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Regulatory Update

TRC’s Reporting Tool Can Help Identify New PFAS under the TRI

Ken Siet and Anita Doepke | May 19, 2020

  • PFAS additions are required for TRI reporting effective January 1, 2020. Reporting forms for these chemicals will be due to EPA by July 1, 2021, for calendar year 2020 data.
  • The TRI reporting threshold is 100 pounds for PFAS, if manufactured, processed, or otherwise used.
  • The PFAS Act of 2019 provides for the automatic addition of more PFAS chemicals to the TRI list, if EPA finalizes a toxicity value for the new compound. Any additional PFAS compounds added to the list will become subject to TRI reporting during the following year.

During the waning days of 2019, the “PFAS Act of 2019” (contained in Section 7321 of the National Defense Authorization Act [NDAA]), was signed into law by President Trump. Our new TRI PFAS Tool utilizes CAS number and nomenclature search to identify possible PFAS usage and potential reporting requirements now required under TRI. The statutory provisions of the PFAS Act trigger reporting of a significant number of per- and polyfluoroalkyl substances (PFAS) for the Toxics Release Inventory (TRI) under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). The U.S. Environmental Protection Agency (EPA) subsequently published a list of 172 PFAS chemicals.

TRC’s Reporting Tool Can Help Identify New PFAS under the TRI

Recommendations from regulatory compliance experts on the new TRI requirements for PFAS:

  1. Maintain consistency with reporting chemicals. Follow the same procedures you have been using for all of your other TRI reporting requirements. For example, if you rely on safety data sheets (SDSs) for chemical and regulatory reporting information, then do that for PFAS. If it has been your practice to use other sources of information beyond SDSs and product specifications for TRI reporting, then continue with this practice. PFAS degradation products could be an issue if it is common knowledge that the product breaks down to a reportable compound.
  2. Identify raw materials that potentially have PFAS constituents. Review current SDSs and updates from suppliers. Manufacturers will have to include all TRI-required compounds on updated SDSs.
  3. If raw materials consist of reclaimed or recycled materials, follow practices similar to other contaminants. If it has been your practice to use common knowledge when reporting contaminants that are TRI reportable compounds, and if it is common knowledge that a TRI PFAS compound is included in recycled materials, then include it; otherwise do not.
  4. Calculate the amount of PFAS manufactured, processed, or otherwise used. Use SDS info and the mass used to determine if the compound exceeds the reporting threshold. For the percentage of compounds going out with product versus going to waste, use data or professional judgement for use in estimating TRI. Sampling should not be required.
  5. Is the reporting limit 100 pounds per compound or class? The NDAA establishes TRI manufacturing, processing, and otherwise uses reporting thresholds of 100 pounds for each of the 172 listed PFAS. The NDAA did not add these as a class.

TRC has developed a TRI PFAS Tool that utilizes search functions by CAS number and nomenclature to identify possible PFAS usage and potential PFAS reporting requirements now required under TRI. The tool searches by CAS number for over 7,000 PFAS identified by the EPA, identifies the 172 TRI-required PFAS, and searches for surfactants and other substances that may contain PFAS but do not explicitly list a PFAS compound by CAS number. The tool can be used as an optional assessment to allow industries to identify and reduce PFAS usage via product substitution in the future.

To learn more about this Tool, click here.

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Ken Siet

Kenneth Siet is a Vice president with TRC and has over 35 years of experience as a former environmental regulator and as an environmental consultant. He has expertise in RCRA, CERCLA, and EPCRA and routinely manages complex environmental issues for various industrial clients. Mr. Siet has managed regulatory complex issues as well contaminated site investigations and remediations at facilities across the country. He has also served as an Expert Witness in both Federal and State courts on private party environmental cases. He routinely negotiates environmental permitting, reporting requirements and enforcement issues with EPA and state regulators on behalf of the firms clients.

Anita Doepke

Antia is TRC’s National Service Leader for Air Quality Services. Throughout her entire career she has been an environmental, health, and safety (EHS) professional serving broad-based industrial operations. She has successfully implemented and managed a variety of EHS programs at both corporate and facility levels and understands industry, from the ground up. With a solid understanding of the regulations, professional respect with regulators, and strong working relationships with environmental staff, Anita has managed and executed hundreds of projects and programs throughout the United States and Canada. Anita can be reached at

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