“Contaminants Compass” is a monthly newsletter that provides updates, legal observations and actionable tips to navigate the evolving legal challenges of per- and polyfluoroalkyl substances (PFAS). This edition discusses how...more
Following several extensions to its statutory deadline, the US Environmental Protection Agency (EPA) released its final Toxic Substances Control Act (TSCA) Reporting and Recordkeeping Requirements for Per- and Polyfluoroalkyl...more
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
From a litigation perspective, designating PFOA and PFOS as CERCLA hazardous substances will have a substantial impact on future litigation. Currently, EPA’s Chemical Data Reporting (CDR) rule under the Toxic Substance...more
A recent announcement by the US Environmental Protection Agency (EPA) got the immediate attention of companies that manufacture, process, or import finished products for sale and use by consumer, commercial, and industrial...more
Did you manufacture or import a water repellant t-shirt or a nonstick cooking pan or high performance mountain wear in the past ten years? If so, you could be required to provide ten years of past data and details regarding...more
Per- and polyfluoroalkyl substances, known collectively as “PFAS,” are synthetic organic compounds that do not occur naturally in the environment. Some of these chemicals have been used for decades in a wide variety of...more
Is This a “PBT 2.0” Scenario in the Making? On June 10, 2021, the U.S. Environmental Protection Agency announced a proposed rule for collecting information about manufactured and imported goods containing any chemical...more
On June 10, 2021, pursuant to Section 8(a) of the Toxic Substances Control Act (“TSCA”), the U.S. EPA proposed a rule requiring manufacturers and importers of per- and polyfluoroalkyl substances (“PFAS”) to report information...more
With the arrival of a new US presidential administration, companies are anticipating potential shifts in enforcement priorities by the US Environmental Protection Agency (EPA) in the areas of climate change, the National...more