Regulating PFAS Under CERCLA – Ambiguities and Uncertainties with Reporting Obligations
On September 6, 2022, the EPA proposed a rule to designate the two most studied Per- and Polyfluoroalkyl Substances (PFAS) compounds, Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS), including their salts and structural isomers, as “hazardous substances” under Section 102(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA). PFAS