FAQ

What is the TRI?

The Toxic Release Inventory (TRI) is a public database that tracks the amount of toxic chemicals released into the environment as reported by industrial and federal facilities. Companies report certain chemicals they release into the air or water, as well as the amount.

The public can access this database through the Environmental Protection Agency (EPA) following Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). By searching for a business, address, or ZIP code, the public can search the TRI for pollutants in their area.

The data found in the TRI is compiled by the companies reporting possible contaminants in their facilities. Because of the vast listing of contaminants available for TRI reporting (nearly 800), organizations often feel overwhelmed and don’t know where to start. However, experts say the amount of required data is often far less — and less complicated — than originally thought.

It isn’t typically necessary to comb through every piece of purchased chemical one-by-one. For instance, assume a client realized they purchased a small amount of paint containing benzene. While benzene is a reportable contaminant, the low volume level of the contaminant would dictate no reporting was necessary.

Data is gathered and logged on the EPA Form R, and reporting is done by logging onto the EPA database and inputting the information from the form. Typically, the larger a facility is, the more contaminant data they must report. For example, a facility involved in manufacturing generating large amounts of electrical power would trigger larger reporting requirements.

Smaller “mom and pop” shops often do not meet volume requirements for reporting. To necessitate reporting, companies must employ more than 10 employees and produce over a certain threshold for a chemical every year — and those thresholds are quite high, often 10,000 or 25,000 pounds of manufacturing or processing. Therefore, in the earlier example of benzene-containing paint, an organization would need to have a minimum of 10,000 pounds of paint to trigger a reporting requirement.

The US EPA provides threshold screening tools and Frequently Asked Question guidance that can help facilities get started, but a data driven big picture approach is often helpful rather than sorting out chemicals one-by-one with the US EPA tools. This can be done by focusing on data such as manufacturing records, chemical purchase and chemical use records to eliminate chemicals clearly below thresholds.

Sometimes chemicals which undergo chemical reactions at a facility will be subject to two categories. first for chemical use and then for incidental chemical manufacture.   For example, lead found in munitions— is counted once when the lead in the explosive is used, and again when it reacts with the oxygen and becomes lead oxide.  Another similar overlooked potentially reportable release, is the formation of nitrates generated from the partial of complete neutralization of nitric acid, a process that is used in water and wastewater treatment. An incidental reaction product is often an overlooked source of TRI reportable emissions.

With other materials, businesses are also required to track what happens after it is used and enters the environment. Is it going into the water or air, or perhaps recycled? Have pollution prevention measures been taken?

While exceptions and regulations regarding the thresholds can be complicated, working with a professional who possesses sharp data management skills can keep you from getting lost in the weeds. A consultant who can step back and look at the bigger picture is invaluable to accurately reporting toxic chemical use.

The consultant’s role is to gather the data, identifying and calculating toxic chemical levels, and inputting that information into the TRI form. Firms like Cameron-Cole, an ADEC Innovation, will also provide clients with a summary of the previous year’s TRI report that explains the process and translates the results into user-friendly language. Communication is key when it comes to understanding TRI reporting, and an expert can ensure your organization reports all necessary chemical levels — as well as not wasting time with unnecessary reporting.

 

Learn more about TRI reporting and the benefits of working with a consultant. 

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