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Toxic Release Inventory (TRI)What is TRI? By Federal law, companies that use more than a certain minimum amount (the "threshold") of any of a long list of toxic chemicals are required to submit a Toxic Chemical Release Inventory (TRI) Form (also known as Form R). Every company in the country has the same filing deadline, July 1, covering the preceding calendar year. Forms are submitted directly to EPA, and to designated state agencies.
TRI reporting is a two-step process.
First, you need to determine whether you are required to submit a Form R. Your company is subject to reporting if it meets two criteria:
Then, for each listed chemical you use above threshold quantities, you will need to report on the Form R how much of the chemical you have "released", and where it went. In the TRI definition, "releases" include not only emitting listed chemicals into the environment, but also sending materials containing listed chemicals off-site for recycling or disposal. You are also asked to report on chemicals that you recycle internally. The purpose is to provide a picture of how you manage your waste.
- You have 10 or more full-time employees (or the equivalent 20,000 hrs/year), and
- Your facility "manufactured, processed, or otherwise used" any of the listed toxic chemicals in amounts greater than threshold quantities.
Note that there are two quantities that matter for each chemical.
- The amount of each chemical that you "manufactured, processed, or otherwise used" determines whether you are required to file a report.
- The amount of each chemical that you "released" is the amount that actually gets reported.
How to report
Getting yourself organized
If you are required to report, you should:
Designate someone at your facility to be responsible for TRI reporting. That person should obtain reporting forms and instructions and should be aware of the reporting deadline: July 1 of each year.
Develop a system for capturing the information you will need on an ongoing basis. Don't wait until June 30 to start pulling it all together. You will need to track reportable materials from the time they enter your facility until the time they leave. You will have to be able to say how much goes where in order to report your releases. You should also keep track of your source reduction and recycling activities, since there is a section on Form R to report these activities, and it provides an opportunity to put positive steps you have taken in the public record.
Maintain a well-organized record keeping system. Form Rs and any supporting information must be retained for a period of three years after the due date of the report. Supporting information should include any assumptions that you are making, and references for any background information that you have used. You should document your thought processes clearly enough that you can explain them in the future if you are ever called upon to do so. You may need to produce these records during inspections. Your records will also help you maintain an accurate and consistent approach to estimating releases in future years.
Filling out Form R
The following information is required on Form R:
Name, location, and type of business.
Off-site locations to which the facility transfers toxic chemicals in waste for recycling, energy recovery, treatment or disposal.
Whether the chemical is manufactured (including importation), processed, or otherwise used and the general categories of use of the chemical.
An estimate (in ranges) of the maximum amount of the toxic chemical present at the facility at any time during the preceding year.
The quantity of the chemical released to each medium (air, land, and water) or transferred offsite during the reporting year.
Waste treatment or disposal methods used, and the efficiency of each method for each waste stream.
Source reduction and recycling activities.
A certification by a responsible facility official that the report is complete and accurate.
You can download the current Form R and instructions from EPAs web site.
What happens to data you submit?
The purpose of the TRI reporting requirement is to inform the public and government officials about routine releases of toxic chemicals to the environment. It is also used to assist in the development of regulations, guidelines, and standards.
Reports are sent to EPA and designated state agencies. EPA records the information from the reports in the TRI database. The public, including communities living around facilities, researchers, and government officials, is able to access this database using the Internet and other means. See the Background documents section for information on sites that allow access to TRI data.
Lead and TRI Reporting. This report, prepared by the STERC staff, provides TRI compliance guidance focusing on the new lead threshold. The document will be updated as necessary.
