Abstract
ACC is strongly opposed to EPA's proposal to designate PFOA and PFOS as hazardous substances under Section 102(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). They have told EPA, the proposal is expensive, ineffective, and unworkable. And they are not alone in their concerns: on November 29, 2022, they published the following list of quotes from organizations from a wide range of sectors across America asking EPA to reconsider.
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