Your supplier won't answer the PFAS question. Now what?

First: silence doesn’t excuse you, but it doesn’t doom you either

Minnesota’s standard (Minn. R. 7026.0080) says you must pursue supply-chain information until it is known— stricter on paper than the federal “reasonably ascertainable” standard. But the same rulebook, and MPCA’s published guidance, anticipate incomplete answers: you report what you’ve obtained by the deadline, keep asking, update by the next February 1, and keep documentation of your efforts (five-year retention). MPCA staff may review that documentation — it is literally the compliance artifact.

The three “unknown” options built into PRISM

• Supplier says “there’s PFAS” but won’t name it: select “PFAS Present but unknown at this time” in the chemical list.
• Chemical known, amount unknown: select “Unknown” in the concentration-range dropdown.
• Function unknown: select “Function unknown at this time”.

Each one is legitimate onlywhile you can show continued efforts to resolve it. An “unknown” with a five-email paper trail is compliance; an “unknown” with nothing behind it is a finding waiting to happen.

When testing beats asking

If a supplier claims trade secrecy or has vanished, Minnesota explicitly allows total organic fluorine (TOF) testing in lieu of unknown chemical identity: report identifier type TOF, name TOF, and the tested result in the concentration ranges. US labs run TOF panels in the low hundreds of dollars per sample. One more trick from MPCA’s guide: a secretive supplier can report their component on your behalf in PRISM, keeping the chemistry confidential from you entirely.

An escalation ladder that actually gets responses

1. Week 0: a specific ask — product, component, the state law compelling you, a reply-by date, and a simple form (not a 40-tab spreadsheet).
2. Week 1–2: reminder with the deadline restated.
3. Week 3: escalate to your commercial contact — the buyer relationship, not the compliance inbox, is your leverage.
4. Week 4+: phone call, logged; then decide: TOF test, supplier-direct PRISM reporting, or file with a documented unknown.

Every step, dated and saved, is your due-diligence record. (This ladder — sending, chasing, logging, and turning answers into filings — is the workflow PFAS Matrix automates.)

What good documentation looks like

• Dated copies of every request and reminder, per supplier, per component.
• Responses (including refusals — a refusal is evidence of effort).
• Notes of calls and commercial escalations.
• Test orders and results, where you went that route.
• A dated decision note: why you filed what you filed.