A rendering of a nanofiltration treatment system at a water treatment plant undergoing upgrades in Broward County, Florida. Image courtesy of Carollo.
By Prinkesh Shah
Over the past two years, PFAS regulation has been anything but settled. In 2024, EPA finalized the first national drinking water standards for PFOA, PFOS, and four additional PFAS compounds.
In 2026, EPA proposed rescinding the standards for those four additional compounds — PFHxS, PFNA, HFPO-DA, and their combined mixture standard — citing a procedural flaw in how the original rule was issued. Public comment on that proposal closed this month, and utilities, states, and manufacturers are watching closely to see how it resolves.
It’s a consequential debate. But it’s also, in a sense, the wrong debate to watch if your interest is whether the nation’s drinking water systems can actually deliver PFAS-free water on the ground. A maximum contaminant level is a number on a page. Whether that number gets met, consistently, at thousands of treatment plants across 50 states, also depends on an implementation issue that receives comparatively less attention: whether the treatment technology itself can be manufactured, qualified, and deployed reliably at scale.
The Gap Between the Standard and the System
Every drinking water treatment technology capable of removing PFAS — granular activated carbon (GAC), ion exchange (IX), or membrane-based systems — has to be validated for the specific performance it claims. That validation is not a one-time event. It is an ongoing manufacturing discipline: standard operating procedures calibrated to the removal threshold in question, statistical process control to catch drift before it becomes an exceedance, corrective-action systems that catch and fix problems in production before a system ever reaches a utility, and quality documentation that proves, batch after batch, that the product will perform as specified once installed.
This is easy to overlook because it happens upstream, in manufacturing facilities and testing labs, long before a treatment system is bolted into a plant. But it is the difference between a treatment technology that works reliably in the field and one that looks good in a lab report and underperforms in practice.
Through my engineering work, I have developed and implemented structured reliability practices — including manufacturing validation procedures, defect analysis methods, corrective-action frameworks, and cross-functional review systems — designed to improve the consistency of membrane filtration products supporting water treatment applications.
This has included work on manufacturing process validation, supplier quality improvement, and defect-reduction initiatives designed to improve the consistency and reliability of membrane filtration products used in drinking water applications.
It’s a consequential debate. But it’s also, in a sense, the wrong debate to watch if your interest is whether the nation’s drinking water systems can actually deliver PFAS-free water on the ground.
Why This Matters More as PFAS Regulation Gets More Complex
The current regulatory landscape makes this gap more important, not less. EPA’s own proposed rescission rule acknowledges that if finalized, states will face a period of divergence — some may retain monitoring or guidance levels for the four PFAS in question, others may not, and primacy agencies will need to individually decide how to revise their programs. Whatever the outcome of the current rulemaking, the practical reality for manufacturers and utilities is a patchwork: different jurisdictions, potentially different expectations, and the same underlying treatment technology having to perform consistently across all of them.
That is fundamentally a manufacturing and quality-systems problem, not just a chemistry problem. A membrane, GAC, or IX system engineered and validated to hit a specific PFAS removal target in one state needs to perform identically in the next state over — and the one after that — regardless of whether the local regulatory language has changed. Achieving that kind of consistency at the scale of more than 17,000 public water systems nationwide requires validation frameworks that are transferable: built once, documented rigorously, and applicable across multiple manufacturing sites and multiple treatment suppliers, not siloed within a single facility.
What Reliable Validation Actually Looks Like
In practice, this means treating PFAS treatment manufacturing the way other high consequence manufacturing sectors treat safety-critical production: qualification protocols that are documented and repeatable, corrective-action systems that catch nonconformances before they leave the facility, and statistical process control that gives early warning of process drift long before a batch would fail a compliance test. It also means building manufacturing review processes that create an audit trail — so that if a utility, a state regulator, or EPA itself asks “how do we know this system will consistently remove PFHxS to the specified level,” there’s a documented, defensible answer.
None of this is technology specific. Whether a utility installs a membrane system, GAC, or ion exchange, the underlying manufacturing reliability challenge is the same: performance claims are only as trustworthy as the validation system behind them.
The Engineering Challenge that Outlasts the Regulatory Debate
Regardless of how EPA’s current rulemaking is finally resolved, the underlying engineering challenge doesn’t go away. The country’s water systems will still need treatment technologies that perform consistently, across jurisdictions, over the long service life of the equipment. That requires investment not just in the chemistry of PFAS removal, but in the manufacturing and quality infrastructure that makes removal performance repeatable and verifiable at scale.
Regulatory clarity is valuable, and the current rulemaking deserves the public attention it’s getting. But clarity in the rule is only half the equation. The other half — arguably the harder half — is making sure the treatment technology can actually deliver on whatever standard ultimately applies, consistently, at every one of the thousands of water systems that will need to rely on it. That is an engineering and manufacturing challenge that warrants continued attention and investment across the water industry, regardless of how the current PFAS rulemaking is resolved.
Prinkesh Shah is a quality and manufacturing engineer specializing in membrane filtration manufacturing and PFAS water treatment systems. He has experience in manufacturing validation, process qualification, supplier quality, reliability engineering and quality systems for membrane filtration products used in drinking water applications. He has also submitted technical comment to an EPA federal rulemaking docket concerning PFAS drinking water standards.
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By Prinkesh Shah
Over the past two years, PFAS regulation has been anything but settled. In 2024, EPA finalized the first national drinking water standards for PFOA, PFOS, and four additional PFAS compounds.
In 2026, EPA proposed rescinding the standards for those four additional compounds — PFHxS, PFNA, HFPO-DA, and their combined mixture standard — citing a procedural flaw in how the original rule was issued. Public comment on that proposal closed this month, and utilities, states, and manufacturers are watching closely to see how it resolves.
It’s a consequential debate. But it’s also, in a sense, the wrong debate to watch if your interest is whether the nation’s drinking water systems can actually deliver PFAS-free water on the ground. A maximum contaminant level is a number on a page. Whether that number gets met, consistently, at thousands of treatment plants across 50 states, also depends on an implementation issue that receives comparatively less attention: whether the treatment technology itself can be manufactured, qualified, and deployed reliably at scale.
The Gap Between the Standard and the System
Every drinking water treatment technology capable of removing PFAS — granular activated carbon (GAC), ion exchange (IX), or membrane-based systems — has to be validated for the specific performance it claims. That validation is not a one-time event. It is an ongoing manufacturing discipline: standard operating procedures calibrated to the removal threshold in question, statistical process control to catch drift before it becomes an exceedance, corrective-action systems that catch and fix problems in production before a system ever reaches a utility, and quality documentation that proves, batch after batch, that the product will perform as specified once installed.
This is easy to overlook because it happens upstream, in manufacturing facilities and testing labs, long before a treatment system is bolted into a plant. But it is the difference between a treatment technology that works reliably in the field and one that looks good in a lab report and underperforms in practice.
Through my engineering work, I have developed and implemented structured reliability practices — including manufacturing validation procedures, defect analysis methods, corrective-action frameworks, and cross-functional review systems — designed to improve the consistency of membrane filtration products supporting water treatment applications.
This has included work on manufacturing process validation, supplier quality improvement, and defect-reduction initiatives designed to improve the consistency and reliability of membrane filtration products used in drinking water applications.
Why This Matters More as PFAS Regulation Gets More Complex
The current regulatory landscape makes this gap more important, not less. EPA’s own proposed rescission rule acknowledges that if finalized, states will face a period of divergence — some may retain monitoring or guidance levels for the four PFAS in question, others may not, and primacy agencies will need to individually decide how to revise their programs. Whatever the outcome of the current rulemaking, the practical reality for manufacturers and utilities is a patchwork: different jurisdictions, potentially different expectations, and the same underlying treatment technology having to perform consistently across all of them.
That is fundamentally a manufacturing and quality-systems problem, not just a chemistry problem. A membrane, GAC, or IX system engineered and validated to hit a specific PFAS removal target in one state needs to perform identically in the next state over — and the one after that — regardless of whether the local regulatory language has changed. Achieving that kind of consistency at the scale of more than 17,000 public water systems nationwide requires validation frameworks that are transferable: built once, documented rigorously, and applicable across multiple manufacturing sites and multiple treatment suppliers, not siloed within a single facility.
What Reliable Validation Actually Looks Like
In practice, this means treating PFAS treatment manufacturing the way other high consequence manufacturing sectors treat safety-critical production: qualification protocols that are documented and repeatable, corrective-action systems that catch nonconformances before they leave the facility, and statistical process control that gives early warning of process drift long before a batch would fail a compliance test. It also means building manufacturing review processes that create an audit trail — so that if a utility, a state regulator, or EPA itself asks “how do we know this system will consistently remove PFHxS to the specified level,” there’s a documented, defensible answer.
None of this is technology specific. Whether a utility installs a membrane system, GAC, or ion exchange, the underlying manufacturing reliability challenge is the same: performance claims are only as trustworthy as the validation system behind them.
The Engineering Challenge that Outlasts the Regulatory Debate
Regardless of how EPA’s current rulemaking is finally resolved, the underlying engineering challenge doesn’t go away. The country’s water systems will still need treatment technologies that perform consistently, across jurisdictions, over the long service life of the equipment. That requires investment not just in the chemistry of PFAS removal, but in the manufacturing and quality infrastructure that makes removal performance repeatable and verifiable at scale.
Regulatory clarity is valuable, and the current rulemaking deserves the public attention it’s getting. But clarity in the rule is only half the equation. The other half — arguably the harder half — is making sure the treatment technology can actually deliver on whatever standard ultimately applies, consistently, at every one of the thousands of water systems that will need to rely on it. That is an engineering and manufacturing challenge that warrants continued attention and investment across the water industry, regardless of how the current PFAS rulemaking is resolved.
Prinkesh Shah is a quality and manufacturing engineer specializing in membrane filtration manufacturing and PFAS water treatment systems. He has experience in manufacturing validation, process qualification, supplier quality, reliability engineering and quality systems for membrane filtration products used in drinking water applications. He has also submitted technical comment to an EPA federal rulemaking docket concerning PFAS drinking water standards.
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