The July 1, 2024, deadline for the TRI Reporting (Toxics Release Inventory) covering activities during the previous calendar year is fast approaching. Manufacturers, including food and beverage, electric utilities, and mining facilities, may need extra time this year to comply with recent rule changes related to per- and polyfluoroalkyl substances (PFAS).
Specifically, this recent action updates the regulations to identify nine per- and polyfluoroalkyl substances (PFAS) that must be reported under the National Defense Authorization Act for Fiscal Year 2020 (FY2020 NDAA) enacted on December 20, 2019. You may be potentially affected by this action if you manufacture, process, or otherwise use any of the PFAS listed in this rule. The following list of North American Industry Classification System (NAICS) codes provides a guide to help you determine whether this action applies to your facility.
TRI Reporting is a two-step process, and covered facilities with at least ten full-time equivalent employees must complete the first step to evaluate whether a report is required each year. For each chemical or PFAS that exceeds a reporting threshold, EPA requires the facility to calculate releases to the air, wastewater, and stormwater and the amount of the chemical recycled or treated on-site or sent off-site for treatment during the previous calendar year.
SCS Engineers presents an on-demand educational video with complimentary articles and additional resources to get you started. Cheryl Moran, a senior project manager with decades of experience in regulatory compliance, sustainable practices, and chemical management, covers what you need to know to get started:
Additional TRI Resources
Authorized under the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Pollution Prevention Act (PPA), the Toxics Release Inventory (TRI) tracks the management of certain toxic chemicals that may pose a threat to human health and the environment.
Manufacturers, including food and beverage, electric utilities, and mining facilities, may need extra time this year to comply with recent rule changes related to per- and polyfluoroalkyl substances (PFAS).
TRI reporting is a two-step process, and covered facilities with at least ten full-time equivalent employees must complete the first step to evaluate whether a report is required each year. For each chemical that exceeds a reporting threshold, EPA requires the facility to calculate releases to the air, wastewater, and stormwater and the amount of the chemical recycled or treated on-site or sent off-site for treatment during the previous calendar year.
TRI Reporting Unscrambled and No-Strings Attached
SCS Engineers presents an on-demand educational video with complimentary articles and additional resources to get you started. Cheryl Moran, a senior project manager with decades of experience in regulatory compliance, sustainable practices, and chemical management, covers what you need to know to get started and what has changed that may require your facility or business to start reporting:
Additional TRI Resources
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin summarizes the 2020 USEPA Adds 172 PFAS Chemicals to EPCRA TRI Reporting Program. The new PFAS rule went into effect on June 22, 2020. However, the rule requires PFAS to be included in TRI reports submitted for all 2020 calendar year activity (i.e., January 1 through December 31). The deadline for submitting the 2020 TRI reports is July 1, 2021.
TRI-Covered Industries include:
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.
Contact https://www.scsengineers.com for an Environmental Engineer near you.
It might feel like the July 1 deadline is far away, but it is time to start preparing to report your releases of toxic materials. The U.S. Environmental Protection Agency (USEPA) indicates that printing and related industries are subject to this report. It is an important part of your environmental compliance strategy if you have a facility with at least 10 full-time equivalent employees in a covered NAICS code that exceeded a reporting threshold in the previous calendar year. Reporting releases of toxic materials on an annual basis is one aspect of the Emergency Planning and Community Right-to-Know Act (EPCRA).
Read the article with steps to your report for printing and related industries.
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right To Know Act (EPCRA), Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) and Section 112(r) of the Clean Air Act
On March 1, each year facilities that use hazardous chemicals in specific quantities must file an EPCRA Tier II report identifying the chemicals with the State Emergency Response Commission, the Local Emergency Planning Committee, and the local fire department.
Easy to avoid mistakes and omissions in Tier II filings may lead to civil penalties of as much as $54.8K per day. Most cited violations involve just a few common chemicals such as ammonia, sulfuric acid inside equipment, and an EHS that is a component of mixtures. These are often overlooked or thought to be exempt from reporting because the threshold for reporting may be low.
Rather than risk non-compliance, ask the professionals at SCS Engineers about common chemical thresholds, voluntary self-disclosure, and EPA’s audit policies.
Read our most recent EPCRA Technical Bulletin, or contact us at .
SCS periodically prepares technical bulletins to highlight items of interest to our clients and friends. These are published on our website. This SCS Technical Bulletin addresses the Emergency Planning and Community Right-to-Know Act (EPCRA). The purpose of specific sections are consolidated and explained by SCS professionals; specifically:
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If you have any questions regarding this technical bulletin, feel free to contact your local SCS Engineers representative, email us at , or contact our professionals listed on the Technical Bulletin.
SCS Engineers provides a free guide to the most common environmental reports due at the federal and state levels. Each guide includes an overview of the reporting due along with the date each state requires submission.
When SCS says free, we mean it. No need to submit your company name, no endless email trail will follow; these are free guides to download and share with others from the compliance experts – SCS Engineers.
Click to download or share each state guide:
If your state is not listed, contact the nearest SCS office to speak with a compliance professional in your area and in your business sector; SCS is nationwide.
If you have questions or need help sorting out details such as which reports apply to your business or step-by-step support on how to prepare your reports in the states listed above, contact our regional professionals.
Learn more about Ann
Ann O’Brien 1-773-775-6362
Learn more about Cheryl
Cheryl Moran 1-608-216-7325
