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Final Rule Alert: 172 PFAS Chemicals Added to EPCRA TRI Reporting List

Posted on 6/23/2020 by Roger Marks

On June 22, 2020, US EPA promulgated a Final Rule to add 172 per- and polyfluoroalkyl substances to the list of toxic chemicals subject to Toxic Release Inventory or TRI reporting under the Emergency Planning and Community Right to Know Act (EPCRA).

The 172 PFAS chemicals will be listed at 40 CFR 372.29 and have been added with reporting thresholds of 100 pounds.

Facilities that manufacture, process, or use 100 lbs. or more of any of the newly-added PFAS chemicals must report on their activity on the EPCRA TRI report due July 1, 2021.

Keep in mind, the 2021 TRI report must cover all activity in 2020—including newly-added PFAS chemicals used, processed, or manufactured between January 1 and June 22 this year.

EPA added these chemicals in part to satisfy a statutory or legal requirement in the most recent National Defense Authorziaton Act (NDAA), section 330A. 

What is EPCRA TRI Reporting?

Also called Form R, EPCRA TRI reporting requires US facilities to report annually on the chemicals they manufacture, process, and use in volumes above the regulatory thresholds that EPA sets in regulation. 

For most chemicals on the TRI list, the reporting threshold is 25,000 pounds for chemicals manufactured or processed and 10,000 pounds for chemicals “otherwise used.” The bulk of the list of covered chemicals is found at 40 CFR 372.65, along with each chemical’s TRI reporting threshold.

“Chemicals of special concern,” which are assigned lower reporting thresholds, are found at 40 CFR 372.28.  

Is My Site Covered by EPCRA 313 Reporting?

if you manufacture, process, or use any of the newly-added PFAS chemicals, you can answer four questions to determine whether EPCRA Section 313 reporting applies to your site’s activities: 
  1. Is your facility’s primary SIC code on the EPCRA Section 313 list?
  2. Does your facility employ ten or more full-time equivalent employees?
  3. Does your facility manufacture, process, or use EPCRA Section 313 chemicals?
  4. Does your facility exceed any of the activity thresholds for EPCRA Section 313 reporting?
For more details on EPCRA reporting applicability, read Know Your EPCRA Reporting Responsibilities.

CERCLA and Chemical Right-to-Know Training 

Many facilities that manufacture, process, and use hazardous chemicals must comply with detailed requirements for chemical inventory reporting, release reporting, and emergency preparedness.

The Superfund and Right-to-Know Act Regulations online course familiarizes EHS professionals with the complex planning and reporting responsibilities in the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). 

Convenient, Effective Online EHS Manager Training

Managing site compliance with the many complex EPA programs that affect your business—from the Clean Air and Clean Water Acts to TSCA, EPCRA, CERLCA, and more—is a major challenge. If you’re new to the field or need an update on changing EPA rules, online training is a convenient way to quickly build in-depth expertise.

The Complete Environmental Regulations online course will prepare you to identify your site's liabilities and responsibilities under major environmental laws and regulations. This course is ideal for new EHS managers, environmental consultants, and anyone who wants clarity about how complex environmental requirements fit together. 

Or check out these courses on specific EPA programs:
 
Clean Air Act Regulations Online
TSCA Regulations Online
Clean Water Act & SDWA Regulations Online
Superfund and Right-to-Know Act Regulations Online 

Tags: chemical reporting, environmental compliance, environmental management, EPCRA, right to know

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