Understanding the EPA Toxic Release Inventory (TRI) Reporting

What is EPA TRI reporting? TRI reporting refers to the Toxics Release Inventory program managed by the US EPA. Companies that deal with the chemicals on the toxics list will need to report them in their inventory, as well as report whether there are spills (even if/when those spills are appropriately managed).

The ultimate goal of EPA TRI reporting is to ensure that all local agencies are well aware of the potential dangers around them. Should a spill or hazard occur, people in the vicinity will be aware that they might be exposed to a dangerous chemical. If there’s an issue such as fire, earthquake, or other disruption, a local agency (such as firefighters or police) will also be aware there may be hazardous chemicals on-site.

EPA TRI reporting concerns the chemicals on the EPA TRI Chemical List/TRI Chemical List 2020, which is updated periodically. Some examples include carcinogens, Persistent Bioaccumulative Toxic chemicals, and chemicals that are toxic to the environment. These are compounds that need to be controlled because they can potentially cause disaster if they are released into the environment or if people or animals are exposed.

Any company that manages these types of chemicals will need to report to the EPA. The TRI reports are due once a year in July and provide a complete chemical inventory. Companies might experience different requirements depending on the number of chemicals they have, the hazardousness of the chemicals, and how that chemical has been assessed on the TRI chemical list.

Because the TRI chemical list does change, it’s important that companies stay up-to-date on their information. National reporting and local reporting processes may also change, such as whether documents are accepted through a given digital platform.

For companies interested in learning more, there is the EPA Enforcement and Compliance History Online website and the site’s associated EPA ECHO Database. ECHO can be used for data downloads, facility searches, and EPA Case Search enforcement for information regarding violations. The EPA Envirofacts website/database also provides reporting help.

EPA CDX

The EPA CDX (Central Data Exchange) supplements EPA reporting systems by performing new and existing functions for TRI reporting. Businesses can acquire an EPA CDX login and connect with the EPA CDX Help Desk if they have any questions regarding the process.

This is also connected to EPA NetDMR; the EPA Network Discharge Monitoring Report. Both CDX and NetDMR work together for TRI reporting. A NetDMR login should also be managed.

Your NetDMR CDX login accounts can be used to connect to and process information for the EPA reporting system. You can use your NetDMR login to acquire information or help online. The NetDMR CDX login has a streamlined data registration path, which makes it easier to connect. Once you have your NetDMR CDX accounts, you can submit your reporting online rather than having to send reports in manually.

The easier the process of reporting is, the more likely it is that it will be done correctly.

TRI Reporting Thresholds

TRI reporting thresholds vary based on the chemicals. The EPA TRI Chemical List, which is updated periodically, shows the reporting thresholds for a given chemical. You do not need to report if you’re below EPA TRI reporting thresholds.

These thresholds are important because they determine the point at which a chemical can become a public concern. Because the chemical list is periodically updated, however, it can be difficult for an organization to keep track of the chemicals they need to report.

EPA reporting software and solutions can make it easier for companies to track exactly which chemicals they have, what the reporting standards are, and when they need to report. Furthermore, they can generate TRI reports for the organization so those reports can be properly sent in.

TRI Reporting Deadline

The TRI reporting deadline is an annual deadline with the TRI reporting due date set at July 1 of each year. EPA Enforcement 2020 includes a clear list of TRI reporting requirements; failure to meet these requirements includes violations and potential penalties.

Most companies will take weeks or months to put together their TRI reports so they are done on time. It’s incredibly important that these documents be recorded by July 1. Companies can make the process easier by automating, optimizing, and improving upon their chemical inventory.

Civil and administrative penalties for not meeting the TRI reporting deadline can vary based on the severity of the penalty and the size of the company. But companies can be liable for up to $25,000 for each violation and there may be multiple violations.

Furthermore, each day that a violation continues is a separate violation. So this can accrue quite considerably if the violation isn’t addressed quickly. Companies need to track their chemical inventory as consistently and correctly as possible to avoid accruing significant fines and experiencing substantial financial damage.

TRI Reporting Forms and Instructions

There are a number of TRI reporting forms and instructions. The EPA Form R/Tri Form R must be listed for each TRI chemical that is produced or processed above the given reporting threshold. As mentioned on the EPA Form R instructions, the TRI facility ID must also be added on this paperwork.

The TRI Form A is a simplified reporting form that can be easier to fill out and read.

TRI Form A can be used for chemicals that are not PBT chemicals, that are under 1,000,000 pounds, and that the total reportable amount doesn’t exceed 500 pounds. When you can, it’s generally better to complete the Form A rather than the Form R, because the Form A can be completed in a fraction of the time.

There are instructions for the process of TRI reporting attached to every form, but often experts within regulatory standards will be the ones who are responsible for filling out these documents. Otherwise, companies that specialize in TRI reporting can help.

TRI-MEweb

TRI-MEweb is an online app, used with a given EPA account, that makes it possible to go through an electronic submission process for TRI reporting. The EPA account is connected to the central data exchange (CDX) but is also a TRI-MEweb user requirement. You will need your EPA account and EPA TRI reporting login to complete your Tri-Me Web registration.

With your TRI-MEweb login, you can file your documents much faster because they can be filed digitally. This also helps you track and retain proof that everything has been documented as it should be. This is one of the important methods that companies can use to reduce the amount of administrative time TRI reporting takes.

The TRI-MEweb app can also be referenced for information about how the platform works, how reporting works, and what companies should do to properly complete their reporting.

While the reporting process is initially complex, most companies should be able to design strict processes for the management of reporting and for the timely submission of forms. There are platforms that are designed to facilitate this, taking a complete inventory of each chemical and printing out the relevant forms that need to be sent in.

Companies that use or produce TRI chemicals in large quantities may even have TRI reporting systems built into their enterprise resource planning (ERP) platform or similar.

EPA Enviromapper

The EPA Enviromapper and the Toxic Release Inventory Map (EPA TRI Map) are incredible tools that make it possible to look up whether there have been disposals or releases in an area. This is part of the necessary reporting process. Individuals have a right to see what has been disposed of in their region.

The EPA TRI Map will show someone how many facilities are in an area, the total releases from all facilities, the total releases per square mile, and the rank of the state itself. Thus, individuals can compare different states in terms of the amount of chemical released within the region.

The Map can also be updated to show states, metropolitan areas, watersheds, and tribal land. These areas are separately tracked due to their fundamental importance and the uneven impact that a chemical release might have on them. Metropolitan areas would have more people impacted, whereas watersheds could impact larger regions.

Meanwhile, the EPA Enviromapper provides access to different databases of EPA environmental data. Those who are looking for more information about how the EPA TRI system works, or how they can start their EPA TRI reporting process, can go on the EPA Enviromapper site to be linked to the correct resources.

Having this information exposed online is an important part of keeping the population up-to-date on what is happening on their land. It’s also critical for environmental scientists and civil engineers who are interested in the information and who need the information to glean key insights about the environment and its health.

EPA ICIS

Companies can have individuals go through EPA TRI training to learn more about TRI reporting. There are also other tools, such as the EPA ICIS (Integrated Compliance Information System), the EPA TRI Explorer database for chemical reports, and the EPA TRI Guidance for reporting instructions.

On the EPA ICIS website, you can look for facilities registered with the EPA, perform a geographical search, or even look for the chemicals that have been reported. The EPA TRI Explorer database makes it easier to find chemicals that have been released in a specific area, for those who are interested about environmental impact. Meanwhile, EPA TRI Guidance is designed more for companies that want to learn more about the process.

It’s critical that companies learn the ins and outs of TRI reporting. TRI reporting can be made easier through the right software platform — a software platform that can help them manage their inventory of chemicals and their toxic release thresholds.

With the right training, companies can ensure that their employees have everything that they need to complete reporting on time. Not being able to report on time is grounds for significant fines and penalties — and these penalties can continue to accrue each day.

While TRI reporting is complex, it’s also essential. Organizations should already be tracking any toxic release chemicals that they have. But many companies will spend months preparing for the TRI report before the annual due date. In addition to the reporting processes, actively managing a chemical inventory can also help provide more checks, balances, and controls for ensuring that toxic chemicals are well handled.