Form R – Toxic Chemical Release Inventory Report
What is a TRI Form R Report?
Form R, the Toxic Chemical Release Inventory (TRI) Report, is a comprehensive annual report that documents the use and release of toxic chemicals that are commonly used in industry. This requirement is identified under Section 313 of the Federal Emergency Planning and Community Right-to-Know Act (EPCRA). The deadline for submittal of the annual Form R Report is July 1st.
Of all the annual Federal and State EPA compliance reports required of industry, the TRI reporting deadline is possibly the most aggressively enforced. The Chicago office of the U.S. EPA is involved in widespread enforcement of this regulation, many times with fines involved.
Helpful hint: TRI Reporting and Form R Reporting are the same thing!
Who needs to file a TRI Form R Report?
A facility must submit TRI Form R Report if it meets these reporting requirements:
- It is in an industrial sector subject to TRI reporting, based on the facility’s NAICS industry code classification. Manufacturing facilities are subject to TRI reporting.
- The facility employed 10 or more full time equivalent employees during the reporting year.
- The facility manufactured, processed or otherwise used a TRI-listed chemical in excess of the applicable reporting threshold for the reporting year.
The reporting thresholds are usually 25,000 lbs or 10,000 lbs depending on how the chemical is processed at the facility. However, some chemicals have very low reporting thresholds of 100 lbs, 10 lbs, or even lower. There are currently 593 individual chemicals and 30 chemical categories on the TRI reporting list. This includes many metals and metal compounds.
All manufacturing facilities should evaluate their TRI reporting requirements every year.
Our staff can conduct a thorough evaluation of your operations to identify toxic chemical usage, and determine if a TRI report is required. If a Form R Report is required, our professional staff has the expertise and experience to quickly and efficiently prepare all of these forms.
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