The EPA recently updated the EPCRA program which governs TRI and Tier II (Community Right to Know or CRTK in New Jersey). This change added certain Per- and Polyfluoroalkyl Substances (PFAS) to the TRI list. Among these added chemicals are chemicals that met two criteria: (1) they were subject to a significant new use rule at either 40 CFR 721.9582 or 721.10536 on or before December 20, 2019; and (2) they were identified as active in commerce on the Toxic Substances Control Act (TSCA) Inventory that was published in February 2019. Chemicals meeting only one of the two criteria were not added to the TRI list. Via the considerations described above, 172 additional chemicals were identified. Similarly, the NJDEP recently sent an email related to the 2020 CRTK. According to this email: "Facilities in New Jersey subject to the Community Right to Know (CRTK) program will be subject to reporting Per- and Polyfluoroalkyl Substances (PFAS) and the Nonylphenol Ethoxylates (NPE) category on the CRTK Survey 2020. There are 172 unique PFAS chemicals and the NPE category covers 13 unique chemicals to be aggregated and reported under the compound category." The 2020 CRTK Survey for NJ and Tier II Reports are due March 1st, 2021.
PFAS are most commonly found in the manufacture of stain resistant and water resistant fabrics, non-stick cookware and in foam fire suppression systems. NPE are most commonly found in detergents, cleaners and emulsifiers.
To see the full list of the added PFAS and NPE CAS numbers, click here.
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