TSCA Section 8(a)(7) PFAS Reporting Rule — A Conversation with Richard E. Engler, Ph.D.
This week I discuss with my colleague, Dr. Richard E. Engler, Director of Chemistry for B&C and The Acta Group, our consulting affiliate, the super-hot topic of per- and polyfluoroalkyl substances (PFAS) reporting under the Toxic Substances Control Act (TSCA). PFAS, the class of so-called forever chemicals, are the talk of this town, and likely the talk of many jurisdictions given the intense global scrutiny all things PFAS endure. Rich and I focus our broad ranging discussion on federal TSCA reporting under TSCA Section 8(a)(7). We discuss what PFAS are reportable, what information is due and by when, why finished product importers are on the hook for reporting, why there is a 12-year look back, and the all-important topic of how much diligence is due before you conclude information is “not known or reasonably ascertainable.” ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2024 Bergeson & Campbell, P.C. All Rights Reserved