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Toxics Release Inventory (TRI) Report – Form R

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Toxics Release Inventory (TRI) Report – Form R

The Form R or Toxic Release Inventory Report (aka TRI report and SARA 313) is a report which must be prepared if a company has used over certain quantities of certain materials that are listed as Form R reportable materials. The report requires facilities to identify these materials and provide a mass balance of where the material went: the product, the water, solid waste, air, etc. CDMS can help you by preparing the reports, evaluating to determine if your facilities qualify for Form R and also submitting the self-disclosure request.

Regulatory bodies
  • EPA (Environmental Protection Agency)
  • CalEPA (California Environmental Protection Agency)
Who needs it

Section 313 of the Emergency Planning and Community Right-to-Know Act (Title III of the Superfund Amendments and Reauthorization Act of 1986) requires that the EPA Toxic Chemical Release Inventory Report Form (aka Form R) be filed by owners or operators of facilities that meet these three requirements:

  • The facility employees have worked a total of 20,000 hours or more during the reporting year (i.e., equivalent to 10 or more full time people),
  • The facility is included in the NAICS codes: 311*, 312*, 313*, 314*, 315*, 316, 321, 322, 323*, 324, 325*, 326*, 327*, 331, 332, 333, 334*, 335*, 336*, 337*, 339* and select other NAICS codes (corresponding to SIC codes 20 through 39),
  • The facility manufactured, processed in excess of 25,000 pounds, or otherwise used in excess of 10,000 pounds of any Section 313 Toxic Chemicals during the reporting year or exceeded thresholds for listed Persistent, Bioaccumulative, and Toxic (PBT) Chemicals. Click here for a list of reportable chemicals.

The Form R report is required if any of the over 600 listed chemicals or substances are used as raw material, or as an ingredient in a material, over the reporting threshold for that chemical.

Common and often overlooked reportable materials include:

  • Lead
  • Metals including Copper, Chrome, Nickel, Zinc (stainless steel includes several reportable materials)
  • Nitric Acid
  • Sulfuric Acid

Note: Each year chemicals are added to and deleted from the Form R list. Companies should re-evaluate reportable chemicals each year. Some chemicals have proposed reporting levels as low as 1 pound per year.

There are not many reports that go directly to the US EPA, but the Form R report does. It is important to submit this report on time to avoid penalties. There is no fee for filing this report but there are large penalties for not filing or for filing late.

Regulation reference
  • Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313.
  • Code of Federal Regulations Title 40, Part 372.
  • California Health and Safety Code Sections 25251-25257.1.
  • California Code of Regulations Title 19, Sections 2770-2774.
What our service provides:

CDMS can help you by preparing the reports, evaluating to determine if your facilities qualify for Form R and also submitting the self-disclosure request.

Request a Free EHS Compliance Assessment

Contact us

What is the TRI Program?
The Toxics Release Inventory (TRI) is a federal and state program tracking toxic chemical releases and waste management at facilities.

What facilities have to report TRI?
Section 313 of the Emergency Planning and Community Right-to-Know Act (Title III of the Superfund Amendments and Reauthorization Act of 1986) requires that the EPA Toxic Chemical Release Inventory Report Form (aka Form R) be filed by owners or operators of facilities that meet these three requirements:

  • The facility employees have worked a total of 20,000 hours or more during the reporting year (i.e., equivalent to 10 or more full time people),
  • The facility is included in the NAICS codes: 311*, 312*, 313*, 314*, 315*, 316, 321, 322, 323*, 324, 325*, 326*, 327*, 331, 332, 333, 334*, 335*, 336*, 337*, 339* and select other NAICS codes (corresponding to SIC codes 20 through 39),
  • The facility manufactured, processed in excess of 25,000 pounds, or otherwise used in excess of 10,000 pounds of any Section 313 Toxic Chemicals during the reporting year or exceeded thresholds for listed Persistent, Bioaccumulative, and Toxic (PBT) Chemicals. Click here for a list of reportable chemicals.

What chemicals require TRI reporting?
Around 760 chemicals are listed for federal TRI reporting. California requires reporting on an additional 600 chemicals.

What data is submitted in Form R?
Total quantities released to air, water, land, off-site transfers, recycling, energy recovery, treatment, etc.

How is the TRI data submitted?
Online using EPA’s TRI-ME web tool. Some data can be withheld for confidential business information.

When is the Form R submission deadline?
Annual reports must be submitted by July 1st covering the prior calendar year’s activities.

Can I get an extension on the Form R deadline?
Yes, a 30-day extension can be requested but the form must be completed by August 1st.

What records do I have to keep for TRI reporting?
Monitoring data, manifests, calculations, basis for estimates, chemical inventories, etc. for 3 years.

How do I know if an accidental release is TRl reportable?
If it exceeds the federal reportable quantities (RQ) for the chemical within a 24 hour period. Immediate notification required.

Are TRI reports publicly available?
Yes, EPA publishes the data on their website and it can be searched by facility, chemical, location, etc.

Can I claim my TRI chemical data is confidential?
Only the specific chemical identity can be claimed confidential, not concentrations or amounts.

Do I have to report a chemical present as an impurity?
If the impurity is listed and exceeds 1% of product/mixture composition, or over de minimis.

Are laboratory activities covered under TRI?
If chemicals are produced, prepared, processed or otherwise used above thresholds.

How do I update or withdraw TRI data later?
Revised or withdrawn forms can be submitted – valid reasons are required.

Can I be fined if I make a mistake on Form R?
Facilities acting in good faith effort will not be penalized for errors later corrected.

Where can I find guidance documents on TRI reporting?
EPA and state websites have sector-specific TRI reporting guidance documents. However, if you have other questions regarding Toxics Release Inventory (TRI) Report – Form R, you can contact us. Our skilled team of EH&S specialists is ready to assist you.

How can I reduce my TRI chemical uses and releases?
Options include input substitution, reformulation, process modifications, improved containment, recycling, etc.