PFAS Addition to TRI Reporting
The National Defense Authorization Act for Fiscal Year 2020 required EPA to add PFAS compounds to the Toxics Release Inventory (TRI), a publicly accessible database of toxic chemical releases from industrial facilities. Beginning with reporting year 2019, facilities meeting threshold criteria must annually report PFAS quantities released to air, water, and land, as well as quantities transferred off-site for disposal or treatment.
The TRI initially added 172 PFAS to the reporting list, with additional compounds added in subsequent years. EPA also lowered reporting thresholds for PFAS to 100 pounds — far below the default 25,000-pound threshold for most other TRI chemicals — reflecting the concern about PFAS toxicity at low concentrations.
What TRI Data Reveals About PFAS Releases
Analysis of TRI data has revealed the geographic concentration of PFAS industrial releases, with significant clusters in the Southeast (textiles and chemicals), Great Lakes region (manufacturing), and Mid-Atlantic states (aerospace and defense). Air releases are the dominant pathway reported, raising concerns about atmospheric PFAS deposition to water bodies and land.
The data has empowered community organizations to identify facilities near their neighborhoods contributing to local PFAS contamination, enabling more targeted advocacy and regulatory action. Environmental justice analysis of TRI data shows that communities of color are disproportionately located near high PFAS-releasing facilities.
Limitations and Future Improvements
TRI reporting covers only facilities above threshold sizes and selected industry sectors, meaning that a substantial fraction of total U.S. PFAS releases goes unreported. Many service sector PFAS uses — dry cleaning, food service, consumer products — fall outside TRI reporting requirements.
EPA has indicated interest in expanding TRI PFAS reporting to additional sectors and compounds. Enhanced reporting requirements, combined with improved monitoring at facility fencelines and in ambient environments, will provide a more complete picture of PFAS industrial contributions to environmental contamination.