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Does our company need to complete a Toxics Release Inventory (TRI)?
The Environmental Protection Agency’s (EPA) Toxics Release Inventory (TRI) Reporting criteria state that you are required to complete a TRI report if your facility:
- Is in a specific industry sector
- Employs 10 or more full-time equivalent employees
- Manufactures, processes, or otherwise uses a chemical listed under Sections 302 and 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) in quantities above threshold levels in a given year.
According to Aaron Martinkus, a Senior Environmental, Health and Safety (EH&S) Consultant at PROtect, “You are required to complete a TRI for each TRI-listed chemical manufactured or processed by your facility in excess of 25,000 pounds in a year or if you otherwise use more than 10,000 pounds of a listed chemical in a year.”
Additionally, there are two stipulations to note: federal facilities must report regardless of industry sector if they meet the other two requirements and Persistent Bioaccumulative Toxic chemicals (PBTs) have lower thresholds than other TRI chemicals.
Ways To Complete A TRI
You’ll need to submit each TRI form to both the EPA and the state in which your facility is located. The most common way to submit a TRI is called Form R. Each Form R submission will include important information regarding your facility and the way a specific TRI-listed chemical was manufactured, processed, managed, and stored.
Form A is a simplified version of Form R offered for chemicals with annual reporting amounts that do not exceed 500 pounds and with amounts manufactured, processed, or otherwise used not exceeding one million pounds.
How PROtect Can Help
In addition to TRI reporting assistance, PROtect offers practical and effective advice, assessments, and reports on key regulations and issues during all phases of an environmental project. To help you with ongoing operational obligations such as maintaining compliance with recurring reporting, planning, and permit submission requirements, we provide:
- Air Emissions Inventory
- Tier II Annual Reporting
- Greenhouse Gas Annual Reporting
- Fuel Additive Manufacturer Annual Reporting
- Toxic Substances Control Act (TSCA). Chemical Data Reporting
- SPCC Plan Review and Updates (including P.E. Certification)
- FRP Review and Updates
- RMP 5-Year Updates
- Hazardous Waste Assistance
- Permit Maintenance and Management
- Regulatory Required Notifications
- 12-Month Rolling Documentation Development
- Emission Testing Coordination
- Post-Inspection Negotiation and Response Assistance
- Representation During EPA and State Inspections
- Environmental Training
- RFS2 Engineering Review – 3 Year Re-registration
- Temporary and Part-Time Staffing
Contact PROtect directly at (316) 927-4290 for a complimentary consultation.
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