EPA Publishes Draft Compliance Guide Addressing Surface Coatings under PFAS SNUR | Bergeson & Campbell, P.C.
What Is Not an Article The draft compliance guide states that products such as paints, lubricants, and fire-fighting foam are not articles. A paint, however, would be considered as part of an article if applied to an article ( e.g., paint on a car is considered as part of an article but paint in a can is not an article under TSCA). Additionally, according to the draft guide, a lubricant applied to an article would be considered as part of an article. The draft compliance guide provides the following example: A lubricant such as automotive grease would be considered part of an article when alr...
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