PFAS in the Workplace: A Risk Manager’s Framework for Occupational Exposure, Regulatory Compliance, and Total Cost of Risk in 2026

Kimberly Long Holt

doi:10.55927/fjas.v5i4.39

Authors

Kimberly Long Holt Health and Safety Concepts – Environmental Health & Safety

DOI:

https://doi.org/10.55927/fjas.v5i4.39

Keywords:

PFAS, Occupational Exposure, CERCLA, Total Cost of Risk (TCOR), Hierarchy of Controls

Abstract

One of the most pressing regulatory and occupational health issues that the risk managers of 2026 will face is the presence of per- and polyfluoroalkyl (PFAS), the so-called forever chemicals. The article offers an ARM-congruent system of dealing with PFAS exposure prior to it being turned into claims, fines, or Superfund liability. The analysis will rely on NIOSH, EPA, peer-reviewed literature, and high-risk occupational exposure pathways of high-risk substances, as well as the rapidly changing federal and state regulatory framework, including current active TSCA Section 8(a)(7) reporting deadlines in 2026. A Hierarchy of Controls framework and Total Cost of Risk analysis are performed on one simple manufacturer with a history of AFFF application. Findings show that CERCLA cleanup liability and civil litigation costs are significantly higher than the workers' compensation exposure.

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