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Toxic Release Inventory (TRI) Reporting

Form R and Form A
What the regs requires

Facilities must report release and other waste management information pursuant to EPCRA Section 313 if they:

  1. have 10 or more full-time employees or the equivalent; 


  2. are in a covered NAICS code; 

    and 

  3. exceed any one threshold for manufacturing (including importing), processing, or otherwise using a toxic chemical listed. 

EPCRA Section 325 allows civil and administrative penalties ranging up to $10,000-$75,000 per violation or per day per violation when facilities fail to comply with the reporting requirements.

 

 
Do I need to file TRI reports?
If you are unsure whether you are required to annually report to the Toxics Release Inventory (TRI), EPA offers a threshold tool. This tool will help determine if you should report based on the Program’s chemical and employee level requirements and your facility’s North American Industry Classification System (NAICS) Code. To take the threshold tutorial click here.

Our View:  E&SSG has provided TRI reporting for clients in all industries for more than 17 years.

What We Offer
TRI Reporting Service

This service is performed in two phases:


Evaluation Phase
The evaluation phase of the E&SSG's SARA Title III Toxic Release Inventory (TRI) Reporting is the first step designed to help determine if you have a requirement to comply with the EPA's Superfund Amendments and Reauthorization Act of 1986, (SARA Title III) section 313. In this step E&SSG will perform the following to help identify if your facility is required to file EPA's TRI, Form R or Form A report(s):


  1. Compile your section 313 inventory; 
  2. Break down the TRI candidates found within your inventory and group them in aggregate chemical totals;
  3. Review all identified Section 313 TRI candidates found in your chemical inventory;
  4. Compile your annual quantities; Match your annual quantities against the EPA section 313 thresholds;
  5. Determine your reporting requirements as they pertain to the regulatory standard; 
  6. Conduct a chemical mass balance formulation for each chemical requiring a TRI report; 
  7. and Determine the acceptable calculated amount of the 313 chemical released.


Reporting Phase
If it is determined in the Evaluation Phase that TRI reports are required, we then prepare the reports on your behalf. The TRI reports are then sent electronically to your facilities certified official for review and final submission.
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