Reminder: Toxic release inventory deadline was July 1st. Did you get your submission in?

(This article was written without AI tools, i.e., ChatGPT.)

Toxic Release Inventory (TRI) reporting was due July 1st. Did you get your submission in? If not, as we say here in Texas, “Put a little giddy-up in your step.”

Being proactive is important because preparing the report can be time-consuming and somewhat confusing. Reporting complexity depends on how many regulated chemicals you have on-site or where they are found in the process, e.g., tank/valve fugitive emissions, loss through cooling, etc.

What is TRI Reporting?

TRI reporting provides data for a publicly available database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. TRI reporting was established under the Emergency Planning and Community Right to Know Act of 1986 (EPCRA) and was expanded by the Pollution Prevention Act of 1990 (PPA).  (Click here for full history.)

Why do we have this rule?

Knowing the history behind certain regulations can help you better understand their importance.

On December 4, 1984, a cloud of extremely toxic methyl isocyanate gas escaped from a Union Carbide Chemical plant in Bhopal, India. Thousands of people died that night in what is widely considered to be the worst industrial disaster in history. Thousands more died later as a result of their exposure, and survivors continue to suffer with permanent disabilities. In 1985, a serious chemical release occurred at a similar plant in West Virginia. (Read more here in an earlier article.)

TRI requires facilities in certain industries that manufacture, process, or use significant amounts of toxic chemicals to report their releases of these chemicals annually. The reports contain information about the types and amounts of toxic chemicals that are released each year: into the air, water, land, and by underground injection. The report also includes information on the quantities of toxic chemicals sent to other facilities for further waste management.

For the TRI home page, click here.

Under TRI, facilities that meet the employee threshold, possess quantities of regulated chemicals, and fall under a regulated industry sector must:

• Submit a TRI Form R (long form) for each TRI-listed chemical manufactured, processed, or otherwise used in quantities above the reporting threshold. *, **, ***
• Submit each TRI form to both the Environmental Protection Agency (EPA) and the state in which the facility is located (or to the appropriate tribe, if located in Indian country).

*Regulated Industries

**Regulated Chemicals and Reporting Thresholds

***Employs 10 or more full-time equivalent employees

To read more on what facilities that meet TRI criteria must do, click here.

Special Considerations/Notes:

• Federal facilities are required to report if they meet the employee and chemical use thresholds, regardless of their industry sector.
• Persistent, Bioaccumulative Toxic chemicals (PBTs) have lower reporting thresholds.
• Facilities may be eligible to submit a shorter version of a TRI form (Form A) if all three (3) of these criteria are met: 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 lbs. The total annual waste management (e.g., recycling, energy recovery, treatment, and disposal or other releases) of the chemical does not exceed 500 lbs.

Ready to report? click here.

Tank operators can find a tool for helping to calculate emissions here: TANKS Emissions Estimation Software, Version 4.09D (Be sure to read the disclaimer on the website).

For a complete listing of archived articles and compliance insights, click here. Past articles cover training requirements, clarification of additional unclear elements within the above rules, and more.

We are here to help solve your compliance questions and challenges. If you need compliance assistance or have questions, please email John K. Carroll III (jcarroll@wittobriens.com), Associate Managing Director – Compliance Services, or call +1 954-625-9373.

Witt O’Brien’s:

• To learn more about Witt O’Brien’s breadth of regulatory compliance and emergency management services, please visit our website.
• Follow Witt O’Brien’s on LinkedIn to stay informed on important updates.
• Witt O’Brien’s is now part of the Ambipar Response Group (NYSE: AMBI)

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