PFAS Tracking Required Under TURA

Massachusetts companies that file toxic chemical use under the Toxics Use Reduction Act will be required to track use of Per- and poly-fluoroalkyl substances (PFAS) beginning on January 1, 2022. See the resources below to help you identify and track the use of the Certain PFAS Not Otherwise Listed (PFAS NOL)” category. Review the guidance document.

Important Dates for PFAS Tracking and Reporting

  TURA tracking starting Report to DEP How Reportable Threshold
TURA Certain PFAS NOL January 1, 2022 July 1, 2023 As a category 25,000 lbs. manufactured/ processed;
10,000 lbs. otherwise used. de minimis exemption applies
172 TRI/TURA PFAS – 2020 January 1, 2021 July 1, 2022 Individually 100 lbs.
(de minimis exemption does not apply; see MassDEP website for details)
Four TRI PFAS – 2021 January 1, 2023 July 1, 2024
Four TRI PFAS – 2022 January 1, 2023 July 1, 2024
Nine TRI PFAS – 2023 January 1, 2024 July 1, 2025

Refer to the Office of Technical Assistance website for more details on PFAS tracking and reporting obligations for the Toxics Release Inventory (TRI) and the Toxics Use Reduction Act.

  • Check your CAS numbers in the OECD Comprehensive Database of PFAS. This database is the most comprehensive searchable list of PFAS and is an important first step to see whether your facility uses PFAS. However, not all PFAS in the database will be reportable under TURA, and alternatively there are PFAS that are not in OECD’s database.
    Additionally, a shorter list of PFAS in commerce from the TSCA CDR is provided in the Guidance below in step 3.

    OECD Portal Database
  • PFAS and their CAS numbers may not be listed on a Safety Data Sheet (SDS). One third of the PFAS in commerce are claimed as Confidential Business Information. In some cases, PFAS are present in products below 1% and thus not listed on the SDS. Therefore, it is important to check with suppliers in addition to checking CAS numbers. The supplier notification letter is intended to help Massachusetts companies request information about products that may contain Certain PFAS NOL and TRI-listed PFAS.

    Download Letter
  • This guidance document describes the TURA Certain PFAS NOL category and provides reporting guidance for all PFAS known to be in commerce according to the 2020 TSCA Chemical Data Reporting. This guidance includes tables of CAS numbers and substances that need to be tracked and the thresholds that they need to be reported at.

    Download the Guidance Document
  • Some of these uses include coatings ( i.e. for fabric, paper, medical devices), surfactants ( fume and mist suppressants, electronic processing chemicals), degreasing (HFE solvents), metal Finishing (fume and mist suppressants, lubricants) and AFFF (Aqueous Film Forming Foam for firefighting).

    Learn more in the policy analysis that discusses expected uses in Massachusetts and view more resources such as presentations, webinars and PFAS information from external resources.

    PFAS Resources