Facilities have less than one month to update and submit their Toxic Release Inventory (TRI)- Form R Annual Report to the Environmental Protection Agency. TRI Form R is due every year on July 1.
The Toxic Release Inventory (TRI) program is designed to compile data on toxic chemical releases and waste management activities reported annually by certain industries to support informed decision making at all levels of the industry, government, non-government organizations, and the public. Toxic chemical releases include air emissions, stormwater discharges, and waste water discharges. Waste management activities include hazardous waste disposal and non-hazardous waste disposals.
Facilities that meet all three of the following criteria are subject to EPCRA Section 313 release and other waste management reporting:
- The facility has 10 or more full-time employees;
- The facility has a primary SIC code subject to reporting requirements
- The facility manufactured (defined to include imported), processed, or otherwise used, in the course of a calendar year, any toxic chemical in quantities greater than the set thresholds.
Currently the Toxic Release Inventory contains over 600 chemicals that are required to be reported every year. Typically, the chemicals covered by the TRI program lead to cancer or other chronic human health effects, adverse acute human health effects, or adverse environmental effects. The list is comprised of different common metals, solvents, hazardous wastes and site remediation wastes. Additionally, the list contains components of chemicals, coolants, paints, polymers, plastics, lubricants and more.
This list is commonly known as the “List of Lists” and is updated annually to determine the chemical usage threshold. 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.
What Happens If You Don’t Submit a TRI?
Just because you may not have had to report chemicals last year or you think things have not changed, does not mean that you can ignore a TRI. Because you manufacture or process chemicals means that the inventory have changed. SRP environmental consultants have seen companies get fined anywhere from $5,000 to $100,000 and up. The EPA will fine companies if they fail to report their TRI on time, or if they fail to report at all. In addition to monetary fines, the EPA has been known to require companies in violation of the Emergency Planning and Community Right to Know Act (EPCRA) to make substantial donations to aid local emergency responders and the community in acquiring equipment to monitor chemical releases, hazardous conditions and more. Furthermore, if the EPA decides that your company is in violation of the EPCRA, they can initiate further investigations into your reporting, record keeping and procedures for handling chemicals. This can lead to more fines, more production lost and drastically hurt your bottom line.
If you are unsure if your facility is required to submit a Toxic Release Inventory form, consult with an environmental professional who has extensive experience in environmental compliance and annual reporting. Contact SRP now at (318) 222-2364 to ensure you stay compliant.