Presentation Title:
Deciphering the PFAS Dilemma: Federal Regulations, Streamlined Definitions, and Their Implications

Background/Objectives:

Per- and polyfluoroalkyl substances (PFAS) regulatory activity continues to evolve and expand across the globe. In February 2019, the U.S. Environmental Protection Agency (EPA) released its PFAS Roadmap, a strategic plan outlining the agency's approach to addressing PFAS contamination and related issues. The EPA's PFAS Roadmap was established to understand, monitor, assess, and manage PFAS in the environment, as well as to develop regulatory requirements to address PFAS.

EPA has moved forward in many regulatory programs, including:

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
Safe Drinking Water Act (SDWA),
Clean Water Act (CWA),
Clean Air Act (CAA),
Emergency Planning and Community Right-to-Know Act (EPCRA), which includes the Toxics Release Inventory (TRI)
Toxics Substance Control Act (TSCA), and
Resource Conservation and Recovery Act (RCRA).

In addition to Federal activity, many states have also developed their own regulatory requirements for water, waste, air, and product programs.

As a result of the dynamic EPA and state regulatory developments, compounded with the rapid advancement of science and technology around PFAS, approaches to and feasibility of addressing PFAS regulatory compliance vary substantially. The regulated community is challenged with understanding the scientific basis of the regulation, the definition of PFAS used for each regulation and the actions required for compliance.

The objective of this panel is to:

Discuss and understand the differences and similarities both comparing PFAS to other chemicals within a program as well as for PFAS specifically across programs,
Discuss the short- and long-term effectiveness of regulations in protecting human health and the environment,
Contemplate potential unintended consequences as well as potential novel approaches for emerging contaminants moving forward.

Approach/Activities:

The following approach is suggested for this panel:

Provide a general understanding of each EPA regulatory program, and general summary of State programs;
Discuss how, why, and where they are different or similar in scientific basis, PFAS definition, and overall approach,
Provide perspectives and experiences from panel members (different types of regulated entities from industry, municipal water, airports, other) on the challenges of proposed regulations.

Results/Lessons Learned:

The desired outcome of the session is understanding of:

Federal regulatory programs addressing PFAS and variability across programs,
Potential challenges across industries related to regulatory requirements and program implementation,
Lessons learned that may be applied to future emerging contaminants.

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David Connolly