SPAN Responds to Minnesota PFAS in Products Reporting Rules and Product Prohibitions
Industry stakeholders urge Minnesota to take a risk-based approach to PFAS management
In advance of the planned rulemaking governing reporting for products containing per- and polyfluoroalkyl substances (PFAS) in Minnesota, the Sustainable PFAS Action Network (SPAN) submitted comments to the Minnesota Pollution Control Agency (MPCA) encouraging reasonable and risk-based management principles that accommodate essential PFAS uses and products that provide important societal benefits.
In the letter, SPAN addressed specific points on which comments were being solicited by MPCA which are of greatest importance to SPAN members, including:
Reporting Requirements – SPAN recommends the information required for reporting be simplified and streamlined to ensure MPCA is focused on gathering the information of greatest interest to PFAS exposures and releases that are likely to occur within the state.
Clarification of Definitions – SPAN requests MPCA clarify in the regulatory proposal the definition of “product.”
Reducing Burdens by Aligning with Federal EPA Reporting Rules; Waiving Certain Reporting Requirements – SPAN recommends MPCA make reasonable efforts to recognize and benefit from information being gathered by EPA and other states to avoid duplicative requirements.
Currently Unavoidable Uses Exemptions & Essential Use Considerations – SPAN recommends MPCA identify as “currently unavoidable” critical PFAS and certain uses that have undergone federal authorizations for specific uses pursuant to programs.
Prioritization – SPAN recommends that a risk-based determination process be structured and applied, taking into consideration factors affecting exposures and hazard.
Minnesota's proposed regulations hold the potential to significantly impact industries that are not only integral to Minnesota’s economy but also contribute substantially to the nation's GDP. SPAN is dedicated to supporting measures that protect human health and the environment while recognizing PFAS compounds’ role in supporting critical industries and Minnesota's economic growth and job creation.
While SPAN reserves the opportunity to comment in greater detail and on additional topics when a proposed regulation is made available by MPCA, the full letter detailing these specific points is available here.
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ABOUT SPAN
Formed in 2021, SPAN members recognize that America’s innovators and industries depend on the responsible management of PFAS compounds. The organization supports science- and risk-based policy approaches that recognize the unique differences of these compounds. Recognizing the essential role of PFAS compounds in enabling economic prosperity, delivering lifesaving equipment and medicine, climate change mitigation, and national security, among many other important applications, SPAN is committed to their sustainable use and responsible management.
