Environmental Notes - December 2022

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EPA Proposes to Expand TRI Reporting Requirements for PFAS and Other Chemicals of Special Concern -

EPA is proposing to add per- and polyfluoroalkyl substances (“PFAS”) subject to reporting under the Emergency Planning and Community Right-to-Know Act (“EPCRA”) and the Pollution Prevention Act (“PPA”) pursuant to the National Defense Authorization Act for Fiscal Year 2020 (“NDAA”) to the list of Lower Thresholds for Chemicals of Special Concern ("chemicals of special concern"). EPA is also proposing to eliminate the de minimis exemption (as hereafter defined) from supplier notifications for all chemicals of special concern, not just PFAS. EPA published the proposed regulation on December 5, 2022 and is accepting public comment through February 3, 2023.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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