July 1, a date marking the end of regulatory reporting season, is almost here. But before EHS managers get a much-needed break from the deadlines, they need to ensure all required reports are completed, which includes the Toxics Release Inventory (TRI) mandated by the EPA. Like the Tier II report, the TRI reporting requirements were implemented in an effort to make the public aware of hazardous chemicals present in their communities. Are you prepared to complete and file your report by the deadline?
Facilities must report release and other waste management information pursuant to EPCRA Section 313 if they:
Under the regulation, “manufacture” means to produce, prepare, compound, or import an EPCRA Section 313 chemical. The reporting threshold is 25,000 pounds. “Process” is the preparation of a TRI-listed chemical (after its manufacture) for distribution in commerce. The reporting threshold is 25,000 pounds. “Otherwise use” refers to any use of the TRI-listed chemical that is not otherwise manufacturing, processing, or storage. This reporting threshold is 10,000 pounds.
You must review the reportable chemical list to check whether your facility is using any of the materials that are Persistent Bioaccumulative Toxic (PBT) chemicals. Within the regulations, there are two separate thresholds for PBT chemicals. The reporting thresholds are set based on the chemical’s potential to persist and bioaccumulate in the environment. The 'manufacturing, processing, and otherwise using' threshold for PBT chemicals is 100 pounds, while for the subset of PBT chemicals that are highly persistent and highly bioaccumulative, it is 10 pounds. One exception is the dioxin and dioxin-like compounds chemical category. The threshold for this category is only 0.1 gram.
On April 29, 2021, the EPA announced that it will be “taking important steps under the Toxics Release Inventory (TRI) to advance Environmental Justice, improve transparency, and increase access to environmental information." The EPA intends to broaden the scope of TRI reporting requirements to cover more chemicals and facilities, including those that do not presently report on ethylene oxide (EtO) emissions, as well as providing new tools to make TRI data more available to the public. This significant change will also include adding natural gas processing facilities to the list of covered industry sectors, and adding TSCA high-priority substances and more PFAS to TRI. We'll keep you posted on the timing of the changes.
A few of the most common issues people face regarding annual TRI reporting are as follows:
Don’t wait until the last minute to complete your TRI report. To ensure compliance, you’ll need to review your entire chemical inventory and then how you use and dispose of these regulated materials. We can help. Click the button below to request a TRI reporting consultation.