TRI, or the Toxics Release Inventory, is an EPA reporting requirement that applies to certain facilities using specified chemicals in a certain way. Does it apply to your facility? If so, did you remember the annual reporting date is July 1st?
First, let’s start with a couple of links to the EPA’s TRI guidance pages. If you want to delve deeper into the requirements, these would be a great place to start.
Whether or not you have to report is based on meeting three requirements…what type of facility you are, what chemicals you may handle, and the volume of chemicals you may handle.
One, if your industry is covered by a NAICS code specified in the TRI Program, or if your facility is a federal facility, then you may be subject to TRI. This is a great place to check which NAICS are covered. If you are not a covered facility, then TRI probably does not apply to you.
Two, if your facility has ten or more full-time employees, you may be subject to TRI. If not, TRI probably does not apply to you.
Three, if your facility manufactures, processes, or otherwise uses a TRI-listed chemical above threshold levels in a given year, you may be subject to TRI. If you do not, TRI probably does not apply to you. It is important to clearly understand what manufactures, processes or otherwise uses means under TRI. The definitions for those three words can be found here.
If you do manufacture, process, or otherwise use a TRI chemical, you need to determine if you exceed the TRI reporting threshold. The thresholds can be found here.
If you look at the TRI thresholds, you will notice that many of them are quite high. But look closer; you will see that some thresholds are 10 lbs or less. Further, EPA has discretionary power to extend reporting requirements to facilities that would not otherwise be covered. The takeaway is that checking the current EPA website to verify your reporting requirements is always good.
If you have questions or need assistance with filing your TRI Inventory Report, Ingenium is here to help. Please email our EHS Department at email@example.com, or visit our website to complete an inquiry.