FPA Signs the U.S. Chamber of Commerce Coalition of Companies and Trade Associations’ Comments Regarding PFAS Designation Under CERCLA

The U.S. Chamber of Commerce Coalition of Companies and Trade Associations (the Coalition) appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA’s) precedent-setting proposed rule in which EPA proposes to define and exercise its authority for the first time under Section 102(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA), also known as the Superfund statute, to designate the following substances as “hazardous substances:” perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), including their salts and structural isomers (hereinafter referred to as the “proposed rule” or “proposal”). This proposed rule is part of EPA’s overall whole-of-government approach to addressing per- and polyfluoroalkyl substances (PFAS) as outlined in its 2021-2024 PFAS Strategic Roadmap.