Forever Chemical Regulation and Accountability Act of 2024

H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. Potential House legislation requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. S. 4187 and H.R. 8074, Forever Chemical Regulation & Accountability Act of 2024, including provisions related to a non-essential use ban of PFAS chemicals and CERCLA liability waivers. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. Potential legislation to promote the competitiveness of domestic polymer manufacturing and use. Potential Senate legislation to reform TSCA Section 5 requirements for significant new use notices. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. EPA's proposed Toxics Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's Proposed Rule on Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act, Docket No. EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries. Consumer Product Safety Administration' Notice on Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (CPSC-2023-0033). Department of Defense report on the critical uses of per- and polyfluoroalkyl substance uses (August 2023).

Client expense: $310,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, White House Office

Water infrastructure funding Infrastructure Investment and Jobs Act Build America, Buy America PFAS legislation including S. 4187/H.R.8074, Forever Chemical Regulation and Accountability Act of 2024 H.R. 8998, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025 S. 4802, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025

Client expense: Not reported · Firm income: $60,000

H.R. 7776, National Defense Authorization Act for Fiscal Year 2023, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS). H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. Potential House legislation requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. S. 4187 and H.R. 8074, Forever Chemical Regulation & Accountability Act of 2024, including provisions related to a non-essential use ban of PFAS chemicals and CERCLA liability waivers. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. Potential legislation to promote the competitiveness of domestic polymer manufacturing and use. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. EPA's proposed Toxics Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's Proposed Rule on Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act, Docket No. EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries. Consumer Product Safety Administration' Notice on Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (CPSC-2023-0033). Department of Defense report on the critical uses of per- and polyfluoroalkyl substance uses (August 2023).

Client expense: $150,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office