In the 2018 reporting season, one of the latest deadlines for environment, health, and safety (EHS) managers is July 1. This is when your Toxic Release Inventory (TRI) report concerning the chemicals you manufactured, processed, or otherwise used in 2017 is due. What changes are there for the 2018 report?
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The Emergency Planning and Community Right-to-Know Act (EPCRA) requires manufacturing facilities to submit an annual toxic chemical release report. The purpose of this reporting requirement is to inform the public and government officials about permitted and accidental releases of specified toxic chemicals to the environment.
Who Must File a TRI Report?
Facilities in different industry sectors, facilities in Indian country, and federal facilities must annually report how much of each toxic chemical they managed through recycling, energy recovery, treatment, and environmental releases.
Either a facility’s owner or operator may file the TRI report, but both will be held responsible if a report is not filed.
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 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.
Note. The threshold quantity is the total amount manufactured, processed, or otherwise used, not the amount released. The threshold activities (i.e., manufactured, processed, or otherwise used) are mutually exclusive. For example, if a facility manufactures 20,000 lb of a non-PBT and also processes 20,000 lb of that same chemical, neither threshold has been exceeded, and reporting is not required.
How to File
The EPA requires facilities to submit all nontrade secret TRI reporting forms electronically using the Toxics Release Inventory—Made Easy Web (TRI-MEweb) online reporting tool. The EPA will no longer accept paper submissions of TRI reports, except for trade secret submissions. Facilities must continue to submit hard copies of the trade secret substantiation form.
What’s New for 2018
The EPA added the hexabromocyclododecane (HBCD) category to the TRI chemical list (CAS 25637-99-4 and CAS 3194-55-6) in November 2016. Facilities that meet TRI reporting thresholds for HBCD must report release information in 2017 for the chemicals on the TRI report due July 1, 2018. According to the EPA, HBCD is a PBT chemical and a lower reporting threshold is therefore justified. The reporting threshold for HBCD is 100 lb.
The primary use of HBCD is as a flame retardant for foams used primarily for thermal insulation boards in building and construction industry. It is also used as a backcoating for a number of upholstery textiles in the automotive industry and as a flame-retardant in electrical and electronic appliances. People may be exposed to HBCD from products and dust in the home and workplace, as well as its presence in the environment.
Note: The EPA designated HBCD in December 2016 as one of the first ten chemicals to be evaluated for risk under the amended Toxic Substances Control Act (TSCA).
Use the TRI P2 Search Tool
One of the aims of EPCRA is to encourage facilities not only to reduce releases of hazardous chemicals but to encourage them not to use these chemicals. The EPA suggests that facilities use the TRI P2 Search Tool to learn from other facilities’ best practices. Under the federal Pollution Prevention Act, the EPA gathers pollution prevention information from facilities. The P2 Search Tool allows comparisons from facility to facility.
Many facilities provide descriptions on measures they have taken to prevent pollution and reduce the amount of toxic chemicals entering the environment. As a result, TRI can serve as a tool for identifying effective environmental practices and highlighting pollution prevention successes.
For example, for 2015, a total of 2,424 facilities (11% of all TRI facilities) reported initiating 7,508 source reduction activities. Good operating practices, process modifications, and spill and leak prevention were the activities reported most frequently.