August Mack Newsletter | February, 2019

The Toxic Release Inventory (TRI): Does it Apply to Me?
by Taylor Allen

What is Form R?

Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), or Title III of the Superfund Amendments and Reauthorization Act, requires the Toxic Release Inventory (TRI), otherwise known as “Form R.” EPCRA is the same regulatory act that requires facilities to submit a Tier II report. Unlike Tier IIs, which require facilities to report the quantity of hazardous materials on-site, Form R reports require public disclosure of the releases of specific chemicals to air, land, and water. The EPA uses this information to assess the need for more regulations or for more stringent regulations on releases.

Who is required to file Form R reports?

Form R reports are required if any facility meets the following three (3) conditions:

  • Facility has 10 or more full-time employee equivalents (i.e. 20,000 hours or greater);
  • Facility’s North American Industry Classification System (NAICS) code is listed in Table 1 or is listed on the United States Environmental Protection Agency’s (US EPA) website; and
  • Facility, in a calendar year, manufactures or processes a listed chemical in an amount of 25,000 pounds or more; otherwise uses a listed chemical in an amount of 10,000 pounds or more; or manufactures, processes, or otherwise uses a persistent bioaccumulative toxic (PBT) listed chemical above the listed threshold for that chemical (PBT thresholds can range from 0.1 grams to 100 pounds).
 

However, facilities may report a shorter version of the TRI report, known as a Form A report, if all the following apply:

  • The chemical being reported is not a PBT chemical;
  • The chemical has not been manufactured, processed, or otherwise used in excess of 1,000,000 pounds; and
  • The annual waste management (e.g., recycling, energy recovery, treatment, disposal, or other releases) of the chemical does not exceed 500 pounds.
 

Both Form R and Form A reports are due by July 1st of each year documenting the waste management from January 1 to December 31 of the previous year.

Each reportable chemical or compound must be reported on a separate Form R, or, if applicable, Form A. For example, a facility could have three (3) chemicals that each require a Form R and one (1) chemical that can be filed with a Form A.

What information is contained in a Form R/Form A?

Each Form R and Form A will contain facility identification (i.e., facility name, TRI facility identification number), certification, public contact, technical contact, all applicable NAICS codes and Dun & Bradstreet Numbers, parent company information, and of course, chemical identification information (i.e., CAS number, generic chemical name, etc.).

Form Rs, however, will require additional information about each chemical, including, but not limited to: Is the chemical produced or imported? How is it used on-site? How much is stored on-site at any given time? How does the chemical leave the facility (i.e., through air emissions, landfill, wastewater, etc.)?   

How are Form R/ Form A reports filed?

Reports are filed via the EPA’s Central Data Exchange (CDX) – the federal electronic reporting program. CDX has multiple applications that are used for submitting various reports. For Form R/Form A reports, the TRI-Meweb application is utilized. A certifying official for the facility must certify and submit each individual report. A certifying official must be a senior official with management responsibility for the person (or persons) completing the form. In other words, the certifying official should be someone with authority over the environmental programs in a facility.


Taylor Allen is a Compliance Specialist with August Mack Environmental, Inc in Lewis Center, Ohio. .  Prior to her employment with August Mack, Taylor received her Bachelor's of Science in Earth System Sciences from Ohio State University. After earning her degree, Taylor worked as a research assistant and environmental educator with Nature's Classroom in Ocean Park, Maine.  During her time in Maine, she collected samples of nearby marsh and ocean water to determine levels of hazardous chemicals and pollutants and led educational activities for nearby schools. She can be reached via email at tallen@augustmack.com


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