12 Chemicals Proposed for EPCRA TRI Reporting List

Posted on 10/19/2021 by Roger Marks

US EPA has proposed adding 12 entries to the list of chemicals subject to Toxic Release Inventory (TRI) reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA).

Section 313 of EPCRA requires facilities that manufacture, import, process, or use certain chemicals to report annually to EPA about their activities if they exceed regulatory thresholds.

The 12 chemicals proposed for addition to the EPCRA TRI reporting list are listed below. EPA has determined that the produce and use levels for each of these chemicals "would result in TRI reports being filed." 
Chemical name CASRN
dibutyltin dichloride 683–18–1
1,3-Dichloro-2-propanol 96–23– 1
Formamide 75–12– 7
HHCB* 1222–05–5
N-hydroxyethylethylenediamine 111–41–1
Nitrilotriacetic acid trisodium salt 5064–31–3
p-(1,1,3,3-Tetramethylbutyl)phenol 140–66–9
1,2,3-Trichlorobenzene 87–61–6
Triglycidyl isocyanurate 2451–62–9
Tris(2-chloroethyl) phosphate 115–96–8
Tris(1,3-dichloro-2-propyl) phosphate 13674–87–8
Tris(dimethylphenol) phosphate 25155–23–1

*1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8- hexamethylcyclopenta[g]-2- benzopyran

Read the proposed rule in the Federal Register (October 18, 2021) 

EPCRA TRI Reporting Thresholds 

Most chemicals on the EPCRA 313 TRI reporting list are assigned reporting thresholds as follows:
  • 25,000 pounds for chemicals manufactured (including imported) or processed; and
  • 10,000 pounds for chemicals “otherwise used.”
(40 CFR 372.25(a) and (b))

HHCB and Chemicals of Special Concern 

EPA assigns significantly lower reporting thresholds for some chemicals of special concern.

In the proposed rule EPA singles out one of the twelve chemicals, HHCB, as a potential chemical of special concern. Citing evidence that suggests HHCB is a persistent, bioaccumulative, and toxic (PBT) chemical, EPA has proposed a reporting threshold of 100 pounds for this chemical. 

Why These 12 Chemicals?

EPA's proposal to add these 12 chemicals to the EPCRA TRI reporting list comes in response to a petition submitted in 2014. The petition asked EPA to add twenty-five chemicals to the TRI list.

EPA gives their reasoning for adding each chemical, and for not adding other chemicals, in the text of the proposed rule, linked above. EPCRA authorizes EPA to add to the list of chemicals for which reporting is required under EPCRA section 313. In 2020, EPA added 172 PFAS chemicals to the TRI reporting list.

EPA Superfund and Right-to-Know Training 

Many facilities that manufacture, process, and use hazardous chemicals must comply with detailed requirements for chemical inventory reporting, release reporting, and emergency preparedness.

The Superfund and Right-to-Know Act Regulations online course guides EHS professionals through the complex planning and reporting responsibilities in the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). 

Tags: chemical reporting, chemicals, EPCRA, Toxic release inventory, TRI

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