EPN Comments on IRFA and Economic Analysis for PFAS Reporting Rule

On Wednesday, December 21, 2022, EPN submitted comments on the Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis for the Toxics Substance Control Act (TSCA) section 8(a)(7) proposed rule on reporting and recordkeeping requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) which followed the completion of a Small Business Advocacy Review (SBAR) Panel. We believe that the SBAR Panel’s recommendations for both exemptions and a finite list of PFAS will limit the effectiveness of reporting and are contrary to the scope of section 8(a)(7). The rule should remain comprehensive to assure that it fills important information gaps on PFAS under TSCA and other EPA authorities. With the new information generated by this rule, EPA can better direct its limited resources toward high-priority risks.

Read the comments.