Designating PFOA and PFOS as CERCLA Hazardous Substances

On October 18, 2021, EPA released its PFAS Strategic Roadmap which builds on and accelerates implementation of existing plans to address PFAS and commits to bolder new policies to address PFAS in the environment. The proposal to designate PFOA and PFOS as hazardous substances was one of several actions mentioned in the Strategic Roadmap. Such designations would require facilities across the country to report on PFOA and PFOS releases that meet or exceed the reportable quantity.