ILMA Urges Relief for PFAS Reporting in Fire Suppression Systems
Yesterday, ILMA submitted comments on the EPA’s proposal to add certain per- and polyfluoroalkyl substances (PFAS), which may be included in firefighting systems, to the Toxics Release Inventory (TRI) program. These aqueous film-forming foam (AFFF) systems are critical for fire safety, especially in industries such as lubricant manufacturing that handle flammable materials.
ILMA argues that facilities should not be required to assume that their fire suppression systems contain TRI-listed PFAS, but instead should only be obligated to report if they know the substances are present. The Association also recommends that available sources such as safety data sheets and supplier notifications be considered sufficient sources of information, and that facilities not be required to conduct further investigation in search of PFAS.
Further, ILMA expressed concern that the proposed categorization of PFAS for TRI reporting is broad and poorly defined, potentially creating confusion and imposing unnecessary compliance burdens. The Association urges a more transparent and well-defined approach to listing PFAS. Overly broad or unclear regulations would hinder members’ proactive efforts to identify PFAS sources and reduce risks.
