Addition of New Chemicals to TRI Reporting

Toxic Release Inventory (TRI), also known as “Form R” reporting, is a USEPA reporting requirement created under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). The TRI Program was established in response to several events that stirred public concern about local preparedness for chemical emergencies and the availability of information on hazardous substances. Submitting these reports helps to support informed decision-making by companies, government agencies, non-governmental organizations, and the public.

The report includes information on the facilities’ environmental releases and other waste management information. These reports are sent to both federal and state agencies. A facility is required to complete and submit a TRI report if they meet the criteria displayed in the diagram below:

Figure 1 – Facility Criteria for Toxic Release Inventory (TRI) Reporting

Lists of applicable NAICS codes and TRI-listed chemicals can be found on the USEPA’s Toxic Release Inventory Program webpage.

USEPA is proposing to add the following 12 chemicals to the list of toxic chemicals subject to TRI reporting:

• Dibutyltin dichloride (CAS No. 683-18-1)

• 1,3-Dichloro-2-propanol (CAS No. 96-23-1)

• Formamide (CAS No. 75-12-7)

• 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran (CAS No. 1222-05-5)

• N-Hydroxyethylethylenediamine (CAS No. 111-41-1)

• Nitrilotriacetic acid trisodium salt (CAS No. 5064-31-3)

• p-(1,1,3,3-Tetramethylbutyl)phenol (CAS No. 140-66-9)

• 1,2,3-Trichlorobenzene (CAS No. 87-61-6)

• Triglycidyl Isocyanurate (CAS No. 2451-62-9)

• Tris(2-chloroethyl) phosphate (CAS No. 115-96-8)

• Tris(1,3-dichloro-2-propyl) phosphate (CAS No. 13674-87-8)

• Tris(dimethylphenol) phosphate (CAS No. 25155-23-1)

In addition, USEPA believes that one chemical should be classified as a persistent bioaccumulative toxic (PBT) chemical and designated as a chemical of special concern with a 100-pound reporting threshold. EPA has classified 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran (HHCB) as a PBT chemical due to its bioaccumulative nature in aquatic species and persistence in soils and sediments. This action lowers the reporting threshold for this compound to 100 pounds as opposed to the normal 10,000-pound and 25,000-pound thresholds for other chemicals.

CFR has over three decades of experience helping facilities complete and submit their TRI reports. Give us a call today for a free consultation.