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 regarding the 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:
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 must determine 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, is designed to reduce paper usage and eventually decrease preparation time for the reports. However, as of now, using this electronic 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 often several 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 continually updated to provide a seamless link between identifying and compiling information for easier, more accurate reporting. For more information about how WASTELINQ can increase productivity 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.