinking water is fundamental to healthy people
and thriving communities. For years, communities,
states, and bipartisan leaders in Congress have
called for the EPA to set nationwide drinking water
standards for PFAS. In April 2024, Administrator
Regan announced the first-ever, nationwide, legally
enforceable drinking water standards for PFAS - the
most significant action the EPA has taken on these
'forever chemicals.' The final rule will reduce PFAS
exposure for approximately 100 million people,
prevent thousands of deaths, and reduce tens of
thousands of serious illnesses. In the final rule,
the EPA established legally enforceable drinking
water standards for several PFAS individually and in
mixtures, including limits for five individual PFAS as
well as limits on mixtures of any two or more of four
PFAS. Decades of research shows that mixtures of
different chemicals can have additive health effects,
even if the individual chemicals are each present at
low levels that may not be expected to result in health
effects alone. The rule is achievable using a range of
available technologies and approaches, and drinking
water systems will have flexibility to determine the
best solution for their community. The EPA will be
working closely with state co-regulators in supporting
water systems and local officials to implement this
rule.

To help catalyze the infrastructure investments and
public health protections in communities across the
country, the EPA continues its work to implement
the unprecedented funding provided in President
Biden's BIL. The BIL invests a total of $9 billion to
address emerging contaminants like PFAS in drinking
water, and the EPA has announced $6.2 billion of this
funding to date. Coupled with the final rule in April
2024, the EPA announced $1 billion of this funding to
address PFAS and other emerging contaminants in
small or disadvantaged communities. Also in April, the
EPA announced Fiscal Year 2024 funding allocations
of almost $1 billion for emerging contaminants work
under the Drinking Water State Revolving Fund.

In May 2024, the EPA also announced its Fiscal
Year 2024 funding allocations for the EPA's Tribal
infrastructure financing programs for PFAS and other
emerging contaminants, including more than $35

million for drinking water and $4.5 million for clean
water. And in October 2024, the EPA announced
Fiscal Year 2025 allocations of almost $1 billion for
emerging contaminants through the Drinking Water
State Revolving Fund. The remaining $2.8 billion in
emerging contaminants funding through the Bipartisan
Infrastructure Law will become available during FY
2025 and FY 2026.

In 2024, the EPA continued to release data collected
under the fifth UCMR. Under the rule, more than
10,000 water systems are collecting data on 29 PFAS
in drinking water to provide unprecedented data on
national-level exposure to these PFAS. As of October
2024, the EPA has released six quarters of monitoring
data, representing half of the total data expected from
2023-2025. UCMR monitoring is not only providing
information for water systems and the public they
serve, but will also enable the EPA, states, and the
public to better understand potential disproportionate
PFAS exposures in drinking water as data collection is
completed. Looking further into the future, in February
2024 the EPA requested comments on monitoring
approaches for the next round of unregulated
contaminant monitoring (2028-2030), including total
fluorine methods for drinking water.

Cleaning Up PFAS
Contamination

The EPA's authorities under CERCLA and RCRA
provide critical tools for cleaning up PFAS
contamination and holding polluters accountable.
In April 2024, the EPA finalized a critical final rule
designating two PFAS—PFOA and PFOS, including
their salts and structural isomers—as hazardous
substances under CERCLA. This designation makes
available CERCLA enforcement authority to compel
potentially responsible parties to conduct or pay for
cleanup of PFOA- or PFOS-contaminated sites and
improves equities by transferring costs of cleaning
up PFOA and PFOS from the Superfund, which has
been historically funded by taxpayer dollars, to those
responsible for contamination. In addition to the final
rule, the EPA issued a separate PFAS Enforcement
Discretion and Settlement Policy Under CERCLA that
makes clear that the Agency will focus on holding
responsible entities who significantly contributed to

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the reiease of PFAS into the environment, including
parties that manufactured PFAS or used PFAS in the
manufacturing process, federal facilities, and other
industrial parties.

Ensuring the appropriate management of PFAS-
containing waste is also a critical EPA priority. In
February 2024, the EPA proposed two rules under
RCRA. In the first rule, the EPA proposed to amend
its RCRA regulations to add nine PFAS, their salts
and structural isomers, as hazardous constituents.
These PFAS would be added to the list of substances
identified for consideration in facility assessments
and, where necessary, considered in any further
investigation and cleanup through the corrective
action process at hazardous waste treatment, storage,
and disposal facilities, in the second rule, the EPA
proposed to modify the definition of hazardous waste
as it applies to cleanups at permitted hazardous
waste facilities. This rule would ensure the EPA's
regulations clearly reflect the EPA's and authorized
states' authority to require cleanup of the full range of
substances that RCRA intends. The EPA is currently
reviewing public comments received on these
proposed rules.

To inform PFAS cleanup decisions, the EPA has
continued to update its Regional Screening Level and
Regional Removal Management Level tables, which
provide risk-based values that help the EPA determine
if further attention is warranted or a removal is
needed. In May 2024, the EPA made further updates

to these tables based on new final scientific values for
PFOA and PFOS developed as part of the EPA's final
PFAS drinking water regulation.

As the EPA's regulatory actions and complementary
state and Tribal steps accelerate actions to remove
PFAS from drinking water, clean up contaminated
sites, and dispose of legacy PFAS-containing
products like firefighting foam, stakeholders are
increasingly seeking clarity about ways to safely
destroy or dispose of PFAS-containing materials.
In April 2024, the EPA reached a key milestone in
this effort by releasing updated interim guidance on
the destruction and disposal of PFAS-containing
materials, building on an earlier document the Agency
issued in 2020 and incorporating new peer reviewed
science. The updated guidance reflects the latest,
best available science to provide information that
managers of PFAS wastes can use to evaluate the
most appropriate destruction and disposal methods
among those currently available. The guidance also
recommends that decision-makers prioritize the
use of destruction and disposal technologies that
have a lower potential for environmental release, to
better protect people and communities from PFAS
exposures. The EPA launched an extended public
comment period on the revised interim guidance
and continues to communicate with stakeholders on
how the Agency can continue to provide updates as
regulations and research advance.

The EPA and State of Washington presenting PFAS drinking water sampling results to residents of the West Plains
Community near Spokane, WA.

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Holding Polluters
Accountable

The EPA has continued to prioritize holding polluters
and other responsible parties accountable for their
actions and for PFAS remediation efforts by using
enforcement tools to identify and address PFAS
releases. The EPA selected Addressing Exposure
to PFAS as one of six National Enforcement and
Compliance Initiatives for 2024-2027. In December
2023, the EPA announced an agreement with the
Chemours Company to conduct sampling for PFAS
contamination near the company's Washington Works
facility, a well-known source of PFAS contamination
for decades. Using the EPA's authorities under
RCRA, the agreement requires the company to take
samples and analyze soil, surface water, sediment,
groundwater, and certain waste streams generated
by the facility to collect information on known and
potential PFAS contamination. This agreement will
provide data to improve the Agency's understanding
of the extent of PFAS contamination and how
migration of PFAS contamination may impact
communities.

EPA inspectors collect samples of drinking water for
PFAS analysis.

The EPA has also continued to focus its enforcement
efforts on identifying and responding to PFAS
releases from federal facilities. In May 2024, the
EPA issued a Safe Drinking Water Act order to the
Department of the Air Force to ensure the Air Force
meets its responsibilities for protecting drinking
water supplies adjacent to the Tucson International
Airport Area Superfund Site, including in communities
with environmental justice concerns. And in July
2024, the EPA and the Department of the Army
announced a joint project to conduct sampling and
testing of private drinking water wells located near
Army installations with known, significant PFAS
contamination to address the presence of PFAS. This
sampling effort initially focuses on nine priority Army
installations and will provide critical data to ensure
military families and the general public remain safe
from exposure to PFAS potentially originating from
these installations. This project builds on the EPA's
regular sampling of private drinking water wells near
military installations with known PFAS contamination
to assess whether contamination has migrated off-site
and potentially impacted nearby communities.

The EPA's designation of PFOA and PFOS as
CERCLA hazardous substances provides the EPA
with critical tools to improve transparency and
accountability for PFAS cleanups. In developing the
rule, the EPA heard concerns from stakeholders about
how the Agency might use its CERCLA enforcement
authorities or its CERCLA enforcement discretion. The
EPA held two public listening sessions to seek input
on concerns about enforcement under CERCLA for
PFAS contamination. In April 2024, the EPA issued
a PFAS Enforcement Discretion and Settlement
Policy Under CERCLA that is consistent with the
EPA's historical approach of developing and applying
enforcement discretion policies that are effective,
well-received by stakeholders, and have given the
EPA the needed flexibility to offer liability comfort or
protections when circumstances warrant. The PFAS
Enforcement Discretion and Settlement Policy Under
CERCLA makes clear that the EPA intends to focus
its enforcement efforts on entities who significantly
contributed to the release of PFAS into the
environment, including parties that have manufactured
PFAS or used PFAS in the manufacturing process,
federal facilities, and other industrial parties. The
EPA's PFAS Enforcement Discretion and Settlement
Policy under CERCLA provides additional clarity
on the Agency's intent not to pursue certain parties

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where equitable factors do not support seeking
response actions or costs under CERCLA, including,
but not limited to, community water systems and
publicly owned treatment works, municipal separate
storm sewer systems, publicly owned/operated
municipal solid waste landfills, publicly owned airports
and local fire departments, and farms where biosolids
are applied to the land.

Enhancing Chemical Safety

In the PFAS Strategic Roadmap, the EPA committed
to leveraging all of its authorities to restrict PFAS, and
that begins with responsible use and management of
these chemicals within the marketplace. The TSCA
and Toxics Release Inventory (TRI) are foundational
tools that the EPA uses to ensure the safety of
chemicals in commerce, to collect information on
PFAS, and to increase transparency so people know
how and where these chemicals are being used
and released. The EPA has continued to use these
authorities to limit use when the Agency knows
the use presents unreasonable risk, or when the
EPA does not have sufficient information to ensure
that unreasonable risks will not occur, including to
potentially exposed or sensitive populations like
children and older adults.

Over the last year, the EPA has continued to leverage
TSCA and TRI to restrict PFAS and to provide
additional information to the public. The EPA has
continued to make progress on implementing
the National PFAS Testing Strategy - announced
concurrently with the PFAS Strategic Roadmap -
including issuing additional test orders in March
2024 requiring two companies to conduct testing
on a chemical used in products and found in air and
in biosolids, and in October 2024 to five companies
for a chemical used to manufacture plastics, resins,
textiles, apparel, leather, and other chemicals.
Information collected under these test orders will
enable the EPA to build data on categories of
PFAS and to take any necessary action to protect
people and the environment. In August 2024, EPA
scientists published a paper describing an approach
for assigning individual PFAS to categories based
on chemical structure and selecting one or more
representative PFAS from a category for additional
data collection. The EPA intends to use this updated
approach to more than double the number of PFAS
considered for data collection efforts under the
National PFAS Testing Strategy.

The EPA has continued to take steps to ensure
that potentially harmful PFAS receive robust EPA
health and safety reviews. In January 2024, the
EPA finalized a rule that prevents companies from
starting or resuming the manufacture or processing
of 329 PFAS that have not been made or used for
many years without a complete EPA review and risk
determination. In the past, these chemicals, known as
"inactive PFAS," may have been used without review
in many industries and may also have been released
into the environment. This action will ensure that the
EPA can conduct a robust review of health and safety
information to determine if any significant new use
may present unreasonable risk to human health or the
environment and that the EPA can put any necessary
restrictions in place before the use could restart.

The EPA has also used its TSCA authorities to
address the presence of specific PFAS formed during
the fluorination of plastic containers, an issue first
brought to the EPA's attention in 2020. In February
2024, the EPA released a new method for detecting
low levels of PFAS in the walls of plastic containers,
allowing companies to test their containers before
use and prevent further contamination. In July 2024,
the EPA granted a petition submitted to the Agency
by community groups, committing to promptly
commence an appropriate proceeding under TSCA
Section 6. On September 30, 2024, the EPA published
a notice in the Federal Register seeking additional
data on the prevalence of certain PFAS during the
fluorination of certain plastic containers, as well as
on the prevalence of fluorinated containers in the
U.S., alternative processes, and risk management
measures, to inform the Agency's path forward with
respect to regulation under TSCA section 6.

The 2016 amendments to TSCA strengthened the
EPA's gatekeeper role to ensure that the Agency can
review the potential risks of new chemicals before
they can enter U.S. commerce and, when necessary,
require appropriate safeguards. Building on a policy
change announced in April 2021 and proposed
regulations in May 2023, the EPA is working to finalize
regulations that, if finalized as proposed, would codify
reforms to the TSCA new chemical review process
to ensure that new PFAS are categorically ineligible
for two exemptions to the full TSCA review process,
which would ensure that new PFAS would go through
the full robust safety review process before they
can enter commerce. In carrying out these reviews,

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the EPA also continues to implement the June 2023
framework to ensure consistency in the assessment
of new PFAS and effective protections against risks to
people's health and the environment.

In the last year, the EPA has further built on earlier
progress to provide high-quality information to the
public on PFAS releases under TBI. In January 2024,
the EPA announced the addition of six additional
PFAS to TRI for the 2024 reporting year. And in
October 2024, the EPA proposed a rule to add
16 individual PFAS and 15 categories of PFAS -
representing more than 100 individual chemicals - to
TRI. These additions build on a final rule from October
2023 requiring reporting on listed PFAS even when
present in small concentrations, resulting in a more
complete picture of the releases and other waste
management quantities for these chemicals.

Reducing the levels of PFAS in products is also a
critical step toward restricting PFAS, and the EPA has
taken significant steps toward providing additional
information and resources on PFAS in products, and
toward preventing PFAS nonessential uses. In January
2024, the EPA enhanced its online search tool for its
Recommendations of Specifications. Standards, arid
Ecolabeis for Federal Purchasing to highlight how
standards and ecolabeis address PFAS. Consistent
with the federal government's goal to avoid procuring
products containing any type of PFAS, the EPA's tool
no longer highlights ecolabeis or standards that only

address individual chemicals like PFOA or PFOS.
And in April 2024, the EPA and the General Services
Administration announced that GSA will be directing
government contractors to purchase cleaning
products for federal buildings that are free from PFAS.
Currently, GSA's Public Buildings Service has more
than 600 contracts for custodial services at more than
1,500 U.S. government-owned buildings at a cost of
more than $400 million per year. These steps by the
EPA and GSA are critical to advancing the federal
government's ongoing efforts to address PFAS in
products and procurement and underscores federal
agencies' accelerated priority to combat PFAS.

Safeguarding Lakes, Rivers,
and Other Waters

The Clean Water Act provides powerful tools for
the EPA to turn off the tap for PFAS discharges to
waterways and prevent contamination at its source.
Key to these efforts are multi-laboratory-validated
methods to detect PFAS in wastewater and other
environmental media. In January 2024, the EPA
finalized two Clean Water Act analytical methods that
the EPA recommends be applied in Clean Water Act
permits. Final EPA Method 1633. validated in close
coordination with the Department of Defense, tests for
40 PFAS in wastewater, surface water, groundwater,
soil, biosolids, sediment, landfill leachate, and fish
tissue. Final EPA Method 1621 is used to determine

ERA inspector Chelsea Dixon and team member collect samples of water for PFAS analysis near Nellis Air Force
Base in Reno, NV.

EPA's PFAS Strategic Roadmap: Three Years of Progress I November 2024


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concentrations of organofluorines in wastewaters and
surface waters. As a next step, the EPA expects to
propose both methods for adoption in the Code of
Federal Regulations (40 CFR Part 136), a necessary
step for them to be nationally required for Clean
Water Act use. In the coming months, the EPA also
plans to propose a rule that would require PFAS
data be reported as part of Clean Water Act permit
applications.

In the coming months, the EPA expects to propose
Effluent Limitations Guidelines for the PFAS
manufacturing sector, which will establish nationally
applicable technology-based standards on some of
the largest sources of PFAS discharges to waterways.
These standards, when finalized after considering
public comments, will be the first of multiple rules
that the EPA is developing to restrict PFAS discharges
from metal finishers and from landfills. The EPA is
also moving forward with a nationwide study of PFAS
influent and sewage sludge at wastewater treatment
facilities and is expecting to publish updates on its
information collection request in the near future before
beginning a two-year study effort. Through this study,
the EPA plans to collect and analyze nationwide data
on PFAS to wastewater treatment plants as well as
PFAS in their influent, effluent, and in sewage sludge
(biosolids).

In the PFAS Strategic Roadmap, the EPA identified
a critical need to provide high-quality scientific
information on the potential risks of PFOA and PFOS
in biosolids that are, for example, land applied as
a beneficial use. Biosolids, the solid material left
over from the wastewater treatment process, can
contain PFAS. When PFAS-contaminated biosolids
are applied to agricultural fields as fertilizer, there is a
potential for the contamination of crops and livestock
and impacts to farmers' lives and livelihoods. The
EPA regulates the disposal and use of biosolids under
the Clean Water Act. In the coming months, the EPA
expects to release a draft risk assessment for these
two PFAS in biosolids to better characterize potential
risks and to inform any appropriate future Clean Water
Act decisions. As this longer-term effort proceeds,
the EPA continues to coordinate closely with federal
partners at the U.S. Department of Agriculture and the
Food and Drug Administration, as well as with state
and utility partners, to identify shorter term steps to
use Clean Water Act authorities and other tools to
reduce PFAS in biosolids and to communicate risks.

To emphasize the importance of partnership across
levels of government, the EPA's Office of Water joined
with state environmental and agricultural agency
leaders to release a Statement of Principles for
Managing PFAS in Biosolids to guide collaboration
on the issue. And, recognizing the complexity of this
aspect of PFAS, in 2023-2024 the EPA convened a
working group of representatives from regulators and
regulated entities across the wastewater, agriculture,
and solid waste sectors to share knowledge and
considerations for the management of PFAS in
biosolids, with a summary report anticipated for
release in the near future.

The EPA is also focused on protecting people and the
environment from PFAS in fish, shellfish, and other
aquatic life. In July 2024, the EPA released updated
recommendations under the Clean Water Act for
contaminants that states, Tribes, and territories should
consider monitoring in locally caught, freshwater
fish. With this announcement, the EPA suggested
that states, Tribes, and territories monitor for twelve
PFAS in these fish to help ensure that state and Tribal
fish advisories consider the latest science. And in
September 2024, the EPA published final, national
recommended aquatic life criteria for PFOA and
PFOS in freshwater under the Clean Water Act. The
Agency also published acute freshwater benchmarks
for eight additional PFAS that have limited data and
acute benchmarks for PFOA and PFOS in estuarine
and marine waters. States and authorized Tribes
can adopt the EPA's final recommended criteria into
their water quality standards and consider the EPA's
aquatic life benchmarks in developing their water
quality standards to protect against harmful effects of
PFOA and PFOS on aquatic life.

Strengthening the Scientific
and Data Foundation

As the EPA has taken these tangible actions both
upstream and downstream of the PFAS problem, the
Agency has continued to pursue a rigorous scientific
agenda to better characterize toxicities, understand
exposure pathways, and identify new methods to treat
and remediate PFAS pollution. Over the past year, EPA
researchers published nearly 30 papers on PFAS in
peer-reviewed scientific journals. These publications
present new information on methods for measuring
PFAS, human exposure to PFAS, human health
and ecological effects of individual PFAS and PFAS

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mixtures, treatment of PFAS-contaminated water,
and destruction and disposal of PFAS-containing
materials. The EPA also updated key data resources
- including the EPA's Drinking Water Treatability
Database, the ECOTOX Knowledgebase, and the
CompTox Chemicals Dashboard - to transparently
share new information. As the EPA learns more about
this class of chemicals, the Agency - and others - can
do more to protect public health and the environment.

In the last year, the EPA continued its work to
advance the science to assess human health and
environmental risks from PFAS. in 2024, the EPA
has continued to make progress in assessing PFAS
under the Agency's Integrated Risk Information
System program, releasing a final assessment
for perfluorodecanoic acid (PFDA) and a draft
assessment for perfluorononanoic acid (PFNA) for
public comment and peer review. Both assessments
highlight the susceptibility of early lifestages to the
health impacts of PFAS, relying on data demonstrating
decreased birth weight in children exposed to PFAS
in setting reference levels. Recognizing the time- and
resource-intensive nature of traditional human health
assessments, the EPA is also pursuing approaches
for generating reference values for chemicals in a
more timely way. In March 2024, the EPA released the
first final assessment under the EPA's Transcriptomic
Assessment Product (ETAP). ETAP is a human
health assessment that uses transcriptomics, which
measures gene activity, to determine the amount of
a chemical that alters normal biological processes.
ETAP provides a reference value for the daily dose
of a chemical where there is likely no appreciable
human health risk and can provide this information for
data-poor chemicals in a timeframe of months rather
than years. The EPA's first final ETAP provides such a
value for perfluoro-3-methoxypropanoic acid (MOPA
or PFMPA).

Given the environmental persistence and health
impacts of PFAS, it is important to understand how
these chemicals accumulate in agricultural plants and
animals, potentially contaminating our food supply.
The EPA, in partnership with the U.S. Department
of Agriculture, announced more than $15 million in
grant funding in September 2024 to ten institutions
for research to reduce PFAS exposure from food
and protect our farmland and farming communities.
Using the EPA's funding, these community-engaged
research projects will investigate topics including

how PFAS accumulates in crops and livestock; the
effects of biosolids, compost and irrigation water on
PFAS piant uptake and accumulation; and strategies
to reduce the risks of PFAS contamination in the food
supply.

Finally, EPA-funded research played a key role in
the Agency's updated interim guidance on PFAS
destruction and disposal. EPA researchers used the
Agency's Rainbow furnace to conduct pilot-scale
studies that provided important insight into the
conditions needed to fully destroy PFAS via thermal
treatment. EPA researchers also authored scientific
reviews of PFAS in combustion-based thermal waste
systems and PFAS in landfills. The scientific review of
PFAS in landfills was informed by work funded by the
EPA in 2019 to identify practical methods to analyze
and treat PFAS in solid waste, landfills, wastewater/
leachates. soils, and groundwater to protect human
health and the environment. Additionally, the EPA
released Other Test Method (QTM) 50. which
measures 30 volatile fluorinated compounds in air,
and an update to OTM-45. The EPA's updated interim
PFAS destruction and disposal guidance recommends
the use of OTM-50 to help collect more data and
reduce uncertainty concerning products of incomplete
combustion from the thermal treatment of PFAS-
containing materials.

EPA researcher Erin Shields testing at the "Rainbow
furnace," the EPA's innovative, pilot-scale tunnel
incinerator, designed to test the effectiveness of PFAS
destruction by incineration.

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Partnerships for
Progress

Critical to the EPA's success under the PFAS Strategic
Roadmap have been the partnerships with states,
Tribes, and other federal agencies in the Biden-Harris
Administration.

States and Tribes

Through the actions outlined in the PFAS Roadmap,
the EPA is providing federal leadership on PFAS, most
significantly through the EPA's final PFAS drinking
water standard. At the same time, the EPA has sought
to support states' ongoing efforts to tackle PFAS
by building critical science, methods, tools, and
technologies. Many states have been taking strong
action for years to characterize PFAS contamination,
set enforceable or non-enforceable health-based
standards, and to hold polluters accountable. In the
past few years, several states have taken their focus
fully upstream of the PFAS problem by enacting
legislation to require data collection on the presence
of PFAS in products and to prohibit PFAS in certain
nonessential products and uses.

In the course of implementing the Roadmap, the
EPA has partnered closely with states on a number
of key areas through the formation of a state-EPA
leadership workgroup to enhance coordination,
information-sharing, and a wide range of PFAS issues
impacting states and the EPA. Outcomes of this
collaborative approach include a workshop on risk
communications, the previously-mentioned principles
on managing PFAS in biosolids, and efforts to better
characterize the effectiveness of PFAS destruction
technologies.

Over the course of the Roadmap's implementation,
examples of collaboration to advance progress on
PFAS across states and EPA regional offices and
researchers include:

•	Continued PFAS monitoring in surface waters and
fish in the Great Lakes.

•	Work with the Michigan agencies to investigate
PFAS at RCRA sites, identifying data gaps and
developing and implementing sampling plans at
several sites in the state.

•	Collaboration with California, Maine, Minnesota,
and Maryland to overcome barriers to non-
targeted analysis of PFAS samples and develop
best practices for broadening its use.

•	Partnering with the state of Washington to better
understand groundwater contamination and
support impacted communities.

Strengthening public health and environmental
protection from PFAS in Indian country has been a
particular priority for the EPA. Informed by ongoing
dialogue with the Tribal PFAS Working Group, an
April 2023 listening session for Tribal partners, one-
on-one support and technical assistance, and formal
government-to-government consultation, the EPA
has provided technical assistance, infrastructure
funding, and other support to Tribal communities
to better understand and address PFAS. EPA
researchers have collaborated on projects with Tribal
partners focused on identifying and characterizing
the extent of PFAS contamination in water, sediment,
fish, and plants near Tribal communities. Several
EPA Regions have used Safe Drinking Water Act
funding to conduct sampling at Tribal public water
systems on a voluntary basis to better understand
the prevalence of PFAS in these systems. Under
BIL, the EPA is investing unprecedented funding to
support drinking water and wastewater infrastructure
in Tribal communities, including more than $35 million
in Fiscal Year 2024. And the EPA has taken a number
of actions directly responsive to Tribal concerns,
including recommendations for which PFAS to
monitor for in fish and shellfish advisory programs;
awarding research grants to support an improved
understanding of PFAS accumulation in finfish and
shellfish species in Tribal regions of Northeastern
Maine and how PFAS contamination may spread to
native plants of cultural importance to Tribes; and
releasing the PFAS Analytic Tools to better enable
Tribal communities to evaluate their exposure to
PFAS.

Federal Partners

Alongside the EPA's October 2021 PFAS Strategic
Roadmap, the White House Council on Environmental
Quality launched the first cross-government
Interagency Policy Committee on PFAS to share
information and collaborate on new policy strategies
to support research, remediation, and removal

EPA's PFAS Strategic Roadmap: Three Years of Progress I November 2024


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of PFAS in communities across the nation. The
EPA has played a leadership role in interagency
efforts to accelerate PFAS cleanup, prevent PFAS
contamination in the food system, address PFAS in
federal procurement, and better understand PFAS in
supply chains for potentially critical or essential uses.
The White House published a March 2023 report
highlighting coordinated progress by the Biden-
Harris Administration under the Interagency Policy
Committee on PFAS. And the EPA has coordinated
closely with its federal partners on key technical and
policy actions, such as the Department of Defense
on validating final EPA Method 1633. the General
Services Administration on removing PFAS from
federal custodial contracts, and the Federal Aviation
Administration on developing a fluorine-free foam
transition plan for aircraft firefighting.

The EPA has also contributed to critical interagency
federal research efforts on PFAS through the
interagency PFAS research and development strategy
team, coordinated by the White House Office of
Science and Technology Policy. The strategy team
published a March 2023 report summarizing PFAS
research in key strategic areas, including safe removal
and destruction of PFAS and alternatives to PFAS
that are safer, as well as gaps in PFAS data and
knowledge. And in September 2024, the strategy
team published a Federal Research and Development
Strategic Plan that lays out actions that federal
agencies can take to address PFAS research needs.

Looking Back and Leaning
Forward

In the PFAS Strategic Roadmap, the EPA outlined
five principles to guide the Agency's approach to
addressing the unique challenges presented by
PFAS contamination. As the EPA recognizes the
actions it has taken over the last several years, it also
acknowledges the efforts that will continue in the
months and years ahead, and considers new areas of
focus. Those principles and areas for future progress
include:

Consider the lifecvcle of PFAS: The EPA will account
for the full lifecycle of PFAS, their unique properties,
the ubiquity of their uses, and the multiple pathways
for exposure.

The Roadmap's holistic focus on restricting,
remediating, and researching PFAS acknowledged the
challenging lifecycle of PFAS and need for the EPA
to leverage the full range of its authorities to tackle
the PFAS problem. The persistence of these 'forever
chemicals' means that taking action to reduce them in
one environmental media - for example, water - may
create challenges in others - for example, biosolid
waste. That's why actions like revised destruction
and disposal guidance and the EPA's upcoming
biosolids draft risk assessment are critical to help
answer scientific questions and ensure public health
and environmental protection. Looking forward,
the EPA will need to further strengthen its focus on
destruction and disposal issues to address PFAS-
containing materials and to sustain growing interest
in researching, developing, and deploying innovative
technologies to remove PFAS from the environment
and effectively destroy them without introducing
additional contamination concerns. The EPA will
also need to continue its scientific and policy efforts
to understand particularly challenging, multi-media
problems like PFAS in biosolids, which can involve
complex interrelationships between wastewater
treatment facilities, landfills, industrial dischargers,
farmers, and the public.

Get upstream of the problem: The EPA will bring
deeper focus to preventing PFAS from entering the
environment in the first place—a foundational step
to reducing the exposure and potential risks of future
PFAS contamination.

The EPA has brought deeper focus to restricting PFAS
before they can cause contamination, including by
imposing restrictions under TSCA on 'legacy' PFAS
and by eliminating exemptions for new PFAS from
robust EPA health and safety reviews. The EPA has
also leveraged its Clean Water Act authorities through
permitting and is poised to release technology-based
effluent guidelines for the most significant categories
of industrial PFAS dischargers. Going beyond
the commitments in the Roadmap, the EPA has
leveraged its leadership role in federal procurement
by supporting Biden-Harris Administration efforts to
restrict PFAS in products purchased by the federal
government. As powerful state efforts to gather
data on the presence of PFAS in products advance,
and as the EPA's data collection under the TSCA
PFAS reporting rule commences, the EPA, states,
federal partners, and the public will have a better

EPA's PFAS Strategic Roadmap: Three Years of Progress I November 2024


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evidence base than ever before to continue efforts
to restrict PFAS nonessential uses as necessary and
to ensure that PFAS are used responsibly where
those uses must continue. The EPA will continue to
implement its Roadmap commitment to build the
technical foundation to address PFAS in air emissions,
exploring opportunities to share data and approaches
with state co-regulators to better understand and help
address these upstream sources of PFAS pollution.

Hold polluters accountable: The EPA will seek to hold
polluters and other responsible parties accountable for
their actions and for PFAS remediation efforts.

Communities across the country are confronting
the challenge of PFAS contamination that affects
their lives and livelihoods. Catalyzed by regulatory
actions by the EPA and states, and bolstered by
unprecedented water infrastructure investments
for PFAS in the BIL, communities are accelerating
efforts to clean up PFAS contamination, install
treatment technologies, and save lives. But the
EPA believes - and communities know - that the
costs of cleaning up PFAS contamination should
be borne by those who significantly contributed
to that contamination, not by communities. The
EPA's CERCLA regulations will help the agency
to recover costs expended to clean up PFOA and
PFOS contamination, which together with the
agency's enforcement discretion policy will help hold
responsible entities who significantly contributed to
the release of PFAS into the environment and support
and sustain communities struggling with a PFAS
burden they did not create. The EPA has continued to
take action under the Addressing Exposure to PFAS
National Enforcement and Compliance Initiative,
which focuses on holding responsible those who
significantly contribute to the release of PFAS into
the environment, such as major manufacturers and
users of manufactured PFAS, federal facilities that
are significant sources of PFAS, and other industrial
parties. By implementing the CERCLA designation,
exploring additional designations, prioritizing PFAS
in enforcement and compliance assurance, taking
site-specific enforcement actions, and finalizing
additional requirements like effluent guidelines,
the EPA will continue to ensure that polluters and
other responsible parties assume responsibility for
remediation efforts and prevent future releases.

Ensure science-based decision-making: The
EPA will invest in scientific research to fill gaps in
understanding of PFAS, to identify which additional
PFAS may pose human health and ecological risks
at which exposure levels, and to develop methods to
test, measure, remove, and destroy them.

Science forms the backbone of the actions discussed
in the PFAS Roadmap, and science has played a
foundational role in each of the EPA's regulatory and
policy actions on PFAS. The EPA's final PFAS National
Primary Drinking Water Regulation represents data-
driven drinking water standards that are based on the
best-available science and meet the requirements
of SDWA. In developing limits for these PFAS, the
EPA considered PFAS health effects information,
evidence supporting dose-additive health concerns
from co-occurring PFAS, as well as national and
state data for the levels of multiple PFAS in finished
drinking water. Similarly, EPA research and science
were foundational to the Agency's 2024 updates to
interim guidance on PFAS destruction and disposal -
evaluating the available science on PFAS in landfills
and providing critical data on PFAS thermal treatment.
Looking ahead, science will continue to guide the
Agency's work on PFAS, from better understanding
the potential for PFAS transport in air, to evaluating
less-studied PFAS exposure pathways like inhalation
or through skin, to building on the categorization
approaches in the EPA's National PFAS Testing
Strategy to evaluate how to best understand and
address PFAS in groups and categories, not just one
at a time.

Prioritize protection of disadvantaged communities:
When taking action on PFAS, the EPA will ensure
that communities experiencing disproportionate and
adverse human health or environmental burdens have
equitable access to solutions.

As discussed in the Roadmap, the EPA has worked
to develop the data and tools needed to identify and
protect overburdened communities and vulnerable
populations that may be disproportionately impacted
by PFAS contamination. Fulfilling a recommendation
from the National Environmental Justice Advisory
Council, the EPA engaged with thousands of
individuals across the country in early 2023 to learn
about how PFAS and other sources of pollution are
impacting communities with environmental justice
concerns. The EPA has taken significant steps
toward gathering and sharing data on how PFAS

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impacts communities, including publicly releasing
the PFAS Analytic Tools and working to complete
nationwide drinking water monitoring for 29 PFAS
at more than 10,000 public water systems. These
and other data will be critical to better understand
and address the potential disproportionate impacts
of this contamination. The EPA launched a new
program to distribute $5 billion in funding under
BiL to address PFAS in drinking water in small or
disadvantaged communities. As the EPA considers
future action on PFAS, the EPA will be guided by the
National Environmental Justice Advisory Council's
encouragement to focus on assisting communities
in responding to PFAS contamination and ensuring
that the EPA provides the necessary resources for
engagement and education.

As the EPA noted in the PFAS Strategic Roadmap, the
actions the EPA outlines in the Roadmap are not the
only actions underway at the EPA, nor will they be the
last. As the EPA learns more about the family of PFAS
chemicals, the Agency can do more to protect public
health and the environment. As the EPA continues to
build the evidence base, as regulatory work matures,
and as the EPA learns more from its partnerships
across the country, the Agency will deliver additional
actions commensurate with the urgency and scale of
response that the PFAS problem demands.

Conclusion

Since releasing its PFAS Strategic Roadmap three
years ago, the EPA has delivered on essential policies,
investments, and research to protect all people
and the environment from the harms associated
with PFAS. With agencies across the Biden-Harris
Administration, the EPA has led efforts to provide
national leadership, restore scientific integrity, and
accelerate efforts at every level of government
to tackle PFAS. That progress provides a critical
foundation of principles, knowledge, tools, and
resources upon which the Agency will continue to
build for years to come.

Photo Credits

On the cover:

1.	iStock

2.	EPA Photo

3.	EPA Photo

4.	iStock

page 3, EPA photo
page 4, EPA photo
page 7, EPA photo
page 8, EPA photo
page 10, EPA photo
page 12, EPA photo

EPA's PFAS Strategic Roadmap:
Three Years of Progress

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oEPA

United States
Environmental Protection
Agency

EPA-800-K-24-002
November 2024


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