What's New for TRI Reports Due July 1?

Posted on 6/20/2022 by Roger Marks

Toxic Release Inventory (TRI) reports, also called “Form R,” are due from designated facilities by July 1.

Under the Emergency Planning and Community Right-to-Know Act (EPCRA) regulations, TRI reporting is required from facilities in certain industry groups that manufactured, imported, processed, or used large volumes of listed chemical substances in 2021.

What’s New for TRI Reports in 2022?

A few important changes are in effect for facilities submitting TRI reports, including:

Natural gas processing facilities that receive and refine natural gas are now subject to TRI reporting (first report due July 1, 2023)
Many PFAS chemicals have been added to the list of reportable substances in recent years
TRI reporting was extended to contract sterilization facilities that manufacture, process, or use ethylene oxide (and ethylene glycol, in some cases)

See all the changes to TRI reporting on EPA’s website.

Who Must Submit TRI Reporting?

EPA lays out who must report in 40 CFR 372.1. Designated facilities that must submit TRI reporting are facilities that:

Employ 10 or more full-time employees (or equivalent hours worked); and
Are assigned SIC Major Group code 10, 12, or 20—39 or SIC Industry Groups 4911, 4931, 4939, 4953, 5169, 5171, 7839; or that are Federal agencies; and
Manufactured, imported, processed, or used a covered chemical in a quantity exceeding the given threshold.

EPA lists each chemical substance for which TRI (“Form R”) reporting is required at 40 CFR 372.65.

Reporting thresholds are found in Part 372.25. Generally, covered facilities must report if they manufactured, imported, or processed more than 25,000 pounds of a listed chemical during the previous year. Facilities that “otherwise used” more than 10,000 pounds of a listed chemical must report as well.

Lower Thresholds for Chemicals of Special Concern

The reporting thresholds for “chemicals of special concern” are significantly lower, due to the potential of some substances to inflict lasting damage on human health or the environment. Chemicals of special concern, which include persistent, bioaccumulative, and toxic (PBT) substances, are listed in 40 CFR 372.28.

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Tags: chemical inventory reporting, EPCRA, Form R, TRI Report

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