The Minimalist’s Guide to TRI Reporting

What is TRI Reporting?

TRI reporting (short for Toxics Release Inventory reporting) is an annual report done by businesses that manufacture, process, or otherwise use hazardous chemicals as part of their operations. TRI reporting is due July 1, every year. Businesses must report the quantity of TRI chemicals and how they are using these chemicals using the EPA's TRI-MEweb system. Not every business needs to report, as there are reporting thresholds set by the EPA (if you aren't sure you need to report, use the EPA's free threshold tool).

The annual Toxic Release Inventory (TRI) report, due July 1, is one of the biggest events in the environmental compliance calendar. And because of all the data collection and calculations required to create the final report, most environmental managers start weeks - if not months - in advance to get everything done on time. When we talk to environmental managers, the weeks leading up to July first are some of the most stressful of the entire year. 

We started to ask ourselves: how can people reduce the amount of stress when it's time to prepare their TRI reports? 

In manufacturing today, there's a push towards being lean and streamlined. It's a truly minimalist and efficient way of approaching business processes. We decided to start applying these minimalist practices to getting ready for the Toxic Release Inventory reporting deadline. 

Here are a few ways to improve your TRI reporting processes to reduce stress without compromising accuracy or data integrity.

Take Stock of TRI Data Frequently, and Make Room to Breath

The list of things to account for when it comes to TRI reporting is seemingly endless and it can get overwhelming quickly. 

• Currently there are over 590 chemicals and 30 chemical categories that are required by TRI reporting.
• These lists change every year and need to be monitored frequently to ensure you are reporting the proper data each year. (The EPA provides a list of updates online each year.)
• The EPA constantly updates and upgrades its TRI reporting software, known as TRI-MEweb. You'll need to make sure your data is formatted properly for upload each year. (Remember to check the most recent updates on TRI-MEweb.)

If you get a headache from just reading that list, chances are your business could do with some de-cluttering and TRI reporting workflow improvements. If you're approach to monitoring these changes is systematic, you'l find it much simpler. 

Since one of the biggest pains in the months leading up to the TRI reporting deadline is this mountain of tasks to do, things to monitor, and chemical data to collect. Most people give themselves a few weeks to get it all done.

Minimalist tip: instead of trying to get everything done in just a few weeks, why not accomplish less time-sensitive tasks throughout the year? This may sound impossible, but with some forethought it’s not.

Here are a few examples:

• Keep up to date with regulation changes as they happen - set aside a time every quarter to review the EPA resources referenced above to see if any changes have been announced. This will give you ample time to adjust your recordkeeping. You can also work with environmental groups that keep track of and maintain chemical regulatory lists for you. 
• Go over your chemical inventory data from last year. Although there will be changes each year, your last TRI report is a great starting point. It will list all the reportable chemicals from last year - so you;ll want to make sure you're including all of them again this year unless you have records showing how you've phased them out. The EPA actually compares your reports and will ask questions if they see you've left certain chemicals out or changes the reporting quantity significantly. For a guide on how the EPA compares TRI reports to see if you need to be audited, check out this link. 
• Refamiliarize yourself with any exemptions your facility claimed last year so you aren’t left scratching your head when it comes time to do complex calculations.
• Collect chemical usage data that is needed for TRI reporting calculations on a monthly basis. Work with your shop floor team to get a constant stream of chemical usage data in smaller chunks, rather than digging back months into your records to find data. This also helps prevent losing data and needing to do some serious digging to find t again. 

Keep Your TRI Data in One Place - Centered and Manageable

One reason TRI reporting is such a time-consuming endeavor is because most facilities have an inefficient environmental data management system.

Environmental and EH&S specialists are often forced to use spreadsheets and enter the same data into several different documents or databases just to complete a report for one substance. This is a waste of your time, and adds to the stress of TRI reporting. 

No wonder those responsible for the TRI report dread it so much!

Most minimalists will tell you that the first step in cleaning up and streamlining is to put everything in front of yourself and take stock. You can apply this same principle to your chemical records: put everything into a centralized database, where data is entered only once - you'll soon spot missing data or contradictions in your records. We recommend switching your environmental management system out for an EMS software  platform with TRI reporting built in. 

Having everything in one place means less searching, less data entry, and simply less time in compiling your report. 

Automate, Automate, Automate

The number one way of minimizing your TRI reporting work is to automate as much of the work as possible.

The biggest time savings come from working with your material vendors (like your coatings manufacturer) to get your product inventory data imported directly into your product database.

Of course, this requires a certain level of trust between the two of you (and a little tech know-how to set up an integration system), but this effort definitely pays off big time when it comes to your TRI duties for the next year.

Another trick to making TRI reporting less of a hassle is to automate the threshold determinations and emissions calculations. Sometimes people do this with the built-in Excel spreadsheet formulas, but it’s preferable to have a less error-prone system in place.

If you’re planning on automating the calculations themselves, make sure you have checks and balances in place to catch any unexpected errors in your system, since you can’t afford to submit incorrect emissions data.

No matter what, the TRI report will always require some time and effort from an environmental specialist who knows the facility inside and out.

However, with some long-term planning, it is entirely possible to make your TRI reporting a truly minimalist experience. 

Want More TRI Reporting Resources? Look No Further!

What we covered here is just the basics of getting a smoother TRI reporting program up and running. There are a number of more advanced tactics that you can apply to your TRI management to protect yourself from EPA audits or common TRI mistakes. 

We recommend you start with this free course from former EPA TRI Coordinator, Nora Lopez. Her course, "EPCRA Essentials Course: Complete Training in SARA, TRI, and Form R Compliance" gives you everything you need to know for TRI reporting.

You can also check out ERA's complete library of TRI resources.

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