Happy New Year! You know what that means – time to start working on those year-end environmental reports.
This year, we are going to focus on changes to the Toxic Release Inventory regulations that went into effect in 2020. These changes must be included into TRI Reporting for the first time in 2021.
According to the EPA, TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. Certain industry sectors must report annually how much of each chemical is released to the environment (in air, water or disposed of on land) and/or managed through recycling, energy recovery and treatment.
In general, chemicals subject to TRI reporting are those that cause cancer or other chronic health effects, have significant adverse acute health effects and pose a significant adverse hazard to the environment. This list of chemicals changes from year to year, but a significant number of chemicals were added for reporting year 2020. These chemicals are commonly referred to as PFAS, which stands for per- and polyfluoroalkyl substances. PFAS are a group of synthetic chemicals that have been manufactured and used in a variety of industries around the globe since the 1940s.
PFAS can be found in food packaging, firefighting foams, stain and grease repellent products, and a wide range of industrial processes. These chemicals are hazardous because many can accumulate and stay in the human body for long periods of time and can result in adverse health effects.
The regulations requiring that PFAS be included in TRI reporting also include requirements for supplier notification. That means if you receive chemicals from a supplier that contain PFAS, they should have notified you and updated safety data sheets for these chemicals. If you are a supplier of these chemicals, you should have notified your customers.
It's also important to note that the reporting threshold for PFAS is only 100 pounds, unlike most other toxic chemicals which have thresholds as high as 10,000 or 25,000 pounds. Therefore, it will be extremely important to look carefully at your inventory.
Finally, this year, facilities are going to need to look extra hard at chemical inventories, safety data sheets and manufacturing records to ensure that any PFAS that are present in the facility have been quantified and tracked to determine how much of these chemicals is released to the environment. This means ensuring all safety data sheets are current as of 2020 and reviewing SDS for all chemicals, not just the ones you know you always report on.