Emerging Environmental Risks & Regulations
In this Q&A, Mike discusses the challenges companies are facing due to PFAS, the impact of new rules on EHS&S leaders’ work, and what he’s looking forward to most about the Forum this year.
What are some of the biggest challenges organizations are facing due to the increased regulatory activity regarding PFAS (PFOA)?
Discovery or the identification of PFAS in the supply chain—particularly for fabricated parts, components, and subassemblies (commonly referred to as ‘article’)—remains a challenge to the regulated community. Of course, complex PFAS definitions predicated on structural configurations do not make discovery any easier. Furthermore, the myriad of new USEPA final and proposed rules, hundreds of PFAS-related state bills and laws, and an equally complex international regulatory scheme will pose a challenge to any EHS&S professional with responsibilities for compliance. Remaining engaged and current on the PFAS regulatory posture will be key to successful compliance.
Among the recent changes to surface water, drinking water, and TSCA reporting rules, which are going to impact EHS&S leaders’ work the most?
Each one of these rules has the potential to impact EHS&S leaders’ work along with the overall risk to their respective businesses. For example, while you may not be a water purveyor, the extremely low—as low as single-digit parts per trillion (emphasis added)—thresholds for some PFAS molecules could carry over to remediation activities as agencies seek to leverage new clean-up criteria. PFAS’ persistent nature, coupled with sampling and analytical challenges for soil and water and potentially low clean-up thresholds, could prove problematic for many businesses and their EHS&S leadership. The new TSCA reporting rule for PFAS expands the universe of newly covered businesses, which are likely not familiar with TSCA reporting and/or use of EPA’s reporting portal, the central data exchange (CDX). First-time users of CDX will likely find it challenging to not only compile their data, but to submit via CDX. My advice: plan accordingly.
What will people who attend your session walk away with?
Perspective. The committee organizers have done an excellent job of pulling together a panel of U.S. manufacturers representing different business sectors and PFAS challenges. Aside from increasing their awareness of recent PFAS regulatory trends, session participants will hear from panel members with experience dealing with clean-up/remediation challenges as well as discovery (in complex durable goods) and PFAS replacement technologies. More importantly, session participants will gain a network to share stories and ideas, and potentially collaborate on solutions related to PFAS.
What are you looking forward to most about FORUM24 and your session?
Collaboration with old friends and establishing new friends and networks on matters related to PFAS and beyond.
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About the Author
Michael Anderson
Lockheed Martin Corp.
Michael (Mike) Anderson is a Technical Fellow within the Corporate ESHS organization. He joined Lockheed Martin in 2015 after spending more than 25 years providing ESH support to the chemicals and consumer products industries. Earlier in his career, he supported the manufacturing and utilities infrastructure at a large chemical manufacturer, providing ESH support on projects such as incineration/wastewater treatment design, permitting, and compliance. Later, Mike was involved in product design and commercialization projects that advanced ‘green’ attributes in products allowing for increased sales and global market penetration. For many years, he has been an active participant in various trade groups and consortiums, frequently speaking at events on environmental and chemical issues. In his current role, Mike partners with government affairs and legal experts along with external consortia partners to seek favorable outcomes for Lockheed Martin as well as the aerospace and defense industry on complex ESHS challenges. He is also recognized by his peers as an expert on per- and polyfluoroalkyl substances (PFAS) and coordinates external engagements and deliverables with key stakeholders. Mike currently resides and works out of his farm/home located in Western Pennsylvania.