Lion's office will be closed November 27 and 28. Online training support is available every day from 8:30 AM to 5 PM ET via support@lion.com.
Search

Question of the Week: Toxic Chemical Inventory (TRI) Reporting

Posted on 5/10/2011 by Lion Technology Inc.

Q. We are a facility that is subject to the toxic chemical inventory reporting requirements at 40 CFR Part 372. During the previous calendar year we mixed 24,800 pounds of a listed toxic chemical into one of our product formulations. In late December, we did add 200 more pounds into a batch processing unit. However, we did not remove the finished product from the unit for packaging until January. For purposes of 40 CFR Part 372, was the 200 pounds of the toxic chemical in the processing unit at the end of December considered processed in the previous or current year?
 
A. The toxic chemical release reporting (TRI) rules define process as “the preparation of a toxic chemical, after its manufacture, for distribution in commerce” [40 CFR Section 372.3]. In the scenario described you are taking a toxic chemical that has already been manufactured and mixing it with other constituents to make your formulation. Therefore, processing would be the activity to consider in terms of reporting applicability. The TRI rules require reporting for any toxic chemical that is processed in quantities of 25,000 pounds or more per site in a calendar year [40 CFR 372.25(a)].
 
The EPA interprets the activity of processing to be reportable when the toxic chemicals are initially prepared. Therefore, the amount of the toxic chemical that was mixed in the processing unit at the end of December would be added to the processing threshold determination for that calendar year, despite the fact that the finished product was not removed until the following calendar year. Since the 200 pounds must be added to the 24,800 pounds already processed, your facility has met the 25,000 pound processing threshold for this toxic chemical. TRI reporting would be required for this toxic for the previous calendar year.

Tags: EPA, EPCRA, reporting and recordkeeping

Find a Post

Compliance Archives

Lion - Quotes

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

Download Our Latest Whitepaper

Some limited quantity reliefs are reserved for specific modes of transport. Use this guide to identify which reliefs you can capitalize on, and which do not apply to your operations.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.