EPA Rule Adds PFAS Chemicals to the TRI Report

EPA has added certain per- and polyfluoroalkyl substances (PFAS) to the list of chemicals which need to be tracked annually on your EPA Toxic Release Inventory (TRI) report (below).   This rule is effective 1/1/2020, so you’ll need to start tracking and collecting data on their usage immediately.

PFAS chemicals (aka PFOS and PFOA because these are the most common PFAS chemicals) have been widely used in industrial processes and can be found in many consumer products including firefighting foam, pizza boxes, cookware, paints and polishes, electronics manufacturing, fuel additives and more.

The new rule was signed into law through the National Defense Authorization Act on December 20, 2019.  Reporting threshold is only 100 pounds, far less than typical TRI chemicals.  The de minimis concentration for PFOA is 0.1% and all other chemicals have a de minimis level of 1%.

Because PFAS chemicals come in so many shapes and sizes and in so many industries and consumer products, it’s thought that an alarmingly high percentage of people have been exposed to them.  Contaminated drinking water is the most documented source, but food, house dust, and workplace exposure are among the top as well. In communities with contaminated drinking water, human health effects that have been found include higher cholesterol, increased uric acid, lower birth weight, lower response to vaccines, diabetes, and cancer.

As a result, dealing with PFAS issues has become an EPA focus.  There have already been other efforts by EPA recently to develop methods and guidance for drinking water monitoring and laboratory testing, development of a PFAS Management Plan, conducting toxicity reviews, development of recommendations for addressing groundwater already contaminated with PFAS, and other actions.

If you need assistance with determining if this new requirement affects your facility, we can help.  Contact us today!