Available Now: 2023 Schedule of Hazmat & RCRA Training
Search

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

Posted on 5/10/2011 by James Griffin

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 exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

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

Download Our Latest Whitepaper

Hazardous materials shipment rejections bear a big cost. Use this guide to end operational and logistical disruptions that severely impact your bottom line.

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.