Aegis Regulatory Alert - May 2023

TRI Reports Due July 1st



What’s New. Toxic Release Inventories (TRI) for 2023 are due for submittal by July 1st 2024.  EPA has included 9 additional Per- and Polyfluoroalkyl Substances  (PFAS) chemicals on the list of chemicals subject to toxic chemical release reports.

  • U.S. facilities across various industries are required by the EPA to report inventories of chemicals that have been released and/or managed as well as practices used to prevent or reduce waste generation.
  • Information gathered from these inventories improves the overall nexus of understanding to allow government and non-government agencies to create better management practices and allows for a more informed public.

Many chemicals/materials that have been in regular use could contain PFAS. The presence of PFAS is not always easy to determine. Many products labeled as “heat/oil/stain/grease or water resistant” may contain PFAS. 

What’s Next. Facilities with NAICS codes covered by the TRI program that use, make, or process chemicals on the TRI list should already be compiling their inventories and preparing to submit. If you find your business’s NAICS is included in the list required to report these newly identified PFAS compounds on this year’s TRI, the information can be difficult to find. PFAS are not always included in the SDS, and it may require additional research/consultation to determine if PFAS are present in materials used at your facility.

Remember the EPA is not only looking for data on releases but is also looking to glean a better understanding of how facilities are managing waste.


Our Team. If you have any questions or are looking for help to streamline your reporting process, reach out to our team. Aegis works with many clients across various industries and can assist in your TRI reporting—and in identifying sources of PFAS. Please contact Chris Lampel at clampel@aegisenv.com for more information.

Resources: 

Basics of TRI Reportinghttps://www.epa.gov/toxics-release-inventory-tri-program/basics-tri-reporting

What is the Toxics Release Inventory?https://www.epa.gov/toxics-release-inventory-tri-program/basics-tri-reporting

Addition of Certain PFAS to the TRI by the National Defense Authorization Act https://www.epa.gov/toxics-release-inventory-tri-program/addition-certain-pfas-tri-national-defense-authorization-act

Federal Register 40 CFR Part 372