On May 17, 2024, the U.S. Environmental Protection Agency (EPA) expanded its Toxic Release Inventory (TRI) program to include seven additional per- and polyfluoroalkyl substances (PFAS), raising the total number of PFAS tracked under the TRI to 196 to report in 2025 for the year 2024—the PFAS to report on for 2023 on July 1, 2024 numbers 186.
This decision, mandated by the 2020 National Defense Authorization Act (NDAA), which requires annual updates to the PFAS list in the TRI, reflects ongoing efforts to monitor and manage environmental exposure to these persistent chemicals.
The EPA removed the de minimis exemption for PFAS under the “chemicals of special concern” category as of October 2023. This elimination underscores the increased regulatory focus on these substances due to their environmental and health risks, thereby intensifying the demands on facilities to track and report PFAS handling accurately. This ongoing regulatory evolution highlights the increasing scrutiny and accountability for environmental stewardship concerning PFAS.
SCS’s educational video Toxics Release Inventory Reporting explains how to identify and quantify facilities subject to TRI reporting, including:
Facilities must start compiling historical and new information to meet compliance requirements. The educational video covers the reporting thresholds and tips for collecting the data, calculating usage, and determining which form to report to the EPA. Some facilities accidentally overreport, so our expert tells you how to avoid this mistake.
Including additional PFAS in the TRI places a greater compliance burden on many industries. Companies must adapt by implementing more rigorous tracking systems and investing in technologies to reduce PFAS emissions or discharges.
Tracking specific product formulations is more important than ever. Safety Data Sheets (SDS) and historical reporting are a good place to start. Still, our expert explains how to minimize your facility’s risk of non-compliance, fines, or legal actions by not relying on SDS. She provides many tips for increasing the accuracy and accountability of this public information.
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The July 1, 2024, deadline for the TRI Reporting (Toxics Release Inventory) covering activities during the previous calendar year is fast approaching. Manufacturers, including food and beverage, electric utilities, and mining facilities, may need extra time this year to comply with recent rule changes related to per- and polyfluoroalkyl substances (PFAS).
Specifically, this recent action updates the regulations to identify nine per- and polyfluoroalkyl substances (PFAS) that must be reported under the National Defense Authorization Act for Fiscal Year 2020 (FY2020 NDAA) enacted on December 20, 2019. You may be potentially affected by this action if you manufacture, process, or otherwise use any of the PFAS listed in this rule. The following list of North American Industry Classification System (NAICS) codes provides a guide to help you determine whether this action applies to your facility.
TRI Reporting is a two-step process, and covered facilities with at least ten full-time equivalent employees must complete the first step to evaluate whether a report is required each year. For each chemical or PFAS that exceeds a reporting threshold, EPA requires the facility to calculate releases to the air, wastewater, and stormwater and the amount of the chemical recycled or treated on-site or sent off-site for treatment during the previous calendar year.
SCS Engineers presents an on-demand educational video with complimentary articles and additional resources to get you started. Cheryl Moran, a senior project manager with decades of experience in regulatory compliance, sustainable practices, and chemical management, covers what you need to know to get started:
Additional TRI Resources
