A TRI Recap
TRI reports are required to be submitted by facilities with 10 or more full-time employees, in specified Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS) codes, that manufacture, process, or otherwise use listed TRI chemicals in excess of the established thresholds. The thresholds per calendar year are:
- 25,000 pounds (lb) per toxic chemical manufactured or processed, other than persistent bioaccumulative and toxic (PBT) chemicals;
- 10,000 lb per toxic chemical for chemicals otherwise used, other than PBT chemicals; and
- As listed in 40 CFR 372.28 for PBT chemicals.
Chemicals Added to TRI
The EPA has made changes to the list of chemicals and chemical categories subject to inclusion in TRI reports.
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o-Nitrotoluene (CAS# 88-72-2)
Facilities were required to include o-Nitrotoluene in TRI reports for the 2014 reporting year (RY) if the applicable thresholds are exceeded. The EPA added o-Nitrotoluene to the TRI list because it was recently classified as “reasonably anticipated to be a human carcinogen” by the National Toxicology Program (NTP).
According to NTP’s 12th Report on Carcinogens (RoC), o-nitrotoluene is used primarily in the manufacture of chemicals that are intermediates in the production of various azo dyes (mostly the bright yellows, oranges, and reds). It is also used in the manufacture of, or the manufacture of intermediates for, other dyes, such as magenta and various sulfur dyes for cotton, wool, silk, leather, and paper. In addition, it is used for explosives and a variety of organic chemicals, including compounds used in the agricultural chemical, pesticide, petrochemical, pharmaceutical, and rubber industries.
Begin to Track the Nonylphenol Category
acilities were not required to include chemicals in the nonylphenol category for the 2014 RY but should begin tracking these chemicals. Reporting nonylphenol category chemicals will begin with the 2015 RY TRI reports due July 1, 2016. The EPA added the nonylphenol category, which includes the following, to the TRI list because the Agency claims that these substances are highly toxic to aquatic organisms:
- 4-Nonylphenol (CAS# 104-40-5)
- Isononylphenol (CAS# 11066-49-2)
- Nonylphenol (CAS# 25154-52-3)
- 4-Isononylphenol (CAS# 26543-97-5)
- 4-Nonylphenol, branched (CAS# 84852-15-3)
- Nonylphenol, branched (CAS# 90481-04-2)
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Nonylphenol is an organic chemical that, according to the EPA, is mainly used in the manufacture of nonylphenol ethoxylates (NPEs). NPEs are used in many common products, including detergents, cleaners, degreasers, and paints and coatings, to name just a few. They were once common ingredients in household laundry detergents but were phased out by manufacturers. Although no NPEs were added in this TRI go-round, their use should be reduced because of the listing of nonylphenols. However, the EPA is considering adding NPEs to the TRI list. The Agency claims that there are plenty of less toxic substitutes for NPEs and advises folks to go to EPA’s Safer Choice website to find them.
Supports TSCA Action Plan
When the EPA initially proposed the addition of a nonylphenol category to the TRI list, the Agency pointed to research that acute and chronic toxicity levels of nonylphenol have been identified for many freshwater and saltwater species. As part of its effort to enhance the existing chemicals program under the Toxic Substances Control Act (TSCA), in August 2010, the EPA issued an action plan for nonylphenol and nonylphenol ethoxylates. The plan outlined the courses of action the Agency is considering pursuing in the near term to address its concerns about these chemicals. One of the steps identified in the plan was to add nonylphenol to the TRI list.