US EPA PFAS Restrictions and Substances

As part of its comprehensive approach to managing PFAS substances, the US Environmental Protection Agency (EPA) has established specific reporting rules under the Toxic Substances Control Act (TSCA) section 8(a)(7), mandating annual reporting on PFAS usage since 2011. This directive mandates detailed reporting on the usage of PFAS chemicals, focusing on their unique chemical structures that denote their inclusion under this rule. Key aspects include:

• Annual Reporting Requirements

  Organizations are obliged to report the utilization of PFAS substances annually, highlighting the EPA's commitment to closely monitoring these chemicals' presence in the environment and industry.

• Record-Keeping Mandate

  A five-year record-keeping requirement post-submission ensures that detailed information about PFAS usage is readily available for regulatory review and compliance verification.

• Chemical Structure Specifics

  The reporting rule targets PFAS substances defined by specific chemical structures, emphasizing the need for accurate identification and reporting of these compounds. Notably, the structures outlined for reporting obligations are

  • (CF2)-CF(R’)R’’, where both the CF2 and CF moieties represent saturated carbons,
  • R-CF2OCF2-R’, where R and R’ can be fluorine, oxygen, or saturated carbons, and
  • CF3C(CF3)R’R’’, where R’ and R’’ are either fluorine or saturated carbons.
• Comprehensive Scope

  The rule has identified 1,462 PFAS chemicals that fall under these reporting requirements, illustrating the vast array of PFAS compounds used across industries and applications.