We explain how much TRI Reporting costs when you hire an expert, versus the price of TRI Reporting on your own.
It's that time of year when we're all wrapped up with Tier II Reporting, and we're just starting to get people calling us asking about Toxic Release Inventory Reporting. Aside from the most frequent question what is TRI Reporting, a pretty common question we hear is:
How much does TRI Reporting cost? What's the price of TRI Reporting if I hire an expert?
Toxic Release Inventory Reporting is required at a wide variety of facilities in the U.S. who manufacture, process or otherwise use toxic chemicals. Due to increasing enforcement of the TRI regulations, many facilities formerly unaware that they are required to report are now facing it for the first time and are unsure how to proceed, or what it's going to cost them to get into compliance. Like hiring an expert to solve any problem, the price is going to reflect the scope and complexity of the task.
We're getting more and more calls and emails from various industries across the U.S. asking for TRI Form R Reporting price quotes. It seems there's more attention being paid to these regulations by regulators, industries, 3rd parties, your community, and the media.
Think back to that fertilizer plant explosion in Texas a few years back that killed 15 people and injured over 175 people. Things like that are polarizing, and really make an impact on people's thoughts and minds. So whether it's a regulator, angry local citizens group, or a ticked-off ex-employee, people are starting to realize more and more that facilities are sitting on top of materials (not always explosive by the way) that can cause real harm to them, their community, and the surrounding environment.
It's getting to the point where saying "I've never heard of Section 313 or Form R or Toxic Release Inventory Reporting… what is it?" isn't holding water anymore. Believe me, if you feign ignorance on the subjects, regulators aren't buying it anymore.
Understanding TRI Reporting Costs & Prices
Conducting Section 313 Reporting, or Form R Reporting, or whatever you want to refer to it as, can be a big unknown for companies. If you aren't an expert yourself, how do you know what's involved? Is this an easy task or an incredibly complicated one? Will I pay a little or a lot to hire an expert? And since you don’t' want to overpay, it'd be nice to have at least some concept of what it will cost.
So here's the answer: It depends.
Not what you're looking for, right? Let me explain, and I'll give you some ballpark figures below.
Imagine you called a mechanic and said my car's acting up, how much to fix it? He's going to start asking questions. A lot of questions. There are too many variables and too many things to consider when it comes to repairing a vehicle for one blanket price. Fixing a tail light that's acting up versus replacing your transmission is going to be very, very different.
Imagine you called an accountant and said I need my taxes done, how much? They'd probably start going through questions like is this for just you or a business? Are you self-employed or do you work for someone? Have you reported in the past, or is this your first time? They would want to know more before they can give you a price.
What I'm getting at is, just like so many other things in life, asking for the TRI Reporting price up front is almost impossible, because there are several, several things to take into consideration. Just like going to the mechanic or getting your taxes done for you, the price of Form R Reporting can, and does, vary considerably depending on the specifics of your facility and your needs.
We've done reporting for large facilities using lots of reportable toxic chemicals and multiple complex release pathways to identify and quantify, and we've done it for simple facilities with one reportable chemical and no environmental releases. Do you think they cost the same? No, they don't.
TRI Reporting Cost Factors
So the cost of reporting is based on the complexity of your operations and facility. Here are some factors that will determine the cost:
- Your Reporting History - Have you ever reported before? More importantly, have you reported correctly before? Are we starting from scratch? Starting from scratch is usually a lot more work, although if what's been done before is incorrect or incomplete, that can also add a lot of work as well.
- Toxic Chemicals At Your Facility - The way it normally goes is the more chemicals, the greater the amount of work, and, therefore, the higher the cost. That's just a generality, but that's the way it almost always goes.
- Modeling Releases - What happens to those toxic chemicals? Are they released to the environment? Have they been spilled or leaked? Are they disposed of by a third party? How much, at what rate, and what is the total volume of the releases? Are they released via air, water, through the ground? If you have no idea at all, and some form of process mapping is involved, this can get very complicated, very quickly. And, therefore, the cost goes up. If, on the other hand, you have a pretty simple process with little or no releases to the environment, your cost will be a lot lower.
- Form A vs Form R Reporting vs Other Reporting - A lot of folks refer to TRI as Form R Reporting, which is kind of incorrect, but kind of right. Are there additional reporting requirements in your state? For instance, New Jersey has RPPR Reporting, which is like TRI, but a bigger headache. Your state may have something similar which needs to be done simultaneously. That will add additional cost.
- How Much Assistance Is Needed - What level of assistance can you provide? Do you have a sophisticated environmental and engineering staff that can help work through these complex issues or are you dumping it all on the lap of the expert to figure out? The more work that's required, the higher the cost will be.
The Average Costs of TRI Reporting
Alright, you've read this far, and you've been hoping for an answer as to what TRI Reporting prices are so let's put some numbers to it.
If you're hiring an environmental expert who really knows what they're doing, the cost of TRI Reporting should be somewhere around $2,000 for simple reporting scenarios.
For more complex reporting situations, TRI Reporting prices could be upwards of $25,000 (think large chemical facilities).
So, TRI Reporting costs between $2,000 and $25,000+ depending on the specifics of your operation.
I know, that's a huge spread, but like I said before, it really depends on a lot of factors. Without learning more about your operation, your reporting history, and your needs, anyone who throws a number at you is either shortchanging themselves or ripping you off.
The Cost of TRI Reporting Enforcement
Now, whether you thing TRI Reporting prices of $2,000 or $25,000 sound too rich for your blood, think about what you're paying for.
If you're a small operation with simple needs and an expert tells you the price of TRI Reporting at your facility would be in the neighborhood of $2,000 per site, that's completely acceptable. There's a lot of evaluation and behind the scenes work that needs to happen.
If you run a massive operation that's complex, with process water & stormwater permits, air permits, your sending materials offsite for disposal and recycling, etc. etc., you're going to need an expert to look into all of it. That's going to be a lot of time, research, and manpower necessary for evaluating your operation, and a $25,000 price tag is justifiable.
Additionally, consider that fines for failing to conduct reporting on time and correctly are some of the largest fines the EPA can hit you with. We've been hired by multi-state organizations that have received TRI Reporting fines in the 8 figure range. Yes, you read that right, I've seen TRI Reporting fines over $10,000,000.
The EPA can, and does, fine you for back years you haven't been reporting, and for every facility. So let's say you've got 15 operations that haven't reported for the past 3 years, you could be looking at 45 separate violations, each for thousands of dollars. Plus at that point, you're really under the microscope, meaning you'll have to get fully into compliance with every applicable law and regulation. So you'll have penalties to pay, permits to pay for, consultants to hire, possibly attorneys to consult with, the list (and price) goes on and on and on…
Can you afford that?
The cost of TRI Reporting depends on you!
The price of TRI Reporting TRI Reporting, honestly, is peanuts to the price you'll pay if you're out of compliance. If you think you need to report and are in over your head, do yourself a favor and start reaching out for some help. Plus, like I've emphasized, the cost of TRI Reporting is going to depend on what type of business you run, your past reporting history, and other complex variables about your operation.
We've been doing reporting for a variety of facilities for years, and we'd love to help. You can imagine I'm a bit biased when it comes to the issue, but you really are better off letting an expert, whether it's us or someone else, at least look over your shoulder to make sure you're doing this right. Yes it may cost more than you're ready to pay, but this is an unavoidable regulation which we see time and time again really hurting facilities. Trying to avoid it because you the think price of TRI Reporting is too high isn't the best call to make for your business.