2019 Toxics Release Inventory (TRI) Reports Due July 1

May 22, 2019

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2019 Updates for TRI Reporting | Due by July 1 2019

The United States Environmental Protection Agency (USEPA) requires facilities to submit Toxics Release Inventory (TRI) reports by July 1 each year. If you are unsure whether your facility meets the reporting criteria, unaware of the steps required to report to the TRI Program, or need a refresher regarding what changes have been made to the program, we have provided some helpful information to help with your self-evaluation so your facility is prepared for the deadline.

2019 TRI Developments & Changes

As in previous years, there are to be expected changes in the TRI reporting program from year to year. For reporting year (RY) 2018, there are four specific developments that should be considered by facilities beginning to prepare their forms.

  1. The RY 2018 TRI Reporting Forms and Instructions (RFI) are currently available for facilities to use as a resource and reference to properly prepare the TRI reports;
  2. The USEPA added a nonylphenol ethoxylates (NPEs) category to the TRI Program in 2018. Facilities that meet the NPEs threshold must have the 2019 RY TRI report submitted for these by July 1, 2020;
  3. The TRI Program made several updates to their Information Collection Request (ICR) reporting forms; and
  4. An update has been made to the minimum threshold for Tetrachlorvinphos (TCVP), from 1.0% to 0.1%.

For information on specific developments, such as the ICR updates, clicking on the hyperlinks will bring you to the specific USEPA web pages that provide program developments and changes.

Created as part of the Emergency Planning and Community Right-to-Know Act (EPCRA), the TRI Program is a resource that allows the USEPA to collect data on the ways in which both industrial and federal facilities have managed toxic chemicals that may pose a threat to the health of both humans and the environment. Under the TRI Program, facilities releasing TRI-listed chemicals to the environment-whether through emission by air or water, or disposal into the land-must report how much of each chemical was released and how they were managed through various methods, from recycling to environmental treatment.

The collection of TRI reports by the USEPA provide information that is used to produce an informative, data-driven resource to help local communities and federal governments develop environmental policies, promote the use of TRI data, and inform the public about possible exposure to TRI chemicals.

There are three specific factors that will dictate whether or not a facility will be required to submit a TRI report to the USEPA. A facility must meet allthree reporting criteria, which include:

  1. Is the facility in a specific industry sector, including electric power generation, manufacturing, mining, etc.;
  2. Does the facility employ 10 or more full-time employees, or any equivalent employees; and
  3. Does the facility manufacture, process or otherwise use a TRI-listed chemical above the annually allotted threshold in a calendar year.

 

Any company that meets all three reporting criteria must submit a TRI Form R for each TRI-listed chemical that is manufactured, processed or used, above the threshold.

For those facilities that have met all three of the TRI reporting criteria and are aware of the updates for RY 2018 reporting, there are four basic steps that must be followed to ensure that all of your documents are prepared and ready to submit.

  1. Collect information on all TRI-listed chemicals manufactured, processed or otherwise used within your facility during the previous calendar year;
  2. Register your facility's Central Data Exchange (CDX) account and begin preparing your facility's TRI data through the CDX-based TRI-MEweb application;
  3. Be sure that the facility's TRI form(s) are certified when they are ready for submission to the USEPA.
  4. Look at your facility's TRI data via the online TRI tools and stay in communication with other facilities within your sector.

 

If you require other information on TRI Reporting and how it might pertain to your facility, you can research the USEPA's updated TRI Reporting webpage. If you have unanswered questions or would simply like to talk with a knowledgeable representative about the reporting process, please reach out and contact one of our expert team members. At GeoInsight, we're here to help you ensure that your company successfully complies with the required reporting.

 

State specific resources:

Here are some links to New England's state specific TRI programs:

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Not sure if the TRI requirements apply to your facility?  Have another question?

Let us help!

It can be difficult evaluating whether your facility must submit a TRI report and file correctly. If you get stuck or have a question, one of GeoInsight's compliance specialists would be happy to help!

For more information contact us:

 

Suzanne Pisano, Compliance Director

Contact Suzanne Pisano

slpisano@geoinc.com | 978.679.1600

 

Tim Kipp, Senior Associate/Compliance Project Manager

Contact Tim Kipp

twkipp@geoinc.com | 860.894.1002