EPA Proposes Addition of 16 Individual and 15 Categories of PFAS to the TRI

Farella Braun + Martel LLP

On October 8, 2024, the EPA proposed adding 16 individual and 15 categories of PFAS to the Toxics Release Inventory (TRI) list of chemicals subject to reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA). As part of this proposed rule, a number of individually listed PFAS will be reclassified as categories of PFAS, which will automatically include the acid and the associated salts, acyl/sulfonyl halides, and the anhydride. For all PFAS listed under this proposed rule, EPA proposes a reporting threshold of 100 pounds and a designation of chemicals of special concern. EPA estimates that the proposed rule will result in an additional 356 to 1,110 TRI reporting forms being filed annually. 

Comments on EPA’s proposed rule are due by December 9, 2024. The proposed rule can be found here and more information on the proposed rule can be found here.

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