Transparency is invaluable in maintaining positive relationships between industries and their stakeholders. Doing so encourages the latter’s participation in the environmental health and safety discourse, ensuring their needs are communicated and met. The Environmental Protection Agency (EPA) therefore implements the Toxics Release Inventory (TRI) Program, which makes the public aware of how hundreds of chemicals are managed by facilities all over the United States. Under the program, specific organizations must monitor their use, storage, and release via waste stream management of any of the 787 toxic chemicals listed by the US Environmental Protection Agency and submit them if they exceed the set threshold levels. Not all facilities that use, handle, and release toxic chemicals must file a TRI, but failing to abide by the program can mean monetary costs for covered organizations. This article gives an overview of the TRI Screening program, detailing what companies must submit an inventory report and how to do so.
What is the TRI Screening Program?
The Toxics Release Inventory Program builds information flow channels among TRI-required organizations and their stakeholders. By complying with the TRI program requirements, organizations give the public access to how much toxic chemicals they release and their methods of waste stream management. In doing so, public authorities are equipped to recommend or require data-backed safeguards against environmental and health issues that could arise.
Requirements for Submitting a TRI Report
All the chemicals that require TRI reporting are split into different categories and subcategories and summarized in this list. These chemicals are either carcinogenic or known to cause adverse impacts on the environment and human health. The EPA has developed a 3-part screening tool to help organizations ascertain whether they are required to submit a TRI Report. To make use of the tool, the following three pieces of information will need to be prepared:
- The organization’s NAIC Code.
NAIC codes group industries according to the nature of their on-site activities. These codes are due to change every five years. Organizations should note that a few modifications were incorporated into the 2017 NAIC codes and have been in effect since January 1, 2022. This screening tool offers facilities the ability to input their NAIC code and receive a notification if the TRI Reporting Program covers that facility.
- The number of annual employee hours.
The threshold for the Employee-Work-Hour criterion in TRI filing is 20,000 hours. This is equivalent to having ten full-time employees or a mix of part-time and full-time employees with a total of 20,000 work hours per year.
The use of chemicals can either pertain to the following:
- Manufacture- the production of a toxic chemical within the organization either through synthesis or importation.
- Processing- the production of a commercial material using a toxic chemical.
- Otherwise used- typically applicable to waste management facilities accepting offsite toxic chemicals for further processing or producing toxic chemicals as a result of their waste stream management.
The TRI screening tool requires a selection of the organization’s chemicals from a dropdown menu and an input of the respective amounts of the chemicals manufactured, processed, or otherwise used. It will then identify whether the chemicals and their quantities meet the threshold required for reporting. Tapping the assistance of chemical inventory management software helps make this process more seamless and accurate by offering immediate, secure access to chemical information and the ability to export this data in the required reporting format.
How to submit the TRI Report
A TRI Screening report is likely required if a facility meets all three of the above-mentioned criteria. The tool only provides an approximation and there are exemptions. The EPA advises that their guidance materials remain superior to any conclusions made by the tool.
Once the requirement has been established, the process for submitting a TRI report is straightforward. The reporting facility can register for an account on the EPA’s website and submit the information required by the TRI Form. After certification, these forms then go to the EPA and to the state (or tribe) where the company is registered. Note that yearly submissions are due every July 1st.
The Toxics Release Inventory Program is a mandatory program that informs stakeholders such as academics, the media, and the rest of the public how industries manage their toxic chemicals. By submitting yearly TRI reports, covered organizations receive feedback from stakeholders and, in doing so, implement safeguards and modifications to existing practices such as waste stream management to enhance environmental and overall safety. These submissions can be expedited with the application of software designed to easily manage and export chemical inventory and safety information.
Sources
- U.S. Bureau of Labor Statistics. (2021, November 10). 2022 North American Industry Classification System (NAICS) revision. https://www.bls.gov/respondents/ars/2022-naics.htm
- US Environmental Protection Agency. (2016, December 29). TRI Threshold Screening Tool. https://trimewebmod.epa.gov/cdx-tri-threshold-screening-tool/action/home/view/tri
- US Environmental Protection Agency. (2023, July 10). TRI compliance and enforcement. https://www.epa.gov/toxics-release-inventory-tri-program/tri-compliance-and-enforcement
US Environmental Protection Agency. (2023, August 14). TRI-listed chemicals. https://www.epa.gov/toxics-release-inventory-tri-program/tri-listed-chemicals
