Regulatory Alert: AAAE to Host Discussion on EPA's Proposed Rule to Designate PFOA/PFOS as Hazardous Substances Under CERCLA

September 30, 2022


AAAE will be hosting a virtual discussion with members on Friday, October 7, at 12-1 p.m. ET, to discuss the U.S. Environmental Protection Agency's (EPA) recently published proposed rule that would designate two PFAS chemicals, PFOA and PFOS, as “hazardous substances“ under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), known as the Superfund law. You can sign up to receive a calendar invite for the meeting using the form here.

The purpose of the discussion is to provide a high-level overview of the proposed rule and its potential impacts; share preliminary points of emphasis that will be included in AAAE's response; and facilitate an open discussion among members on the proposal. We would greatly appreciate your participation and any contributions you can make to the conversation. This will be helpful as AAAE continues to develop its response to EPA.

As a reminder, EPA has set Monday, November 7, as the date for airports, industry stakeholders, and the public to respond to the proposal. We expect to hold another virtual meeting with members closer to the deadline to ensure a coordinated response within the airport community and to gather any additional feedback. Please reach out to Justin Barkowski if you have any questions.

Resources on EPA's CERCLA Proposal
EPA's Proposed Rule to Designate PFOA/PFOS as Hazardous Substances 
EPA's Press Release on the Proposed Rule 
EPA's Summary of the Proposed Rule 
EPA's Strategic Roadmap on PFAS (Oct. 2021) 
AAAE's September 6 Regulatory Alert on Deadline for Responding 
AAAE's August 26 Regulatory Alert on EPA's Proposed Rule 
AAAE's October 18 Regulatory Alert on EPA's Strategic Roadmap on PFAS