Pollution is one of the most significant global problems affecting ecosystems, wildlife, and human health. As governments and industries worldwide face the challenges of pollution, there has been a growing interest in the environmental effects of per- and polyfluoroalkyl substances (PFAS).
The Toxics Release Inventory (TRI) requires PFAS reporting, which provides valuable information on the environmental fate, consequences, and release levels of these synthetic chemicals. For reporting year 2023, nine new PFAS have been added to the reporting requirements. Additionally, the United States Environmental Protection Agency (EPA) has proposed new rules that could change PFAS reporting requirements.
If you are required to fulfill TRI reporting obligations, here are the details you need to know about PFAS reporting and how your reporting process might change in the future.
What Are PFAS?
PFAS are synthetic chemicals used to make a variety of products. They were invented in the 1930s, and are highly resistant to heat, water, and oil, making them ideal of non-stick surfaces, waterproof materials, and moisture barriers.
However, these chemicals are harmful to humans and the environment and have been linked to several health issues including cancer, reproductive issues, and immune system problems.
Because PFAS are so hard to break down, they are known as “forever chemicals” and they persist in the environment, which has led to widespread contamination. They can even be found in products that have not intentionally used PFAS and in resources such as water, soil, and food, making them a matter of increasing concern for regulatory agencies.
What is the Toxics Release Inventory (TRI)?
Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) is also known as Toxics Release Inventory (TRI). This requires certain facilities that manufacture, process, or otherwise use listed chemicals in amounts equal to or above reporting thresholds to report annually on their environmental releases (air, water, and waste).
This data is due to the EPA on July 1st each year for chemical usage during the previous calendar year.
What is the Relationship Between TRI and PFAS?
PFAS can be released into air, water, and land during manufacturing processes or when products containing PFAS are used or disposed of. Understanding the amount of PFAS released and their location is critical to developing remediation and mitigation strategies and reducing human and environmental exposure.
The TRI tracks the release, transfer, and waste management of PFAS, providing valuable information about PFAS in the environment.
For reporting year 2023 (report due July 1, 2024), nine new PFAS are subject to reporting, bringing the total number of PFAS subject to TRI reporting requirements to 189.
|CAS Number||Chemical Name|
|2728655-42-1||Alcohols, C8-16, γ-ω-perfluoro, reaction products with 1,6-diisocyanatohexane, glycidol and stearyl alc.|
|2738952-61-7||Acetamide, N-[3-(dimethylamino)propyl]-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs.|
|2742694-36-4||Acetamide, N-(2-aminoethyl)-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., polymers with N1,N1-dimethyl-1,3-propanediamine, epichlorohydrin and ethylenediamine, oxidized|
|2744262-09-5||Acetic acid, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., 2-hydroxypropyl esters|
On December 5, 2022, the EPA also proposed a rule that would improve reporting on PFAS. Under this proposed rule, facilities would not be able to rely on the de minimis exemption to avoid reporting PFAS when they are used in low concentrations. It is anticipated that this rule will become finalized in the next couple of years.
Find TRI and PFAS Reporting Solutions
As our knowledge of PFAS keeps improving, the regulations regarding such substances will continue to be updated. When PFAS were first added to the list of chemicals subject to reporting in 2021, there were 160 PFAS chemicals. Now the list for reporting year 2023 will contain 189 PFAS. That list will continue to grow as our knowledge grows, and it’s important to stay updated on these changes to remain compliant.
Tetra Tech can help your facility navigate the various TRI reporting stages—from determining reporting requirements to submitting Form As or Form Rs—so your facility can maintain its compliant status. Contact us today at [email protected] to get started.