ILTA, Industry Coalition Submit Comments to EPA on PFAS

ILTA, as part of an industry coalition, submitted comments to the U.S. Environmental Protection Agency February 3 in response to the Advanced Notice of Proposed Rulemaking regarding the addition of certain PFAS to the Toxic Release Inventory. 

“We understand and appreciate the importance of responsibly reporting the releases of certain PFAS from industrial and federal facilities and recognize the need for an appropriate risk-based federal approach for potentially including certain PFAS chemicals that is based on the best available science and weight of the scientific evidence,” the coalition wrote. “The appropriate addition of chemicals to the TRI helps better inform decisions made by all stakeholders as further regulatory actions are contemplated by federal, state, and local agencies alike. To fulfill these goals, it is important that PFAS reporting presents an accurate view of releases to the environment. We are committed to working with regulators to protect human health and the environment.”

The coalition’s comments addressed three main issues:

1. EPA should act expeditiously to assess the 160 PFAS added to the list of chemicals covered by the TRI reporting requirements by the “National Defense Authorization Act for Fiscal Year 2020” (“NDAA”) to determine their applicability, as prescribed in in section 313(d) of the EPCRA;

2. Should EPA decide to add additional PFAS to the TRI, the Agency should do so on an individual chemical basis, or in limited instances, as discreet groups; and,

3. EPA should use the best available science, weight of the evidence, and provide a clear rationale if the reporting threshold is lowered for any PFAS that may be added to the TRI.