Breadth of US EPA's proposed PFAS reporting rule unprecedented,experts say

摘要

The US EPA can expect industry pushback on its newly proposed per-and polyfluoroalkyl substance(PFAS)reporting rule,legal experts say,especially regarding the coverage of downstream and small businesses and the lack of exemptions for the compounds'occurrence as byproducts or impurities.Meanwhile,environmental and public health advocates applauded the reporting mandate(see box),and called for it to go even further.The agency proposed the rule on 10 June,requiring a one-time disclosure of PFASs manufactured and imported since 1 January 2011.As put forward,the rule would make companies provide 22 kinds of details-including exposure and health data-on over 1,300 substances,encompassing small businesses,byproducts,impurities and articles containing the compounds.That is"an extremely broad reporting requirement“,said Christopher Blunck,of counsel with Bergeson & Campbell.The proposed rule's absence of limits or conventional exemptions is"not precedented“,he said,and it foreshadows similar reporting obligations for substances in articles.