U.S. EPA Designation of PFOA and PFOS as hazardous substances under CERCLA

On April 17, 2024, EPA designated two per- and polyfluoroalkyl substances —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 (“CERCLA”). As a result of designation, CERCLA and EPCRA reporting requirements apply to releases of PFOA or PFOS or their salts and structural isomers. For additional information see https://www.epa.gov/epcra/designation-pfoa-and-pfos-hazardous-substances-under-cercla-release-reporting-requirements.