Toxic Release Inventory Reporting: Screening and Sampling for PFAS Chemicals

In January 2020, the United States Environmental Protection Agency (US EPA) significantly expanded the Toxic Release Inventory (TRI) chemical list by adding 172 chemicals. The newly added chemicals belong to the PFAS (per- and poly-fluoroalkyl substances) family and are highly persistent and resist degradation after release into the environment. With the addition of the PFAS chemicals, the list of TRI chemicals has grown to 767. The deadline for 2020 TRI reporting (which includes the expanded list of PFAS chemicals) is July 1, 2021.

Who needs to submit a TRI report?

Industrial and federal facilities that use above a certain amount of any TRI chemical during the calendar year must submit a TRI report to the USEPA. For the PFAS chemicals, the annual use amount that triggers reporting 100 pounds.

Where are PFAS chemicals found?

PFAS chemicals have become a worldwide pollutant found on every continent due to their widespread use for the following: waterproofing, food packaging, fire-fighting products, plastics, wiring, carpet and textiles, and other consumer products. Industrial facilities that manufacture these products will need evaluate their use of PFAS chemicals as part of TRI Reporting.

Estimating PFAS use and Testing for PFAS Releases

Facilities will need to screen and estimate their 2020 annual PFAS chemical use and may elect to test for PFAS chemicals in their release streams as part of TRI Reporting.

For more in-depth learning about TRI Screening and Testing for PFAS chemicals, SLR presented a webinar on this topic in September 2020. The webinar includes a review of available analytical methods to test for PFAS in different media such air, wastewater, stormwater and waste. The webinar recording can be view at the following link: https://attendee.gotowebinar.com/recording/7517241561830631184

TRI Programme History

In 1987, the United States initiated the TRI reporting programme, the first Pollutant Release and Transfer Register (PRTR) programme in the world. Over the past 30 years, these programmes have spread across the globe and over 50 countries have developed their own PRTR programmes.

While the U.S.’s TRI programme may have been a global first, the study and regulation of PFAS chemicals in the U.S. lags behind several other countries such as Canada and Australia. SLR’s global team of scientists and engineers have been engaged in PFAS work for well over two decades working to develop new PFAS test methods, remediation strategies, and policy guidance in multiple countries. SLR’s team of scientists and engineers has been active in global PFAS work for well over two decades - working to develop new PFAS test methods, remediation strategies, and policy guidance in multiple countries.

Upcoming PFAS Legislation – House Bill 535

The goal of the TRI programme, like other international PRTR programmes, is to improve the transparency of the release of pollutants into the environment, to allow for better decision-making by the public, policymakers, scientists, and industry representatives. Additional legislation is currently underway in the U.S. to establish PFAS cleanup levels and acceptable concentrations for drinking water, groundwater, soil, and air quality under House Bill 535.

Please reach out to SLR for your TRI reporting and PFAS compliance needs, including:

• Facility screening for chemical use and TRI-reporting obligation and report preparation
• Auditing of existing TRI reporting programmes
• Assistance with the selection of analytical methods and sampling for PFAS in water, soil, air, or waste
• Identification of PFAS chemical alternatives for use in manufacturing processes
• Management, treatment, and disposal of PFAS-contaminated wastes
• Due diligence and risk analysis related to possible environmental contamination, including PFAS

Contact TRI@slrconsulting.com or awallendahl@slrconsulting.com with any questions you may have.