Emerging Contaminants
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How Low Can You Go—U.S. EPA Attempts to Answer that Question With New PFAS Health Advisory Levels
U.S. EPA issued its long anticipated interim updated drinking water health advisories for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) that replace previous health advisories for these per- and polyfluoroalkyl substances (PFAS) that had been set at 70 parts per trillion (ppt). Continue reading
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U.S. EPA Updates Regional Screening Levels to Add Five New PFAS Chemicals
On May 18, 2022, U.S. EPA updated its Regional Screening Level tables to include five new per- and polyfluoroalkyl substances (PFAS). The five new PFAS compounds added to the RSL tables are hexafluoropropylene oxide dimer acid and its ammonium salt (HFPO-DA – sometimes referred to as GenX chemicals), perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), perfluorononanoic… Continue reading
CERCLA, Climate Change, Contamination, Emerging Contaminants, Groundwater, RCRA, Sustainability, WaterAgency for Toxic Substances and Disease, ammonium salt, CERCLA, Contamination, Corporate Environmental Lawyer, EPA, GenX chemicals, hexafluoropropylene oxide dimer acid, HFPO-DA, industrial soil, Jenner & Block, perfluorononanoic acid, perfluorooctanesulfonic acid, perfluorooctanoic acid, PFAS, PFHxS, PFNA, PFOA, PFOS, Polyfluoroalkyl, RCRA, Regional Screening Level, remediation, RSL, Steven M. Siros, tap water -
Vermont Joins Growing Number of States Allowing Medical Monitoring for Alleged Exposure to Chemicals
On April 21st, Vermont Governor Phil Scott signed into law Senate Bill 113 that provides a cause of action for medical monitoring for individuals exposed to toxic chemicals. Continue reading
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“Silent Spring” and the Life Cycle of Emerging Contaminants
On the 60th anniversary of the publication of Rachel Carlson’s groundbreaking book “Silent Spring”, the world continues to struggle to manage the human health and environmental risks associated with newly discovered emerging contaminants. Continue reading
Climate Change, Consumer Law and Environment, Contamination, Emerging Contaminants, Groundwater, Sustainability, TSCA, Water1, 4-dioxane, asbestos, chemicals, Corporate Environmental Lawyer, DDT, dioxin, Earth Week, Emerging Contaminants, environment, EPA, global stewardship, Groundwater, human health, Jenner & Block, MTBE, PCB, pesticides, PFAS, Rachel Carlson, Silent Spring, soil, Steven M. Siros, strategic roadmap, TSCA -
Earth Week Series: The Future of Environmental Regulation
As we near Earth Day 2022, the United States may be headed toward a profound change in the way EPA and similar administrative agencies regulate the complex areas of environmental law. EPA began operating more than 50 years ago in 1970, and has been tasked with promulgating and enforcing some of the most complex regulations… Continue reading
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Earth Week Series: Imagine a Day Without Environmental Lawyers
On this 52nd anniversary of Earth Day, I am not writing yet another, typically not very funny, riff on one of Shakespeare’s most famous lines.[1] Instead, I am inspired by one of the most popular of our blogs, written in 2017 by our talented former partner, E. Lynn Grayson, “Imagine a Day Without Water.” To… Continue reading
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U.S. EPA’s Addition of 1-BP to CERCLA Hazardous Substance List Likely Precursor to Similar Actions on PFAS
On April 8, 2022, U.S. EPA added the industrial solvent 1-bromopropane (1-BP) to its list of CERCLA hazardous substances; this listing was triggered by U.S. EPA’s decision to add 1-BP to the Clean Air Act’s list of hazardous air pollutants in January 2022. Continue reading
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U.S. EPA Releases “ECHO Notify” to Increase Public Awareness of Enforcement Related Information
On March 22, 2022, U.S. EPA released a new web tool designed to ensure that information regarding environmental violations and enforcement actions is more readily available to the public. The new tool, called ECHO Notify, allows users to sign up for weekly emails when new information is available with respect to violations of environmental statutes… Continue reading
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U.S. EPA Announces Plan to Tighten PFAS Reporting Requirements
In connection with the release of its 2020 Toxics Release Inventory (TRI) National Analysis which evidenced a 10% decline in environmental releases of TRI chemicals between 2019 and 2020, U.S. EPA also announced that it intends to initiate a rulemaking later in 2022 that will, among other things, remove the de minimis exemption for reporting… Continue reading
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PFOA and PFAS Take Another Step Towards Becoming Full-Fledged Members of the CERCLA Family of Hazardous Substances
On January 10, 2022, U.S. EPA forwarded a proposed rule that seeks to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as “hazardous substances” under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Although not unexpected since this was a key element of U.S. EPA’s PFAS Strategic Roadmap, U.S. EPA’s proposed rule is unique… Continue reading