While it seems the most costly mistakes could occur during emission or threshold calculations, the reality is the biggest and most frequent mistakes come from simply misunderstanding TRI reporting regulations.
In fact, these mistakes are so common the EPA includes a warning about them in the appendix material to the TRI reporting regulations.
Here are the 7 most common TRI reporting mistakes made every year, and how you can avoid them:
1) Not including a signed Certification Statement
It may sound basic, but if you submit a paper copy of the TRI report be sure to sign ALL of the appropriate documents stating that the report is done accurately and to the fullest extent of the EPA’s regulations.
The signing officer and a public contact need to be included in your TRI submission.
There is a quick fix: use the online reporting tool TRI-ME web instead.
2) Incomplete Form Rs
Although it might seem like a shortcut, you cannot cut corners by grouping together different 313 chemicals onto a single Form R “page one”.
Every 313 chemical needs to have its own Form R package, which is 5 pages long stapled together (in paper form). Anything else is immediately considered an incomplete submission by the EPA.
How to avoid: Submit everything online or make sure every 313 chemical has its own Form R.
3) Estimating Threshold Determinations
Your TRI reporting responsibilities don’t just include reporting if you exceed a threshold.
You also need to concretely demonstrate whether you meet reporting thresholds or not. In this case, a best guess just will not do.
This means some actual number crunching and record management needs to happen before you start reporting.
How to avoid: The best way to not catch yourself estimating threshold determinations is to budget some time in advance to get all the prep work done instead of waiting until you are running out of time. You don't need a whole team of people, just a way to work smarter.
4) Overlooking Non-Manufacturing Activities
It’s a misconception that TRI reporting only applies to chemicals that get manufactured in your facility.
In reality, you must report any 313 chemical that is manufactured, processed, or otherwise used on-site.
You also need to report chemicals used in activities like equipment cleaning and those that are generated during the combustion of fuel.
How to avoid: The EPA recommends that all facilities take a systematic approach to identify all chemicals used in your processes.
5) Ignoring 313 Chemicals in Mixtures
Just because a reportable 313 chemical is part of a mixture or an alloy doesn’t mean that it isn’t still reportable.
Unless you can apply the de minimis exemption, you’ll need to figure out exactly how much of your reportable chemicals is in your mixtures.
How to avoid: Again, it comes down to having a good system in place to keep track of what chemicals enter your facility, and at what concentration.
6) Forgetting Coincidental Manufacturing
Some of your processes might actually be generating reportable 313 chemicals as a by-product, and it’s your duty to report them.
One of the most common examples of this is the nitrate compounds that are the result of nitric acid neutralization.
How to avoid: Know your processes inside and out and carefully track what’s leaving your facility, because it might not be the same as what’s coming in.
7) Overlooking Container Residue & Cleaning
It might be the last thing on your mind, but you need to account for any 313 chemical residue in your containers.
Even an “RCRA empty” drum is expected to have a trace amount of residue in it. And if you clean or rinse your drums you will need to report the amount of chemicals being released in the waste water.
How to avoid: Keep the big picture in mind. That means taking a cradle to grave (or cradle to cradle if your facility recycles) approach to every material entering and existing your facility. Ask: where does it go when you’re done with it?
If you're worried about your TRI reporting this year, download our TRI reporting survival guide:
About the Author: Alex Chamberlain is a writer and blogger who regularly contributes to ERA Environmental Management Solutions' blog. You can find Alex on Google+, LinkedIn & ERA's Environmental Compliance Blog