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PFAS compliance — PFOA, PFOS, and the Hazard Index.

The federal PFAS National Primary Drinking Water Regulation sets individual MCLs for PFOA and PFOS, and a Hazard Index MCL for a four-PFAS mixture (PFHxS, HFPO-DA, PFNA, PFBS). Procedural compliance clauses live in 40 CFR 141 Subpart Z (§§ 141.900–141.905); the numeric MCLs and Health-Based Water Concentrations (HBWCs) are codified in § 141.61(c). Community water systems that detect a PFAS must disclose it in the annual Consumer Confidence Report per § 141.153(d)(4).

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MCLs and Hazard Index

Verified against eCFR § 141.61(c) on 2026-04-18.

PFAS MCLs are codified as concentrations in § 141.61(c). Four of the six regulated PFAS do not have individual MCLs — they are regulated through the Hazard Index, a unitless sum of hazard quotients that must be ≤ 1. The Health-Based Water Concentration (HBWC) is the denominator in each component’s hazard quotient.

§ 141.61(c)
4.0 ng/L (0.0000040 mg/L)
PFOA
§ 141.61(c)
4.0 ng/L (0.0000040 mg/L)
PFOS
§ 141.61(c)
Hazard Index component
HBWC = 10 ng/L
PFHxS
§ 141.61(c)
Hazard Index component
HBWC = 10 ng/L
HFPO-DA (GenX)
§ 141.61(c)
Hazard Index component
HBWC = 10 ng/L
PFNA
§ 141.61(c)
Hazard Index component
HBWC = 2000 ng/L
PFBS
§ 141.61(c)
HI = 1 (unitless)
Hazard Index PFAS (mixture)

Hazard Index formula (from § 141.61(c)): HI = ([HFPO-DA]/10) + ([PFBS]/2000) + ([PFNA]/10) + ([PFHxS]/10), with concentrations and HBWCs expressed in ng/L. An HI > 1 indicates the mixture exceeds the MCL.

Subpart Z · procedural sections

§§ 141.900–141.905.

Subpart Z governs monitoring, compliance determinations, reporting, and violation classifications. Individual MCL values and HBWCs live in § 141.61(c). This split — numeric limits in Subpart G, procedural rules in Subpart Z — follows the pattern EPA uses for most NPDWR families.

§ 141.900

General requirements

Purpose, applicability, and general framework of the PFAS NPDWR. Applies to community water systems and non-transient non-community water systems.

Read on eCFR →
§ 141.901

Analytical requirements

Approved analytical methods (EPA Methods 533 and 537.1) for PFOA, PFOS, PFHxS, PFNA, HFPO-DA, and PFBS. Minimum reporting levels and laboratory certification.

Read on eCFR →
§ 141.902

Monitoring requirements

Initial monitoring schedule, routine monitoring, and triggered-monitoring requirements based on detections above trigger levels. Reduced monitoring eligibility.

Read on eCFR →
§ 141.903

Compliance requirements

Running annual average compliance determinations for each individual PFAS MCL plus Hazard Index compliance for the regulated PFAS mixture (PFHxS, HFPO-DA, PFNA, PFBS).

Read on eCFR →
§ 141.904

Reporting and recordkeeping requirements

Reporting to primacy agencies, public notification triggers, and record-retention obligations for PFAS monitoring results and compliance determinations.

Read on eCFR →
§ 141.905

Violations

Types of violations (MCL, monitoring, reporting) and the corresponding public notification tier under Subpart Q.

Read on eCFR →
Related

PFAS in your Consumer Confidence Report.

Any PFAS detected at or above the analytical minimum reporting level must be disclosed in the annual Consumer Confidence Report per 40 CFR § 141.153(d)(4). Both the individual concentration and, for the four Hazard Index PFAS, the system’s Hazard Index calculation must be presented. See our Consumer Confidence Report guide for the section-by-section walkthrough, or draft your own on the CCR Agent.

Numeric values in this reference are sourced directly from the eCFR on 2026-04-18. If EPA updates the rule (as has happened with the LCR→LCRI transition), we re-fetch the snapshot and publish the delta in our changelog.

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Agent-native · SOC 2 roadmap · 5-year retention (§ 141.155(h) requires 3 min.)