EPA’s actions are too little and too late. While years down the road some communities may benefit from EPA’s action today, it does nothing to stem the tide of future Superfund sites caused by toxic PFAS contamination.
EPA continues to ignore the one law that will allow it to manage PFAS waste from cradle to grave and prevent future PFAS contamination, the Resource Conservation Recovery Act. The absence of federal standards for tracking and managing waste contaminated with toxic PFAS poses a significant and growing threat to our health, water, soil and food systems and EPA’s inaction on this front is inexcusable.
Finally, this designation signals that EPA will continue to avoid treating all PFAS as one class of chemicals. It is unfathomable to think that EPA’s small staff can effectively evaluate and regulate the thousands of PFAS that now exist, and there is no reason to do so as they all have similar structures and characteristics
Since EPA does not appear to be ready to regulate all PFAS as a class, it may be condemned to playing a futile game of regulatory Whack-a-Mole for generations to come. Further, EPA’s failure to regulate PFAS wastes makes containing contamination almost impossible.