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July 16, 2019

Following the Red Tape Road: A Guide to Regulatory Compliance in TRI Reporting


The Rise of Regulation
Regulations at every level are constantly updated with the intention of making industrial plants more transparent regardingthe chemicals that they store and use.  This increased paperwork burden poses a challenge to companies attempting to control costs while remaining in compliance with such regulationsalongside the myriad of requirements necessary in maintaining a business.

In order to ensure such regulatory compliance, EHS Managersmust function as their companies’ resident experts in several areas. Unfortunately, however, this can prove to be a time-intensive task. Many facets of an EHS Manager’s job can be tedious and confusing, demanding vast swaths of a manager’s limited time. The foremost example of such work is TRI (Toxic Release Inventory) reporting.  

What is TRI Reporting?

Before addressing the particular difficulties of TRI, it is important to first understand that it is merely one component of a comprehensive set of regulations known as EPCRA (Emergency Planning and Community Right to Know Act).

Distinguishing between the particular requirements of TRI reporting as opposed to the general requirements within EPCRA is a source of confusion for many EHS Managers. Tier II of EPCRA deals with the volume and type of chemicals found on one’s site at any given time. Meanwhile, Section 112 (r)addresses the presence of a compliant Risk Management Plan for each of the chemicals on site which might necessitate one.

Requirements for TRI reporting go through a series of qualifications as follows:

1. The facility has 10 or more full time employee equivalents (i.e. a total of 20,000 hours or greater; see 40 CFR 372.3).
2. The facility is included in a North American Industry Classification System (NAICS) Code that is on the EPCRA Section 313 list or is a Federal facility.
3. The facility manufactures, imports, processes or otherwise uses any ECPRA section 313 chemical in quantities greater than the established threshold in the course of a calendar year.

For a more comprehensive explanation of the TRI system, the report explanation document can be downloaded here.


The Difficulties of TRI Reporting

Following TRI qualifications, a reporting facility mustdetermine whether a simplified Form A can be submitted in lieu of the more complicated Form R.  This can be determined by assessing whether the chemical is a designated PBT (Persistent,Bioaccumulative, and Toxic) compound, or by whether the volume of any Section 313 chemicals used is less than 1,000,000 lbs. and the reportable amount of that compound is less than 500 lbs.  Being as the Form A submission is must less complicated than that of Form R, it is much more efficient for the EHS Manager to use this form whenever possible.

The EPA’s new web-based reporting tool, TRI-MEweb, isdesigned to reduce paper usage and eventually decrease preparation time for the reports.  However, as of now, using thiselectronic report does not make the process faster or easier.  The last assessment from the Federal OMB office estimates that the time involved in accurately compiling and reporting each chemical on a Form R submission totals 35 hours.  

How WASTELINQ Helps

Luckily, there is another option: WASTELINQ.  WASTELINQ’swaste management software is capable of detecting and compiling information associated with Section 313 chemicals for reporting, which results in a radical decrease in the time and effort expended by EHS Managers. The current Section 313 inventory list from EPA contains about 650 chemicals that are compiled by CAS numbers.  However, because there are oftenseveral different names for a given chemical compound, WASTELINQ’S database can recognize over 4,000 different chemical names in order to ensure that chemicals are filed appropriately.  Further, WASTELINQ’s database is continuallyupdated to provide a seamless link between identifying and compiling information for easier, more accurate reporting.  For more information about how WASTELINQ can increaseproductivity in the management of industrial and hazardous waste, please contact us at www.wastelinq.com.

  

Founded in 2017, WASTELINQ (an E4 Holdings Company) provides innovative technology solutions designed and tested by waste industry service experts to waste industry customers and service providers. Leveraging industry-specific technical expertise, WASTELINQ’s “service as a software” enables customers to utilize proven solutions that achieve both environmental and financial stewardship, maximizing the business value of responsible waste management strategy. Additional information can be found at www.WASTELINQ.com or by contacting sales@WASTELINQ.com.

 

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