On September 6, 2022, the United States Environmental Protection Agency (EPA) published in the Federal Register its proposal to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), including their salts and structural isomers, as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as “Superfund.” Comments to EPA’s rule proposal must be
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