• Multi-Association Comments on EPA's Proposed Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS

December 6, 2022

Dear Dr. Freedhoff: The undersigned organizations respectfully request that you extend the comment period for the Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis for the proposed Toxic Substances Control Act (TSCA) section 8 (a)(7) reporting and recordkeeping rule by 30 days.

We appreciate your ongoing consideration of our suggestions in our previously submitted comments on the proposed rule (“coalition comments”) that the agency more fully assess the anticipated costs of the rule as originally proposed and examine alternatives. However, the current 30-day timeframe for commenting on the IRFA and updated economic analysis is insufficient, especially (but not only) for small businesses, to assess EPA’s revised analysis of the costs and benefits of the proposal and alternatives and to provide meaningful comment. An extension is required to ensure that all stakeholders have more time to respond to the multiple, complex issues for which the agency is seeking public comment, including how it conforms to the requirements of the Regulatory Flexibility Act and Paperwork Reduction Act, and other benefit-cost tradeoffs.