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Toxic Release Inventory (TRI) Form R: Tips and Best Practices

by Ken Beach, CHMM, EHS Project Manager

There are numerous companies these days who use hazardous chemicals in their manufacturing process. Between the chemicals processed, produced as a by-product, or otherwise used, companies are required to file special reports when meeting certain thresholds. One report, due every year on July 1, is the Toxic Release Inventory (TRI) Form R Report. The Toxic Release Inventory (TRI) reporting requirements, found in Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA), requires companies subject to the requirements to report the quantities released and the “ultimate fate” of certain chemicals, which are found on the Consolidated List of Lists (EPA 550-B-15-001 March 2015). Reporting thresholds for most chemicals are 10,000 to 25,000 pounds, however they can be as low as 0.1 grams for very toxic chemicals.

These reports can be overwhelming and carry with them large penalties (>$30,000) if not reported. Below are five things to know about Form R and the e-filing process.

     - Form R is due July 1st for the prior reporting year, but the earlier you get started, the better chance you have of meeting the deadline.

     - Visit the United States Environmental Protection Agency (USEPA) website or contact Fehr Graham to conduct a review to determine if your company meets the threshold for employees, NAICS code, and TRI chemicals with quantity limits.

     - If you process, produce, or use hazardous chemicals, regardless of quantity,  determine if you need to report and maintain records of your determinations.

     - Processing includes: sawing, grinding, welding, plating, treating, or changing the physical characteristics in which you may have a release to the environment.

     - Remember the total amount of chemicals, even those found in mixtures, should be added together for threshold quantities. Common reportable hazardous chemicals include:  phenol, formaldehyde, xylene, lead, copper, chromium, nickel, and manganese.
Remember, Fehr Graham has an experienced staff that can help you through the process of filing your TRI Form R. Please reach out to one of our experts by contacting us at 815.235.7643.


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