EPA developed and issued an action plan to address PFASs that identified a series of actions. One action was to add PFAS substances to its Emergency Planning and Community Right-to-Know Act Toxic Release Inventory (TRI) reporting requirements. As EPA was working on this, the 2020 National Defense Authorization Act was passed and signed into law. The law requires EPA to include 160 PFASs in the reporting requirements with a reporting threshold of 100 pounds per year. This is important for printing operations with more than 10 full time employees, as the TRI requires facilities that use or produce any listed chemical above the 100-pound threshold to immediately begin tracking releases of PFAS to the environment and report annually to the EPA. Reporting on these chemicals used, manufactured, or processed in 2020 will be due by July 1, 2021.
The comments submitted by the US Chamber of Commerce, that were cosigned by SGIA, urged EPA to only add any more PFAS chemicals on an individual basis and not add them as a category. The comments also requested EPA to review the 160 PFAS chemicals added as a result of the 2020 National Defense Authorization Act to ensure they meet the criteria for chemicals to be reported, and to also provide justification if the 100-pound reporting threshold within 5 years should be revised per the 2020 National Defense Authorization Act. The last request was to delay the reporting requirement until July 1, 2022 to allow time for notifications of the presence of the chemicals to prepared and provided to end users.
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