Colorado is moving from PFAS awareness to action through monitoring, regulation, remediation, and long-term risk management efforts.
What are PFAS?
Per-and polyfluoroalkyl substances (PFAS) are a group of widely used man-made chemicals with components that break down very slowly over time. These “forever chemicals” are commonly found near military bases, airports, and industrial sites, and travel through air or water to areas far from their origin point.
Available data indicates that PFAS could pose serious risks to both human health and the environment. Because these chemicals persist for long periods and can accumulate over time, concerns regarding exposure and long-term effects continue to grow.
PFAS remediation efforts typically include efforts to remove contaminants from a site, whether that be soil, groundwater, sediment, or surface water. As PFAS compounds are extremely resistant to breaking down, remediation strategies must be strategic and targeted.
Colorado has taken a pragmatic approach that goes beyond awareness, instead focusing on proactive, innovative action.
Where are PFAS Found in Colorado?
PFAS contamination can originate from a variety of sources, many of which have been a focus of investigation and management efforts in Colorado. Understanding where PFAS are commonly found can help organizations identify potential exposure pathways and proactively manage risks.
Historically, PFAS investigations in Colorado have focused on several common sources and pathways, including firefighting foam used at airports and training facilities, industrial activities, consumer products, wastewater systems, biosolids, and potential impacts to drinking water resources. Understanding these pathways helps regulators and organizations identify where contamination may occur and how future releases can be prevented.
One example of how the state has increasingly focused on reducing PFAS releases at the source is House Bill 22-1345, known as the Perfluoroalkyl and Polyfluoroalkyl Chemicals Consumer Protection Act, which prohibits the sale or distribution of certain products containing intentionally added PFAS chemicals.
These products include carpets or rugs, fabric treatments, food packaging, oil and gas products, textile furnishings, and more. Beyond consumer products, Colorado is also evaluating potential PFAS impacts to agricultural operations. State efforts are increasingly focused on understanding how PFAS may move through irrigation water, groundwater, biosolids, and other pathways that could affect operations.
The 2024 PFAS Action Plan serves as Colorado’s framework for managing PFAS risks across the various sources of potential exposure.
Drinking Water
- Currently building a state lab with capacity to test for PFAS in drinking water.
- Partnering with water systems to assess PFAS levels, inform the public on tap water levels, and reduce PFAS levels.
- Administering the PFAS Grant Program to support communities and water systems with testing, treatment, and emergency assistance.
- Partnering with local public health agencies to provide PFAS testing for potentially impacted private wells.
Food and Agriculture
- Ensuring information is provided from entities producing biosolids, including additional product testing and reporting on source identification and control.
- Partnering with the Colorado Department of Agriculture to update available information on known and potential PFAS sources and extracting, compiling, and evaluating data on irrigation water, groundwater, and current and historic biosolids use at agricultural operations.
- Monitoring activities at the federal level, particularly involving the Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA).
Firefighting Foam
- Developing regulations with stakeholders for any entity using firefighting foam containing PFAS to prevent new contaminant releases in accordance with HB 22-1345.
- Partnering with the Colorado Department of Transportation to expand the PFAS Takeback Program to include firefighting foam containing PFAS from commercial airports.
- Requiring entities with PFAS-containing firefighting foam to register through the Certificate of Registration Program every three years as required by HB 19-1279.
How is Colorado Acting on PFAS Risk Management?
Colorado’s PFAS monitoring and mitigation techniques have evolved significantly throughout the past decade. Regulators have focused on gaining a better understanding of where PFAS occur, how residents may be exposed, and what actions are needed to address contamination.
The state has been actively addressing PFAS concerns since at least 2016, investing heavily in monitoring, drinking water testing, stakeholder engagement, and source reduction. These efforts culminated in the 2024 PFAS Action Plan, which provides a roadmap for progress moving forward.
The Action Plan has three primary objectives:
- Identify and minimize Colorado residents’ exposure to PFAS.
- Assess and provide information on PFAS health risks.
- Limit the amount of PFAS entering the environment and address known PFAS contamination.
Together, these efforts have laid the foundation for a more comprehensive approach to PFAS management across Colorado, reflecting a broader shift from understanding PFAS contamination to actively managing exposure and reducing future risks.
Challenges in PFAS Investigation, Management, and Remediation Efforts in Colorado
Managing PFAS contamination presents unique challenges because these compounds are persistent, mobile, and often difficult to completely remove from the environment. Thousands of PFAS compounds exist, and analytical methods for evaluation and management continue to evolve.
Unlike many conventional contaminants, PFAS remediation often focuses on reducing exposure and managing long-term risks rather than the complete destruction of contaminants. Depending on site conditions, treatment approaches may include granular activated carbon, ion exchange systems, reverse osmosis technologies, source control measures, and ongoing monitoring programs.
PFAS remediation challenges are compounded by the fact that multiple exposure pathways exist for these compounds. As we learn more about Colorado’s expanding PFAS framework, it becomes clear that the state’s strategy reflects a progression from identifying contamination to actively managing risks and reducing future releases.
Awareness campaigns — such as monitoring, testing, and data collection — have paved the way for management and action, including regulations on drinking water, firefighting foam controls, exposure reduction, and long-term remediation and management strategies.
Organizations will likely need flexible, long-term management strategies as scientific understanding and regulations continue to develop. Those with in-depth knowledge of potential PFAS considerations will be better prepared to navigate tomorrow’s regulatory landscape.
As Colorado’s PFAS framework continues to evolve, organizations may benefit from working with experienced environmental professionals who can help evaluate potential risks, navigate regulatory requirements, and develop long-term management strategies.
Cameron-Cole, an ADEC Innovation, specializes in assisting our clients with complex environmental liabilities. We provide technical support to clients addressing regulatory response and litigating against the manufacturers of PFAS. Contact us for a free consultation to discuss your current and potential future obligations and how to prepare for the response to the latest PFAS regulations.
This blog provides general information and does not constitute the rendering of legal, economic, business, or other professional services or advice. Consult with your advisors regarding the applicability of this content to your specific circumstances.
