With the yearly July 1 due date for submitting Harmful Release Stock (” TRI”) reports right around the corner, on June 22nd, the U.S. Epa (” EPA”) completed the addition of 9 more per- and polyfluoroalkyl compounds (” PFAS”) to the list of chemical topic to the reporting program (beginning with reports due next year– July 1, 2024– for the 2023 reporting year).
The guideline, initially proposed in January 2023, belongs to a bigger effort by the Biden Administration to effectuate their PFAS Strategic Roadmap and control the chemicals. EPA last upgraded the list of PFAS topic to the TRI reporting program in July 2022.
The extra 9 PFAS were included pursuant to the 2020 National Defense Permission Act (” NDAA”), which states numerous systems by which extra PFAS can be contributed to the list of reportable chemicals. Pursuant to the NDAA, EPA needs to examine private service info (” CBI”) declares prior to including PFAS to the TRI list if the chemical undergoes a claim of defense from disclosure. After evaluation, EPA figured out that the following 4 PFAS are no longer private and hence included them to the TRI:
- Alcohols, C8-16, γ-Ï-perfluoro, response items with 1,6-diisocyanatohexane, glycidol and stearyl alc. (2728655-42-1);
- Acetamide, N-[3-(dimethylamino)propyl]-, 2-[(γ-Ï-perfluoro-C4-20-alkyl)thio] derivs. (2738952-61-7);
- Acetic acid, 2-[(γ-Ï-perfluoro-C4-20-alkyl)thio] derivs., 2-hydroxypropyl esters (2744262-09-5); and
- Acetamide, N-( 2-aminoethyl)-, 2-[(γ-Ï-perfluoro-C4-20-alkyl)thio] derivs., polymers with N1,N1-dimethyl-1,3- propanediamine, epichlorohydrin and ethylenediamine, oxidized (2742694-36-4).
Furthermore, the NDAA instantly includes PFAS to the TRI upon the Firm’s completion of a toxicity worth. EPA completed toxicity worths for the following chemicals in December 2022, hence including them to the TRI:
- PFBA (375-22-4);
- Perfluorobutanoate (45048-62-2);
- Ammonium perfluorobutanoate (10495-86-0);
- Potassium perfluorobutanoate (2966-54-3); and
- Salt perfluorobutanoate (2218-54-4)
Now, an overall of 189 PFAS chemicals go through TRI reporting requirements. The addition of these 9 PFAS works on January 1, 2023. Appropriately, centers that make, procedure or otherwise utilize any of these chemicals from that date forward should report releases and other waste management activities including the compounds for the 2023 reporting year (reports are due July 1, 2024). Thus, centers need to be tracking making use of these chemicals now. Needed PFAS reporting for TRI Reporting Year 2022 is due on July 1, 2023.