Eighteen AGs Filed Comments Urging EPA to Require Broad PFAS Disclosure

FEBRUARY 3, 2020

New York Attorney General Letitia James led a coalition of 18 attorneys general in filing comments in response to the Environmental Protection Agency’s (EPA) request for input on the potential addition of certain PFAS (per- and polyfluoroalkyl substances) to the Toxics Release Inventory (TRI), a list of chemicals subject to stringent release reporting requirements that provide federal, state and local authorities with critical information on pollutant discharges and potential harm to the environment. In their comments, the AGs urged the EPA to “list PFASs on the TRI, both as a single category listing … and as individual listings for specific compounds in the category,” and noted that “each individual PFAS ‘can reasonably be anticipated to cause’ … harms to human health and adverse effects to the environment.” The AGs also recommended that the agency establish a TRI reporting threshold of one pound for all PFAS, given their “high persistence and bioaccumulative tendencies.”