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 (“PFOS”) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”).  The rule was published in the Federal Register on May 8, 2024 and as a result will become effective 60 days later on July 8, 2024.   

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