How Will EPA’s Proposed CERCLA Hazardous Substance Designation of PFOA and PFOS Impact the Environmental Due Diligence Practice?

Jeffrey D. Marshall, PE, and Michael J. Miller, CHMM, discuss environmental due diligence and how the proposed CERCLA rule could impact the number of recognized environmental conditions. The authors discuss the type of properties and former uses that are more likely to see an increase in PFAS-related issues during an environmental assessment.

We welcome you to share this article using the icons at the bottom of the page.




[ii] The HS designation of the salts and structural isomers of PFOA and PFOS may be considered somewhat non-specific, leading to confusion, particularly among non-chemists.  As such, we hope that the final HS rule will provide more clarity and specificity – e.g., a list of specific PFOA and PFOS salts and isomers, including CAS numbers.

[iii] Presumptive Contamination:  A New Approach to PFAS Contamination Based on Likely Sources (Salvatore, D., K. Mok, K. Garret, G. P:oudrier, P. Brown, L. Birnbaum, G.Foldenman, M. Miller, S. Patton, M Poehlein, J. Varshavsy)  In Environmental Science and Technology Letters, 2022 

[iv], October 21, 2022.



Additional Information: Environmental Due Diligence