Keeping an accurate record of your different environmental outputs - i.e. air emissions, water discharges, and waste generation - throughout the year is the foundation of Toxic Releases Inventory reporting (TRI). If your record keeping isn’t accurate, your annual report won’t have legs to stand on. But there’s another pressing issue in EHS management that can also jeopardize your TRI reports and put you at risk for fines, even if your record keeping is pristine.
That urgent issue is this: segregated EHS teams that don’t speak to each other.
Sadly, many enterprises divide their environmental compliance management into different emissions media or reports, and assign disconnected teams of EHS professionals to each one… without ever giving them a way to communicate properly. For example, a squad of air specialists might be doing the air reporting for a group of facilities, while a totally separate group of EHS managers from another site is assigned to do the National Emissions Inventory report for those same facilities.
A Growing Compliance Management Problem
What the EPA is reporting seeing more and more is that group A and group B aren’t communicating – they aren’t sharing records, they aren’t agreeing on estimation methodologies, they are filing reports that paint the same overall picture. Consequently, enterprises end up shooting themselves in the foot by filing conflicting reports that just end up getting them audited.
Here’s one classic real-world example our EPA auditor contacts have seen: an enterprise was required to track and report mercury releases from multiple sites. A mercury task force was created, and they used the most stringent monitoring estimation methodology to track releases and begin reducing them. At another site of this enterprise, a TRI reporting team was in charge of submitting mercury releases under TRI guidelines. However, the TRI team never consulted the mercury team and used a much more general estimation methodology and came up with vastly different numbers.
The EPA looked at both reports and wondered why the enterprise was reporting two very different sets of numbers. The difference was so vast, an audit was called for, and it was revealed that the enterprise was inconsistent in how it was calculating and reporting emissions – even though it did the right thing by creating a task force and using a more accurate monitoring method.
What Can You do to Prevent it?
There are two factors at work in these types of situations:
- A lack of systems and standards for communicating environmental data and emission records
- Failure to validate TRI reports for consistency with other data submitted to the EPA
Without a central repository of EHS data, and without an approach to verifying TRI data, you are putting your business at risk for noncompliance fines and penalties. ERA’s compliance specialists recommend using a tool that creates a centralized, online database for all your records and reports, so that even if you aren’t in constant communication with other EHS teams, you can be confident you are all using the same data and same methodologies. You can see how ERA helps enterprises like yours create a master centralized database here.
For the above reasons, ERA Environmental has teamed up with a recently-retired high level EPA TRI Coordinator to find out how the EPA hunts down red flags in TRI reports based on inconsistencies in reported emissions. We’ve created a short, free eBook that will teach you how to use your own NEI (National Emissions Inventory) data to determine if you are being consistent in the picture you are painting for the EPA and if you’re triggering any red flags that will get you audited.
- Where to find the highest-quality NEI data for your enterprise.
- Which types of red flags get prioritized by the EPA when it comes time to decide who gets audited.
- How to use that data to spot red flags in your TRI report in order to avoid fines and penalties, including insight on the auditors’ calculation used to determine if your NEI and TRI data aren’t in sync.
- Solutions and fixes to the root causes of common TRI red flags. You’ll be surprised how often enterprises make the same type of mistake every year, and how easy they are to fix.
- A straightforward solution to your TRI reporting problems.
The free eBook is available now, and is a must-read for any TRI reporter. You can download your free copy today by clicking the offer below. Learn more about TRI reporting red flags, improving accuracy, and protecting yourself from fines.