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PFAS Reporting and Your Business 

John StoneOther

PFAS reporting requirements are changing – and what the U.S. Environmental Protection Agency (EPA) decides could affect your business. Currently, the EPA is finalizing and publishing rules surrounding the production and use of PFAS substances. The goal is to establish a database that can be used for future regulations.  PFAS compounds are used across all industries and in many safety-critical applications for which there is no substitute.  Fluoroelastomers, a subset of PFAS compounds, have not been shown to have the negative health effects of PFAS chemicals like PFAO and PFOS, both of which have been found in drinking water. Yet fluoroelastomers could be covered by new EPA regulations. 

If you use fluorocarbon (FKM, Viton®), fluorosilicone (FVMQ), FFKM or AFLAS, what the EPA decides about PFAS reporting will apply to your business. Moreover, complying with these rules could require significant resources to meet the reporting requirements. Keep reading to learn more, or contact The Rubber Group for more information. 

PFAS Reporting Requirements 

The EPA will require PFAS reporting from the period beginning January 1, 2011, to the present. This is a one-time event. If your business is affected by this requirement, the EPA rule will require you to collect and report the following information.      
  • A. The covered or common trade name and identity of each chemical substance or mixture 
  • B. Categories or proposed categories of use for each substance or mixture. 
  • C. The total amount of each substance or mixture manufactured or processed, the amounts manufactured or processed for each category of use, and reasonable estimates of the respective proposed amounts. 
  • D. Description of byproducts resulting from the manufacture, processing, use, or disposal for each substance or mixture.  
  • E. All existing information concerning the environmental and health effects of each substance or mixture. 
  • F. The number of individuals exposed, and reasonable estimates regarding the number of individuals who will be exposed to each substance or mixture in their places of work and the duration of their exposure. 
  • G. The manner or method of disposal of each substance or mixture, and any change in such manner or method.  
If actual data is not available, the EPA rule says that reasonable efforts must be made to estimate the required data. 

Reporting Platform and Timing 

Reporting will be done through the EPA Central Data Exchange (CDX). The EPA already uses this system to collect other types of information, so the CDX was selected because many companies are familiar with it. The CDX also has provisions for keeping proprietary business information confidential. 

Once this rule is published/enacted, companies will have one year to collect the data and six months to finish reporting to the EPA. For more information,