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NACWA, AWWA, and AMWA Weigh In on EPA’s TSCA Proposed Rulemaking to Require Reporting and Recordkeeping for PFAS

September 30, 2021

In comments submitted to EPA on September 24, NACWA, the American Water Works Association (AWWA), and the Association of Metropolitan Water Agencies (AMWA) offered support for the Agency’s efforts to use the Toxic Substances Control Act’s (TSCA) Section 8(a)(7) reporting and recordkeeping requirements as a means to broaden the universe of understanding on PFAS, where it has been discharged, and its uses.

Both the drinking water and wastewater community have had to quickly respond to greater regulatory initiatives on PFAS – including increased monitoring requirements. This proposed rulemaking would require manufacturers (including imports and small businesses) that have manufactured PFAS in any year since January 1, 2011 to report information to the Agency including use, production volume, disposal practices, and worker exposure and hazard data.

NACWA, AWWA, and AMWA strongly support EPA’s effort to gather this information as it presents an “opportunity to assist public water systems and POTWs implementing industrial pretreatment programs” by further informing utilities on active (or past) PFAS sources and uses and allows utilities to respond accordingly. NACWA looks forward to EPA’s response to these comments and how the Agency will move forward with identifying “active” PFAS manufacturing and commercial sources.

If members have questions on EPA’s TSCA Section 8(7)(a) reporting or recordkeeping proposal for PFAS, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.

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