Dear Members of the House of Representatives:
We, the undersigned organizations, strongly oppose H.R. 2467, the “PFAS Action Act.” Our organizations are committed to ensuring the safety of our employees and the communities where we live and operate. This legislation would delay and complicate contamination remediation issues.
Product safety provides the foundation of consumer trust, and our members devote significant resources to achieve this effort. Every member of the value chain has an important part to play to ensure the products consumers use are safe and sustainable. We remain committed to advancing effective, science-based solutions to PFAS challenges.
This spring, we sent a letter to EPA Administrator Michael Regan regarding possible designation of PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). As stated then, CERCLA is not an effective policy tool to fulfill the goal of accelerating cleanup in communities.
Moreover, EPA has existing authority to meet the intent of this legislation and should be provided the time, resources, and flexibility to make its determination regarding how best to address PFAS concerns. This approach should be made with guidance from the new PFAS Council review process, consistent with sound science and accepted principles for protecting public health and the environment.
Finally, a bill of H.R. 2467’s magnitude and complexity, including the proposed sector- based wastewater effluent guidelines, deserves the opportunity to be examined at length in a committee setting. Many major stakeholders, including EPA, the Department of Defense, other federal agencies and states have all taken significant actions to address PFAS since the last time we had a venue to discuss within a committee.
We oppose the PFAS Action Act and ask that the House of Representatives do so as well. We stand ready to assist you throughout the legislative process and engage on a better way to move forward on this issue.
American Chemistry Council
American Coatings Association
American Council of Engineering Companies
American Forest & Paper Association
American Fuel and Petrochemical Manufacturers
American Petroleum Institute
Flexible Packaging Association
National Association of Chemical Distributors
National Association of Printing Ink Manufacturers
National Association for Surface Finishing
Plastics Industry Association
U.S. Chamber of Commerce