Advocacy Comments on EPA’s Initial Regulatory Flexibility Analysis for its Proposed Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances Under the Toxic Substance Control Act

On December 19, 2022, Advocacy submitted comments on the Environmental Protection Agency’s (EPA) published Initial Regulatory Flexibility Analysis (IRFA) and updated economic analysis. EPA completed a Small Business Advocacy Review (SBREFA) panel for its previously proposed rule for reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substance Control Act (TSCA). EPA is now seeking public comments on its IRFA, published after the proposed rule.

For more, read the public comment letter and fact sheet, which highlights Advocacy’s concerns and recommendations.