It is undeniably in your best interest to avoid featuring on the ECHO list. But what's the best way to do this?
This database includes environmental information about the chemicals and substances you use in your facilities, which end up forming your pollution. It also contains more sensitive information about why you violated and how much you paid in penalties. It also contains your public contact information.
This information is shared through the ECHO list for 3 years after each year of noncompliance.
The facilities and businesses on the ECHO list have in some way fallen out of compliance with one of the environmental acts designed to protect the public and the environment:
- the Clean Air Act (CAA)
- the Clean Water Act (CWA)
- the Resource Conservation and Recovery Act (RCRA)
- the Safe Drinking Water Act (SDWA)
- the Emergency Planning and Community Right-to-Know Act (EPCRA)
One of the easiest ways to fall out of compliance is to fail to, or inaccurately submit your Toxic Release Inventory (TRI) report by July 1 each year.
Here are 3 strategies that you can implement today to keep yourself off of the EPA’s ECHO list this year and for years to come.
Prioritize time for TRI reporting activities
One of the biggest hurdles in TRI reporting is the huge number of hours the process can take. Proper data preperation is key and TRI reporting requires the collection of a year’s worth of emissions and substance data.
It also involves calculating toxic emissions and reporting them using the EPA’s online TRI reporting tool, TRI-ME Web.
This intimidating time commitment often has people putting off their TRI reporting activities until it’s too late, or hiring costly consultants to do it at the last minute.
The solution is simple: prioritize time to collect all of your emission data from the reporting period well in advance of the July 1st deadline.
After all, you won’t know how big a job the actual reporting is going to be until you’ve gathered the raw data. This way you’ll be better able to predict how much more time you’ll need and budget accordingly.
This can make all the difference in meeting the TRI reporting deadline and avoiding fines.
Research the latest regulations
Your TRI reporting requirements can change from year to year, even if you haven’t changed a single process or substance in your facility.
You can’t assume the time it took or the methods you used last year set the standard for this year’s TRI reporting.
The EPA is constantly evaluating substances and adding to the reportable substance list to better protect the environment and the general public.
That’s why it’s important to have a system in place for keeping up with the latest environmental regulations before you need them, so you can be prepared and proactively adjust your TRI reporting processes.
Knowing the latest regulations also means that you won’t submit an inaccurate report and end up on the ECHO list, even though you submitting a perfectly good report.
Get familiar with important TRI reporting exemptions
The TRI reporting process is full of exemptions that can have a big impact on your overall emissions. For example, many reportable substances should only be included in certain forms, like fumes or dust.
Another misunderstood exemption is the De Minimis exemption regarding certain concentrations of non-PBT chemicals in mixtures.
Every year facilities make the mistake of over-reporting their emissions because they aren’t aware of these exemptions.
This strategy is perhaps the most difficult. It takes experience and time to study and understand the intricacies of the EPA’s TRI reporting regulations. Time that the typical EH&S specialist simply does not have due to a dozen other environmental reports and permits that need constant attention.
A Better Way
All of the above strategies have something important in common: they can be done using a environmental management system.
Having an environmental system in place can assist in the implementation of these compliance strategies and even automate many of the processes.
If you're looking for a way to improve your TRI reporting, or are unsure about upcoming changes, you can download our free TRI Reporting Survival Guide.
December 22, 2011