The Pennsylvania Department of Environmental Protection (“PADEP”) published guidance regarding registering and permitting storage tanks that contain perfluorooctanoic acid (“PFOA”), perfluorooctanesulfonic acid (“PFOS”). This...more
We have been closely monitoring the progress of the United States Environmental Protection Agency (“EPA”) proposed rule to designate perfluorooctanic acid (“PFOA”) and perfluorooctane sulfonic acid (“PFOS”), two per- and...more
In September 2022, the United States Environmental Protection Agency (“EPA”) proposed to designate perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”), including their salts and structural isomers, as...more
On April 13, 2023, the United States Environmental Protection Agency (“EPA”) published an Advanced Notice of Proposed Rulemaking (“ANPRM”) in the Federal Register that requested comments on whether EPA should consider...more
On September 6, 2022, the United States Environmental Protection Agency (EPA) published in the Federal Register its proposal to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), including their...more
As part of its “PFAS Strategic Roadmap,” EPA has stated that it intends to designate PFOA and PFOS as “hazardous substances” under the Comprehensive Environmental Responses, Compensation, and Liability Act (CERCLA). EPA took...more
The process to revise regulations in Pennsylvania is often long and involved, and the Pennsylvania Department of Environmental Protection’s (PADEP) revision to its Act 2 Chapter 250 regulations to incorporate cleanup...more
We’ve discussed in our previous posts the process that EPA will likely use to designate PFOA and PFOS as “hazardous substances,” how that designation will impact responsible parties, and what effects it may have on current...more
In two of our previous posts, we discussed the United States Environmental Protection Agency’s (EPA) “Hazardous Substance” Designation Process and the Implications of a Designation on Responsible Parties. Here, in this post,...more
The Biden Administration has pledged to designate certain PFAS as hazardous substances under federal law. What effect would the United States Environmental Protection Agency’s (EPA) designation of PFOA and PFOS as “hazardous...more
For the past several years, much attention has been focused on the United States Environmental Protection Agency’s (EPA) legal authority to respond to PFAS contamination. When EPA published its PFAS Action Plan in February...more