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ARTICLE · 29 SEPTEMBER 2022

EPA Proposes Listing PFOA And PFOS As Hazardous Substances

Taft, Stettinius & Hollister LLP
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The Environmental Protection Agency (EPA) issued a proposed rule to designate two per- and polyfluoroalkyl substances (PFAS) — perfluorooctanoic acid (PFOA) and...

United StatesEnvironment
Robert A. Bilott
Robert A. Bilott
John Huldin
John Huldin
William Sweet
William Sweet
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The Environmental Protection Agency (EPA) issued a proposed rule to designate two per- and polyfluoroalkyl substances (PFAS) — perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), including their salts and structural isomers — as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 102. The 60-day public comment period for the proposed rule ends on Nov. 7, 2022, and can be submitted at docket EPA-HQ-OLEM-2019-0341 on www.regulations.gov.

PFOA and PFOS were historically used in many consumer products including carpets, clothing, fabrics, food packaging, and nonstick cookware. PFOA and PFAS are also prevalent in manufacturing processes including wetting agents/fume suppressants, plating processes, processing aids in textile coating applications, insecticides, certain types of adhesives, cleaning products, and coating products. Environmental sources include direct and

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