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

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry.

Frances Mona

Shipping Manager

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops.

Stephanie Gilliam

Material Production/Logistics Manager

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

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

Download Our Latest Whitepaper

In most cases, injuries that occur at work are work-related and must be recorded to maintain compliance with OSHA regulations. This report shows you the 9 types of injuries you don’t record.

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.