Toxic Inventory Release (TRI) reporting is the most difficult time of the year for EHS professionals: it’s an annual compendium of your air, water, and waste emissions that forces you to look back at all your records, activities, and materials used throughout the entire year.
Because the scope of TRI Reporting is so large – both in time covered and variety of emissions media – it is shockingly easy to make a major mistake in a calculation that could result in getting audited by one of the EPA’s trained environmental auditors. TRI is a prime opportunity to get heavily fined and see your stock value plummet if you aren’t careful.
Once you’ve submitted your TRI report, it undergoes heavy scrutiny from EPA auditors who have been meticulously trained to hunt down red flags in your TRI report. Eagle-eyed auditors know exactly what to look for, and it’s time you learned how to spot the red flags before they do so that you can correct them before they cost you.
We teamed up with a recently-retired high-level TRI coordinator to learn exactly how a TRI report is scrutinized and how auditors decide which facilities to target for an investigation. We’ve been given permission to share this vital information with you so that your TRI reports will be more accurate.
For a full run-down of the common TRI reporting best practices outside of this auditing topic click here: TRI Reporting Best Practices.
Here’s the Insider Scoop on How Auditors Check and Verify Your TRI Report
One of the secrets is to look back at your National Emissions Report (NEI) data and verify TRI emissions against the picture you painted about your air emissions during your last NEI report. EPA Auditors look back at your NEI data - which is compiled by the State and EPA in a public-access database called ECHO (Compliance Enforcement and History Online). They’ve been directed to look for specific red flags:
- Significant discrepancies between emissions reported for NEI and TRI. Your NEI and TRI emissions look suspiciously different, auditors will want to dig deeper. (EPA does not expect, of course, that the numbers will necessarily match, as TRI and NEI reports don’t always capture the same types of data.)
- TRI-reportable emissions being present in your NEI records but not in TRI report. This means you’ve forgotten or omitted something. It often means you’ve overlooked a TRI category.
- Major discrepancies – is your NEI data and GTRI data saying something completely different? It surprising how often a facility will use one estimation method for NEI and another for TRI, resulting in different emission reports.
This is just a surface look at how auditors detect red flags in your TRI air emissions reports and put you on the watch list for further audits and investigations. For a more in-depth look, click here to learn more about accurate TRI Reporting.
If one or more of these red flags has been spotted in your report, it’s time to prepare for a follow up phone call or in-person audit. Prepare yourself by getting all your records from the year, chemical inventory data, and calculations for that particular type of emission and putting them in one centralized location. The EPA auditors are data-focused and will need to see every scrap of data you can dig up to justify your TRI report.
Get the Full Report and Protect Yours Enterprise from Penalties
ERA has compiled the complete list of tips and step-by-step guidelines for spotting and fixing red flags into a short, helpful eBook which is now available as a free download. In just a few minutes, you’ll learn essential skills and best practices:
- 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 synch.
- 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.
This eBook is essential reading for any TRI reporter. It gives you the steps you need to accurately validate and feel confident about your final TRI report. Be securer in the knowledge you’ve red flag-proofed your TRI air emissions report this year by downloading the short eBook today.