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The Impact of Chevron’s Demise on the Regulation of PFAS

On June 28, 2024, in its decision in Loper Bright Enterprises, et al. v. Raimondo, et al., the U.S. Supreme Court held that its longstanding precedent granting deference to administrative agencies established in the 1984...more

PFOA and PFOS Are Now CERCLA Hazardous Substances

As we have previously reported, EPA has designated perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability...more

Designation of PFOA and PFOS as CERCLA Hazardous Substances to Become Effective on July 8, 2024

As previously reported, on April 19, 2024, the U.S. Environmental Protection Agency (“EPA”) released the pre-publication notice of its final rule designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid...more

EPA Designates PFOA and PFOS as CERCLA Hazardous Substances

On April 19, 2024, the U.S. Environmental Protection Agency (“EPA”) released the pre-publication notice of its final rule designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as hazardous...more

EPA Issues Final MCLs for PFOA, PFOS, PFNA, GenX, PFHxS, and PFBS

On April 8, 2024, the EPA Administrator signed the final rule establishing drinking water standards, also known as MCLs, for six PFAS (PFOA, PFOS, PFNA, GenX (HFPO-DA), PFHxS, and PFBS). The final MCLs for PFOA and PFOS are...more

Maine and Minnesota Accepting Proposals Through March 1, 2024 for “Currently Unavoidable Use” Exemptions from Upcoming State Ban...

By statutory enactment, Maine intends to ban the sale, marketing, and distribution of products or product components containing intentionally added PFAS, effective January 1, 2030. 38 M.R.S. § 1614. This follows Maine’s...more

EPA Proposes to List Nine PFAS as RCRA Hazardous Constituents

On February 8, 2024, EPA published a proposed rule to list nine PFAS, their salts and their structural isomers, as hazardous constituents under RCRA regulations. If the proposed rule is finalized, the nine PFAS (PFOA, PFOS,...more

Hardwick Ohio PFAS Class Action Dismissed for Lack of Jurisdiction

The Sixth Circuit ruled that a complaint on which a trial court had certified a class that included every person subject to the laws of Ohio must be dismissed. The complaint was filed by Kevin Hardwick, a firefighter,...more

PFAS Class Action Against Cosmetic Company Dismissed

In March 2022, a putative class action lawsuit was filed in the U.S. District Court for the Southern District of New York against L’Oreal U.S.A., Inc. alleging that the company had violated a host of state consumer protection...more

PFAS Among EPA’s Enforcement Initiatives

On August 17, 2023, EPA’s Office of Enforcement and Compliance Assurance (OECA) released its National Enforcement and Compliance Initiatives (NECI) for FY 2024-2027, which include addressing exposure to PFAS as an enforcement...more

USGS Studies PFAS in Tap Water

As part of the PFAS Strategic Science Vision for the U.S. Geological Survey (“USGS”) and consistent with the National Defense Authorization Act for Fiscal Year 2020, which identified activities related to PFAS where USGS...more

EPA Receives Extensive Comments on its Proposed PFAS MCLs

On May 30, 2023, the comment period closed on EPA’s proposed maximum contaminant levels (“MCLs”) for six PFAS at which time EPA had received 97,793 comments. Under the proposed rule EPA would set MCLs for Perfluorooctanoic...more

EPA Announces $75 Million to Pennsylvania to Address PFAS/Emerging Contaminants and Proposed PFOA and PFOS Drinking Water...

On February 14, 2023, the U.S. Environmental Protection Agency (“EPA”) announced $75 million in funding under the Infrastructure Law to go to Pennsylvania to address PFAS and other emerging contaminants in drinking water....more

EPA’s Motion to Dismiss Chemours’ Challenge of the GenX HAL Denied

As previously reported, The Chemours Company FC, LLC (“Chemours”) filed a Petition for Review with the Third Circuit U.S. Court of Appeals challenging the United States Environmental Protection Agency (“EPA”)’s Health...more

City of Philadelphia Joins the Fray in Suit Against PFAS Manufacturers

On November 4, 2022, the City of Philadelphia filed suit against companies it alleges manufactured or distributed PFAS-containing AFFF and/or other PFAS Products. The City asserts claims in its capacity as a water provider, a...more

EPA Files Motion to Dismiss ACC Petition for Review of PFOA and PFOS HALs and Reports Proposed MCLs are Expected in 2022

On September 15, 2022, the U.S. Environmental Protection Agency (“EPA”) filed a motion to dismiss the American Chemistry Council (“ACC”)’s petition for review challenging EPA’s interim Lifetime Health Advisory Levels (“HALs”)...more

Chemours Appeals EPA’s GenX Health Advisory Level

On July 13, 2022, The Chemours Company FC, LLC (“Chemours”) filed a Petition for Review with the Third Circuit U.S. Court of Appeals challenging the United States Environmental Protection Agency (“EPA”)’s Health Advisory...more

Under the SEC Proposed Rule on Climate Disclosures, PFCs are Perfluorocarbons, not Perfluorinated Chemicals

The Securities and Exchange Commission (SEC)’s much-anticipated and ground-breaking proposed rule for the disclosure of climate-related risks, “The Enhancement and Standardization of Climate-Related Disclosures for Investors”...more

$10 Billion Allocated to Addressing PFAS Under Bipartisan Infrastructure Law

The bipartisan Infrastructure Investment and Jobs Act (“Infrastructure Act”) signed by President Biden on November 15, 2021 provides for $10 billion in funding to address PFAS contamination, nationwide. In a letter to...more

California Proposes Public Health Goals For PFOA And PFOS

On July 22, 2021 the California Office of Environmental Health Hazard Assessment (“OEHHA”) released a Draft Technical Support Document proposing a public health goal (“PHG”) of 0.007 parts per trillion (ppt) for PFOA and 1...more

California Requires PFAS Investigation At Refineries And Terminals Statewide

The California State Water Resources Control Board (“State Water Board”) has issued an Order to approximately 160 bulk fuel storage terminals and refineries in California requiring implementation of a PFAS site investigation....more

Pennsylvania Reports The Results Of The Second Round Of Statewide PFAS Sampling

On March 12, 2021 the Pennsylvania Department of Environmental Protection (“PADEP”) announced the results of the second round of testing public water systems for PFAS. PFAS were not detected in 65% of the 114 water systems...more

EPA Takes Two More Steps Down The Long And Winding Road To National Primary Drinking Water Regulations For PFAS

In the March 3, 2021 Federal Register, EPA issued its final regulatory determinations for substances on the fourth Drinking Water Contaminant Candidate List (“CCL 4”). Under the federal Safe Drinking Water Act, EPA is...more

NJDEP Sues The United States Over PFAS Contamination

On January 14, 2021, the New Jersey Department of Environmental Protection (“NJDEP”) filed suit against the United States to compel the United States to address immediately contamination of New Jersey groundwater with PFOA...more

North Carolina Files Suit Against DuPont And Chemours Over GenX And Other PFAS Contamination

On October 13, 2020, North Carolina, acting through its Attorney General, filed suit in state court against DuPont, Chemours and related companies seeking costs to investigate, assess, remediate, restore and remedy PFAS...more

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