PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To revoke the approval of approximately 600 per- and polyfluoroalkyl substances (PFAS) that were granted through low-volume or low-release and low-exposure exemptions to the premanufacture notice requirements of the Toxic Substances Control Act

Earthjustice and a coalition of environmental and health organizations petitioned the EPA to revoke PMN exemptions for approximately 600 PFAS. The petitioners argue that the weight of scientific evidence proves PFAS pose unreasonable risks to human health and the environment, including to susceptible subpopulations, thereby failing the legal standard for exemptions under the Toxic Substances Control Act (TSCA). They highlight that current LVE and LoREX thresholds allow contamination levels far exceeding safe drinking water health advisories and that the EPA's voluntary stewardship program has a withdrawal rate of less than 3 percent.

• The petitioners argue that the EPA has a legal duty to revoke previously granted LVEs and LoREXs if new scientific information indicates the chemicals no longer meet the legal standard of not presenting an unreasonable risk.
• The EPA's LVE threshold of 10,000 kilograms per year can result in surface water concentrations (500 to 5,200,000 ppt) that are significantly higher than safe drinking water levels; for some PFAS, this is up to 1.3 billion times lower than the permitted surface water contamination.
• Certain subpopulations, including firefighters, nursing mothers, infants, children, and communities in polar regions, are identified as being at greater risk due to higher exposure or greater susceptibility to PFAS harm.
• The EPA's voluntary PFAS LVE stewardship program is characterized as ineffective, with only 17 LVEs withdrawn, representing a withdrawal rate of less than 3 percent of the estimated 600 PFAS in commerce through LVEs.
• The petition asserts that the Byproducts Exemption allows toxic PFAS to enter the environment without adequate review, citing the Cape Fear River tragedy where GenX was discharged for nearly 40 years as a byproduct.
• The petitioners claim that the LVE and LoREX processes lack transparency, as they do not require the same public notification in the Federal Register as the full PMN process.
• The petition argues that the current Polymer Exemption is too narrow and should be amended to exclude all PFAS polymers, regardless of whether the perfluoroalkyl moiety is bound to a carbon or sulfur atom.

APA

Madiraju, K. S., Gartner, E. C., & Joglekar, R. (2022). PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To revoke the approval of approximately 600 per- and polyfluoroalkyl substances (PFAS) that were granted through low-volume or low-release and low-exposure exemptions to the premanufacture notice requirements of the Toxic Substances Control Act. Earthjustice. https://earthjustice.org/wp-content/uploads/pfas_revocation_petition_submitted.pdf

Chicago

Madiraju, Kartik S., Eve C. Gartner, and Rashmi Joglekar. PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To revoke the approval of approximately 600 per- and polyfluoroalkyl substances (PFAS) that were granted through low-volume or low-release and low-exposure exemptions to the premanufacture notice requirements of the Toxic Substances Control Act. Earthjustice, 2022. https://earthjustice.org/wp-content/uploads/pfas_revocation_petition_submitted.pdf.

Wikipedia

{{cite press release |last1=Madiraju |first1=Kartik S. |last2=Gartner |first2=Eve C. |last3=Joglekar |first3=Rashmi |title=PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To revoke the approval of approximately 600 per- and polyfluoroalkyl substances (PFAS) that were granted through low-volume or low-release and low-exposure exemptions to the premanufacture notice requirements of the Toxic Substances Control Act |publisher=Earthjustice |date=13 October 2022 |url=https://earthjustice.org/wp-content/uploads/pfas_revocation_petition_submitted.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{madiraju2022petition, author = {Madiraju, Kartik S. and Gartner, Eve C. and Joglekar, Rashmi}, title = {{PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To revoke the approval of approximately 600 per- and polyfluoroalkyl substances (PFAS) that were granted through low-volume or low-release and low-exposure exemptions to the premanufacture notice requirements of the Toxic Substances Control Act}}, publisher = {Earthjustice}, year = {2022}, month = oct, url = {https://earthjustice.org/wp-content/uploads/pfas_revocation_petition_submitted.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }