On November 10, 2025, the United States Environmental Protection Agency (US EPA) released a pre-publication notice regarding the proposed changes to the Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Rule Under the Toxic Substances Control Act (TSCA) [TSCA section 8(a)(7)]. The proposed changes seek to preserve essential PFAS data collection, while adding certain exemptions to ease compliance for companies. Read the US EPA press release here. Major proposed changes are summarized in Table 1 below.
Table 1 Proposed Changes to the PFAS Reporting Rule Under TSCA
Notes: CAS = Chemical Abstracts Service; CDX = Central Data Exchange; No. = Number; PFAS = Perfluoroalkyl and Polyfluoroalkyl Substances; TSCA = Toxic Substances Control Act; US EPA = United States Environmental Protection Agency.
Once the proposed rule is published in the Federal Register, US EPA will seek public comments on the proposed changes for 45 days in docket #EPA-HQ-OPPT-2020-0549.
Next Steps:
1. Stakeholders are encouraged to provide comments to US EPA on the proposed rule.
2. Companies should evaluate the potential implications of the proposed rule to their portfolio and get ready for reporting by summer of 2026.
Contact Gradient scientists for support on PFAS reporting under TSCA and for US states, including Minnesota and New Mexico.
Contacts:
Gradient Principal Scientist Dr. Isaac Mohar will be presenting at the Pharma Ed Resources, Inc. Extractables & Leachables West 2025 Summit, November 4-5, 2025 in La Jolla, CA.
“An Overview of Polyfluoroalkyl Substance (PFAS) Toxicology, Regulation, and Biocompatibility.” I. Mohar
Gradient Principal Scientist Chris DesAutels will be presenting on a panel at the A&WMA Lake Michigan States Section 2025 Annual Air Conference in Oakbrook Terrace, IL on October 21, 2025.
Gradient is pleased to announce the latest addition to our team of toxicologists, Dr. Rachel Rogers. Dr. Rogers is an experienced environmental health scientist and manager, providing scientific and technical expertise on a range of issues, including chemical safety, exposure and risk assessment, toxicology, epidemiology, and risk management of per- and polyfluoroalkyl substances (PFAS) and other environmental chemicals. Dr. Rogers served most recently as the subject matter expert on PFAS for the Agency for Toxic Substances and Disease Registry/National Center for Environmental Health (ATSDR/NCEH), and was a senior advisor for chemical safety for the Council on Environmental Quality (CEQ) within the Executive Office of the President under the Biden administration. Dr. Rogers has an M.A. in environmental studies from Brown University, and a Ph.D. in toxicology from the University of Georgia.
Sample publications by Rachel Rogers:
“National Emerging Contaminants Research Initiative Implementation Plan.” 2024. A Report by the Joint Subcommittee on Environment, Innovation, and Public Health Contaminants of Emerging Concern Strategy Team of the National Science and Technology Council. Strategy Team Member.
Lynch, M; Lay, C; Sokolinski, S; Antezana, A; Ghio, C; Chiu, W; Rogers, R. 2023. “Community-facing toxicokinetic models to estimate PFAS serum levels based on life history and drinking water exposures.” Environ. Int.
“Per- and Polyfluoroalkyl Substances Report to Congress.” 2023. A Report by the Joint Subcommittee on Environment, Innovation, and Public Health, PFAS Strategy Team of the National Science and Technology Council. Technical Writing Team Member for Epidemiology and Environmental Justice.
Chiu, W; Lynch, M; Lay, C; Antezana, A; Rogers, R. 2022. “Bayesian estimation of human toxicokinetics of PFOA, PFOS, PFHxS, and PFNA from studies of contaminated drinking water.” Environ. Health Perspect.
LaKind, J; Verner, M; Rogers, R; Goeden, H; Naiman, D; Marchitti, S; Lehmann, G; Hines, E; Fenton, S. 2022. “Current breast milk PFAS levels in the US and Canada: After all this time why don’t we know more?” Environ. Health Perspect.
Rogers, R; Breysse, P; Reh, C. 2021. “Advancing per- and polyfluoroalkyl substances (PFAS) research: An overview of ATSDR and NCEH activities and recommendations.” J. Expos. Sci. Environ. Epidemiol.
The addition of Dr. Rogers to our team strengthens Gradient’s robust capabilities in human toxicology, environmental risk, exposure assessment, and epidemiology. Learn more about our Risk Sciences here.
Please join us in welcoming Rachel Rogers.
Gradient is presenting at the Society for Chemical Hazard Communication (SCHC) 2025 Annual Meeting, taking place September 23-25, 2025 in Washington, DC.
Gradient environmental engineer and GIS specialist Naomi Slagowski will be presenting on a panel at the Brownfield Coalition of the Northeast (BCONE) Northeast Sustainable Communities Workshop (NSCW) 2025 taking place September 17-18, 2025 in Schenectady, NY.
Gradient Senior Environmental Scientist Dr. Qian Zhang will be presenting at the 2025 American Center for Life Cycle Assessment (ACLCA) Conference taking place September 16-19, 2025 in Atlanta, GA.
Gradient is presenting at EUROTOX 2025, taking place September 14-17, 2025 in Athens, Greece.
In this issue of Trends, we provide several articles on the topic of food and beverages as it relates to chemical exposure and human health.
Our first article discusses nutritional epidemiology and its role in understanding the risks and benefits of food. The second article explores chemicals in food packaging and test methods to assess their potential migration. The third article takes a closer look at food warning labels and related regulations, and our fourth article provides an overview of recent efforts by the United States Food and Drug Administration (US FDA) to make changes to food safety standards.
Gradient contributors to this Trends issue include Drs. Julie Goodman, Denali Boon, Caroline Tuit, and Steven Boomhower, and Ari Lewis, M.S.
Articles:
Gradient is presenting at North American Biocompatibility Summit (NABS) 2025, taking place in Minneapolis, Minnesota on September 10, 2025.