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Government Safety RegulationsEnvironmental Health and SafetyIndustrial HygieneSustainability in Health and SafetyWorkplace Training Strategies

Reduce your chemical footprint: Best Toxics Release Inventory reporting practices for 2021

By Mark Chocola
Toxic chemicals

Credit: Getty Images

March 24, 2021

The U.S. Environmental Protection Agency (EPA) released its 2019 Toxics Release Inventory (TRI) National Analysis earlier this year, and companies across the nation are actively working to reduce their chemical footprint. Despite a minor increase in the Pacific Southwest Region, the overall release of TRI chemicals was down by 9 percent in 2019.

The TRI works to track the management of certain toxic chemicals released by industrial facilities. More than 700 chemicals are tracked across 33 categories, each of which is released - intentionally or not - as solid, liquid, or vapor. Every chemical on the list can cause damage to the environment or have adverse effects on humans, such as cancer or other health problems.

In tracking the release of toxic chemicals, the EPA allows the public a fully transparent view of how companies adhere to environmental laws. It also gives a clearer look at the damage each company is or isn’t causing.

In 2021, it’s more important than ever to make sure your company is environmentally friendly by actively working to reduce the chemical waste it produces and releases. If you don’t, you run the risk of losing customers and being fined. Here are four easy ways to make sure your company is playing its part in the effort.

Know whether your company needs to file a TRI report with the EPA

The TRI program requires facilities within specific industries, including manufacturing, electric power generation, and chemical manufacturing, to file a report each year. This report outlines how much of any chemical was released into the environment, how it was managed, and if the release was planned or unplanned.

Your company is required to submit a TRI report if it:

  • Has 10 or more full-time employees or 20,000 man-hours
  • Falls under the North American Industry Classification System (NAICS) code
  • Manufactures or imports, processes, or uses any listed chemical in a quantity greater than the threshold amount (25,000 pounds for any listed chemical manufactured, imported, or processed by the facility; 10,000 pounds for any listed chemical that is used annually)

Update your TRI data consistently and save historical data

To make sure your company will have the report at its most accurate - and ready on time -  it’s important to take a number of steps.

Above all, standardize your recordkeeping. All relevant employees should be able to easily understand how to navigate it, read it, and, more importantly, add to it.

Ideally, data should be updated on a monthly basis to keep it as accurate as possible. Consider avoiding mismanagement or confusion by investing in a reporting software that automates the process, including the calculations, for you.

Even after a TRI report is filed with the EPA, keep your records on hand to avoid any future discrepancies.

File your TRI report by July 1

If your facility meets the requirements of those required to submit a report to the EPA, be ready for the July 1 deadline.

The TRI program will begin to release reporting instructions, updated training materials, and TRI-MEweb reporting software by January. Carefully review and prepare each form with relevant data along with any prevention activities that your company participated in throughout the previous calendar year.

Should a company fail to submit a report on time - or not report its findings at all - it will face significant fines from the EPA. These vary greatly can often be worth hundreds of thousands of dollars. The EPA can also open investigations into your reporting, recordkeeping, and waste handling, which can result in more fines - all the more reason to be diligent.

In addition to these fines, the EPA has also required companies to make substantial donations to the communities impacted by chemical releases.

The bottom line is that not submitting your TRI report on time or at all will greatly impact your bottom line. It’s best to begin preparing as early as January to make sure everything is in line.

Work to identify ways to reduce waste in your facility

Facilities are required by the EPA to report on the source reduction activities (also known as pollution prevention) that they implemented during the previous calendar year. These activities, which include recycling and treatment, help to eliminate or reduce the use of TRI-listed chemicals and, in turn, reduce chemical waste. This element of reporting helps to shine a light on the methods working for other facilities so that companies can learn from others’ best practices.

The report noted that for the first time in five years, industrial and federal facilities alike increased their pollution prevention activities to reduce or eliminate their waste. In total, over 1,000 facilities implemented more than 3,285 new source reduction activities. Most often, the focus was on good operating practices (40%), process modifications (21%), and spill and leak prevention (10%).

In 2021, it will be extremely important to be mindful of environmental law and the impact your company has - or face consequences from both the government and the public.

KEYWORDS: environmental safety toxic substances waste management

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Mark Chocola is the national sales director at Hazardous Waste Haulers Environmental. HWH specializes in hazardous and non-hazardous waste removal, transportation, and disposal needs across the country to help companies lessen their environmental footprint.

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