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Regulatory Updates

TRI PFAS Reporting Requirements Continue to Expand

Jeff Ramey, Melissa Hart, and Robert Hanley | January 16, 2023

On January 6, 2023, the United States Environmental Protection Agency (USEPA) announced the automatic addition of nine additional per- and polyfluoroalkyl substances (PFAS) to the Toxics Release Inventory (TRI) reporting requirements for the 2023 reporting year (due July 1, 2024). This brings the list of PFAS for reporting year 2023 to a total of 189 PFAS. PFAS were originally added as TRI reportable compounds by the National Defense Authorization Act of 2020 (NDAA 2020), which includes ongoing criteria for adding additional PFAS to the TRI reportable list. These criteria have resulted in a longer list of TRI reportable PFAS compounds each subsequent year.

What PFAS were added and are they in your inventory?

The nine additional PFAS include four PFAS compounds that were declassified as confidential business information (CAS numbers: 2728655-42-1, 2738952-61-7, 2744262-09-5, and 2742694-36-4) in an update to the Toxic Substances Control Act (TSCA) inventory in February 2022, and five PFAS associated with the final toxicity values for perfluorobutanoic acid (PFBA) (CAS numbers: 375-22-4, 45048-62-2, 10495-86-0, 2966-54-3, and 2218-54-4). NDAA 2020 includes a provision that automatically adds PFAS to the TRI list once the USEPA finalizes a toxicity value. For these five substances, USEPA issued toxicity values in December 2022.

As required by the Emergency Planning and Community Right-to-know Act (EPCRA), if your facility manufactures, processes or otherwise uses one or more of these nine chemical substances, you should begin tracking such activities beginning January 1, 2023.

What do you need for Reporting Year 2022?

Again, the nine PFAS added in 2023 will not require reporting until 2024. The list of TRI reportable PFAS for reporting year 2022 (due July 1, 2023) remains 180 PFAS listed in 40 CFR Part 372.65 (d) and (e). Currently, releases of PFAS are subject to 100-pound manufacturing, processing or otherwise using thresholds established by the NDAA 2020. If your facility meets any one of these three thresholds, then it must report for all activities for that chemical. Currently, reporting is not required if a PFAS is present in a mixture below the de minimis exemption (1% for TRI-listed PFAS and 0.1% for perfluorooctanoic acid (PFOA)). A December 2022 proposed rule would eliminate the de minimis exemption for PFAS. USEPA believes this would increase the number of TRI-listed PFAS compounds reported in future reporting years; however, the de minimis exemption is still applicable for reporting year 2022.

TRC’s PFAS Reporting Tool – TRI Reporting

TRC has the expertise and the tools to guide our clients with assessing the presence of PFAS compounds used at a facility and TRI reporting. We have developed a proprietary PFAS Reporting Tool that simplifies the identification and assessment process for determining the reportability of PFAS chemicals subject to TRI and the current and historical facility usage of PFAS. By working with one of our experienced chemists to guide the evaluation, use of this tool will enable a faster, more comprehensive inventory of potential PFAS chemical usage for compliance reporting, can help identify substitute products to reduce PFAS usage in the future, and can identify potential PFAS use issues with liability consequences.

PFAS Reporting Tool

TRC created a PFAS Reporting Tool that makes identifying the chemicals you process, use or manufacture at your facility easier, faster and more comprehensive.

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We Can Help Simplify TRI Reporting for PFAS

TRC’s dedicated team of PFAS experts are ready to help you conduct your annual TRI reporting in a timely and accurate manner to ensure compliance with TRI requirements and better identify the potential liabilities associated with PFAS usage during due diligence. We are on the forefront of emerging PFAS regulations and guidance and can strategically guide you through the challenging process of addressing PFAS reporting obligations, identifying potential contamination concerns, and managing the ever-evolving regulatory environment and technical uncertainties.

For more information on TRI reporting and PFAS analysis, contact:

Jeff Ramey

Jeff Ramey is a principal chemist with almost 20 years of professional experience in the environmental industry. Jeff serves as a technical lead for analytical forensics, data validation, fingerprinting, investigation, and remediation of emerging contaminants, PFAS, and well-established contaminants of concern. He has supported private and public clients, leading PFAS investigations and negotiating site-specific sampling and analysis plans and cleanup criteria with multiple regulatory agencies with absent or developing PFAS standards. He regularly presents on PFAS at technical conferences and contributes to trade organizations and stakeholder groups concerned with emerging contaminant regulations, reporting, and enforcement. Jeff is a member of TRC’s PFAS CORE Team where he developed TRC’s proprietary PFAS Reporting Tool.

Robert W. Hanley

Robert Hanley is a Senior Consultant at TRC, supporting transaction due diligence environmental and compliance assessments, and multimedia environmental compliance audits. He has a deep understanding of Toxic Substances Control Act requirements for chemical data reporting, new chemical Pre-Manufacture Notifications, and TSCA significant new use rules and notification requirements. His auditing experience includes specialized knowledge of RCRA and Toxic Substances and Control Act (TSCA) reporting and record keeping requirements. He also provides short-term, on-site environmental management support. Dr. Hanley holds a Ph.D degree in Biology from the University of Alabama, with a specialization in environmental engineering. Contact Rob at

Melissa Hart

Melissa Hart has over 30+ years of experience in private industry and consulting. Her environmental experience is focused on air pollution regulatory compliance; EPCRA/SARA compliance (including Tier II inventory, TRI reporting, and auditing); due diligence; air permitting; civil penalty calculations and enforcement negotiation; and Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS). Ms. Hart has worked in multiple industrial sectors, including aircraft and automotive assembly/manufacturing; automotive parts; food and beverage operations; miscellaneous metal fabrication; fertilizer plants; air filter fabrication; and miscellaneous surface coating operations. She holds a BS in Chemical Engineering from University of Missouri – Columbia.

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