Last week’s iteration of the Environmental Law Institute’s (ELI) monthly PFAS webinar focused on state PFAS regulations for consumer products. Echoing the message from prior meetings, the speakers implored manufacturers in this realm to conduct due diligence investigations in preparation for forthcoming enforcement. However, they noted that significant challenges exist for even the most well-intentioned producers. Namely, state regulations are often vague and broad, and PFAS release and exposure during the manufacturing process can be unforeseen and quite surprising. This creates an environment that can lead to hesitation and inaction, decisions that can ultimately be detrimental and costly.
Just the Beginning: EPA’s MCL Announcement for PFAS Indicates that Additional Regulatory Action is Imminent
We are once again eager to share our takeaways from the Environmental Law Institute’s (ELI) monthly PFAS webinar. This month’s speakers provided an in-depth discussion on the EPA’s recent announcement that established Maximum Contaminant Levels (MCLs) for six PFAS: PFOA, PFOS, PFHxS, PFNA, and HFPO-DA, as well as mixtures containing two or more of PFHxS, PFNA, HFPO-DA, and PFBS. This very informative session went beyond the immediate effects of this designation and, instead, largely focused on what is still in store for PFAS regulatory action. The theme that resonated most with us is that this decision is just the beginning.
Be Prepared: EPA’s PFOA and PFOS CERCLA Designation Is Imminent
Taylor Research Group (TRG) recently attended the Environmental Law Institute’s (ELI) monthly PFAS webinar briefing, and we are eager to share our key takeaways from a very timely and informative panel session. The Environmental Protection Agency (EPA) will designate Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA hazardous substances any day now, so the panelists focused on the policy implications of this forthcoming designation. The theme that resonated most for TRG is that industrial firms (and their in-house or outside legal counsel) should prepare now to limit their potential liability costs.
PFAS: Military Usage Still a Major Concern
Last week we began our series of blogs reflecting on material covered in the Impact of PFAS on Environmental Litigation (Virtual) Conference hosted by Perrin Conferences, with a look at the federal government’s recent actions to address PFAS in the environment. This week, we’ll take another look at military sources of PFAS contamination. TRG has been a pioneer in researching historical usage and disposal of PFAS end-products such as AFFF during the last decade. In the coming years, we expect our research into AFFF and other PFAS and PFAS-containing chemicals to continue to grow, as our current and future clients in both government and the private sector seek out our in-depth knowledge of the relevant federal, state, and local records and our ability to provide detailed information relevant to their cases.