Bergeson & Campbell, P.C. (B&C®) is pleased to offer the recording, slides, and written Question and Answer (Q&A) document from our “PFAS Reporting Rules — What Every Company Needs to Know” webinar, focusing on the U.S. Environmental Protection Agency’s (EPA) proposed reporting rules for per- and polyfluoroalkyl substances (PFAS), presented by B&C Managing Partner Lynn L. Bergeson and Director of Chemistry Richard E. Engler, Ph.D.
Do you wonder if the PFAS reporting rules extend to domestically produced articles? Or if businesses that incorporate PFAS into their products are required to notify the end users? Do you know whether you need to report your Low Volume Exemption (LVE) substance? We encourage you to view the webinar and read the additional materials to learn answers to these and other questions related to EPA’s recent PFAS actions.
We also encourage you to consider the following issues discussed in the webinar and to submit comments to EPA regarding how these will affect your operations:
- Identifying chemicals subject to reporting (i.e., specific PFAS and whether to include imported articles);
- Considerations for economic analysis;
- Submission period;
- Potential duplicative reporting concerns;
- Scope of “existing environmental and health information” collected;
- Additional data elements or information collected;
- EPA’s use and publication of non-confidential business information (CBI);
- Availability of joint submissions; and
- Small manufacturer considerations (i.e., regulatory and non-regulatory assistance and outreach).
Comments on EPA’s proposed PFAS rules are due on September 27, 2021.