Avoiding Trouble with TRI Reporting

Industrial facility operators are subject to a myriad of reporting requirements from state and federal government related to toxic and hazardous chemicals.

One of those important requirements is the Toxics Release Inventory (TRI) program, which was created to be a resource to provide communities with information about toxic chemical releases and pollution prevention activities reported by industrial and federal facilities.

The TRI is a key component of the Emergency Preparedness and Community-Right-to-Know Act (EPCRA) which was signed into law in 1986 following several deadly industrial disasters involving chemical releases. These days, tens of thousands of companies file TRI reports for more than 600 different chemicals each year.

Is Your Facility Subject to TRI Reporting?

Generally, any facility that manufactures, processes, or otherwise uses toxic chemicals specified under EPCRA Section 313 must submit a TRI report to the Environmental Protection Agency (EPA) each year by July 1.

There are four criteria that determine if a facility must report:

  • It is located in a “covered sector” defined by NAICS codes.
  • It employs 10 or more people full-time.
  • It works with a chemical listed on the toxics release inventory.
  • The TRI-listed chemical exceeds its threshold in a given year.

When an industrial facility meets all four criteria, it is subject to TRI reporting, which is some of the most time-consuming annual reporting that a facility will undertake.

Among other challenges, the roster of TRI-listed chemicals can change from one year to the next. That list currently includes more than 700 individual chemicals in 30 different categories.

Terminology can also be tricky. TRI reporting may be referred to as EPCRA Section 313 reporting, SARA Section 313 reporting, Form R reporting, or Form A reporting.

ONE Environmental Can Help

ONE Environmental has significant experiencing helping industrial operator clients wade through the complexity and comply with TRI reporting requirements. This includes analyzing the client’s facility to accurately determine whether a TRI report filing is required and verifying the exact federal and state environmental requirements that apply to the client’s locations.

The ONE team can also prepare and file TRI reports on a client’s behalf, thus reducing the risk of errors or omissions that can lead to penalties.

Visit the Services page on the ONE Environmental website to learn more about TRI and other types of reporting and compliance offerings that can save time and deliver peace of mind.