by John J. Kowalski, CHMM
On December 4, 2019, the U.S. Environmental Protection Agency (EPA) published an advance notice of proposed rulemaking (ANPRM) seeking public comment as EPA considers a future rule to add certain per- and polyfluoroalkyl substances (PFAS) to the list of toxic chemicals subject to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and Section 6607 of the Pollution Prevention Act (PPA). EPCRA Section 313 requires certain facilities that manufacture, process, or otherwise use listed toxic chemicals in amounts above reporting threshold levels to report their environmental releases and other waste management quantities of such chemicals annually to EPA and the States. These facilities must also report pollution prevention and recycling data for such chemicals under Section 6607 of the PPA. The information submitted by facilities is compiled in the Toxics Release Inventory (TRI).
PFAS are synthetic organic compounds that do not occur naturally in the environment. They contain an alkyl carbon chain on which the hydrogen atoms have been partially or completely replaced by fluorine atoms. According to EPA, some PFAS may be toxic, persistent in the environment, and accumulate in wildlife and humans. Currently, about 600 PFAS are manufactured, imported, or used in the United States.
You may be affected by this ANPRM if you manufacture, process, or otherwise use PFAS. Comments must be received on or before February 3, 2020.
Environmental Protection Agency. “Addition of Certain Per- and Polyfluoroalkyl Substances; Community Right-to-Know Toxic Chemical Release Reporting.” Federal Register 84 (4 December 2019): 66369-66373. https://www.govinfo.gov/content/pkg/FR-2019-12-04/pdf/2019-26034.pdf
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