PFAS And TRI: More, Lots More, To Come

Given today's incessant media coverage and regulatory attention to PFAS (per- and polyfluoroalkyl substances), and their widespread presence in a host of products, it may seem surprising at first that the recently published 2021 Toxic Release Inventory ("TRI") preliminary data on PFAS is so limited. Indeed, out of the 75,890 total entries reported to TRI for all chemicals in 2021 (from approximately 21,000 facilities), EPA received a mere 92 PFAS reporting forms on 46 different PFAS from 45 facilities. However, EPA is poised to expand dramatically the scope of facilities likely to file TRI reports for PFAS in coming years.

This is the second year that PFAS, known more colloquially as the "forever chemicals" due to their persistence and years-long degradation process, have made an appearance on the TRI, a publicly available database containing information on toxic chemical and waste management activities in the U.S. Their inclusion is relatively new, only being added