PFAS Compliance: How to Identify and Manage Forever Chemicals in Your Business

Per- and polyfluoroalkyl substances (PFAS) have emerged as one of the most significant environmental risks and health challenges facing businesses today. These “forever chemicals,” named for their remarkable persistence in both the environment and the human body, are present in countless industrial facilities and consumer products across virtually every sector of the economy. 

The human health implications of PFAS exposure are particularly concerning. Scientific studies have linked these chemical substances to several severe public health conditions, including various types of cancer, liver damage, decreased fertility, increased risk of asthma, and compromised immune system function. For employers, this presents a dual challenge: ensuring worker safety and managing potential liability. Long-term exposure in industrial settings can put employees at risk, making proper identification and management of PFAS-containing materials crucial for workplace safety.

The regulatory landscape around PFAS is rapidly evolving. In a significant recent development, on January 3, 2025, the EPA expanded its Toxic Release Inventory (TRI) to include nine additional PFAS chemicals, reflecting the growing focus on controlling these hazardous substances. This expansion means more employers than ever must track and report their PFAS usage, with non-compliance potentially resulting in substantial fines and legal consequences.

Identifying PFAS in your operations can be challenging due to their widespread use across industries. From manufacturing facilities to service providers, these chemicals can be present in numerous forms.

Types of Products Containing PFAS – How to Identify Them

Understanding where PFAS substances may be present in your facility requires a comprehensive knowledge of both industrial and commercial products that typically contain these substances. Below, we break down common sources and provide practical guidance on identification methods.

Industrial Products

PFAS are prevalent in numerous industrial applications, particularly where water resistance or non-stick properties are desired. Key products include:

• Non-stick coatings and surfaces found on industrial equipment and manufacturing tools
• Water-repellent treatments used in textile and leather processing
• Aqueous Film Forming Foam (AFFF), a critical firefighting agent particularly common in aerospace and military facilities
• Metal plating solutions used in electronics and automotive manufacturing
• Semiconductor etching compounds essential in electronics production

Commercial Products 

Many everyday commercial products in workplace settings contain PFAS:

• Stain-resistant treatments on carpets, upholstery, and workplace furnishings
• Water-resistant coatings on protective gear and equipment
• Grease-proof packaging materials, including food service containers and wrapping
• Industrial cleaning solutions, especially those designed for heavy-duty degreasing
• Polishing and waxing compounds used in maintenance operations

Hidden Sources of PFAS

Beyond obvious sources, PFAS can lurk in unexpected places within your facility. Understanding these hidden sources is crucial for comprehensive management.

Equipment and Infrastructure

• Legacy firefighting system components may contain PFAS residues from previous AFFF use
• Protective coatings on pipes and storage tanks, particularly in older facilities
• Maintenance equipment surfaces, especially those treated for water or stain resistance
• Building materials and insulation installed before PFAS regulations
• Historical contamination in facility infrastructure from decades of industrial use

Process-Related Sources PFAS can enter your facility through various indirect routes:

• Recycled materials that may contain legacy PFAS compounds
• Cross-contamination from shared equipment used with PFAS-containing materials
• Maintenance products and lubricants, particularly those advertising water-resistant properties
• Third-party supplied components that may contain undisclosed PFAS treatments
• Imported materials where PFAS content may not be properly documented

Comprehensive Chemical Inventory Assessment

Effectively managing PFAS requires a systematic approach to inventory assessment and documentation.

Initial Steps Begin with these fundamental actions:

• Conduct a thorough SDS database review and organization, ensuring all documentation is current and accessible
• Analyze historical purchase records to identify potential PFAS-containing materials
• Evaluate process flows to understand where PFAS might be introduced or created
• Establish clear communication channels with suppliers regarding PFAS content
• Perform detailed equipment and material audits across your facility

Assessment Methods Implement these proven strategies:

• Develop and follow laboratory testing protocols for suspected PFAS-containing materials
• Verify supply chain documentation and certificates of analysis
• Create detailed process maps to identify potential PFAS pathways
• Implement risk-based prioritization to focus resources on highest-risk areas

Documentation Requirements Maintain comprehensive records including:

• Up-to-date chemical inventory records with PFAS clearly identified
• Detailed process use documentation showing where and how PFAS-containing materials are used
• Analysis of potential exposure pathways within your facility
• Phase-out planning documents for PFAS alternatives
• Regulatory compliance records demonstrating due diligence and proper management

By implementing these systematic approaches to PFAS identification and management, businesses can better protect their workers, maintain compliance, and prepare for future regulatory requirements. 

Current Regulatory Landscape

The regulatory framework for PFAS is experiencing unprecedented expansion at both federal and state levels. The EPA’s recent addition of nine PFAS chemicals to the Toxic Release Inventory in January 2025 exemplifies the accelerating pace of regulatory oversight. Federal regulations now require comprehensive reporting of PFAS usage, releases, and disposal practices, with a particular focus on manufacturing facilities and industries with known PFAS applications.

State-level regulations often exceed federal requirements, creating a complex compliance landscape for businesses operating across multiple jurisdictions. Some states have implemented strict PFAS limits in drinking water supply, while others require extensive testing and remediation programs. This patchwork of regulations requires businesses to maintain adaptable compliance strategies that can accommodate varying requirements.

Industry-specific considerations add another layer of complexity. For example, aerospace and firefighting facilities face unique requirements regarding AFFF usage, while food packaging manufacturers must comply with specific FDA guidelines. Employers must stay informed about both broad PFAS regulations and industry-specific requirements to maintain compliance.

The Critical Role of SDS Management in PFAS Compliance

Traditional Safety Data Sheet (SDS) management methods, such as paper filing systems or basic spreadsheets, are inadequate for managing PFAS compliance. These outdated approaches lack the sophistication needed to track complex chemical families, and cross-reference regulatory lists.

Digital SDS management revolutionizes PFAS identification and tracking. M3V’s Chemical Management Navigator enables users to:

• Instantly search for PFAS-containing materials across their entire chemical inventory
• Automatically flag new products containing PFAS or PFAS precursors
• Generate regulatory compliance reports with a few clicks
• Access up-to-date chemical information from any location

Key PFAS information in Safety Data Sheets can be subtle and easy to miss without proper tools. Digital systems help identify PFAS through:

• Chemical name and synonym recognition
• CAS number identification
• Composition analysis
• Regulatory references

Best Practices for PFAS Management

Effective PFAS management requires a comprehensive approach:

• Digital Inventory Management
  • Maintain real-time inventory updates
  • Enable quick identification of PFAS-containing materials
• Systematic Screening
  • Establish clear protocols for new chemical evaluation
  • Implement approval processes for PFAS-containing materials
  • Regular review of existing inventory
• Staff Training
  • Provide regular updates on PFAS regulations
  • Train on proper handling and disposal procedures
  • Ensure emergency planning response
• Phase-Out Strategy Development
  • Identify PFAS alternatives
  • Create timeline-based replacement plans
  • Monitor new technologies and solutions

Leveraging Technology for PFAS Compliance

M3V’s Chemical Management Navigator provides essential tools for PFAS compliance:

• Automated PFAS tracking and reporting
• Real-time access to chemical information
• Emergency response support
• Integration capabilities with existing systems
• Custom reporting features for regulatory submissions

Managing PFAS compliance requires a sophisticated approach combining robust digital tools, comprehensive procedures, and ongoing vigilance. As regulatory requirements continue to evolve, businesses must stay ahead of compliance demands through proper chemical management practices and technology adoption.

M3V Data Management provides the tools and support needed to navigate the complex landscape of PFAS compliance. Our system helps businesses maintain compliance, protect workers, and prepare for future regulatory changes.

Compliance is serious business but it doesn’t need to be expensive or complicated.

Sources:

• https://www.epa.gov/pfas/pfas-explained 
• https://www.tdi.texas.gov/tips/safety/forever-chemicals.html#:~:text=PFAS%2C%20an%20abbreviation%20for%20per,form%2C%20and%20my%20 industrial%20 processes. 
• https://www.cdc.gov/niosh/pfas/about/index.html