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- EPA (Environmental Protection Agency)
- CalEPA (California Environmental Protection Agency)
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. 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 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: 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. 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. What is the TRI Program? What facilities have to report TRI? What chemicals require TRI reporting? What data is submitted in Form R? How is the TRI data submitted? When is the Form R submission deadline? Can I get an extension on the Form R deadline? What records do I have to keep for TRI reporting? How do I know if an accidental release is TRl reportable? Are TRI reports publicly available? Can I claim my TRI chemical data is confidential? Do I have to report a chemical present as an impurity? Are laboratory activities covered under TRI? How do I update or withdraw TRI data later? Can I be fined if I make a mistake on Form R? Where can I find guidance documents on TRI reporting? How can I reduce my TRI chemical uses and releases?
Toxics Release Inventory (TRI) Report – Form R
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The Toxics Release Inventory (TRI) is a federal and state program tracking toxic chemical releases and waste management at facilities.
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:
Around 760 chemicals are listed for federal TRI reporting. California requires reporting on an additional 600 chemicals.
Total quantities released to air, water, land, off-site transfers, recycling, energy recovery, treatment, etc.
Online using EPA’s TRI-ME web tool. Some data can be withheld for confidential business information.
Annual reports must be submitted by July 1st covering the prior calendar year’s activities.
Yes, a 30-day extension can be requested but the form must be completed by August 1st.
Monitoring data, manifests, calculations, basis for estimates, chemical inventories, etc. for 3 years.
If it exceeds the federal reportable quantities (RQ) for the chemical within a 24 hour period. Immediate notification required.
Yes, EPA publishes the data on their website and it can be searched by facility, chemical, location, etc.
Only the specific chemical identity can be claimed confidential, not concentrations or amounts.
If the impurity is listed and exceeds 1% of product/mixture composition, or over de minimis.
If chemicals are produced, prepared, processed or otherwise used above thresholds.
Revised or withdrawn forms can be submitted – valid reasons are required.
Facilities acting in good faith effort will not be penalized for errors later corrected.
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.
Options include input substitution, reformulation, process modifications, improved containment, recycling, etc.