David Fischer Quoted in Inside PFAS Policy Article on TSCA Reporting Rule

Keller and Heckman Counsel David Fischer was quoted in the Inside PFAS Policy article, “Environmentalist Warns PFAS Reporting Waivers At Odds With Hill Mandates.” The article examines the Trump EPA’s proposal to roll back the Biden-era Toxic Substances Control Act (TSCA) reporting rule for per- and polyfluoroalkyl substances (PFAS) manufacturers and importers.

Referring to the “pretty comprehensive changes to the PFAS reporting rule,” David commented that the rule has “what we hoped would have been reflected when the rule first came out a few years ago but regrettably did not at that time. I think generally industry [will be pleased] … regarding a number of these changes.”

David also noted “one of the ironies” of the proposed rule, mentioning that “there’s this massive effort and expensive effort to collect data, and [it] may just sit on the EPA servers and not be looked at because EPA doesn’t really have to do anything with the data, necessarily. There clearly is a need to weigh the cost and benefits of this information and make sure it’s not duplicative, and whether there’s going to be some utility in the data.”

Finally, considering the multiple delays to the reporting period, David said, “I think it’s fair for EPA to assume that folks have enough familiarity and have done enough legwork to get prepared to submit, so my sense is that it’s probably reasonable. Given that there’s going to be less to report now and there’s already been a fair amount of review of this whole effort, I guess I’d be surprised that folks had concerns about this reporting period being shortened, but we’ll have to wait and see.”

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