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TRI/Form R Season is Upon Us!

From the desk of Gavin L. Biebuyck, Principal

What is TRI Reporting?

Toxics Release Inventory (TRI) Reporting is required for manufacturers in certain industrial categories, with more than 10 employees, that handle listed toxic substances in quantities that exceed annual thresholds that depend on the type of processing (“manufacture”, “process”, or “otherwise use”) and the type of toxic material. For most of the TRI-listed toxics,  the reporting thresholds are either 25,000 pounds/year (“manufacture” or “process”) or 10,000 pounds/year (“otherwise use”) but lower reporting thresholds have been established for Persistent Bioaccumulative Toxic chemicals. The TRI reports for 2017 are due on July 1, 2018, but since that falls on a Sunday this year, reports are due by midnight on Monday, July 2. TRI requires online submission of Form R reports detailing any environmental releases of the toxic substances to air, wastewater, or stormwater, and any transfers to landfills or recycling centers. TRI reporting must be completed online using EPA’s TRI-ME software and must be certified by a company official.

What’s New for 2018?

There are some new elements for the 2017 reporting due on July 2, 2018.

+ A new chemical category, Hexabromocyclododecane (HBCD), has been added to TRI for the 2017 reports. HBCDs are brominated flame retardants used in some textiles and Styrofoam products used in the construction industry. HBCD has been added as a Persistent Bioaccumulative Toxic (PBT) chemical with a much lower TRI reporting threshold of 100 pounds/year. Note that PBTs are treated differently from other TRI substances and SDS de minimis levels do not apply. This means that any and all amounts of PBTs known to be present in raw materials, fuels, or process aids, or coincidentally produced during manufacture need to be accounted for to assess TRI reporting applicability. Other PBTs include lead and mercury compounds.

+The 2017 TRI reports must now identify a facility’s NAICS Code(s) using the 2017 updated codes.

+Reporting de minimis levels have been revised from 1.0% to .01% for certain substances that have now been identified as carcinogens (e.g., MIBK). This impacts whether these substances must be reported on SDS sheets. It is very important to obtain the most up-to-date SDS for all chemicals used at a facility.