The Environmental Protection Agency (EPA) has mandated new reporting and recordkeeping requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA). This guide offers a clear roadmap to understanding and adhering to these obligations.
Who Needs to Report?
Entities that have manufactured (including imported) PFAS substances for commercial purposes since January 1, 2011, are subject to this rule. Key industries include:
- Construction
- Manufacturing
- Wholesale trade
- Retail trade
- Waste management and remediation services
If your business operations fall within these sectors, it is crucial to determine your reporting obligations under this rule.
Reporting Requirements
Required submissions include detailed information about the PFAS substances manufactured or imported, covering aspects such as:
- Chemical identity and structure
- Usage categories
- Production volumes and by-product details
- Environmental and health impacts
- Exposure and disposal methods
Reporting Period and Deadlines
The initial reporting window opens one year after the rule's effective start on November 13, 2023. Most entities must report within six months, while small manufacturers dealing in PFAS-containing articles have up to 12 months.
Recordkeeping
It is imperative to maintain comprehensive records of all submitted information for at least five years post-submission. This facilitates easy access to data for compliance verification and future reporting needs.
Compliance Tips
- Early Preparation: Begin collecting necessary data well in advance of the reporting deadline to ensure thorough preparation and review.
- Clarify Scope: Clearly understand which substances are included under the rule and the specific information required.
- Maintain Accurate Records: Implement a strong recordkeeping system to ease compliance and simplify future reporting processes.
- Expert Consultation: For clarity on the rule's applicability or assistance with compliance strategies, reach out for expert guidance.
Adhering to the PFAS reporting rule is vital for ensuring transparency and accountability in managing the environmental and health impacts of these substances. To navigate these complex requirements confidently, consider partnering with specialists who can provide expert guidance and support.
Need Help with PFAS Compliance?
Don't navigate the complexities of PFAS reporting alone. Contact the experts at Foresight for professional support to ensure full compliance with the rule. Our team is equipped to help you understand your obligations, manage your reporting, and keep impeccable records. Reach out today to secure your peace of mind in meeting EPA requirements.
