Managing risk in an age of missing information


In 1998 Google was founded, Jesse “the Body” Ventura was elected Governor of Minnesota, “Titanic” swept the Oscars, I graduated from college, and the EPA was first alerted to the health hazards of toxic fluorinated chemicals, known as PFAS.

PFAS have been an emerging contaminant throughout my career in risk management, environmental, health and safety compliance. However, it is only within the last decade that PFAS have really captured the attention of policymakers.

In October of 2021, EPA released its “PFAS Road Map” detailing a timeline for the agency to set standards and guidelines surrounding PFAS in drinking water, wastewater, air and other releases. This road map is a glimpse into the future. However, we have the experience of the past year as we navigated one of the first actionable federal regulations that covered PFAS: the addition of 172 PFAS chemicals to the Emergency Planning and Community Right-to-Know Act (EPCRA) Toxic Release Inventory (TRI) reports that are required of covered industries that produce, manufacture or otherwise use related materials.

Under EPCRA, suppliers are required to notify customers subject to reporting that a product contains a covered chemical such as these specific PFAS. Supplier notifications commonly take the form of safety data sheets or product labeling, product literature or notification letters. As we assisted our industrial clients with their annual TRI Reports, it became clear that information from suppliers was a significant data gap in preparing these reports and assessing PFAS risks.

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GSA Business, 1 February 2022