The attorneys, scientists, regulatory specialists, and business consultants of Bergeson & Campbell, P.C. (B&C®) and our consulting affiliate The Acta Group (Acta®) relentlessly participate in and track developments regarding the global regulatory approach to PFAS. We offer this constantly updated library of PFAS resources to help those in the chemical and chemical products industry understand what they need to know and what it means to their business.
EPA and Other Agency PFAS links:
- Recording, transcripts, and slides from EPA webinar “TSCA Section 8(a)(7) Rule: Reporting and Recordkeeping Requirements for PFAS” held January 25, 2024
- EPA PFAS Resource Page
- EPA List of PFAS for TSCA Section 8(a)(7) Rule
- PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024
- EPA PFAS Strategic Roadmap: Research Tools and Resources Webinar Archive
- EPA PFAS Resources, Data and Tools
- EPA PFAS Analytic Tools
- EPA Press Releases Related to PFAS
- European Chemicals Agency (ECHA) PFAS Resource Page
- OECD Portal on Per- and Polyfluoroalkyl Substances (PFAS)
- Minnesota Pollution Control Agency PFAS ban
B&C RESOURCES:
PFAS Summary – Bans, Restrictions, Reporting, and Minimizing Liability (download PDF)
Selected Regulatory Memoranda
- September 4, 2024
EPA Will Postpone Submission Period for TSCA Section 8(a)(7) Reporting on PFAS - August 28, 2024
Canada Will Hold Information Session on Section 71 PFAS Survey - August 21, 2024
EPA Authors Describe Categorization Approach to PFAS to Identify Potential Candidates for Testing and Human Health Assessments - August 7, 2024
Maine Seeks Comments on Concept Draft Language for PFAS in Products Rule - July 16, 2024
EPA Grants TSCA Section 21 Petition Seeking Section 6 Rule Prohibiting Three PFAS Found in Fluorinated Plastic Containers - May 17, 2024
EPA Holds Webinar on “Reducing PFAS in Products: Progress and Challenges” - May 9, 2024
EPA Issues First-Ever Drinking Water Standards for PFAS - January 30, 2024
EPA Holds Webinar on PFAS Reporting Rule Requirements
Selected Articles
- Lynn L. Bergeson, “Reporting PFAS: reporting burden is the least of businesses’ worries,” Financier Worldwide, December 2023.
Ask just about anyone doing business in the US making or importing products that contain chemicals what they think about the US Environmental Protection Agency’s (EPA’s) new per- and polyfluoroalkyl substance (PFAS) reporting rule, and you will get a decidedly grumpy response. Granted, no businessperson welcomes any new chemical reporting obligation, but by any standard, the EPA’s 11 October 2023 final PFAS reporting rule is problematic and is inviting uniquely scathing criticism. - Lynn L. Bergeson, “EPA Issues Final Rule on TSCA PFAS Reporting Requirements,” Chemical Processing, October 16, 2023.
On September 28, 2023, the U.S. Environmental Protection Agency (EPA) released its long-overdue final rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The rule requires reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS). As discussed in this article, the final rule is not what many of us expected nor wanted. - Lynn L. Bergeson, “EPA Rolls Out New PFAS Framework,” Chemical Processing, August 16, 2023.
The U.S. Environmental Protection Agency (EPA) announced on June 29, 2023, a new regulatory framework for addressing new per- and polyfluoroalkyl substances (PFAS) and new uses of existing PFAS. The framework outlines the EPA’s planned approach when reviewing these chemicals to ensure that, before they are allowed to enter commerce, they meet the safety standard under Section 5 of the Toxic Substances Control Act (TSCA). This article explains the significance of this development.
Webinars/Podcasts/Seminars
- PODCAST — Canada Proposes Exclusion of Fluoropolymers from PFAS — A Conversation with W. Scott Thurlow, All Things Chemical® podcast, August 15, 2024
- WEBINAR ON DEMAND — Determining PFAS Content in Your Supply Chain and Expanding Data Collection Practice
During this one-hour webinar, Richard E. Engler, Ph.D., Director of Chemistry, B&C, and Lynn L. Bergeson, Managing Partner, B&C, reviewed what PFAS are reportable, what information is due and by when, why finished product importers are on the hook for reporting, why there is a 12-year look-back, and the all-important topic of how much diligence is due before concluding information is “not known or reasonably ascertainable.” - PODCAST — TSCA Section 8(a)(7) PFAS Reporting Rule — A Conversation with Richard E. Engler, Ph.D., All Things Chemical® podcast, March 7, 2024
- PODCAST — TSCA Reform — Seven Years Later: Per- and Polyfluoroalkyl Substances (PFAS) Session, All Things Chemical® podcast and recording from the TSCA Reform — Seven Years Later conference, sponsored by B&C, the Environmental Law Institute, and the George Washington University Milken Institute of Public Health, November 2, 2023
- WEBINAR ON DEMAND — Preparing A PFAS Gameplan in the U.S., UK, and EU
During this one-hour webinar presented by Acta and EPPA, Meglena Mihova, Managing Partner of EPPA, a Brussels-based regulatory and public affairs consultancy; Richard E. Engler, Ph.D., Director of Chemistry, Acta; and Lynn L. Bergeson, President, Acta, discussed bans, restrictions, and reporting requirements for PFAS and the need to balance commercial imperatives with legal, commercial, and stewardship sensitivities.
- PODCAST — PFAS under REACH — A Conversation with Jane S. Vergnes, Ph.D., All Things Chemical® podcast, May 25, 2023
- WEBINAR ON DEMAND — TOP TSCA TOPICS: PFAS Cumulative Risk, NAMs, Risk Evaluations, CBI, and More
This one-hour webinar, presented by B&C, featured Anna B. Lowit, Ph.D., Senior Science Advisor, EPA Office of Pollution Prevention and Toxics (OPPT); Richard E. Engler, Ph.D., Director of Chemistry, B&C; and Lynn L. Bergeson, Managing Partner, B&C, discussing groundbreaking science policy initiatives in furtherance of implementation of TSCA and other consequential rulemakings involving PFAS reporting.