ASDWA, ACWA, and ECOS Submit Joint Comments on EPA’s Proposed TSCA PFAS Reporting Rule

On September 27, ASDWA, the Association of Clean Water Administrators (ACWA), and the Environmental Council of the States (ECOS) submitted a joint letter of comment to EPA on the “TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS.” Our joint comments support the promulgation of a robust, comprehensive, and transparent rule as part of a holistic, whole-of-government approach that will help states’ and water systems’ understanding of, and ability to assess and address PFAS. The letter provides seven specific recommendations for EPA to:

  1. Establish Consistent Annual PFAS Reporting Requirements
  2. Provide Easy Access to Reporting Data
  3. Require Reporting of PFAS in Articles
  4. Amend the PFAS Structural Definition and Applicability to Include Entire Class of PFAS
  5. Limit CBI PFAS Data Reporting Exemptions
  6. Require Analytical Methods Reporting
  7. Clarify and Require Reporting when the Specific PFAS is Not Known or Reasonably Ascertainable
  8. Work with States to Ensure PFAS Reporting Addresses Needs Across Programs

For more information, read the letter here.