Multi-Association Comments to EPA on its Draft Interim Recommendations to Address Groundwater Contaminated with PFOA and PFOS

June 11, 2019

Dear Mr. Foster:

We, the undersigned organizations (collectively, the Associations), write to you to express our concerns regarding the U.S. Environmental Protection Agency’s (EPA or Agency) draft set of recommendations for mitigating groundwater contaminated with perfluorooctanoic acid (PFOA) and/or perfluorooctane sulfonate (PFOS).

The Associations understand the importance of responsibly managing water resources and have been working to protect clean water for decades. Many of the Associations’ members have manufactured or used products containing PFOS and/or PFOA in the past when they were previously in the U.S. stream of commerce, and we recognize the need for an appropriate risk-based federal approach to regulating these two chemicals that is based on the best available science and data. The Associations applaud EPA for recognizing that the government should not regulate PFAS as a class, and that PFAS is a broad family of chemicals with varying properties.