TOXIC RELEASE INVENTORY (TRI)
CUSTOMIZED ENVIRONMENTAL
TRAINING
WELCOME
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INSTRUCTOR
Insert Instructor Name Here
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OBJECTIVES
 Discuss Who Must Report Toxic Chemical Releases.
 Discuss What Must Be Reported.
 Discuss the Types of Chemicals That Are to be Reported.
 Discuss Reporting Exemptions.
 Explain How to Determine Thresholds.
 Discuss Releases.
 Discuss Trade Secrets.
 Describe EPA’s Form A and Form R.
 Discuss Source Reduction.
 Discuss Recordkeeping.
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GOALS
 Understand Who Must Report Toxic Chemical Releases.
 Understand What Must Be Reported.
 Understand the Types of Chemicals That Are to be Reported.
 Understand Reporting Exemptions.
 Be Familiar With How to Determine Thresholds.
 Understand the Different Types of Releases.
 Understand How To Report Trade Secrets.
 Be Familiar With EPA’s Form A and Form R.
 Understand Source Reduction.
 Be Familiar With Required Recordkeeping.
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BACKGROUND
 In 1984, a chemical release in Bhopal India killed
thousands of people.
 In 1998, 61,234 industries reported a total of 7.3 billion
pounds of hazardous chemicals released to the air, land
and water in the United States.
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LEARNERS
 Supervisors
 Facility Engineers
 Maintenance Personnel
 Department Managers
 Building Occupants
 Process Specialists
 Environmental and Safety Committees
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OVERVIEW
The goal of this course is to provide supervisors
with the tools needed to prepare a Toxic Chemical
Release Inventory (TRI). It recommends practical,
actions that can be carried out by facility
management, maintenance personnel and building
occupants. The course will help you in preparing
this annual requirement and help your facility
personnel better understand the EPCRA 313
process.
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WHAT THIS COURSE DOES NOT DO
The course is not intended to provide every answer
to TRI reporting. This course provides only the
framework for TRI. This course does provide
sources of additional help at the end of the course.
For complex questions beyond the scope of this
course, it is recommended that additional training or
outside assistance be solicited.
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EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW ACT
 Sections 311 and 312 of EPCRA require businesses
to report the locations and quantities of chemicals
stored on-site to state and local governments.
Section 313 requires businesses to report the more
than 600 designated toxic chemicals released to the
environment.
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FEDERAL REGULATIONS
Pertinent Regulation:
 40 CFR 372 Toxic Chemical Release Reporting:
Community Right-To-Know
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SOME OF THE RESPONSIBILITIES
UNDER EPCRA
 Facility owners/operators that have on their premises
chemicals designated under EPCRA as “extremely
hazardous substances” must cooperate with state and
local planning officials in preparing comprehensive
emergency plans (Sections 302 and 303);
 Facility owners/operators must report accidental
releases of, “extremely hazardous substances” and
CERCLA “hazardous substances” to state and local
response officials (Section 304); and
 Facility owners/operators must make Material Safety
Data Sheets (MSDSs) available to officials and must
also report, to local and state officials, inventories
(including locations) of chemicals on their premises for
which MSDSs exist (Sections 311 and 312).
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SECTION 313
 Section 313 of EPCRA requires certain businesses to
submit reports each year on the amounts of toxic
chemicals their facilities release into the environment,
either routinely or as a result of accidents.
 The purpose of this reporting requirement is to inform
government officials and the public about releases of
toxic chemicals into the environment.
 Section 313 requires facilities to report releases to air,
water, and land. The reports must be sent to the U. S.
EPA and to designated state agencies. Reports are due
by July 1 each year.
Those who fail to report as required are subject to civil
penalties of up to $27,500 a day.
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WHO MUST REPORT
A plant, factory, or other facility is subject to the
provisions of Section 313 if it meets all three of the
following criteria:
1. It is included in a covered Standard Industrial
Classification (SIC) code A facility must report to TRI if it
conducts manufacturing operations within SIC codes 20
through 39 and or if it is in one of the following
industries: metal mining, coal mining, electrical utilities,
RCRA Subtitle C hazardous waste treatment and
disposal facilities, chemical distributors, petroleum
terminals, and solvent recovery services
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WHO MUST REPORT
2. If it has 10 or more full-time employees (or the
equivalent 20,000 hours per year
3. It manufactures, imports, processes, or otherwise
uses any of the toxic chemicals listed by EPA in
amounts greater than the “threshold” quantities
specified below. At present, there are more than 650
chemicals and chemical categories are covered. The list
is subject to change by the EPA Administrator who can
add or delete chemicals from the list
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WHAT MUST BE REPORTED TO
TRI
Information reported by facilities includes:
 Basic information identifying the facility
 Name and telephone number of a contact person
 Environmental permits held
 Amounts of each listed chemical released to the
environment at the facility
 Amounts of each chemical sent from the facility to
other locations for recycling, energy recovery, treatment,
or disposal
 Amounts of each chemical recycled, burned for
energy recovery, or treated at the facility
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WHAT MUST BE REPORTED TO
TRI
 Maximum amount of chemical
present on-site at the facility during
the year
 Types of activities conducted at
the facility involving the toxic
chemical, and
 Source reduction activities.
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THRESHOLDS
 Thresholds are specified amounts of toxic chemicals
used during the calendar year that trigger reporting
requirements.
 If you manufacture or import any of the listed toxic
chemicals, the threshold quantity will be:
25,000 pounds over the calendar year.
 If you process any of the listed toxic chemicals, the
threshold quantity will be:
25,000 pounds over the calendar year.
If you otherwise use any of the listed toxic chemicals
(without incorporating it into any product or producing it
at the facility), the threshold quantity is:
 10,000 pounds over the calendar year.
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MANUFACTURE
Manufacture – means to produce,
prepare, import, or compound one
of the toxic chemicals on the list.
For example, if you make a dye for
clothing by taking raw materials
and reacting them, you are
manufacturing the dye. You would
also be covered if you were a
textile manufacturer who imported
a dye on the list for purposes of
applying it to fabric produced at
your plant.
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PROCESS
Process – in general, is the incorporation of a toxic
chemical into a product and includes making mixtures,
repackaging, or using a chemical as a feed-stock, raw
material, or starting material for making another
chemical.
Examples of processing include:
– Adding a solvent to dilute when making a paint,
coating, or other mixture;
– Using a chemical as reactant in the manufacture of a
pesticide (e.g., using chemical A to make chemical B).
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OTHERWISE USE
Otherwise Use – applies to any use of a toxic chemical at a
covered facility that is not covered by the terms “manufacture”
or “process” and includes use of a toxic chemical contained in
a mixture or trade name product. This includes disposal,
stabilization, and treatment for destruction if the facility that
conducted these activities received the toxic chemical for
purposes of waste management. Examples include:
 Using a metal cutting fluid that contains diethanolamine;
 Using a heat transfer fluid containing biphenyl;
 Using trichloroethylene to degrease tools;
 Using chlorine in waste water treatment;
 Using Freon 113 as a refrigerant to cool process streams.
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FACILITY
Facility - all buildings, equipment, structures, and other
stationary items which are located on a single site or on
contiguous or adjacent sites and which are owned or
operated by the same person. Warehouses on the
same site as covered facilities are covered at the same
threshold levels. Stand-alone warehouses that do not
support a covered operation are not currently covered.
The reporting thresholds apply to toxic chemicals known
by the owner or operator to be used in amounts above
the thresholds. Section 313 requires suppliers of
mixtures and trade name products to notify customers
of the presence of Section 313 listed toxic chemicals in
their products above certain de minimis concentrations.
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CHEMICALS
 EPA has compiled a list of more than 650 chemicals.
 This list grows each year.
 How EPA lists some of the Toxic Release Chemicals:
CAS Number
Chemical
De Minimis %
7664-41-7
Ammonia
1.0
7440-38-2
Arsenic
.1
7440-39-3
Barium
1.0
7440-47-3
Chromium
1.0
7440-48-4
Cobalt
.1
7440-50-8
Copper
1.0
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CHEMICALS


The top 20 chemicals released in 1998 were:
Zinc compounds
Styrene
Nitrate compounds
Hydrochloric acid
Methanol
Phosphoric acid
Ammonia
Methyl ethyl ketone
Manganese compounds
Chromium compounds
Toluene
Carbon disulfide
Xylene (mixed isomers)
Dichloromethane
n-Hexane
Glycol ethers
Copper compounds
Lead compounds
Chlorine
Ethylene
These chemicals accounted for 2.376 billion pounds.
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CHEMICAL CATEGORIES
 Section 313 requires reporting on the toxic chemical
categories listed on the following slides, in addition to the
more than 650 specific toxic chemicals mentioned
previously.
 The metal compounds listed unless otherwise
specified, are defined as including any unique chemical
substance that contains the named metal (e.g., antimony,
nickel, etc.) as part of that chemical's structure.
 Toxic chemical categories are subject to the 1 percent
de minimis concentration unless the substance involved
meets the definition of an OSHA carcinogen in which
case the 0.1 percent de minimis concentration applies.
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CHEMICAL CATEGORIES
 Antimony Compounds
 Arsenic Compounds
 Barium Compounds
 Beryllium Compounds
 Cadmium Compounds
 Chromium Compounds
 Cobalt Compounds
 Copper Compounds
 Cyanide Compounds
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CHEMICAL CATEGORIES
 Diisocyanates
 Ethylenebisdithiocarbamic acid, salts and esters
 Certain Glycol Ethers
 Lead Compounds
 Manganese Compounds
 Mercury Compounds
 Nickel Compounds
 Nicotine and salts
 Nitrate compounds
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CHEMICAL CATEGORIES
 Polybrominated Biphenyls (PBBs)
 Polychlorinated alkanes
 Polycyclic aromatic compounds (PACs)
 Selenium Compounds
 Silver Compounds
 Strychnine and salts
 Thallium Compounds
 Warfarin and salts
 Zinc Compounds
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CHEMICAL QUALIFIERS
Qualifers are only reportable if in listed form.
1. Aluminum (fume or dust) - Only if in a fume or dust.
2. Aluminum oxide (fibrous forms) - Only if in a fibrous
form.
3. Ammonia – Only 10 percent of aqueous forms. 100
Percent of anhydous forms.
4. Asbestos (friable) - Only if it is a friable form.
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CHEMICAL QUALIFIERS
5. Hydrochloric acid - Only if it is an aerosol form.
6. Phosphorus (yellow or white) - Only if it is a yellow or
white.
7. Sulfuric acid (acid aerosols) - Only if it is an aerosol
form as defined.
8. Vanadium (fume or dust) - Only if it is in a fume or
dust form.
9. Zinc (fume or dust) - Only if it is in a fume or dust
form.
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CHEMICAL QUALIFIERS
 The qualifier for the following two chemicals is based on
the chemical activity rather than the form of the chemical.
Both are subject to EPCRA section 313 reporting
requirements only when the indicated activity is performed.
1. Isopropyl alcohol (manufacturing - strong acid process,
no supplier notification.)
•The qualifier is “Only if it is being manufactured by the
strong acid process.”
2. Saccharin (manufacturing, no supplier notification)
•The qualifier is “Only if it is being manufactured.”
 Manufactures of these chemicals do not need to notify
their customers that these are reportable EPCRA section
313 chemicals.
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EXEMPTIONS
Under certain circumstances, some or all
of the reporting requirements under
Section 313 may not apply to a facility.
The following are the major exemptions:
 De minimis
 Articles
 Laboratory Activities
 Other Exemptions
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DE MINIMIS
De minimis concentrations of a toxic chemical in
certain mixtures.
In determining whether the amount of a toxic chemical
used at your facility exceeds the EPA reporting
threshold, you are not required to count the amount of
chemical present in a mixture if
 its concentration is less than 1 percent of the mixture,
or
 its concentration is less than 0.1 percent of the
mixture when the chemical is defined by the
Occupational Safety and Health Administration (OSHA)
as carcinogenic.
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ARTICLE
Articles. In considering whether a reporting threshold
has been exceeded, you are not required to count toxic
chemicals present in articles processed or used at your
facility. An “article” is a manufactured item:
(1) which is formed to a specific shape or design during
manufacture;
(2) which has end use functions dependent in whole or
in part upon its shape or design during end use; and
(3) which does not release a toxic chemical under
normal conditions of processing or use of that item at
the facility or establishments.
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LABORATORY ACTIVITIES
Laboratory Activities. In considering
whether a reporting threshold has been
exceeded, you are not required to count
toxic chemicals that are manufactured,
processed, or otherwise used for
research or quality control in a laboratory
at a covered facility under the
supervision of a technically qualified
individual. This exemption does not
apply to production, processing, or the
use of toxic chemicals in laboratories for
distribution in commerce or in pilot plant
scale operations.
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OTHER EXEMPTIONS
Other Exemptions. You are not required to count toxic
chemicals that are used at your facility for any of the
following purposes:
 As a structural component of the facility;
 In routine janitorial or facility grounds maintenance;
 In foods, drugs, cosmetics, or other items for
personal use, including supplies of such items (for
example, in a facility-operated cafeteria);
 In motor vehicle maintenance (including motor fuel);
 In process water and non-contact cooling water as
drawn from the environment or from municipal sources,
or in air used either as compressed air or as part of
combustion.
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OWNERS OF LEASED PROPERTY
Owners of Leased Property.
The owner of a covered facility is
not subject to reporting under
Section 313 if the owner’s only
interest in the facility is
ownership of the real estate
upon which the facility is
operated. However, the operator
of the facility must report if the
criteria are met.
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DETERMINING THRESHOLDS
 Compare quantities of EPCRA Section
313 chemicals that you manufacture,
process, or otherwise use to the
respective thresholds for those activities.
 EPA has worksheets, or you can make
up your own similar to the ones on the
following slides that will assist you in
determining whether your facility has
exceeded any of the reporting
thresholds.
 Worksheets are not required and the
completed worksheet(s) should not
accompany Form R reports submitted to
EPA and the State.
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DETERMINING THRESHOLDS
Mixture Name
Ammonia
Total Weight (lb)
500,000
Percent EPCRA Sec. 313 Chemical by 10%
Weight
EPCRA Sec. 313 Chemical Weight (lb) 50,000
Manufactured Amount (lb)
35,000
Processed Amount (lb)
10,000
Otherwise Used Amount (lb)
5,000
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DETERMINING THRESHOLDS
Mixture
Ammonia
Applicable Exemption (de minimis,
facility
article, facility, activity, etc.)
Fraction or Percent Exempt (if Applicable) 10%
Amount of Manufactured Exempt (lb)
3,500
Amount of Processed Exempt (lb)
0
Amount of Otherwise Used Exempt (lb)
0
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DETERMINING THRESHOLDS
Manufactured Processed
Amount
Amount
Gross
Amount
Exempted
Amount
35,000
10,000
Otherwise
Used
Amount
5,000
3,500
0
0
10,000
5,000
Net Amount 31,500
Report on
Form R
Yes, Amount is No, Amount
greater than
is less than
25,000 lb
25,000 lb
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No, Amount
is less than
10,000 lb
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DETERMINING THRESHOLDS
 Threshold determinations of EPCRA
Section 313 chemicals that are reused at
facilities are based only on the amount of
the EPCRA Section 313 chemical that is
added during the year, NOT the total
volume in the system.
This does not apply to EPCRA Section
313 chemicals "recycled" or "reused" off-site
and returned to a facility. Such EPCRA
Section 313 chemicals returned to a facility
are treated as the equivalent of newly
purchased material for purposes of Section
313 threshold determinations.
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RELEASES
 EPCRA defines a release as any “spilling, leaking,
pumping, pouring, emitting, emptying, discharging,
injecting, escaping, leaching, dumping, or disposing into
the environment.
 Under Section 313, covered facilities are required to
take into account in their reports all toxic chemicals
entering each environmental medium (e.g., “routine”
and “accidental” releases.)
 Reporting under Section 313 includes the total
amount of the toxic chemicals, both routine, operational
and accidental releases.
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RELEASES
Air Emissions. Releases to air are
reported either as point source or
fugitive emissions. Point source
emissions, also referred to as stack
emissions, occur through confined air
streams, such as stacks, vents, ducts,
or pipes. Fugitive emissions are all
releases to air that are not released
through a confined air stream.
Fugitive emissions include equipment
leaks, evaporative losses from surface
impoundments and spills, and releases
from building ventilation systems.
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RELEASES
Surface Water Discharges.
Releases to water include
discharges to streams, rivers,
lakes, oceans, and other bodies of
water. This includes releases from
contained sources, such as
industrial process outflow pipes or
open trenches. Releases due to
runoff, including stormwater runoff,
are also reportable to TRI.
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RELEASES
Underground Injection. Underground
injection is the subsurface
emplacement of fluids through wells.
TRI chemicals associated with
manufacturing, the petroleum industry,
mining, commercial and service
industries, and federal and municipal
government-related activities may be
injected into Class I, II, III, IV, or V
wells, if they do not endanger
underground sources of drinking water
(USDW), public health, or the
environment.
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RELEASES
On-site Land Releases.
 On-site releases to land occur within
the boundaries of the reporting facility.
 Releases to land include disposal of
toxic chemicals in landfills, land
treatment/application farming, surface
impoundments, and other land disposal
methods or releases to land.
Facilities separately report amounts
released to RCRA subtitle C landfills
from amounts released to other on-site
landfills.
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TRADE SECRETS
 For any EPCRA Section 313 chemical whose identity
is claimed as trade secret, you must submit to EPA two
versions of the substantiation form
 One set of reports, the "unsanitized" version, should
provide the actual identity of the EPCRA Section 313
chemical.
 The other set of reports the "sanitized" version,
should provide only a generic identity of the EPCRA
Section 313 chemical. If EPA deems the trade secret
substantiation form valid, only the sanitized set of forms
will be made available to the public.
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PBT REPORTING
Businesses must report Pesticides and Other Persistent
Bioaccumulative Toxic (PBT) Chemicals.
Required to Report if:
 Facility manufactures 100 pounds of that PBT
chemical during the calendar year.
 Facility processes 100 pounds of that PBT chemical
during the calendar year.
 Facility otherwise uses 100 pounds of that PBT
chemical during the calendar year.
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HOW TO REPORT
 The owner or operator of a covered facility must
report annually. Reports must be submitted on or before
July 1 and cover activities that occurred at the facility
during the previous calendar year.
 EPA will provide a reporting form (EPA Form A or
Form R) with instructions and technical guidance on
how to calculate toxic chemical releases or emissions
from your facility.
 You are not required to measure or monitor releases
for purposes of Section 313 reporting. You may use
readily available data to report the quantities of
chemicals that you use and the amounts released into
the environment.
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FORM A
 This is based on an alternate threshold for facilities with
low amounts of an EPCRA Section 313 chemical in waste.
 The Form A serves as an alternate to Form R, such that
completion of the Form A is in lieu of Form R. The Form A
consists of two parts, but only consists of a total of two
pages.
•Part I, Facility Identification Information, which also
includes the "certification" regarding the eligibility to use
the Form A; and
•Part II, Chemical Identification The Form A may be used
to report multiple chemicals.
•A complete report for Form A consists of at least two
pages for each submission.
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FORM R
Form R consists of two parts that are on 5 pages.
Part 1 asks facility information:
Section 1 – Reporting Year
Section 2 – Claiming a Trade Secret
Section 3 – Certification
Section 4 – Facility Identification
Section 5 – Parent Company Information
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FORM R
Part 2 asks for chemical related information:
Section 1 – Toxic Chemical Identity
Section 2 – Mixture Component Identity
Section 3 – Activities and uses of the toxic chemical at
the facility
Section 4 – Maximum amount of the toxic chemical
onsite at any time during the calendar year.
Section 5 – Quantity of the toxic chemical entering each
environmental medium (e.g. water, air, land) onsite.
Section 6 – Transfers of the toxic chemical in wastes to
off-site locations
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FORM R
Part 2 (continued):
Section 7a - On-site waste treatment methods and
efficiency
Section 7b – On-site energy recovery processes
Section 7c – On-site recycling processes
Section 8 – Source reduction and recycling activities
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SOURCE REDUCTION
The Pollution Prevention Act of 1990 (PPA) requires
facilities to report the quantities of TRI chemicals they
manage in waste, both on- and off-site. The PPA also
requires facilities to provide information about the efforts
they have made to reduce or eliminate those quantities.
Through source reduction, risks to people and the
environment can be reduced, financial and natural
resources can be saved that would otherwise have to
be expended on environmental clean-up or pollution
control, and industrial processes can become more
efficient.
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SOURCE REDUCTION
Source reduction is defined in the Pollution Prevention
Act of 1990 as any practice that:
 reduces the amount of any hazardous substance,
pollutant, or contaminant entering any wastestream or
otherwise released into the environment (including
fugitive emissions); and
 reduces the hazards to public health and the
environment associated with the release of such substances, pollutants, or contaminants.
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SOURCE REDUCTION
Facilities have found that the following measures help in
source reduction and fewer emissions:
 Good Operating Practices
 Tighter Inventory Control
 Better Spill and Leak Prevention
 Raw Material Modifications
 Improved Process Modifications
 Cleaning and Degreasing
 Better Surface Preparation/Finishing
 Better Product Modification
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PUBLIC ACCESS TO REPORTS
 The law requires facilities covered by Section 313 to
send toxic chemical release reports both to EPA and to
the state in which the facility is located. At EPA, the
Office of Pollution Prevention and Toxics is responsible
for receiving and processing the data. The agency
designated to receive reports in your state is listed in
the instructions for Form R.
 EPA is required by law to make the data in the reports
available to the public through a computer database.
(You can claim the toxic chemical identity to be a trade
secret, but you must justify the claim to EPA.)
 The database is intended to help answer citizens’
questions about toxic chemical releases in their
community.
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RECORDKEEPING
 Sound recordkeeping practices are essential for
accurate and efficient TRI reporting.
 Facilities must keep a copy of each report filed for at
least three years from the date of submission. These
reports will be of use when completing future reports.
 Facilities must also maintain those documents,
calculations, worksheets, and other forms upon which
they relied to gather information for prior reports.
 In the event of a problem with data elements on a
facility’s Form R or Form A report, EPA may request
documentation from the facility that supports the
information reported.
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WHAT YOU CAN DO
 Check that you have 10 or more full-time employees
(that is, if the total annual hours worked by all
employees is at least 20,000 hours).
 Check the SIC code list to determine whether your
facility is covered.
 Check the list of toxic chemicals covered by Section
313 to see if any are manufactured, imported,
processed, or otherwise used by your facility. Your
chemical supplier is required to inform you if any of the
Section 313 toxic chemicals are contained in mixtures
sold to you. Also, the EPA document “Common
Synonyms for Section 313 Chemicals” can assist you in
identifying toxic chemicals.
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WHAT YOU CAN DO
 Determine whether you manufactured, processed, or
otherwise used any toxic chemical on the list in an
amount greater than the thresholds.
 If you meet the criteria, request copies of the
reporting form, instructions, and any of the appropriate
guidance documents from EPA.
 Begin to develop the appropriate information to report
your releases and your source reduction and recycling
activities.
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WHAT YOU CAN DO
 Maintain a recordkeeping system
that will help you estimate releases
for future years. You should
designate someone at your facility to
be responsible for reporting under
Section 313. That person should
obtain reporting forms and
instructions and should be aware of
the reporting deadline: July 1 of each
year.
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ADDITIONAL TRI INFORMATION
 To request copies of TRI and EPCRA documents or
to obtain further information about the program, contact
the toll-free Emergency Planning and Community Rightto-Know Information Hotline at 1-800-424-9346.
 TRI information is also available on the TRI Web site
at www.epa.gov/tri.
 Other potential sources of TRI information include the
state EPCRA section 313 contact, or your EPA Regional
Office.
Toxic Release Inventory 62/65
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TIPS FOR USING CONTRACTORS
 Remember, You Control Your Facility or Area!
 Review Procedures With Them Before Starting the Job!
 Ensure They Are Properly Trained!
 Determine Their Environmental Compliance Record!
 Determine Who Is in Charge of Their People!
 Determine How They Will Affect Your Facility’s
Environmental Compliance!
Toxic Release Inventory 63/65
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ELEMENTS OF A SUCCESSFUL
TRI PROGRAM
1. DETAILED WRITTEN TRI GUIDELINES.
2. DETAILED WRITTEN TRI BEST MANAGEMENT
PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP
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THE IMPORTANCE OF A
CLEAN ENVIRONMENT
“I would ask all of us to remember
that protecting our environment is
about protecting where we live and
how we live. Let us join together to
protect our health, our economy,
and our communities -- so all of us
and our children and our
grandchildren can enjoy a healthy
and a prosperous life.”
Toxic Release Inventory 65/65
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Carol Browner
Former EPA
Administrator
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