TRI Reporting is no joke. It seems like every year more and more facilities are getting in trouble for non-compliance, and end up facing massive financial penalties. Many people call it by different names, and here we discuss that issue.
When it gets to be this time of year, we start hearing a couple of terms thrown around and we get asked one question particularly a lot:
Is Form R Reporting the same as TRI Reporting?
It's a great question. Both terms refer to Section 313 Reporting (which I'll explain below), so the answer is sort of yes.
What is TRI Reporting?
Let's remember what Toxic Release Inventory Reporting is in the first place. It's required for any facility with a covered SIC code (nearly all industrial facilities), with at least 10 full-time employees (or the equivalent), and which triggers the reporting threshold for any of over 600 chemicals categorized by the USEPA as being “toxic”. The volume of chemical doesn’t have to be present at any one time, it’s determined by cumulative manufacturing, processing, or use over the course of a calendar year. While for most Toxic Release Inventory Reporting chemicals, the threshold is 25,000 pounds, some that are considered particularly toxic (known as Persistent, Bioaccumulative Toxic, or “PBT") have much lower, such as 100 pounds for lead (Pb) and 10 pounds for mercury (Hg).
In the past, you used to be able to do reporting on paper forms, and submit them to the appropriate state and local agencies. Now, it all has to be done electronically. The form that is most used for reporting is known as “Form R”. Therefore, in the minds of many, Toxic Release Inventory Reporting is also commonly known as Form R Reporting. A bit confusing, but easy to understand, right?
So in some ways, TRI and Form R Reporting are the same thing.
However, I think calling it Form R Reporting doesn’t do justice to the reporting process itself, since there’s also another very important form which can be a real time-saver. That form is known as Form A, and can be used for any non-PBT listed chemical that has less than 500 pounds of releases to the environment. So in a way you could also call it Form A Reporting.
When you report electronically, you’ll see both Form R and Form A. While you have to use Form R to identify your toxic chemicals, Form A is optional, and should be used when it fits the situation since it’s a lot easier.
Bonus! Is TRI Reporting the same as Section 313 Reporting?
We get this a lot, and it just confuses things even more. Section 313 Reporting (a name which I hate by the way) is based off of the section in EPCRA regulations that outline the reporting requirements that many people refer to as TRI. So, yes, it is the same as Section 313 Reporting.
I know what you're thinking. Trust me, I can't stand how this reporting requirement can have so many different names either. Add in the fact regulators call it everything from Form R to Section 313 Reporting, and it just confuses everyone.
It might seem like a small detail, but knowing the terminology of this reporting requirement can make the difference between reporting correctly (or at all), and avoiding a big penalty from the USEPA. If you're struggling with Toxic Release Inventory Reporting this year, let us know by clicking here to contact us, or give us a call at 609-693-8301 to discuss your needs today!
We explain the difference between Form A & Form R Reporting when it comes to TRI Reporting. With the New Year creeping around the corner, we're starting to hear from a lot of old & new clients about...