The US Environmental Protection Agency (EPA) has issued a final rule on reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS) through the Toxic Substances Control Act (TSCA). This rule requires manufacturers and importers to report their PFAS identities, uses, releases, disposals, exposures, health effects, and other information dating back to January 1, 2011.
Notably, the reporting standard requires information “to the extent known or reasonably ascertainable by the manufacturer”; this includes data from previously conducted testing, as well as publicly available information such as scientific studies. Many companies may not currently possess all available environmental or health information or human health data, as required in the final rule. As a leader in systematic literature review methods with a proven track record conducting state-of-knowledge assessments on specific chemistries, ToxStrategies is positioned to assist manufacturers in identifying this type of information related to their specific PFAS chemistries. We have several turn-key offerings, including systematic literature search methodology and artificial intelligence solutions to target relevant studies, that can assist manufacturers with efficiently determining what was reasonably ascertainable year by year. Our team of toxicologists is also well-suited to assist manufacturers with interpreting the rule and organizing the data for submission; for example, using OECD harmonized templates for environmental and health effects data or coordinating joint submissions.
According to EPA, submitters have until May 8, 2025, to submit information via a new online reporting tool (small manufacturers may have until November 10, 2025). The complete published rule, including lists of required information, can be found in the Code of Federal Regulations.
For more information on our literature search capabilities and PFAS expertise, please visit our publications page or contact Kara Franke or LeeAnn Racz.