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Congressional Allocation Signifies EPA Intent to Maintain the One-Time PFAS Reporting Rule Under TSCA Section 8(a)(7)

Recently, Congress allocated approximately $17 million in EPA’s fiscal year 2025 budget to modernize outdated technical systems and accelerate chemical reviews which may help resolve ongoing concerns about the functionality...more

House Republicans Seek to Rescind Late-Term EPA Rule Curtailing PFAS Exemptions for New Chemicals

House Republicans have introduced a joint resolution under the Congressional Review Act (CRA) to nullify a rule issued by the Environmental Protection Agency (EPA) late in the prior administration. The rule narrowed the...more

Maryland Files PFAS Suit Against Downstream Manufacturer

Maryland has filed suit against W.L. Gore & Associates (Gore), a downstream user of PFAS-containing materials, alleging that its manufacturing processes contributed to PFAS contamination through its use of...more

Court Approves 60-Day Stays in Legal Battles over Biden-Era PFAS Regulations amid Administration Shift

In a move that signals potential policy shifts under the new administration, the U.S. Court of Appeals for the District of Columbia Circuit granted EPA’s requests for 60-day stays in two high-profile cases challenging...more

New York and California’s Restrictions on PFAS in Apparel Takes Effect

New York and California have recently imposed sweeping prohibitions on the sale of apparel containing per- and polyfluoroalkyl substances (PFAS). These prohibitions have a broad scope and are effective and enforceable as of...more

Uncertain Times Ahead for EPA Regulation of PFAS

With 2024 winding down and a change of presidential administration imminent, it is worthwhile to consider the state of EPA’s efforts to regulate per- and polyfluoroalkyl substances (PFAS). In this connection, EPA recently...more

PFAS in Fire Protection Products Continues to Generate Litigation, Liability

Litigation risks associated with per and polyfluoroalkyl substances (PFAS) continue to grow, as demonstrated by settlements over the last year in the set of claims being adjudicated in a multidistrict litigation (MDL-2873) in...more

EPA Issues Proposed Rule Adding New PFAS to the Toxics Release Inventory (TRI)

On October 1, 2024, the U.S. Environmental Protection Agency (EPA) proposed to add 16 individual per- and polyfluoroalkyl substances (PFAS) as well as 15 PFAS categories, representing over 100 PFAS to the Toxics Release...more

EPA Issues Eight-Month Delay of the Reporting Period for the PFAS Reporting Rule under TSCA Section 8(a)(7)

On September 5, the U.S. Environmental Protection Agency (EPA) cut industry a significant break by postponing the reporting period for the one-time reporting rule for per- and polyfluoroalkyl substances (PFAS) under Section...more

The End of Chevron Deference Could Spell Trouble for EPA’s PFAS “Hazardous Substance” Rule

A recent Supreme Court ruling could further jeopardize EPA’s PFAS hazardous substance designation, as the agency is attempting to advance a novel use of delegated legislative authority to further regulate PFAS chemicals....more

EPA Finalizes Rule Designating PFAS Substances as Hazardous Constituents Under CERCLA

On April 19, 2024, the Environmental Protection Agency (EPA) finalized its long-awaited rule designating two PFAS compounds, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), as “hazardous substances”...more

PFAS Hazardous Substance Designation Clears White House Review, Nearing Finalization

The Biden Administration is continuing its efforts to regulate per- and polyfluoroalkyl substances (PFAS). On April 15, 2024, the White House Office of Management and Budget (OMB) completed its review of an Environmental...more

EPA Finalizes Stringent Regulation of PFAS in Drinking Water

On April 10, 2024, the Environmental Protection Agency (EPA) finalized a National Primary Drinking Water Regulation under the Safe Drinking Water Act to establish Maximum Contaminant Levels (MCLs) for five per- and...more

EPA Proposes to Designate Nine PFAS Compounds as Hazardous Constituents, Seeks Industry Input

The clock is winding down on businesses interested in commenting on EPA’s proposal to designate nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recover Act (RCRA)....more

Major PFAS Legislation Stalled Amid Debate on PFAS Liability for Passive Receivers

As in 2023, Congress continues to focus on PFAS issues in the first months of 2024. In this 118th Congress, at least 39 bills focused on PFAS have been introduced along with several dozen additional bills that tangentially...more

Fire-Resistant Turnout Gear Represents a New Frontier in PFAS Liability

The risks associated with PFAS-containing materials are expanding into new areas, as litigation and regulatory enforcement actions continue to rise. Recent trends suggest that employers who provide fire protection gear to...more

EPA Updates PFAS TRI Reporting Requirements

On October 2023, the U.S. Environmental Protection Agency (EPA) published a final rule in the Federal Register modifying reporting requirements for per- and polyfluoroalkyl substances (PFAS) in the Toxics Release Inventory...more

The CPSC Solicits Stakeholder Input on PFAS and PFAS-Related Risks

On September 20, 2023, the Consumer Product Safety Commission (CPSC) published a Federal Register Notice to request information on PFAS from “all stakeholders such as consumers, manufacturers and importers, government...more

EPA Drops Pre-Publication of the Long-Anticipated Final Version of Its One-Time PFAS Reporting Rule under TSCA Section 8(a)(7)

On September 28, 2023, the U.S. Environmental Protection Agency (EPA) finalized the long-awaited one-time reporting rule for per- and polyfluoroalkyl substances (PFAS) that the Agency had proposed in June 2021 under Section...more

The Long Road to PFAS Regulation

In April 2023, the EPA issued an Advanced Notice of Proposed Rulemaking (ANPRM) requesting input on the designation of seven PFAS as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and...more

Update: Maine and Massachusetts Consider PFAS Legislation

Maine proposes a new rule to its PFAS legislation, while the Massachusetts Legislature considers two bills around banning specific PFAS-containing products. Since many companies that do business in the United States do so...more

EPA Proposes Stringent Regulation of PFAS In Drinking Water

As expected, as part of the implementation of its 2021 PFAS Strategic Roadmap, the United States Environmental Protection Agency (EPA) has proposed a new rule to establish Safe Drinking Water Act Maximum Contaminant Levels...more

North Carolina, California, Wisconsin and Illinois Sue Companies over PFAS “Forever Chemicals” Contamination

Since mid-2022, North Carolina, California, Wisconsin and Illinois each have sued primary and secondary manufacturers of PFAS and PFAS-containing products for alleged environmental damage caused by the distribution of their...more

Effective January 1, 2023, Numerous States Begin to Impose Notification Requirements and Prohibitions on Products Containing...

Multiple states have enacted laws that impose prohibitions or notification obligations on the commercial distribution of PFAS-containing products, with requirements under the laws of three states (California, Maine and New...more

Industry Awaits as the TSCA PFAS Reporting Rule Looms

EPA has proposed a special one-time reporting rule that will require businesses to go on record with the agency memorializing their contributions to PFAS in the marketplace. The final PFAS reporting rule is expected to be...more

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