Every year, EHS professionals struggle to gather the previous year's emissions data that they had long forgotten, and spent hours (that could have been otherwise used) trying to recover that lost data to submit this year's TRI report. If you didn't properly maintain your records throughout the year, the entire month of June may have been taken over by backtracking and trying to piece together a whole year of material and waste data.
And after TRI reporting is complete, every year EHS professionals vow to do something different next year. Did you make a similar promise to yourself this year?
This short article will tell you the best way to keep that promise and avoid TRI-reporting stress next year by giving you the tips and best practices that will improve your TRI reporting.
TRI Basics: What is it and Who Reports?
The Toxics Release Inventory is an EPA database that contains information on releases of toxic chemicals from industrial facilities across the United States. This database covers over 680 toxic chemicals from over 20,000 facilities. Data on industry toxic chemical releases and waste management activities provides transparency to government agencies, NGOs, and the general public.
You are required to report if you are a source of emissions that meets all three of the following criteria:
1. Your facility has 10 or more full-time employees or 20,000 man hours defined by the EPA.
2. Your facility has a North American Industry Classification System (NAICS) code that falls under EPA TRI reporting requirements. For a complete list of NAICS codes required to submit TRI reports, check this site.
3. You manufacture, process, or use more than the following threshold amounts:
for non-PBT chemicals:
25,000 lbs manufactured; or
25,000 lbs processed; or
10,000 lbs otherwise used.
For PBT chemicals:
10 or 100 lbs depending on the chemical; or
0.1 grams of dioxin or dioxin-like compounds
If your facility meets the above criteria you should have filed a TRI report by July 1 this year. Keep in mind that even if you didn't meet the above criteria this year, it is still possible your operations this year will increase and bump you up into needing to report. It's a good idea to confirm your TRI reporting requirements every year rather than making assumptions.
TRI Reporting Overview
The TRI reporting process today involves submitting your emissions report using the EPA's online reporting tool, TRI-MEweb. Each chemical you release is reported on TRI-MEweb by filling out either a Form A or a Form R; facilities determine which form to use by following the EPA's guidance document found on Toxic Chemical Release Inventory Reporting forms and Instructions. Read Section B on page 9 for full details.
TRI-MEweb is a relatively straightforward reporting tool. But it is also simply a reporting tool. It will not complete complex emissions calculations for you or provide any EHS management information about your facility. It does, however, accept formatted data inputs from other reporting systems - so if you're looking for a faster way to complete TRI reports and get insight into your operations, consider an EHS reporting software platform.
In addition to reporting each chemical on TRI-MEweb, you must also submit Source Reduction and Pollution Prevention practices. These are steps you plan on following to reduce the impact of your operations, including reducing the amount of pollutants released or any practices that reduce the hazards to public health and the environment.
Some examples of source reduction activities improving maintenance schedules, instituting better labelling procedures, installing vapor recovery systems, and many others. An extensive list of source reduction activities can be seen in the EPA's activity codes (W-codes) in the follow section on how to report source reduction plans.
How to Report Source Reduction
Reporting your reduction practices for TRI is a three-step process:
1. Identify whether your facility implemented any new Source Reduction Activities for the reporting year.
2. Select all relevant source reduction activity codes (W-codes) from the EPA's list:
Good operating procedures (e.g. improved maintenance schedule)
Inventory control (e.g. institute better labeling procedures)
Spill and leak prevention (e.g. improved rinse equipment)
Raw material modifications (e.g. increased purity)
Process modifications (e.g. instituted re-circulation within a process)
Cleaning and degreasing (e.g. improved rinse equipment)
Surface preparation and finishing (e.g. improved application techniques)
Product modifications (e.g. modified packaging)
3. Select all relevant source reduction method codes (also known as T-codes) from the list below. T-codes indicate the internal and/or external methods you used to identify the possibility for implementing a source reduction activity.
Internal P2 audit
External P2 audit
Materials balance audit
Participative team management
State government technical assistance program
Federal government technical assistance program
Trade association assistance program
TRI Reporting Best Practices
No matter how experienced you are in TRI reporting, there will always be room for improvement. After two decades of working closely with EHS managers to complete TRI reports (back from when paper copies were the only reporting method to today's sophisticated e-reporting tools), we've figured out some of the most important best practices that save you from a TRI-induced migraine.
The cornerstone of any easy TRI submission is having good, clean data on hand when you need it. You should keep and maintain EHS records of your emissions and material usage on a regular basis - preferably at least monthly, if not more. Of course, collecting good data is no help if you don't store it in a standardized and organized manner. We recommend a centralized database that follows a clear logic about where to store data: that way anyone on your team can collect data and you'll still know exactly where to find it. Having powerful search functions and audit trails will also be helpful in tracking when and where data came from.
Automate and Build In Calculations
No matter how diligent you and your team are when it comes to emissions calculations, doing them by hand for each and every chemical for your TRI report is almost guaranteed to produce a small human calculation error.
That's why another best practice is to automate your emission calculations as much as possible. That way you can rely on having the right results, and it will take less time too. Depending on the type of database you're using to store your chemical data, you have a few options. A popular choice for spreadsheet users is to build custom formulas to automatically calculate emissions - this works fine for a small database in some cases, but after a year or two of data getting plugged into the spreadsheet most EHS managers find that their results start getting thrown off by small data entry errors which become impossible to find.
A more long-term option is to use a reporting platform that has the necessary TRI calculations built right in. You can either plug your own data into the software, or, better yet, have the software handle both the data management and processing, and get reliable emission results out the other end.
Because TRI-MEweb accepts input from third-party reporting tools to be uploaded and submitted, you shouldn't be hesitant to implement a TRI reporting tool if you're spending more than a few hours on your annual TRI reporting. The EPA is happy to accept more accurate data, and you'll save significant time and money off your TRI report each year.
Save Historical Data, Regardless of Reporting Status
All of the emission calculations you did for the year, even if you were not required to report, should be saved and kept in an accessible location where it can be accessed on demand by your EHS team. This historical data is essential, regardless of whether you submitted it or not.
A common mistake many businesses make is to assume if they didn't have to report this year then there's no reason to keep the records they used to determine if they were above or below the triggering thresholds. Unfortunately, an environmental auditor will be expecting to see those records, so if you don't have them you'll either have to redo all the work, face stiff fines, or even be suspected of failing to report TRI reports when you should have. You should also keep copies of every confirmation of receipt TRI-MEweb provides on file.
Keeping historic TRI data on hand isn't just to protect your business in case of audits, it also plays an essential role in your business' continuous improvement cycle. Being able to compare and benchmark TRI data year to year will be one of the best methods for charting your growth and for seeing if your source reduction activities are paying off.
Follow these straightforward best practices, and your next TRI report will be more acccurate, take less time, and more useful to your business development.
Free Download: TRI Accuracy eBook
ERA has partnered with former EPA TRI Coordinator Nora Lopez to create a comprehensive PDF guide for analyzing your own TRI report for common errors and red flags that the EPA uses to determine if your submission needs an in-depth review.
We're proud to offer this guide as a free on-demand download. Get your copy here:
Image Credit: Courtney Rian
December 11, 2017