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Managing risk in an age of missing information

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By Jackie Baxley, EHS Practice Leader, HRP Associates Inc.

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.

Suppliers are required to notify customers subject to reporting that a product contains certain chemicals.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.

Merging this experience with the stated goals of the PFAS Road Map to, “pursue a comprehensive approach to proactively prevent PFAS from entering air, land and water at levels that can adversely impact human health and the environment,” it raises the question of how companies will identify potential sources of PFAS within their processes so they can source-reduce or source-replace when information is still limited?

Is only within the last decade that PFAS have really captured the attention of policymakers.The Road Map addresses this by removing “de minimis” eligibility from supplier notification. Additionally, organizations can take a systematic approach, identifying process or products that are higher risk by applying knowledge of the types of chemicals and products that contain PFAS.

HRP recommends organizations 1) identify processes or products that may contain PFAS, 2) contact the suppliers of those products asking specifically about the presence or absence of PFAS chemicals, and 3) document all correspondence and information requests to show your due diligence in ensuring receipt of best available information.

As EPA marches through its road map, organizations can best manage risk now by understanding if and how PFAS are used within their organization and make strides to reduce or replace those sources. HRP has been assisting organizations with this risk assessment process and stands ready to help move your environment forward.

This content first appeared in the GSA Business Report Book of Experts.


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