Per- and polyfluoroalkyl substances (PFAS) continue to be the hot-button issue in environmental law, with increasing regulation at the state and federal level and tens of billions of dollars in litigation at stake. While much of the focus has deservedly been on evolving liability considerations, PFAS are also becoming subject to a wide array of mandatory reporting and notification requirements with major compliance and business implications.
For instance, the U.S. Environmental Protection Agency (EPA) recently announced amended Toxics Release Inventory (TRI) reporting requirements in an effort to increase transparency, environmental information, and environmental justice. The scope of the TRI now includes many new PFAS chemicals and the automatic addition of more PFAS is also anticipated upon EPA’s future publication of toxicity assessments. EPA announced proposal of even more far-reaching new reporting requirements under the Toxic Substances Control Act (TSCA) which would require all manufacturers (including importers) of a host of PFAS in any year since January 1, 2011 to electronically report certain information to EPA. Information related to specific chemical identity, categories of use, production volume, byproducts, environmental and health effects, exposure and disposal information are all potentially reportable under the proposed rule.
These notable developments in the regulatory paradigm underscore the need for companies to revisit their practices and prepare for heightened compliance. They must also keep themselves abreast of emerging regulatory developments to avoid liabilities. Given the intense focus on PFAS at every level of government and in the public sphere, the new PFAS reporting obligations are likely to have significant impacts on the regulated community and provide an abundance of new (publicly-available) information regarding PFAS use.
In this LIVE Webcast, environmental law attorneys Chase Dressman (Taft Stettinius & Hollister LLP) and Marcia Mulkey (Cozen O’Connor) will present a comprehensive discussion of the new PFAS reporting requirements. Speakers will also discuss current and emerging regulatory developments and share best practices to prepare for compliance.
Some of the major topics that will be covered in this course are:
- PFAS: An Overview
- National Defense Authorization Act (NDAA)
- The Toxics Release Inventory (TRI) Program
- Toxic Substances Control Act (TSCA)
- New PFAS Reporting Requirements
- Critical PFAS Issues and Challenges
- Best Compliance Practices Regarding PFAS
- PFAS Regulatory Outlook
- EPA Audit Policy and How it May Apply to PFAS Compliance