The due date of July 1, 2019 is fast approaching, and if you work for a facility that meets the Environmental Protection Agency’s criteria, you are probably already preparing your RY 2018 Toxics Release Inventory (TRI) report. In fact, almost all industrial facilities are required to submit their TRI annually, which the EPA publishes in a national, public database. The information is made available to the public about how companies are managing their toxic chemical and hazardous waste and what types of toxic chemicals they are releasing into the environment over the calendar year. Companies also report on how they are reducing their toxic chemical waste production and preventing it from being created at all. The TRI reporting program was originally created when the government passed the Emergency Planning and Community Right to Know Act of (EPCRA) in 1986. The Community Right to Know provisions ultimately help increase public awareness of possible sources of pollution, toxic chemicals and hazardous waste in their communities.
If you are not sure whether your facility is required to complete a Toxics Release Inventory or how to create one, read this basic guide to understanding TRI reporting.
Am I required to complete a Toxics Release Inventory report?
If the answer is yes to all three of the following criteria, your facility must report to the TRI program:
- Employs 10 or more full-time equivalent employees
- Manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above threshold levels in a given year. TRI-listed chemicals can vary from year to year, so be sure you are aware of any changes. TRI-listed chemicals are toxic chemical that may have adverse effects on humans or the environment
- Is either A) a federal facility or B) in a TRI-covered industry sector, such as mining, hazardous waste, manufacturing, utilizes, etc.
Almost all industrial facilities are required to complete Toxics Release Inventory reports. Completing the reports correctly will help protect the environment, the communities surrounding your facilities, and your company’s bottom line.
What are the common mistakes on Toxics Release Inventory reporting?
Companies face severe consequences for incorrect TRI reports, but TRI reporting is not always as straightforward or easy as it seems. Experts like those at Enviro-Safe Resource Recovery can help ensure your TRI reporting is accurate so you avoid the following pitfalls:
- Inaccuracies on your TRI reporting can cause devastating effects on the environment and human health.
- Noncompliance with federal reporting may result in heavy fines, penalties and legal liabilities, which will reflect negatively on your company’s reputation and will affect your bottom line. Fines may be leveled against you for past failures to report at each facility.
- Often, toxic chemicals are present in materials and products your company is using or has purchased but may not be aware of. Your company will be held responsible for reporting all toxic chemicals, and not knowing enough is not considered an excuse. Be sure you have an expert like those at Enviro-Safe who can help you understand all reportable chemicals at your facility.
- It is possible you are overreporting your toxic chemicals. Most commonly, people may double count chemicals that have been recycled, incorrectly report still bottoms, or misreport their solvent recovery and miss out on their air emission credits. It is also possible you may be missing opportunities to recycle certain chemicals. Consult the experts at Enviro-Safe to learn more about how recycling toxic chemicals can earn you air emission credits.
- Some company’s mistake the Tier II chemical inventory report with their TRI report. The requirements for both are in the same section of EPA regulations, but they are not the same report, so make sure you are correctly reporting on both.
- Toxics Release Inventory requirements change each year, so make sure you do not miss this year’s updated report requirements.
How do I make sure I am correctly completing my Toxics Release Inventory reporting?
If you are uncertain whether you are in compliance, it is crucial to ask professionals to review your processes. Send us a message today or call us at 262-790-2500 to get started today to meet the July 1 deadline.
