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Understanding the Toxic Release Inventory and EPCRA Requirements

The federal Toxic Release Inventory (TRI) program tracks the management of toxic chemicals that may pose a threat to human health and the environment. Facilities in the United States within specific industry sectors are required to annually report the amount of each chemical that it releases to the environment and managed through recycling, energy recovery and treatment. The EPA defines a "release" of a chemical as an emission to the air or water, or placed in some type of land disposal.

When a company submits the TRI information, it is compiled by the EPA and becomes part of the national Toxics Release Inventory data base. The TRI Program was created in response to a few events that raised public worry about adequate preparedness for chemical release emergencies and the lack of available information on hazardous substances at local facilities.

One tragic event occurred in December 1984 when a toxic gas cloud comprised of 30 tons of methyl isocyanate gas escaped from a Union Carbide Chemical pesticide plant in Bhopal, India. The methyl isocyanate gas stayed low to the ground, causing victims throats and eyes to burn, inducing nausea, and leading to thousands of deaths that night in Bhopal, making it the world’s worst industrial disaster in history. Thousands more died in the following months as a result of their exposure, while survivors suffer with permanent injuries and disabilities. The following summer in August 1985, a serious toxic chemical release occurred at another Union Carbide plant, this one located in West Virginia. The toxic cloud released from the plant injured more than 100 local residents.

In response to these events, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986 to support and promote emergency planning and to provide the public with information about releases of toxic chemicals in their community. The TRI program was established in Section 313 of EPCRA.

TRI data, submitted by industrial facilities and made available to the public, is due by July 1st with the submittal of TRI forms (Form R) for toxic chemical management that occurred during the previous calendar year. To determine whether a facility must comply with TRI reporting requirements, a facility must meet all three of the criteria below, according to the EPA:

  • Is in a specific industry sector (e.g., manufacturing, mining, power generation)

  • Employs 10 or more full-time equivalent employees

  • Manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above threshold levels in a given year.

In general, chemicals covered by the TRI Program are those that cause:

  • Cancer or other chronic human health effects

  • Significant adverse acute human health effects

  • Significant adverse environmental effects

More than 650 chemicals are currently covered by the TRI Program. Facilities that manufacture, process or use any of these chemicals in amounts above established levels must submit annual TRI reports for each chemical.

Generally, facilities that report to TRI are large facilities involved in manufacturing, mining, power generation, chemical manufacturing and hazardous waste treatment. According to the EPA, not all industry sectors are covered by the TRI Program, and not all facilities in covered sectors are required to report to TRI.

TRI compliance requires an experienced environmental professional. CFR Environmental has a long track record of providing its clients with the expertise required for TRI reporting compliance and assists clients in determining the specific forms required for submittal to the EPA. Contact CFR Environmental for guidance.

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