We explain TRI Reporting costs & prices and the factors that influence costs.
Spring time means a few things for us here at RMA. Aside from the weather getting nice and the fact that we're frequently back outside doing field work, there's one thing that happens like clockwork, every year, around late April / early May. People start looking back into TRI Reporting.
For some folks, TRI Reporting is no big deal. For others, it's either a hurdle to overcome, or it's an entirely new concept. Regardless, many people have questions about this somewhat difficult environmental regulation.
Aside from the normal questions of what is TRI Reporting, is TRI Reporting the same as Community Right-to-Know (Tier II) Reporting, and is TRI Reporting the same as Form R Reporting or SARA Title II Reporting, there's one question that's usually on anyone's mind.
Price. People simply want to know what does TRI Reporting cost?
Simple enough, right? When you consider most folks aren't sure what TRI Reporting actually entails, the length of investigation, and the complexity of reporting, it's only natural that people wonder what it actually costs. So let's dive into this area of concern and see if we can't iron out the answer.
What's the price or cost of TRI Reporting?
I'll give you two answers right here regarding the price of TRI Reporting.
The cost to conduct reporting on time and in full compliance with the regulations depends.
It's impossible to pin a firm number on the reporting, because it depends on a couple of different variables. Imagine you were in the market for a hot-tub. How much does it cost? It depends on the size, the manufacturer, where it's going, do you need to run electrical to where it's going, etc. There's a lot of variables that go into the price, and with TRI Reporting, variables do, and can make a huge difference.
But, the cost to report and get into compliance with TRI Regulations if you've failed to report or report incorrectly and get in trouble with a regulatory agency or 3rd party environmental group doesn't depend, because the answer is simply a lot. I don't want to bog you down with the details, but from our experience we've routinely seen fines for failing to report well into the multi-million dollar range, once you factor in penalties and fines, the cost to hire legal aid, environmental consultants, and the prices associated with getting into complete compliance with all regulations.
Point is, while it may be hard to give you a price for reporting, it's easy to give you a price for not reporting. At the end of the day, reporting and getting into compliance with TRI Reporting regulations is going to be considerably cheaper.
TRI Reporting Costs Explained
These factors may seem trivial, but for the environmental professional evaluating your facility, they can, and routinely do, impact the price of TRI Reporting. For proper, adequate, and reliable reporting, your facility needs to be fully evaluated from multiple angles, and these variables can make the cost go either up or down, depending on your operation & processes.
The type of facility impacts TRI Reporting costs.
Simply stated, the complexity of your operation will impact the cost. For example, a simple machine shop with one reportable chemical found in one product would be considerably easier than a concrete plant with multiple reportable chemicals found in multiple products, which would be easier than a complex chemical production facility with a variety of chemicals in multiple ways found in a variety of products.
The complexity of your operation impacts TRI Reporting pricing.
Regardless of the shape & size of your operation, what you actually do there is going to impact costs. If your operation is highly complex, with multiple various release pathways, with a variety of materials with numerous reportable chemicals in them, you're looking at a pretty complex reporting process. If your facility only releases chemicals through air emissions from one product, then reporting would be considerably easier.
The cost of TRI Reporting may be impacted by the materials being evaluated & chemicals being reported on.
A facility with higher amounts of chemicals that must be evaluated will require a lot more work than a simple facility which uses only a few chemicals. And, the number which ultimately require reporting will also affect the cost of reporting, as a facility with a hundred chemicals to report on will cost more than a facility with only one or two chemicals to report on.
Bear in mind, just because you may have a toxic chemical which could be reported on, if it doesn't meet reporting threshold levels, then it doesn't need to be reported. But, in order to report, it all needs to be evaluated, which raises the cost.
Release pathways & their complexity impact the price of TRI Reporting.
A large, complex facility with multiple releases to the environment of toxic chemicals will require far more work than one that has only one release pathway, such as air emissions from a stack only.
And, if these release pathways aren’t known and have to be identified and quantified, it will be a lot more work than a facility with only a small number of well documented release pathways.
Your previous TRI Reporting history may impact the cost.
For example, has your operation reporting in the past? Is the prior reporting accurate? The availability of good past reporting will reduce the overall cost compared to a facility where we’re starting from scratch.
Another thing to consider if you're starting from scratch is are you taking a risk by starting to report out of the blue. Some folks elect to protect themselves through the use of an environmental audit and take advantage of the USEPA's Audit Policy. A lot of folks ask do I need an environmental audit to start doing TRI Reporting?
How quickly you need to get this done impacts TRI Reporting costs.
Like taxes, the price may go up the closer to the reporting deadline you get. If you walk in the day before taxes are due to an accountants office, you'll likely end up paying a premium to get things filed on time. Same goes with TRI Reporting. Just remember the difference between Tier II Reporting deadlines & TRI Reporting deadlines. Don't confuse the two!
A simple fact about the price of TRI Reporting.
If there's one thing you should take away from these variable, it's that the size & complexity of your operation are largely going to be the biggest factor in the cost of TRI Reporting, for multiple reasons.
So what does TRI Reporting actually cost?
From our experience, TRI reporting costs will run anywhere from between $1,250 for the simplest facility to well over $25,000 or more for a very complicated facility. This is assuming you're using a qualified environmental professional who knows what they're doing. Generally our pricing has always fallen within that range, regardless of the type & complexity of a facility.
We've heard of "local guys" completing the job for a couple of hundred dollars per facility, as well as "industry giants" charging $100,000+ for elaborate reporting package deals. While it's easy to dismiss the big guys and say they're overcharging, I'd be wearier of the "local guys" completing the job for such a low amount.
Regardless of who you end up going with, you want to make sure they have experience working within your industry, understand the full extent of evaluation that's needed for TRI Reporting, and are capable of completely the work on time and accurately.
TRI Reporting is no joke, and it seems like every year it gets more and more spotlight as more folks are becoming subject to enforcement by 3rd party environmental groups and regulatory agencies. Don't end up as the next headline.