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Toxic Release Inventory (TRI) Reporting

Toxics Release Inventory (TRI) Program

tox report, tri reporting guidance

What is TRI?

The Toxic Release Inventory (TRI) is a resource for learning about toxic chemical releases and pollution prevention activities reported by industrial and federal facilities. Toxic Release Inventory data support informed decision-making by communities, government agencies, companies, and others. Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) created the TRI Program.

The deadline to file a facility TRI report with the State and Local Environmental Agencies is July 1 each year and, if not filed on time, it could subject you to enforcement actions including significant penalties.  

TRI Reporting Criteria

If a facility meets all three of the criteria below, it must report to the TRI Program.

  • Is in a specific industry sector (e.g., manufacturing, mining, electric power generation). Note that federal facilities must report regardless of industry sector if they meet the other two criteria.
  • Employs 10 or more full-time equivalent employees
  • Manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above threshold levels in a given year. Note that Persistent Bioaccumulative Toxic chemicals (PBTs) have lower thresholds than other TRI chemicals.

What type of data reported by facilities?

Industrial facilities report toxic release inventory data about how they are managing chemical waste through:

  • Recycling
  • Energy recovery
  • Treatment
  • Disposal
  • Environmental releases

Additionally, facilities tell EPA about how they are reducing the amount of chemical waste that enters the environment and/or how they are preventing waste from being created in the first place.

TRI Reporting, by Federal and State regulations, requires that facilities annually report the manufacturing, processing, or otherwise use of toxic chemicals in excess of reporting thresholds. TRI Form R Reporting thresholds are typically 25,000 pounds (for manufacture or processing), 10,000 pounds (for other use), or even significantly lower thresholds for particularly toxic chemicals. For certain toxic chemicals, identified as PBT chemicals (persistent bio accumulative toxic chemicals), the TRI Reporting threshold can be much lower, such as 100 pounds for lead and 10 pounds for mercury.

TRI Reporting, as laid out in the Federal EPCRA regulations (Emergency Planning and Cleanup Responsibility Act, otherwise known as SARA – the Superfund Amendments and Reauthorization Act), Section 313, require annual tox report of toxic chemicals and their releases to the environment be made to the Federal government and also to State and local agencies. It is important to note that TRI Reporting is different reporting than SARA Tier II Reporting, with different chemicals, reporting criteria, deadlines, tri reporting guidance, and reporting processes. Doing TRI Reporting does not eliminate the need for other reporting. And, failure to perform this required annual TRI Reporting may carry significant penalties.

How can we help?

RSB Environmental is a full-service environmental consulting firm, specializing in turnkey environmental solutions and environmental compliance. Our knowledge and experience allows us to execute efficiently and cost-effectively.

RSB Environmental is the leading expert in TRI Reporting requirements in Texas. We can evaluate the applicability of TRI Form R Reporting requirements for each facility, and lead you through the reporting every step of the way. If TRI Reporting is necessary, we can analyze your potential for release pathways, and provide sound estimates of your releases. Should it be necessary, we also have a proven track record of using the USEPA Audit Policy in order to minimize your liability if it’s found that your TRI Reporting record is incomplete or lacking.

Whatever you may need regarding Hazardous Materials Reporting, RSB Environmental can help you comply (starting at $1500) with these TRI Reporting requirements to stay in compliance and out of trouble.

Let RSB Engineers help you comply with these requirement. We are certified Professional Engineers. If you desire to meet and discuss more about how we can help or you want to receive a proposal, please do not hesitate to contact me at 1-800-304-6517, or by email to info@rsbenv.com.

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