Do You Have Chemicals that Meet TRI Form R Requirements?

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triformrAt SRP Environmental we meet clients that are surprised to discover a chemical (or its component) at their facility is hazardous and needs to be considered for annual reporting. Chemical inventory reporting is required by all facilities that meet the criteria set forth in the Emergency Planning and Community Right-To-Know Act (EPRCA) Section 313 and is regulated by theEnvironmental Protection Agency (EPA).

 

Overlooking chemicals often happen due to employee turnover, a product change, promotions within the company to new responsibilities, or expanded responsibilities that require more attention. Although growth within the business is preferred, the added responsibility can be challenging without professional consultants to help. See the TRI Form R page for a brief summary of TRI Form R requirements, criteria, and how Environmental Consultants can assist with this type of project.

 

Federal law, 40 CFR 372, identifies over 600 hazardous chemicals described as the “List of Lists”. This listing includes common metals, pure solvents, hazardous wastes, and site remediation wastes. This listing also includes components of chemicals, coolants, rust inhibitors, paints, polymers, plastics, lubricants, steel alloys, and pre-fabricated metals.

 

The “List of Lists” chemical listing is updated annually and used to determine if the chemical usage threshold is exceeded. The chemical usage threshold is 25,000 pounds for any listed chemical that is manufactured, imported, or processed at the facility on an annual basis. The chemical usage threshold is 10,000 pounds for any listed chemical otherwise used on an annual basis. There is an additional threshold requirement that is less that both the 25,000 and the 10,000 pound thresholds. This lesser reporting requirement applies to Persistent, Bio accumulative, Toxic chemicals (PBTs), which can be as little as 1 pound per year. If the chemical usage rate is exceeded for manufactured, processed, otherwise used, or PBTs, then all possible toxic releases and waste management must be consider and reported using the Toxic Release Inventory Form R Annual Report to the EPA via online electronic submission.

 

Analyzing every chemical in your facility inventory should be completed every year to ensure proper reporting and waste management required by the EPA. Relying on SRP Environmental as professional consultants to evaluate and complete this task will ensure reporting mistakes from your compliance past do not haunt your compliance future.


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