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Indiana Department of Environmental Management

Pollution Prevention

Pollution Prevention > Toxics Release Inventory > TRI: Who Must Report? TRI: Who Must Report?

TRI Reporting Criteria

A facility must report to TRI if it:

  • Is in a specific industrial sector (e.g., manufacturing, mining, electric power generation);
  • Employs 10 or more full-time equivalent employees; and,
  • Manufactures or processes >25,000 lbs. of a TRI-listed chemical or otherwise uses >10,000 lbs. of a listed chemical in a given year.

Additionally, Persistent, Bioaccumulative, Toxic chemicals (PBTs) have lower reporting thresholds:

  • >100 lbs. of Aldrin, Lead, Lead Compounds, Methoxychlor, PACs, Pendimethalin, Tetrabromobisphenol A, Trifluralin
  • >10 lbs. of Benzo(g,h,i)perylene, Chlordane, Heptachlor, Hexachlorobenzene, Isodrin, Mercury, Mercury Compounds, Octachlorostyrene, Pentachlorobenzene, PCBs, Toxaphene
  • >0.1 grams of Dioxin and Dioxin-like Compounds

If a facility meets these criteria, it must:

  • Submit a TRI Form R or Form A (Certification Statement) for each TRI-listed chemical it manufactures, processes, or otherwise uses in quantities above the reporting threshold.
  • Submit each TRI form to U.S. EPA.

A facility is eligible to submit a Form A if:

  • The chemical being reported is NOT a PBT chemical;
  • The chemical has not been manufactured, processed, or otherwise used in excess of 1,000,000 lbs.; and,
  • The total annual waste management (i.e., releases including disposal, recycling, energy recovery, and treatment) of the chemical does not exceed 500 lbs.

Please note that these are only general criteria. For more specific guidance on what chemicals and activities are subject to TRI reporting requirements, visit the Guidance Documents on U.S. EPA’s Web site.

Methods of Reporting

There are two (2) methods available to regulated facilities for submitting TRI data to the U.S. EPA:

  1. The majority of facilities submit TRI reports via TRI-MEweb, U.S. EPA's online TRI reporting application.
  2. Facilities are encouraged to use the fillable/printable TRI forms if they need to submit their forms in hard copy.
How to Submit Your TRI Report

Indiana only accepts reports submitted electronically via internet to the U.S. Environmental Protection Agency’s Central Data Exchange. Facilities submitting by internet or fillable/printable TRI forms are exempt from any separate mailing to Indiana Department of Environmental Management. Indiana does not impose additional requirements on facilities beyond what is required by federal law and regulations

Not all pollution generated by manufacturers and industry is reported on TRI. However, TRI does have certain advantages:
  1. It is multi-media. Facilities must report the amounts they release to air, land, water, and underground injection, and must report how much they send off-site;
  2. All quantities are reported in pounds. This reporting has an advantage compared to other databases, which often report releases as concentrations, or other databases which report releases by volume of waste. These measures are often impossible to convert into pounds;
  3. This means that it's relatively easy to obtain TRI data, that the data is well-known, and that it is becoming a "yardstick" for measuring progress in pollution prevention and waste generation.

The TRI data is reported by individual facilities, which send their reports to U.S. EPA every year. These reports are completed using a "Form R" or a "Form A" and submitted either in hard copy or with the TRI-Made Easy web (TRI-MEweb) reporting tool via the internet.

To better understand Indiana TRI data, it is recommended that you contact IDEM's Office of Pollution Prevention and Technical Assistance at (800) 998-7901.