Lawrence (Larry) Culleen Discusses PFAS Reporting Waivers With Inside PFAS Policy
Lawrence Culleen, Arnold & Porter Environmental partner and former manager in various U.S. Environmental Protection Agency (EPA) chemical regulatory programs, was quoted in the Inside PFAS Policy article, “Optimistic Industry Groups Ramp Up Advocacy For PFAS Reporting Waivers.” The publication reported on efforts being made to secure improvements and exemptions in EPA’s efforts to amend its PFAS reporting rule under the Toxic Substances Control Act (TSCA).
The publication reported that Larry would encourage EPA to align the PFAS reporting rule with exemptions that “classically appear” in TSCA chemical data reporting regulations and that doing so could simplify and streamline the process.
“I personally think that if the agency’s mission here is to gain a complete awareness of where PFAS are produced, used and distributed in the U.S. that they can get perhaps 95 percent of that information if those exemptions are included in the final rule,” he explained.
Larry also noted that while some industry sectors are pressing for broader revisions, the EPA is unlikely to alter the rule’s 2011–2022 “lookback” period for which the authorizing legislation specified reporting must be provided.
“Why pick a fight that they may not need to pick, so to speak, and I think you can achieve the other modifications without violating the terms of the NDAA per se nor its spirit,” he said.
