NWRA Urges EPA Not to Designate PFOA and PFOS as Hazardous Substances

NWRA Urges EPA Not to Designate PFOA and PFOS as Hazardous Substances

Arlington, VA – The National Waste & Recycling Association (NWRA) submitted comments to the U.S. Environmental Protection Agency (EPA) that urged the agency not to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). NWRA recommended the EPA convene the stakeholder community to discuss the best approaches to retain the benefits of products that contain PFAS and reduce the adverse impacts of PFAS on human health and the environment.

“We appreciate the opportunity to share our concerns with the EPA as it undertakes this rulemaking process,” said NWRA President and CEO Darrell Smith. “We believe that owners and operators of landfills, as well as the millions of small and large businesses in communities across the United States, are likely to experience direct negative economic impacts, significant supply chain disruptions and other unintended consequences resulting from this new CERCLA liability. Therefore, we respectfully ask the EPA to engage the stakeholder community on this important issue.”

NWRA previously sought relief from CERLCA liability in a letter to the leadership of the U.S. Senate Environment and Public Works Committee earlier this year.


The National Waste & Recycling Association (NWRA) represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that manage waste, recycling and medical waste, equipment manufacturers and distributors, and various other service providers. For more information about NWRA, please visit www.wasterecycling.org.

Brandon Wright
National Waste and Recycling Association