The Toxic Chemical Release Inventory (TRI) report deadline is approaching rapidly! TRI reports are due July 3rd this year, as the normal due date of July 1st falls on a weekend. There are several changes to this year's TRI report that might affect your facility, including:
- The most noticeable change is the improved TRI-MEweb functionality EPA implemented this year. While this is not a regulatory or methodology change, the EPA retooled the software portal that facilities use to access, navigate, prepare, validate, and submit their TRI reports in EPA's consolidated data exchange (CDX). Some of these changes include easily accessible and improved online help (including live chat support), simplified navigation and facility management, enhanced options for certifying officials, improved error checking, and improved ease of access to previously submitted information. For more information, the EPA released a TRI-MEweb training video, and also posted answers to questions that were raised during the initial training video presentation.
- With the new TRI-MEweb rollout, there have been occasional glitches with some sections of the online forms. Trinity has found that clearing the web browser's cache may assist in removing some of the critical error messages encountered.
- There is a new chemical that needs to be reported in reporting year (RY) 2016 TRI: 1-Bromopropane (CAS No. 106-94-5). This chemical must be reported in this year's TRI report if your facility manufactures, processes, or uses this chemical and reporting thresholds for this chemical are exceeded. 1-Bromopropane is a liquid or gaseous solvent that has a wide range of industrial purposes, such as in asphalt production, synthetic fiber production, aviation maintenance, and degreasing plastics, optics, and metal surfaces.
- In an effort to push a focus on pollution prevention, EPA has increased the importance and convenience of the pollution prevention (P2) information reported in Section 8.10 and 8.11 of Form R. Such information may be highlighted in the annual TRI national analysis, which displays source reduction activities reported or production-related waste managed for a handful of parent companies. This change encourages more public transparency and accountability, so facilities may wish to be more thorough in responding to the P2 information in Form R. Furthermore, P2 data can be accessed at the corporate level through the TRI P2 Search Tool.
- Something to keep in mind for next year's TRI report is that a new chemical category has been added for the RY2017 TRI: the Hexabromocyclododecane (HBCD) category, including CAS numbers: 3194-55-6 (1,2,5,6,9,10- hexabromocyclododecane) and 25637-99-4 (hexabromocyclododecane). If your facility manufactures, processes, or otherwise uses this flame retardant (commonly used in polystyrene foam, upholstery or fabrics, and electronics), consider collecting release and other waste management information for the RY2017 TRI.
For more information on TRI reporting, including how your facility may be affected by the changes noted above, or if you have general questions about TRI applicability or reporting, please reach out to your local Trinity Consultants office.