In September, 2021, ACWA jointly submitted comments with ASDWA and ECOS in response to EPA’s Proposed Rule, “Toxic Substances Control Act Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (Docket # EPA-HQ-OPPT-2020-0549-0001).” The rule would require persons that manufacture (including import) or have manufactured any PFAS analytes in any year since January 1, 2011, to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards.

ACWA, ASDWA and ECOS’ letter offers several recommendations:

• Work with States to Ensure PFAS Reporting Addresses Needs Across Programs
• Establish Consistent Annual PFAS Reporting Requirements
• Provide Easy Access to Reporting Data
• Require Reporting of PFAS in Articles
• Amend the PFAS Structural Definition and Applicability to Include Entire Class of PFAS
• Limit CBI PFAS Data Reporting Exemptions
• Require Analytical Methods Reporting
• Clarify and Require Reporting when the Specific PFAS is Not Known or Reasonably Ascertainable