Understanding TRI Reporting: Form A, Form R, and TRI-MEweb

The deadline is right around the corner for the 2011 reports (July1) so make sure you know your way around the reporting requirements.


Facilities required to submit Toxic Chemical Release forms complete a separate Form R or Form A for each listed chemical or chemical category that is manufactured, processed, or otherwise used in excess of the threshold amount. EPA has streamlined the forms to eliminate reporting similar data in different sections of the form.

The owner or operator must submit to EPA and to the state in which the facility is located a completed EPA Form R (EPA Form 9350-1) and, for the dioxin and dioxin-like compounds category, EPA Form R Schedule 1 (EPA Form 9350-3).

Trade Secret Claims

Because all information not claimed as a trade secret is widely available to anyone who wishes to review it, it is a good idea to make a trade secret claim for any information requested on Form R that might give your competitors—or anyone at all—any type of advantageous information.


EPA has developed the TRI-MEweb software for Form R submissions required under EPCRA and the Pollution Prevention Act of 1990. EPA prefers the TRI-MEweb reporting application. TRI-MEweb is a Web-based application that can be accessed anywhere with a connection to the Internet. TRI-MEweb requires no downloads or software installations.

There are many benefits to using the software. TRI-MEweb allows facilities to file a paperless report, significantly reduce data errors, and receive instant receipt confirmation of their submissions.

If you are using TRI-MEweb for the first time, certifying officials must register for the application that requires the printing, completion, and mailing of an electronic signature agreement.

TRI-MEweb submissions are NOT available for trade secret claims. Facilities must continue to submit hard copies of the TRI reporting forms and trade secret substantiation form.

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Facilities that meet the annual reporting thresholds for manufacturing, importing, processing, or using a toxic chemical may not have to file Form R for that chemical if they store less than 1 million lb and do not release, dispose of, treat, recover, burn, or transfer off-site a total of more than 500 lb of that toxic chemical. If a facility is under the 500-lb annual reportable release limit, the owner or operator may submit the certification Form A in lieu of Form R.

However, this alternative threshold is applied on a chemical-by-chemical basis. Therefore, a facility may submit a Form R for certain chemicals and a Form A for others (for example, facilities must use Form R for all PBTs).

Facilities that manufacture, process, or use more than 1 million lb of a toxic chemical are not eligible to use the alternative threshold, even if they released less than the 500-lb annual reportable amount of that toxic chemical.


Form A does not require release, other waste management, or source reduction reporting. A facility must certify that it is eligible to use Form A. The Form A Certification Statement provides communities with information that the chemical is being manufactured, processed, or otherwise used at facilities. The Certification Statement also provides compliance monitoring and enforcement programs and other interested parties with a means of tracking chemical management activities and verifying overall compliance with the rule.

A senior management official must sign and submit a cover letter with Form A stating:

"I hereby certify that to the best of my knowledge and belief for the toxic chemical listed in this statement, the annual reportable amount, as defined in 40 CFR 372.27(a), did not exceed 500 pounds for this reporting year and that the chemical was manufactured, or processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year."

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Each owner or operator who submits a Form A must retain the following records for 3 years:

  • A copy of each certification statement submitted,
  • All supporting documentation used to make the compliance determination that the facility is eligible to apply the alternate threshold, and
  • Documentation supporting the certification statement, including the determination that the alternate threshold applies for each toxic chemical, the calculation of the annual reportable amount, and receipts or manifests associated with the transfer of each waste chemical to off-site locations.

EPA has identified more than 650 chemicals and chemical categories that are subject to the TRI annual reporting requirement. But there are some exemptions. See tomorrow’s Advisor on all the chemicals that you don’t have to report.

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