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 your free PDF copy of our RY 2023 TRI Checklist

Reporting Criteria

  • Confirm that your facility’s NAICS code is required to report -OR-
  • You are a federal facility which must report regardless of SIC or NAICS codes -AND-

  • That your facility employs the equivalent of 10+ full-time employees (20,000+ work hours) -AND-

  • Your facility manufactures, imports, processes, or otherwise uses TRI-covered chemicals  above their reporting thresholds

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 NINE polyfluoroalkyl substances (PFAS) added to the RY 2023 TRI list of reportable chemicals

  • Bear in mind the updated De minimis levels of 0.1% for six new carcinogenic chemicals identified by the International Agency for Research on Cancer

  • Review the TWELVE new chemicals added to the TRI chemical list in response to a petition by the Toxics Use Reduction Institute (TURI)

  • Review TRI regulatory publications for industry-specific updates or changes

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 22 chemicals/compounds designated as persistent, bio-accumulative, and toxic (PBT) chemicals, including the newly added 1,3,4,6,7,8-hexahydro-4,6,6,7,8,8-hexamethylcyclopenta [g]-2-benzopyran for RY 2023

  • 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

Form Submission

  • Don’t forget about the new rule for RY 2023 on reporting a foreign parent company if applicable

  • Confirm Form A eligibility criteria is met when/if applicable

  • Complete a Form R (or Form A, if eligibility criteria is met) for each chemical exceeding report threshold

  • NOTE: Hard-copy filing is ONLY accepted for trade-secret reporting

Central Data Exchange and TRI-Meweb

  • Confirm that your company has a Central Data Exchange (CDX) account

  • Confirm that BOTH the Preparer and Certifier have appropriate access to TRI-MEweb

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

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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 2023

Join ERA's team of environmental and regulatory experts for an A to Z of TRI reporting obligations for 2023.

Thursday, May 9th.

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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.

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