While product importers were spending the summer poring over the Instructions for Reporting PFAS Under TSCA Section 8(a)(7) (May 2024), the U.S. Environmental Protection Agency (EPA) was working on a Direct Final Rule and...more
Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more
7/19/2024
/ CERCLA ,
Corrective Actions ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Hazardous Waste ,
PFAS ,
RCRA ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
The U.S. Environmental Protection Agency (EPA) published a far-reaching and important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured and...more
6/27/2024
/ Compliance ,
Data Collection ,
Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Final Rules ,
Hazardous Substances ,
Importers ,
Imports ,
NDAA ,
PFAS ,
Recordkeeping Requirements ,
Reporting Requirements ,
Supply Chain ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
The U.S. Environmental Protection Agency (EPA) on April 19, 2024, announced its Final Rule designating two per- and polyfluoroalkyl substances (PFAS) compounds – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid...more
4/29/2024
/ CERCLA ,
Compliance ,
Discharge of Pollutants ,
Drinking Water ,
Due Diligence ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Manufacturers ,
PFAS ,
Regulatory Reform ,
Toxic Chemicals ,
Water Supplies
The U.S. Environmental Protection Agency (EPA) issued a proposed rule on Sept. 6, 2022, to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), along with their structural isomers, as hazardous...more
4/5/2024
/ CERCLA ,
Clean Water Act ,
Congressional Committees ,
Congressional Investigations & Hearings ,
Contaminated Properties ,
Enforcement ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
Hazardous Waste ,
Mitigation ,
PFAS ,
Proposed Rules ,
Public Health ,
Safe Drinking Water Act ,
Site Remediation ,
Wastewater
With the completion of the voluntary phaseout of one form of short-chain per- and polyfluoroalkyl substances (PFAS) as a grease-proofing agent, the U.S. Food and Drug Administration (FDA) has rejected the view that...more
4/3/2024
/ FDCPA ,
Food and Drug Administration (FDA) ,
Food Manufacturers ,
Food Safety ,
Hazardous Substances ,
Importers ,
Imports ,
Inspections ,
PFAS ,
Product Packaging ,
Regulatory Requirements ,
Toxic Chemicals
The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more
2024 is off to a busy start for folks following state laws related to per- and polyfluoroalkyl substances (PFAS) in products. Multiple states have passed legislation impacting product manufacturers and retailers. Maine and...more
2023 was a busy year for folks following legal developments related to per- and polyfluoroalkyl substances (PFAS). In December, the U.S. Environmental Protection Agency (EPA) issued its Second Annual Progress Report. Some of...more
1/18/2024
/ Air Quality Standards ,
Bodily Injury ,
CERCLA ,
Certifications ,
Compliance ,
Contamination ,
Discovery ,
Drinking Water ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Substances ,
Manufacturers ,
Multidistrict Litigation ,
NDAA ,
PFAS ,
Popular ,
Proposed Rules ,
Reporting Requirements ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Wastewater
The U.S. Environmental Protection Agency (EPA) published a far-reaching and enormously important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured...more
10/20/2023
/ Compliance ,
Effective Date ,
Environmental Protection Agency (EPA) ,
Filing Deadlines ,
Final Rules ,
Hazardous Substances ,
Importers ,
Manufacturers ,
NDAA ,
PFAS ,
Reporting Requirements ,
Statute of Limitations ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Waste Management
Odds are that businesses involved in any kind of manufacturing or sale of physical products will be impacted by developments in legislation or case law involving per- and polyfluoroalkyl substances (PFAS). How big of an...more
9/27/2023
/ Consumer Product Companies ,
Contamination ,
Drinking Water ,
Hazardous Substances ,
Infrastructure ,
Manufacturers ,
PFAS ,
Product Packaging ,
Public Health ,
Toxic Chemicals ,
Toxic Exposure ,
Transportation Industry ,
Utilities Sector
The U.S. Environmental Protection Agency (EPA) announced on July 25, 2023, a proposed rule, published in the Federal Register on Aug. 9, 2023, to update the Air Emissions Reporting Requirements (AERR) to collect certain...more
Minnesota is competing with Maine to have the most rigorous regulations for per- and polyfluoroalkyl substances (PFAS). Minnesota Gov. Tim Walz signed HF 2310 into law on May 24, 2023. Similar to Maine's PFAS requirements,...more
7/28/2023
/ Amended Legislation ,
Certification Requirements ,
Compliance ,
Consumer Product Companies ,
Governor Walz ,
Hazardous Substances ,
Labeling ,
Manufacturers ,
PFAS ,
Product Labels ,
Product Packaging ,
Reporting Requirements ,
Supply Chain ,
Toxic Chemicals ,
Waste Management
The U.S. Environmental Protection Agency (EPA) on April 12, 2023, released an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input and data to assist in the consideration of potential development of future...more
The U.S. Environmental Protection Agency (EPA) on March 29, 2023, published in the Federal Register its long-awaited proposal to regulate per- and polyfluoroalkyl substances (PFAS) under the Safe Drinking Water Act (SDWA)...more
3/30/2023
/ Comment Period ,
Contamination ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
PFAS ,
Proposed Regulation ,
Public Health ,
Public Hearing ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Exposure
The U.S. Environmental Protection Agency (EPA) in 2022 advanced many of its regulatory priorities laid out in its October 2021 PFAS Strategic Roadmap across multiple regulatory programs. Below are some of the highlights, many...more
1/10/2023
/ CERCLA ,
Corporate Counsel ,
Drinking Water ,
Enforcement ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
NPDES ,
PFAS ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA)
On October 24, 2019, The U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register following its earlier...more
On April 25, 2019, The U.S. Environmental Protection Agency (EPA) announced issuance of Draft Interim Recommendations to Address Groundwater Contaminated with Perfluorooctanoic Acid and Perfluorooctane Sulfonate. According to...more
4/29/2019
/ CERCLA ,
Comment Period ,
Contamination ,
Draft Guidance ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Groundwater ,
Hazardous Substances ,
Interim Guidance ,
Public Comment ,
Public Health ,
Site Remediation ,
Toxic Chemicals
By way of background, in 2016 the New York State Department of Environmental Conservation (NYSDEC) listed two long-chain per- and polyfluoroalkyl substances (PFAS)—PFOA and PFOS—as hazardous substances. However, NYSDEC did...more
4/23/2019
/ Contamination ,
Discharge of Pollutants ,
Drinking Water ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Groundwater ,
Hazardous Substances ,
Regulatory Requirements ,
Site Remediation ,
Soil ,
Statistical Sampling ,
Surface Water ,
Toxic Chemicals ,
Wastewater
On April 11, 2019, President Trump signed an Executive Order on Promoting Energy Infrastructure on Economic Growth which included provisions related to updating regulations linked to facilities which handle liquefied natural...more
4/12/2019
/ Energy Policy ,
Energy Sector ,
Executive Orders ,
Hazardous Substances ,
Infrastructure ,
Liquid Natural Gas ,
Oil & Gas ,
PHMSA ,
Railroads ,
Regulatory Requirements ,
Risk Assessment ,
Rulemaking Process ,
Safety Standards ,
Transportation Industry ,
Trump Administration
On Feb. 26, 2019, the U.S. Environmental Protection Agency (EPA) published its latest efforts to evaluate the toxicity of per- and polyfluorinated alkyl substances (PFAS) in accordance with its previously announced PFAS...more
On Feb. 14, 2019, U.S. Environmental Protection Agency (EPA) Acting Administrator Andrew Wheeler held a live-streamed press conference in Philadelphia, Pennsylvania describing the release of EPA's anticipated PFAS Action...more
2/19/2019
/ Contamination ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Groundwater ,
Hazardous Substances ,
Pollution Control ,
Public Health ,
Regulatory Agenda ,
Regulatory Oversight ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Utilities Sector ,
Water Supplies
As described in previous blog posts on May 7, 2018 and March 13, 2018, regulatory changes are needed before liquefied natural gas (LNG) can be transported by rail tanker cars under applicable Hazardous Materials and Carriage...more
10/30/2018
/ Department of Transportation (DOT) ,
Energy Sector ,
Federal Railroad Administration ,
Hazardous Substances ,
Liquid Natural Gas ,
Notice of Proposed Rulemaking (NOPR) ,
Oil & Gas ,
Permits ,
Petition for Rulemaking ,
PHMSA ,
Railroads ,
Regulatory Agenda ,
Safety Precautions ,
Transportation Industry
In the wake of the PFAS National Leadership Summit convened by the U.S. Environmental Protection Agency (EPA) on May 22-23, 2018, EPA opened a public docket to solicit comments on per- and polyfluoroalkyl substances (PFAS), a...more
On June 19, 2018, the Massachusetts Department of Environmental Protection (DEP) Bureau of Waste Site Cleanup (BWSC) issued its Interim Guidance on Sampling and Analysis for PFAS at Disposal Sites Regulated under the...more
6/26/2018
/ ATSDR ,
Chemicals ,
Contaminated Properties ,
Department of Health and Human Services (HHS) ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Groundwater ,
Hazardous Substances ,
Regulatory Standards ,
Toxic Chemicals ,
Water ,
Water Supplies