983423 - Tri-Listed PFAS and Reporting in 2021:  What We Know About These Chemicals

The annual Toxics Release Inventory (TRI) due on July 1, 2021 for the reporting year 2020 will now include 172 per- and polyfluoroalkyl substances (PFAS) due to the passage of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 and the USEPA’s final rulemaking in June 2020. The reporting threshold for “manufacturing, processing and otherwise use” for each of the listed PFAS is 100 pounds. The de minimis concentration level in a mixture currently remains 1% by weight (except for PFOA at 0.1%).
USEPA’s TRI web page on the “Addition of Certain PFAS to the TRI by the National Defense Authorization Act” explains that most of the listed PFAS are based on “an active chemical substance in the February 2019 update to the TSCA Inventory” (See NDAA, Public Law 116-92, Section 7321(b)(1)). Facilities often look first for Aqueous Film Forming Foam (AFFF) in on-site fire suppression systems, but the sources of the majority of the TRI-listed PFAS are not well understood. In this first year of reporting, several questions arise, such as:
• What products contain TRI-listed PFAS?
• Where are these lesser-known PFAS likely to occur at facilities?
• How can they be quantified for thresholding and reporting?
• When it comes to mixtures, facilities that do not manufacture PFAS are not likely to obtain helpful information from a Safety Data Sheet (SDS) or suppliers. How do industries contend with this?
This presentation will summarize the authors’ ongoing research and evaluation, initiated in 2020, of the 172 TRI-listed PFAS to better understand their classifications, potential sources and uses. It will provide illustrations to advance our knowledge of TRI-listed PFAS based on the data evaluated. The presentation will also provide perspective on what meeting either the de minimis concentration levels or the reporting thresholds would mean in terms of the quantity of use of a particular substance. Finally, it will provide a strategy for addressing TRI reporting and documentation requirements while acknowledging current data limitations associated with TRI-listed PFAS.