TRI Reports Due June 30 - Are You Ready?

The Toxic Release Inventory (TRI) is yet another addition to our regulatory "alphabet soup". If this regulation has not applied to you in the past, you may not be familiar with it. Ignorance of the law is no excuse - so perhaps this is your year to start tracking TRI chemicals for your facility.

What is TRI? The Toxic Release Inventory is tied to the Emergency Planning & Community Right to Know Act (EPCRA). The section of the EPCRA regulations that deal with TRI reporting is called "Section 313". So when folks are talking about this regulation, you may hear it by several names: EPCRA, Community Right to Know, 313 or TRI.

This headache we have to deal with each year has a sordid reason for coming to be. In 1984 the Union Carbide plant in Bhopal India had an accident releasing a cloud of methyl isocyanate into the community. The community was not aware of the hazards of the chemical or how to protect themselves. The release killed thousands. In response to this rude awakening, the EPA created EPCRA and a mechanism for the community at large to know what air pollutants you are putting into the air they are breathing.

 

EPA’s list current spans 593 chemicals and 30 chemical categories (some with as many as 60+ chemicals in the category). An example of the chemical categories is glycols, polycyclic aromatic compounds and diisocyanates to name a few.

EPA is constantly changing the list of chemicals for which you are required to report.

Each year in 2nd quarter, companies exceeding the "threshold quantities" of listed chemicals submit a TRI/313 report for the previous year’s production usage. In 2011, EPA has added 16 more chemicals to the list. To find a list of the chemicals, check out this link: www.epa.gov/tri/trichemicals/index.htm.

What is a Threshold and how do you know if you’ve surpassed it? Good of you to ask. EPA has established criteria for facilities to count the chemicals & compounds they have determined are reportable. There are two basic categories of chemicals in the TRI list - the standard "plain vanilla" chemicals and the Persistently Bioaccumulative Toxics (PBT) - the "bad boys".

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