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MassDEP: New PFAS listings change how facilities must report under TURA
Summary
MassDEP staff outlined changes for Toxics Use Reduction Act reporting for reporting year 2024 including recent PFAS additions moved from TRI to TURA lists, lower de minimis thresholds for some chemicals and new reporting timelines; DEP emphasized use of updated guidance in the reporting appendices.
Massachusetts Department of Environmental Protection officials told attendees at a Terra reporting spring training that recent additions of per- and polyfluoroalkyl substances to the federal Toxics Release Inventory and to Massachusetts’ Toxics Use Reduction Act chemical lists require different reporting approaches this year.
The new federal TRI listings mean some PFAS must be reported individually at the TRI threshold and, for several chemicals, are now or soon will be reportable under TURA at a 100‑pound threshold. "TRI PFAS are no longer eligible for the de minimis exemption because EPA has designated them as chemicals of special concern," Lynn Kane, MassDEP TURRA program, said during the webinar.
Why it matters: PFAS reporting thresholds and category assignments determine whether facilities must submit a full TURA report, whether fees apply, and whether firms must list chemicals individually rather than under the TURA “certain PFAS — not otherwise listed (NOL)” category. MassDEP staff said they have published updated PFAS guidance and four tables in the TURA reporting appendices to help filers identify which PFAS must be reported individually this year and which remain in the NOL category temporarily.
MassDEP presenters summarized the immediate changes and timing. Kane said a set of fluorochemicals added to TRI in 2023 are reportable individually under TURA for reporting year 2024; those TRI-listed PFAS generally carry a 100‑pound per‑year reporting threshold for TRI and are treated individually in DEP guidance. Kane also noted that the TURRA Administrative Council has voted to add additional PFAS to the TURA list effective for reports due July 1, 2026 (reporting year 2025), and that further PFAS additions are scheduled for the following reporting year.
Heather Tenney of the Toxics Use Reduction Institute (TURI) explained the TURI/TUR science advisory process that generated the TURA “certain PFAS NOL” definition and the practical reason for retaining that category: it groups molecular structures that meet a scientific definition but are not otherwise listed. "That category includes a perfluoroalkyl moiety with three or more carbons or a perfluoroalkyl ether moiety with two or more carbons," Tenney said, describing the definition used for the NOL category.
Kane and Tenney urged filers to consult the PFAS guidance starting on page 63 of the TURA reporting appendices and to use the TURA chemical list and the guidance tables (tables 1–4) to determine reporting obligations. The guidance lists TRI‑origin PFAS that are reportable individually at 100 pounds, TURA PFAS that remain on the 25,000/10,000‑pound thresholds, PFAS overlapping c1–c4 halogenated categories, and the larger certain‑PFAS NOL list of substances known to be in commerce.
Other changes noted: Kane said the TRI de minimis level for trivalent antimony compounds changed from 1 percent to 0.1 percent after an IARC carcinogen assessment, which affects reporting under the antimony compounds category; she also reported one new chemical and one new chemical category added to the TURA chemical list for reporting year 2024 (details and cast numbers are in the TURA appendices).
What filers should do next: MassDEP staff advised facilities to review the PFAS tables in the appendices, check safety data sheets and supplier information, and contact TURI or OTA for assistance with chemical identification. The speakers repeatedly stressed that not all PFAS in commerce appear on public lists because of confidential business information and said filers should compare the chemical structure or CAS numbers to the definitions in the guidance when in doubt.
MassDEP closed the segment by pointing attendees to the updated TURA reporting instructions and the PFAS guidance in the appendices and offering follow-up help by email and the program’s contact channels.
