TRI Checklist

ERA has developed this checklist to assist the EHS and safety managers who devote countless hours to the complex TRI reporting tasks in addition to the time they devote to maintaining the safety procedures that provide safe work environments for American workers and their communities nation-wide.

Receive a free PDF copy of the RY 2022 TRI Checklist

TRI Chemical Compilation

Account for ALL chemical sources, including contractor chemicals, maintenance repairs, and other one-off activities in your list of TRI reportable chemicals
Count TRI chemicals that are repackaged for subsequent commercial distribution (including sent for recycling) as a processing activity
DO NOT overlook coincidental manufacture, which is a production of an EPCRA Section 313 chemical (e.g.: by-product or impurity) as a result of the manufacture, processing, or otherwise use or disposal of another chemical or mixture of chemicals

Chemical List Changes

Account for the FOUR polyfluoroalkyl substances (PFAS) added to the RY 2022 TRI list of reportable chemicals
Bear in mind the updated De minimis level of 0.1% for aniline (62-53-3) and acrolein (107-02-8)
Review TRI regulatory publications for industry-specific updates or changes
NOTE: If your facility processes natural gas (NGP), you must submit your first TRI report this year (July 1st, 2023)

Toxic Chemical Activity Thresholds

Identify all categories of chemical use and include all chemicals rather than only those whose thresholds are exceeded
Evaluate threshold quantities as the total amount of chemicals manufactured, processed, or otherwise used, NOT the amount of TRI chemical released or managed as waste
Apply the sum of chemical/compound to each activity threshold, including all facility threshold activities. Be aware that some discrete amounts of a TRI chemical can go through more than one threshold activity, and must be counted towards each threshold activity
Account for the lower thresholds of the 21 chemicals/compounds designated as persistent, bio-accumulative, and toxic (PBT) chemicals
Count original chemical amounts used in threshold activity ONLY ONCE per reporting year to avoid over-reporting
Chemicals sent off-site and returned are considered new materials and count towards activity thresholds
Account for the exact fate of each of your chemicals after POTW treatment. In the event that the information is unavailable, you are required to use the default POTW distribution percentages

Chemical and Release Calculations

Make sure that your chemical data sources adequately cover non-exempted composition thresholds
Confirm Basis of Estimate Codes are accurate
Factor waste treatment and disposal method release pathways
REMEMBER: Threshold calculations are based on the sum of the chemical (or chemical compounds in a category) under each of the activities manufactured, processed, or otherwise used throughout the reporting year

Reporting Exemptions

Apply De minimis exemptions to non-PBT TRI chemicals in a mixture or product
DO NOT apply De minimis exemptions to the manufacturing of chemicals OR as manufacturing by-products OR as wastes
Article Exemptions DO NOT apply to TRI chemical releases during their normal use
Article Exemptions DO NOT apply to actual manufacturing of articles
Laboratory Activity Exemptions DO NOT apply to cases where TRI chemicals are used in specialty chemical production, pilot scale plant operations, non-laboratory set activities, or support services
Motor Vehicle Maintenance Exemption is an Otherwise Use Exemption and DOES NOT apply to TRI chemicals released through fuel combustion

Validation, Recordkeeping, and Documentation

Validate that TRI reporting is consistent with other relevant regulatory compliance and permitting requirements (i.e. NEI, RCRA, etc.)
Reconcile emission inventory data with TRI data. (Check out our blog on using NEI data to catch TRI red flags).
Account for and safely archive historic reports, documents, and records that may be necessary for amending TRI report or environmental audit

Need More TRI Resources? We've Got You Covered.

TRI Survival Guide

How to avoid common reporting errors, ways you may be over/under-reporting certain chemicals, the best inventory tracking methods... this guide has it all.

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TRI Webinar RY 2022

Join ERA's team of environmental and regulatory experts for an A to Z of TRI reporting obligations for 2022.

Thursday, May 11th.

TRI Software Brochure

Using an exact virtual model of your process and materials, our software calculates your emissions and generates accurate reports based on your facilities’ day-to-day activities.

Read our brochure