The Alliance for Telomer Chemistry Stewardship (ATCS1) appreciates this opportunity to provide comments on the Preliminary Draft Rule Language: Safer Products for Washington Implementation Phase 4 as it relates to per- and polyfluoroalkyl substances (PFAS). ATCS is a global organization that advocates on behalf of C6 fluorotelomer-based products. Our members are leading manufacturers of fluorotelomers in North America, Europe and Japan. Our mission is to promote the responsible production, use and management of fluorotelomers, while also advocating for a sound science- and risk-based approach to regulation.