PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To prohibit the use of certain exemptions to the premanufacture notice requirements of the Toxic Substances Control Act for per- and polyfluoroalkyl substances (PFAS)

The petition argues that PFAS, due to their toxicity, persistence, and bioaccumulation, cannot meet the legal standard of not presenting an 'unreasonable risk' required for PMN exemptions. It specifically targets the Byproducts, Low Volume (LVE), Low Release and Exposure (LoREX), and Polymer exemptions, asserting that these loopholes allow hazardous chemicals to enter the market without adequate safety review or public notification.

• PFAS are characterized by extreme environmental persistence and bioaccumulation, with some variants taking between 1,200 and 1,700 years to degrade.
• Exposure to PFAS is linked to severe health effects, including cancer, immune suppression, and liver damage, with some substances exerting toxicity at parts per trillion levels.
• The petition argues that the Byproducts Exemption allows PFAS to enter the environment with virtually no regulatory oversight, citing the Cape Fear River crisis where GenX was discharged for nearly 40 years as a byproduct.
• The Low Volume Exemption (LVE) and Low Release and Exposure (LoREX) exemptions are criticized for allowing contamination levels in surface and drinking water that exceed safe thresholds, particularly for infants.
• The petition claims that manufacturers frequently use the LVE to circumvent the full PMN process; between 2006 and June 2016, EPA granted 83 percent of the 328 LVE applications for PFAS.
• The current Polymer Exemption is deemed insufficient because it only excludes a subcategory of PFAS polymers, whereas the petitioners argue all PFAS polymers should be ineligible.
• The petition asserts that the Challenged Exemptions fail to provide adequate public notification, preventing communities from knowing about the risks of new PFAS entering the market.

APA

Novak, S., Youhana, M., & Joglekar, R. (2021). PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To prohibit the use of certain exemptions to the premanufacture notice requirements of the Toxic Substances Control Act for per- and polyfluoroalkyl substances (PFAS). Earthjustice. https://earthjustice.org/sites/default/files/files/pfas_pmn_exemptions_petition_04-27-2021.pdf

Chicago

Novak, Suzanne, Michael Youhana, and Rashmi Joglekar. PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To prohibit the use of certain exemptions to the premanufacture notice requirements of the Toxic Substances Control Act for per- and polyfluoroalkyl substances (PFAS). Earthjustice, 2021. https://earthjustice.org/sites/default/files/files/pfas_pmn_exemptions_petition_04-27-2021.pdf.

Wikipedia

{{cite report |last1=Novak |first1=Suzanne |last2=Youhana |first2=Michael |last3=Joglekar |first3=Rashmi |title=PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To prohibit the use of certain exemptions to the premanufacture notice requirements of the Toxic Substances Control Act for per- and polyfluoroalkyl substances (PFAS) |publisher=Earthjustice |date=27 April 2021 |url=https://earthjustice.org/sites/default/files/files/pfas_pmn_exemptions_petition_04-27-2021.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{novak2021petition, author = {Novak, Suzanne and Youhana, Michael and Joglekar, Rashmi}, title = {{PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To prohibit the use of certain exemptions to the premanufacture notice requirements of the Toxic Substances Control Act for per- and polyfluoroalkyl substances (PFAS)}}, institution = {Earthjustice}, year = {2021}, month = apr, url = {https://earthjustice.org/sites/default/files/files/pfas_pmn_exemptions_petition_04-27-2021.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }