Missing from the Record: A Quantitative Examination of PFAS Underreporting in EPA Data
The Toxics Release Inventory (TRI) is a public database from the Environmental Protection Agency (EPA) that tracks toxic chemical releases by industrial sites across the United States, with facilities required by law to report their emissions.
This system helps communities understand the pollution in their environment. Among these chemicals are PFAS—“forever chemicals” that don’t break down and accumulate in the body and the environment. Exposure to PFAS has been linked to serious health problems like cancer and immune system issues.
When facilities underreport PFAS releases, it hides the true risks from communities, making it harder for people to protect their health and environment.
Background
Every year, EPA releases waste manifest records under the Resource Conservation and Recovery Act (RCRA), a federal law governing the management and disposal of hazardous waste. Both these records and the TRI include data related to PFAS waste.
In 2022, by cross-referencing these datasets, I aimed to identify whether facilities had underreported their PFAS releases to the TRI.
Project Outputs
Identifying corporations potentially violating reporting laws and sending formal letters outlining findings, supported by detailed exhibits.
Methodology
I used Microsoft Access and SQL to sort through and compare data between the TRI and RCRA manifest records.
Team
Eve Gartner, Earthjustice, Attorney
Sonya Lunder, Sierra Club, Senior Toxics Advisor
Denise Trabbic-Pointer, Sierra Club, Volunteer/TRI Technical Expert
Timeframe
March 2022 - August 2022

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It all begins with an idea. Maybe you want to launch a business. Maybe you want to turn a hobby into something more. Or maybe you have a creative project to share with the world. Whatever it is, the way you tell your story online can make all the difference.
Make it stand out.
It all begins with an idea. Maybe you want to launch a business. Maybe you want to turn a hobby into something more. Or maybe you have a creative project to share with the world. Whatever it is, the way you tell your story online can make all the difference.