With the new proposal, EPA seeks to limit the reporting burden on the chemical industry.
By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick
On November 10, 2025, the US Environmental Protection Agency (EPA) released its much anticipated proposed changes to what is often referred to as the “8(a)(7) Rule” that requires businesses to report on the manufacture and import of certain per- and polyfluoroalkyl substances (PFAS).1 As the name suggests, the rule derives from
The record-low health advisories form part of the EPA’s 2021 PFAS Strategic Roadmap, which forecasts further regulatory action at both state and federal levels.
By Julia Hatcher, Kegan A. Brown, Thomas C. Pearce, Taylor West, Andy Landolfi, and Phil Sandick
On June 15, 2022, the United States Environmental Protection Agency (EPA) issued interim, updated drinking water health advisories (HA) for two of the most common per- and polyfluoroalkyl substances (PFAS): perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS).[1] EPA also issued two final HAs for perfluorobutane sulfonic acid and its potassium salt (PFBS) and hexafluoropropylene oxide and its ammonium salt (GenX).[2]
A revised standard highlights the need for parties to consider non-scope considerations when conducting environmental assessments for transactions.
By Kegan A. Brown, David S. Langer, Thomas C. Pearce, and G. Jack Mathews
The American Society for Testing and Materials (ASTM) Committee on Environmental Assessment, Risk Management and Corrective Action recently released an updated standard for conducting Phase I Environmental Site Assessments (ESAs). The newly revised standard, known as the ASTM E1527-21 standard, includes specific directions for how emerging contaminants, including per- and polyfluoroalkyl substances (PFAS), may be addressed in ESAs. Parties conducting due diligence or involved in transactions for which an ESA will likely be used to assess more than just the “all appropriate inquiry” component of a CERCLA defense should be aware of what the new standard requires for PFAS, especially as regulatory standards evolve or are adopted on a state and federal level. Parties should be aware that the new standard does not create any requirements that Phase I ESAs address any PFAS until EPA acts to list the specific PFAS at issue as a CERCLA hazardous substance, so there is a risk that a Phase I ESA will not cover a significant potential area of environmental concern.