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North America Update Dec-Jan 2020


PFAS Action Plan Update

Back on December 4th 2019, the EPA released an Advanced Notice of Proposed Rulemaking (ANPRM) for the potential addition of certain per-and polyfluoroalkyl substances (PFAS) to the Toxic Release Inventory (TRI) under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). If promulgated, this will require facilities that handle PFAS compounds above a certain threshold in certain industries to report environmental release and waste management quantities to the EPA. The public comment period for the ~600 PFAS compounds active in U.S. commerce will close February 3rd, 2020.

Read the full release here:

Working Approach - Updated

Back in December 2019, the EPA held a public consultation to discuss their updated Working Approach to processing Section 5 notice determinations, such as Premanufacturing Notices (PMNs) and Significant New Use Notices (SNUNs). This updated approach discusses the EPA’s general guiding principles for making these determinations, in addition to a sample application demonstrating the updated approach. This was done to help identify information that submitters should include to assist the EPA in their decision making, increasing transparency with the Section 5 notice assessments.

The new Working Approach can be found here:


Updates to Environmental Emergency Regulations

Recent amendments to the Environmental Emergency Regulations (SOR/2019-51) results in the increased strength of emergency management in Canada. Administered and enforced by Environment and Climate Change Canada (ECCC), SOR/2019-51 supplies to any person or company that owns or has charge, management or control of any of the 249 substances listed in Schedule 1. With these amendments come several increased responsibilities, including:

  • Updating your Environmental Emergency Plan (E2 Plan) at least annually;
  • Submitting notices of compliance to the ECCC;
  • Performing annual simulations of exercises enacting your E2 plan;
  • Performing extensive simulations every 5 years.

Further information can be found at the link here:

Yordas can help provide assistance with preparing the mandatory written reports. Click here to view more about our Global Chemical Notification services.


Dr Mike Wolfe, North America: Associate Regulatory Consultant, Yordas Group