Regulatory News

Guest Submission from RadTech Board of Director’s President Michael Gould

EPA Will Propose Designation of PFOA and PFOS as CERCLA Hazardous Substances
The US Environmental Protection Agency (EPA) announced on August 26, 2022, that it will propose to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), “two of the most widely used per- and polyfluoroalkyl substances (PFAS),” as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The proposal will include the salts and structural isomers of PFOA and PFOS. The rulemaking would require entities to immediately report releases of PFOA and PFOS that meet or exceed the reportable quantity (RQ). EPA will publish a notice of proposed rulemaking (NPRM) in the Federal Register “in the next several weeks,” beginning a 60-day comment period. For more information on the proposed rule, read the full memorandum at

Rita LoofRita Loof,
director of regional environmental affairs, RadTech International
North America


Changes to VOC Rule in Michigan

Michigan’s Department of Environment, Great Lakes and Energy (EGLE) announced changes to its volatile organic compound (VOC) regulation, Part 6, Emission Limitations and Prohibitions – Existing Sources of VOC Emissions. The definition of “existing source” varies depending on date of installation and type of process. The amendments will address requirements of the reasonable available control technology (RACT) provisions in the Clean Air Act. According to the public notice, the state must promulgate new, more stringent rules setting or revising emission standards and operational requirements for certain types of existing emission sources. Ten counties in Michigan are considered to be in “non-attainment.”

“The CAA requires Michigan to show reasonable further progress by reducing VOC emissions in the nonattainment areas by 15% from the baseline year,” stated the public notification. “To meet this requirement, beyond the reductions gained from implementing VOC RACT rules, EGLE also has revised and drafted additional rules that address volatile chemical products.” Rules listed for consideration include:

  • Rule 336.1610. Emission of volatile organic compounds from existing automobile, light-duty truck and other product and material coating lines. This rule also applies to coatings for cans, coils, large appliances, metal furniture, magnet wire and the nonmetallic surfaces of fabrics, vinyl or paper.
  • Rule 336.1620. Emission of volatile organic compounds from existing flat wood paneling coating lines.
  • Rule 336.1621. Emission of volatile organic compounds from existing metallic surface coating lines.
  • Rule 336.1630. Emission of volatile organic compounds from existing paint manufacturing processes.
  • Rule 336.1632. Emission of volatile organic compounds from existing automobile, truck and business machine plastic part coating lines.
  • R 336.1660. Standards for volatile organic compounds emissions from consumer products.

A public meeting is on the calendar in late October 2022. If approved, the rules will be submitted to the EPA as an amendment to the Michigan State Implementation Plan (SIP). Additional information may be found at

Prop 65 Committee Issues Document on Bisphenol A

California’s Office of Environmental Health Hazard Assessment (OEHHA) announced a meeting of the Carcinogen Identification Committee (CIC), which will be held virtually on December 14, 2022. The CIC will consider the listing of Bisphenol A at this meeting. The agency has released a document entitled “Evidence on the Carcinogenicity of Bisphenol A,” which is available for public review. Comments on the document must be received by November 14, 2022. According to OEHHA, the document “presents evidence relevant to the evaluation of the cancer hazard of bisphenol A (BPA).” The document can be found at