December 27, 2022: NCHR public comments on EPA’s proposed draft supports the need for recordkeeping and reporting as they are vital steps toward managing perfluoroalkyl and polyfluoroalkyl substances (PFAS). However, there are accountability loopholes identified in this proposed draft that could allow manufacturers to take advantage of the system, ie. making it optional to register an unknown chemical with a CASRN or other identifier and not required. It is for reasons like this that we believe the draft does not go far enough.
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