Dear Mr. Bushman: The undersigned Associations submit these comments to the U.S. Environmental Protection Agency (“EPA” or “Agency”) as it considers proposing a future rule to add certain per- and polyfluoroalkyl substances (“PFAS”) to the Toxics Release Inventory (“TRI”).1 Many of our members manufacture, transport, store or use products that contain certain PFAS, and therefore have a vested interest in the outcome of this rulemaking.
We understand and appreciate the importance of responsibly reporting the releases of certain PFAS from industrial and federal facilities, and recognize the need for an appropriate risk-based federal approach for potentially including certain PFAS chemicals that is based on the best available science and weight of the scientific evidence. The appropriate addition of chemicals to the TRI helps better inform decisions made by all stakeholders as further regulatory actions are contemplated by federal, state, and local agencies alike. To fulfill these goals, it is important that PFAS reporting presents an accurate view of releases to the environment. We are committed to working with regulators to protect human health and the environment.