Updates to the Toxics Reporting Inventory (TRI) Reporting Requirements

It's that time of year again! Annual TRI reports are due on July 1, 2009 and there have been a few changes to the reporting requirements. On April 21, 2009, the 2009 Omnibus Appropriations Act removed the requirements that were added to the TRI rules as part of the TRI Burden Reduction Final Rule, published in the Federal Register on December 22, 2006. The intent of the TRI Burden Reduction Rule was to expand the criteria that industry could follow in order to report using Form A.

Industries typically submit either Form A or Form R for chemicals that are required to be included in the TRI. Form A is a less burdensome form to complete and does not require details such as chemical releases to the air, water, and land as required by Form R. As a result of the 2009 Omnibus Appropriations Act, the requirements to determine if a facility is eligible to submit a Form A have changed. Facilities will not be able to use Form A for any chemical that meets the definition of a PBT chemical. For Reporting Years 2006 - 2007, PBT chemicals could be included on Form A if specific criteria were met. In addition, facilities can now use Form A for non-PBT chemicals if the annual reportable amount is less than 500 pounds and the quantity of manufactured/processed/or otherwise used is less than 1,000,000 pounds. For Reporting Years 2006 - 2007, if a non-PBT chemical had an annual reportable amount less than 5,000 pounds, Form A could be used.

In addition to the above changes, the National Council for Air and Steam Improvements (NCASI) has updated toxic emission factors for pulp and paper mills and wood products facilities. Facilities in those industries will need to update their emission calculations to reflect the revised NCASI emission factors. 

The Reporting Year 2008 will be the last year facilities can submit their TRI using the TRI-ME desktop software. In future Reporting Years, TRIs can be submitted either using TRI-MEweb application or the paper Forms A or R.

For questions regarding TRI Reporting, contact Melissa Hillman at mhillman@trinityconsultants.com or (253) 867-5600.