Toxics Release Inventory (TRI) reporting requirements changed on March 11, 2009, as a result of a change in federal law. These changes affect TRI reports due July 1, 2009. The change returns TRI reporting requirements back to the rules in effect prior to December 22, 2006.
The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals be submitted on the more detailed “Form R.” For all other chemicals the shorter form, “Form A” may be used only if 1) the annual reporting amount is 500 pounds or less, and 2) the chemical was manufactured, processed or otherwise used in an amount less than 1 million pounds during the reporting year.
U.S. EPA will issue a rule shortly to revise the regulatory text in the Code of Federal Regulations to reflect these changes. TRI-ME software and other reporting assistance materials are being revised and will also be available soon.
Due to the timing of the legislation, facility owners and operators, including many small businesses, will not have as much time as usual to prepare TRI estimates, and they may not have acquired or retained the relevant data from 2008. Owners or operators of facilities may use readily available data of the amounts involved (where such data are not available, reasonable estimates may be used) to complete Form R.
TRI reports for 2008 are due on July 1, 2009. If you have questions about reporting requirements, please contact the TRI Database Manager at (800) 988-7901.