Landfill and Sewage Treatment Plant PFAS Monitoring Chemical Control Order
A new Landfill and Sewage Treatment Plant PFAS Monitoring Chemical Control Order (CCO) has been introduced.
The CCO (PDF 262KB) requires licensed landfills and sewage treatment plants (STPs) to monitor for per‑ and polyfluoroalkyl substances (PFAS) and report results to the EPA.
The CCO will commence on 1 October 2026.
Introduction of PFAS Monitoring CCO
PFAS are chemicals that persist in the environment. Landfills and sewage treatment plants generally receive PFAS from other sources, rather than creating them. These facilities are considered secondary receivers of PFAS.
Currently, monitoring requirements for PFAS differ across sites. This makes it difficult to compare data and understand PFAS pathways across NSW.
The EPA has introduced this CCO to:
- establish consistent, science‑based PFAS monitoring requirements
- improve understanding of PFAS concentrations and pathways from licensed landfills and STPs
- collect data to inform future regulatory decisions
- support protection of the environment.
The requirements align with the PFAS National Environmental Management Plan (PFAS NEMP 3.0).
Who the CCO applies to
The CCO applies to:
- licensed landfills in NSW
- licensed sewage treatment plants in NSW
If you hold an environment protection licence for one of these facilities, you must comply with the CCO from 1 October 2026.
What licence holders must do
Under the CCO, relevant licence holders must:
- monitor for PFAS at specified locations
- use approved sampling and analytical methods
- monitor on a quarterly basis
- report results to the EPA in the required format and timeframes.
PFAS (per- and polyfluoroalkyl substances) are a group of synthetic chemicals used in a wide range of industrial and consumer products. They do not easily break down and can persist in the environment for a long time. PFAS can accumulate in soil, water, and living organisms, creating potential exposure pathways for humans and wildlife.
A CCO is a regulatory tool under the Protection of the Environment Operations Act 1997 that allows the EPA to control the use, handling, and disposal of certain chemicals. It can also require monitoring or phase-out of specific substances.
The CCO aims to prevent or minimise an adverse effect on the environment by establishing consistent monitoring requirements for PFAS at licensed sewage treatment plants and landfills. This monitoring data will help us assess the PFAS concentrations at these sites and inform if further investigations and action are needed.
The PFAS NEMP has identified that landfill leachate and effluent from sewage treatment plants are secondary sources of PFAS in the environment. The PFAS NEMP contains guideline values that act as a trigger to undertake further investigations if those values are exceeded. Monitoring helps identify where PFAS is entering the environment and in what concentrations. This data is essential for assessing environmental risks and determining whether further regulatory action is needed.
All licensees for landfills and sewage treatment plants which hold an Environment Protection Licence (EPL) must comply with the CCO. This includes closed sites with active licences.
For landfills, monitoring of leachate must occur once per year, and for downgradient groundwater, four times per year on a quarterly basis.
If a landfill doesn’t have an appropriate groundwater monitoring location, then a surface water monitoring location can be used.
For sewage treatment plants, monitoring of treated effluent must be conducted four times per year on a quarterly basis.
The EPA does not expect new monitoring locations to be established.
Use a downgradient surface water monitoring location if a site does not have groundwater monitoring wells.
The analysis must be performed in accordance with the methods described in the Approved methods for the sampling and analysis of water pollutants in NSW, using a method that is appropriate for the analysis of PFAS in Aqueous Samples by LC-MS/MS, based on USEPA 1633A.
Table 1 in the CCO lists the chemicals as:
- Perfluorooctanoic acid (PFOA)
- Perfluorooctanesulfonic acid (PFOS)
- Perfluorohexanesulfonic acid (PFHxS) and
- Perfluorobutanesulfonic acid (PFBS).
The monitoring data will help us assess the PFAS concentrations at these sites and inform if further investigations and action are needed. We will collate and analyse the monitoring data to identify trends and inform future regulatory decision‑making.
If a licensee already conducts monitoring for PFAS that meets the requirements of the CCO, then the licensee can submit that data to the EPA for consideration.
National guidance on PFAS sampling and analysis is set out in Chapter 18 of the PFAS National Environmental Management Plan version 3.0.