MayDay in this business marks the start of the Toxic Release Inventory (Form R) reporting season. As you settle in to assembling your chemical processing, transfers and releases data, here are a few key things to know and places to go to get through the adventure…
Chemical List Updates
The one recent change to the TRI chemicals list for 2012 reporting is the reinstatement of the reporting requirement for hydrogen sulfide. If you haven’t been reporting this chemical in the past few years, but manufacture, process or otherwise use it in TRI threshold quantities, you must report for 2012.
The Environmental Protection Agency (EPA) has issued a proposed rule to require electronic submission of TRI forms, which can be found at this page: www.epa.gov/tri/lawsandregs/electronicreporting/index.html.
The rule has not been finalized. So, for 2012, the agency will continue (reluctantly) to accept paper copies of TRI Form R (and Form A) reports.
Electronic filing through the on-line TRI-MEweb program is the preferred reporting method. In a rare instance of agreeing with the regulatory agency, we strongly advise use of TRI-MEweb, as it helps identify and avoid many potential errors that may arise when you fill out forms for printing (like a typo in the EPA ID Number for an off-site transfer location, a seemingly minor error that turns out to be notably frustrating to correct later – and don’t get me started on actual arithmetic mistakes!).
TRI-MEweb resources can be found at: www.epa.gov/tri/reporting_materials/trimeweb/index.html
But to use TRI-MEweb, you must first register with the EPA Central Data Exchange: https://cdx.epa.gov/
For other information and general TRI reporting guidance, you can either visit the EPA page at www.epa.gov/tri/reporting_materials/guidance_docs/index.htm or, as always, contact T. Cozzie Consulting with questions or requests for assistance.