By Neno Duplan, Founder & CEO, Locus Technologies
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TL;DR
On February 23, 2026, the EPA finalized a rule adding sodium perfluorohexanesulfonate (PFHxS-Na) to the Toxics Release Inventory — bringing the total number of PFAS substances tracked under TRI to 206. For anyone not watching this space closely, that number might not seem significant. But if you’re responsible for environmental compliance at a facility that manufactures, processes, or otherwise uses PFAS chemicals, it’s a signal you can’t afford to ignore.
The more important story isn’t any single chemical addition. It’s the structural reality behind it: under the 2020 National Defense Authorization Act, EPA is required to add new PFAS compounds to TRI automatically, every year. This isn’t a regulatory trend that might plateau. It’s a compliance obligation that is legally mandated to keep growing. The question for environmental managers isn’t whether their PFAS reporting burden will increase; it’s whether their systems are built to handle a moving target.
The Treadmill Problem
Most environmental data management and compliance programs were designed for a relatively stable regulatory landscape. You build your reporting workflows, you configure your thresholds, and you run your annual TRI submissions. That model worked reasonably well when the list of regulated substances changed slowly and predictably.
PFAS has fundamentally changed that calculus. PFHxS-Na, the compound added this week, is subject to a 100-pound reporting threshold (lower than many conventional TRI chemicals) because it’s classified as a chemical of special concern. That lower threshold means facilities need finer-grained data about chemical use and releases than they may be accustomed to collecting. And with the next PFAS addition already on its way, facilities that are manually rebuilding their tracking workflows each year are on a treadmill with no off switch.
The organizations that will handle this well are those that have moved beyond compliance-as-event and adopted compliance-as-infrastructure. The difference isn’t ambition; it’s architecture.
PFAS Is Not a Single Problem
Part of what makes PFAS compliance so demanding is that it doesn’t live in a single environmental medium. TRI reporting captures releases to air, water, and land. But PFAS contamination, and the regulatory scrutiny that follows it, cuts across groundwater monitoring, soil assessment, wastewater discharge, stormwater management, and remediation programs simultaneously. A facility might be managing PFAS in its discharge permit, its groundwater monitoring wells, its air emissions inventory, and its TRI report all at once, each with different agencies, different thresholds, and different timelines.
This is precisely the operational gap Locus EIM is designed to close. PFAS management requires more than tracking individual data streams — it demands an integrated environmental information architecture where air, water, soil, waste, and remediation data are structured within a unified, cross-media data model. When groundwater analytical results, discharge monitoring reports, air emissions inventories, and TRI submissions reside in a single, defensible system of record, organizations gain traceability from raw lab data through final regulatory submission.
This cross-media reality is exactly where siloed environmental tools break down. When your air data lives in one system, your groundwater data in another, and your waste manifests in a third, PFAS becomes nearly impossible to manage holistically. You can’t see the full picture, and you can’t respond quickly when requirements change — which, as we’ve established, they will.
What We’ve Learned from 4 Million PFAS Records
First, PFAS detection is both industry-agnostic and location-agnostic. These compounds are not confined to a narrow sector or geography; they are being identified in manufacturing, utilities, airports, landfills, wastewater treatment plants, military installations, nuclear weapons sites, and commercial facilities alike — across urban, rural, coastal, and inland environments. The ubiquity of PFAS means virtually any organization with environmental exposure may face regulatory scrutiny, regardless of its core business model. At Locus, we’re currently tracking more than 4 million PFAS records across our customer base. That’s not a marketing statistic. It’s a reflection of the actual complexity these organizations are managing, and it’s given us direct experience with what works and what doesn’t in PFAS data management at scale.
A few things become clear at that scale.
- First, the data diversity is enormous: PFAS compounds appear across sampling types, concentration units, detection limits, laboratory methods, and regulatory frameworks that don’t always map cleanly onto each other.
- Second, the data volume grows faster than most organizations anticipate, especially as monitoring requirements expand and detection capabilities improve.
- Third, the organizations managing this well share a common trait: their environmental data and compliance platform was built to be configured, not just installed.
Built for a World That Doesn’t Stand Still
The architectural principles that matter most in this environment aren’t the ones that tend to dominate software marketing conversations. They’re less glamorous but far more consequential:
Metadata-driven design means that when a new PFAS compound enters TRI (or any other regulatory list) it can be added to the system and associated with the correct thresholds, reporting rules, and workflows without a software development cycle. The platform adapts because its structure is defined by configuration, not code.
True unification across environmental media means that the same compound can be tracked through its entire environmental footprint — from air emissions to a stormwater sample to a monitoring well — within a single platform, against a single data model. This is the only way to understand cumulative PFAS exposure and respond coherently to regulators who are increasingly asking cross-media questions.
Multitenant cloud architecture means that regulatory updates, new chemical definitions, and evolving reporting requirements can be deployed across the entire customer base simultaneously. Every organization using the platform benefits immediately when the system is updated. There’s no lag waiting for an on-premise upgrade cycle while the regulatory calendar keeps moving.
These aren’t abstract technical attributes. In a regulatory environment built to keep expanding, they are the practical difference between a compliance program that keeps pace and one that perpetually scrambles to catch up.
Transparency Is the Direction of Travel
EPA’s framing of this latest TRI addition is worth noting. The agency explicitly described it as a matter of community right-to-know — the public’s ability to see what chemicals are being used and released in their neighborhoods. That framing reflects a broader shift in how environmental performance is evaluated, not just by regulators but by investors, insurers, lenders, and communities.
PFAS is increasingly a disclosed liability in ESG filings, a question on environmental due diligence checklists, and a driver of reputational risk that extends well beyond the permit. Organizations that treat their environmental data as a compliance artifact (something produced once a year and filed) are going to find that posture increasingly is increasingly problematic. The organizations that will navigate this environment well are those that treat environmental data as an operational asset: accurate, continuous, auditable, and accessible.
What to Do Now
The first TRI report for PFHxS-Na isn’t due until July 2027. That window is an opportunity, not a grace period. Facilities that use it to build the data infrastructure they’ll need (and that’s the right mental model, “infrastructure”, not a workaround) will be in a fundamentally different position than those that start assembling records manually in the spring of 2027.
The questions worth asking now are straightforward:
- Do we have a system that can track PFAS use and releases at the granularity that a 100-pound threshold demands?
- Can we trace PFAS across environmental media within a single software platform that will be around 10 years from now?
- When the next compound is added to TRI (and it will be) how long will it take us to incorporate it into our reporting workflow?
If the answer to any of those questions is uncertain, the time to address it is now, while the calendar is on your side.
Neno Duplan is the Founder and CEO of Locus Technologies, a provider of cloud-based environmental compliance and data management software. Locus serves some of the world’s largest industrial organizations and currently manages more than 4 million PFAS records across its platform – a figure that grows daily.
Locus is the only self-funded water, air, soil, biological, energy, and waste EHS software company that is still owned and managed by its founder. The brightest minds in environmental science, embodied carbon, CO2 emissions, refrigerants, and PFAS hang their hats at Locus, and they’ve helped us to become a market leader in EHS software. Every client-facing employee at Locus has an advanced degree in science or professional EHS experience, and they incubate new ideas every day – such as how machine learning, AI, blockchain, and the Internet of Things will up the ante for EHS software, ESG, and sustainability.
