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.
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Check CAS Numbers
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.
OECD Portal Database
Additionally, a shorter list of PFAS in commerce from the TSCA CDR is provided in the Guidance below in step 3. -
Send Letters to Suppliers
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 -
Review the Guidance for Reporting PFAS Under the Toxics Use Reduction Act
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 -
Common Industrial Uses of PFAS
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 -
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