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05/06/2008
TRI: What You Must Report

With the July 1 toxics release inventory (TRI) reporting deadline fast approaching, it's good to review your reporting requirements before the mad rush to meet the deadline sets in.

The community right-to-know provision of EPCRA Section 313 requires certain facilities to annually report data to EPA and states on its releases and other waste management activities for certain chemicals and make the data available to the public on a database-namely TRI.

EPCRA Section 313 reporting is required if your threshold quantities are exceeded for any EPCRA Section 313 chemical that is manufactured, processed, or otherwise used at your facility.

You are required to report any EPCRA Section 313 chemical, not listed as a PBT chemical, that is manufactured or processed at your facility in excess of 25,000 pounds per chemical or category over the calendar year.

You are required to report any EPCRA Section 313 chemical, not listed as a PBT chemical, that is otherwise used at your facility in excess of 10,000 pounds per chemical or category over the calendar year.

Note: PBT chemicals have their own thresholds.

Manufacture means to produce, prepare, import, or compound one of the chemicals on the list (e.g., if you make dye for clothing by taking raw materials and reacting them, you are manufacturing the dye).

Process means the incorporation of a listed chemical into a product for further distribution into commerce (e.g., adding a solvent as a dilutant when making paint, coating, or mixture is processing).

Otherwise use means the use of any EPCRA Section 313 listed chemical at a covered facility that is not covered by the terms of "manufacture" or "process" and includes uses of a listed chemical contained in a mixture or trade name product (e.g., using trichloroethylene to degrease tools is otherwise use).

You can download the EPCRA Section 313 chemical list for reporting year 2006 (the most recent list) here.


View more resources on Community Right to Know.

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