Supporting Industries with TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS
Introduction
The Environmental Protection Agency (EPA) has implemented the TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), aiming to address the significant concern surrounding these persistent chemicals. Industries across various sectors must comply with these regulations to ensure environmental safety and public health. Environmental Science and Engineering Partners (ESE) is dedicated to providing comprehensive support to industries navigating these stringent requirements.
Understanding PFAS
PFAS are synthetic organic compounds known for their resistance to degradation due to the strong carbon-fluorine bonds within their structures. These substances have been utilized for decades in numerous consumer and industrial products, leading to widespread environmental presence and bioaccumulation in both wildlife and humans. As of February 2023, EPA has identified 1,462 PFAS covered by TSCA, with 770 actively in U.S. commerce.
Key Characteristics of PFAS
- Highly resistant to degradation
- Persistent in the environment
- Ability to bioaccumulate in organisms
- Long retention time in the human body
TSCA Section 8(a)(7) Requirements
Industries involved in the manufacturing, processing, or importing of PFAS must adhere to the TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements. These regulations mandate detailed documentation and reporting to ensure comprehensive tracking and management of PFAS substances.
Reporting Requirements
EPA is requiring any person that manufactures (including import) or has manufactured (including imported) PFAS or PFAS-containing articles in any year since January 1, 2011, to electronically report information regarding PFAS uses, production volumes, disposal, exposures, and hazards. Industries must report:
- The number of individuals exposed to PFAS and the duration of their exposure
- The method of disposal of PFAS substances
- Any changes in the disposal methods
This direct final rule changes the data submission period to open on July 11, 2025 when the Agency expects the software reporting application to be fully functional. Most reporters would be required to complete all reporting by January 11, 2026. Small businesses reporting data solely on importing PFAS contained in articles will have until July 11, 2026 to submit reports.
How ESE Can Support Your Business
ESE offers specialized services tailored to help industries meet their TSCA Section 8(a)(7) reporting and recordkeeping obligations. Our expert team provides:
- Consultation Services: In-depth guidance on understanding and meeting EPA requirements.
- Documentation Assistance: Comprehensive support in preparing accurate reports and records.
- Training Programs: Educational resources and training sessions for your staff to ensure compliance.
- Disposal Method Optimization: Advice on efficient and compliant disposal methods for PFAS substances.
- Continuous Support: Ongoing assistance to address any regulatory changes or updates.
Conclusion
Compliance with the TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements is crucial for industries managing PFAS substances. ESE is committed to providing the necessary expertise and support to ensure your business meets these regulations effectively. By partnering with ESE, you can navigate the complexities of PFAS reporting with confidence and contribute to a safer environment.
