On January 15, 2015, EPA proposed a significant new use rule (SNUR), pursuant to the Section 5(a) of the Toxic Substances Control Act (TSCA), 15 U.S.C § 2604, to restrict the manufacture of long-chain perfluoroalkyl carboxylate (LCPFAC) chemicals, the most prominent of which is perfluorooctanoic acid (PFOA), as well as the use of perfluoroalkyl sulfonate (PFAS) chemicals in carpets.   Because of their stain and water repellent and non-stick properties, PFOA and other LCPFACs were at one time widely used in products such as rain jackets, non-stick cookwear, carpeting, fabrics, floor waxes, and wax paper. However, their use has been significantly curtailed following growing concerns about adverse health effects. According to EPA, LCPFACs are bioaccumulative in wildlife and humans, and are persistent in the…