New PFAS: Is Anything NOT Reportable? — A Conversation with Richard E. Engler, Ph.D.
This week I sat down with Dr. Richard E. Engler, B&C’s and The Acta Group’s (our consulting affiliate) Director of Chemistry, to discuss a very new component on the U.S. Environmental Protection Agency’s (EPA) PFAS Action Plan. The plan represents EPA’s “all of agency” approach to address the risks posed by per- and polyfluoroalkyl substances (PFAS) that can accumulate in humans and remain in the body for long periods. PFAS have been widely used in many consumer articles for years, and the action plan represents the totality of EPA’s actions to identify areas of risk and steps to address risks to human health and the environment.
EPA recently proposed a PFAS reporting rule under the Toxic Substances Control Act (TSCA) that would compel the submission of certain information on some 1,000 listed PFAS chemicals. The proposal is controversial because of how it defines this class of chemicals, the standard of knowledge that triggers reporting, and the types of entities subject to the reporting requirements. Rich Engler helps us understand what these issues are and why you should care.
PLEASE NOTE: At the time of recording, the comment period was set to close on August 27, 2021. On August 3, 2021, the U.S. Environmental Protection Agency (EPA) published a Federal Register notice extending the comment period until September 27, 2021. Comments can be submitted to docket ID number EPA-HQ-OPPT-2020-0549 on www.regulations.gov. Additional details can be found in our July 29, 2021, blog item, “EPA Extends Comment Period on Proposed TSCA Reporting and Recordkeeping Requirements for PFAS.”
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