TRI Form R for electroplating and metal finishing shops

This page explains what the rules and common practice call for. Every site is different, and what a survey or a filing needs at your facility is something we work out with you after we see it.

The Toxics Release Inventory (TRI) is the annual toxic chemical release report filed with EPA. Form R is the full report and Form A is the shorter alternative. This page covers how the reporting works for an electroplating or metal finishing shop.

Start with the reference documents, because knowing what exists will save you a search.

In the late 1990s, EPA published a series of industry guidance documents for TRI reporting, and it is the series people mean when they refer to “the EPA industry guidance”. The series covers semiconductor manufacturing, electricity generating facilities, petroleum refining and chemical distribution, but it has no volume for metal finishing or electroplating.

What does exist is older: an issue paper from January 1990 (“Section 313 Reporting: Issue Paper, Clarification and Guidance for the Metal Fabrication Industry”) that covers electroplating by name. The rule has been amended extensively since then, so treat it like any 1990 document: useful on concepts, unreliable on current chemical lists and thresholds.

The working reference for a plating shop today is the 2019 questions and answers document (EPCRA Section 313 Questions and Answers Consolidation Document), which addresses plating scenarios directly.

→ Do you have to file a Form R?

TRI chemicals in a plating shop

Of that list, only lead is on EPA's list of “chemicals of special concern”, which carries stricter reporting rules. Chromium, nickel, copper, zinc and cyanide compounds are not on it, so they carry the ordinary reporting thresholds:

• 25,000 lb if the chemical is manufactured or processed
• 10,000 lb if it is otherwise used

For these chemicals you can still use Form A, report amounts as a range, and apply the de minimis exemption for small concentrations. Applying the 100 lb special concern threshold to a chrome or nickel line is a costly misreading.

Lead is the exception, and the difference is substantial. Lead has a 100 lb threshold, no Form A, no range reporting and no de minimis exemption.

There is one carve-out: lead contained in a stainless steel, brass or bronze alloy. That lead keeps the ordinary 25,000 lb and 10,000 lb thresholds and the ordinary reporting options, which matters to any shop that finishes brass or bronze parts.

The October 31, 2023 rule (88 FR 74360) is often described as the source of those lead restrictions, but it is not. Lead and lead compounds went on the special concern list at 100 lb under an earlier rule, 66 FR 4500 (January 17, 2001), which first applied to reporting year 2001. The loss of Form A, range reporting and the de minimis exemption came with that listing.

The 2023 rule did two things. It added per- and polyfluoroalkyl substances (PFAS) to the special concern list, which extended the same restrictions to PFAS. It also removed the de minimis exemption from supplier notification for every chemical of special concern. Supplier notification is the written notice a seller sends its customers about listed chemicals in a product. That second change is the new restriction, and it is the one a plating shop that sells chemicals needs to read.

The metal compound problem

This is the technical point that decides most plating Form Rs, and it runs against intuition.

The rule groups metal compounds into categories, such as “chromium compounds”, and it has two halves that work in opposite directions:

For the threshold determination, count the total weight of the whole compound category. For releases and waste management, report the weight of the parent metal only.

Take “chromium compounds”. To decide whether you crossed 25,000 lb processed or 10,000 lb otherwise used, you count the full weight of the compounds, meaning the chromium plus everything bonded to it. Once you have crossed the threshold, you report releases as the weight of the chromium metal only.

Two mistakes follow directly from this:

Shops under-count in the threshold determination. A shop may track its baths by chromium content and compare that figure to the threshold, which is the wrong comparison. A count based on the metal portion alone can put you below a threshold you actually crossed.

Shops over-report releases. This is the mirror-image mistake, because entering the full compound weight in the release columns inflates every number on the form.

Take the conversion factor from your bath chemistry, not from a generic table. Your supplier's technical data sheet gives the compound and its concentration, and the metal fraction follows from the compound's chemical formula.

→ How to calculate releases without monitoring data

Where the reportable quantities are

Plating shops routinely underestimate reportable quantities, because the releases you can see are small. The quantities are in how the waste is managed:

• Wastewater treatment sludge. In most shops this is waste code F006, and it is the single largest destination for plated metals. Shipping it off-site for disposal or treatment is reportable.
• Spent bath and stripping solutions shipped off-site.
• Rinse water discharged to the public sewage treatment plant, which the form calls a publicly owned treatment works (POTW). This is a reportable transfer, at the metal concentration in the discharge.
• Drag-out and rinse losses, which are the source of most of the metal in the sludge.
• Air emissions from tanks, particularly chromic acid mist from hard chrome, and scrubber blowdown.
• Filter media, cartridges and cloths.
• Metal recovered for reclamation. Recycling counts toward the annual reportable amount, even though it is good practice.

That last point matters for Form A. To use Form A, your annual reportable amount must not exceed 500 lb, and recycling and energy recovery are included in that total. A shop that reclaims metal from its sludge therefore has a small release number and a large reportable amount.

→ Form A or Form R

Same tanks, two kinds of air sample

One technical point crosses over between programs and is worth naming, because it affects both the Form R numbers and the workplace air monitoring in the same room.

The right filter for hexavalent chromium depends on the bath. Hexavalent chromium is one form of chromium, while total chromium means all forms together. The standard metals cassette used for total chromium is not the right filter for hexavalent chromium from a plating tank. Hexavalent chromium needs a PVC filter, and the analytical method and sample handling are different as well.

A survey run with the metals kit on a chrome line gives you a total chromium number but no valid hexavalent result, and hexavalent chromium is what OSHA's chromium standard actually regulates.

So you have two different questions, answered from two different samples. One is the air emission estimate for your Form R, and the other is your workers' exposure, for OSHA. A shop that has one does not have the other. The same site visit can collect both, using different filters and different pumps on the same tanks during the same shift.

→ Hexavalent chromium air monitoring · → Acid mist monitoring · → Air monitoring surveys

Cyanide, briefly

Cyanide compounds have their own reporting category and their own handling issues. The technical point for Form R is that destroying cyanide in wastewater treatment is treatment, and treated quantities are reportable.

A shop that oxidizes cyanide on site and reports zero because nothing left the building has misread the categories. On-site treatment is a waste management activity you must report, not the absence of one.

Supplier notification, if you sell plated parts or chemicals

The rule calls this notice to customers supplier notification, and there are two different situations to consider.

If you sell chemicals, such as bath makeup, brighteners or additives, and you are in SIC codes 20 through 39, the rule requires an annual notice. (SIC is an older system of industry classification codes.) The notice goes with the first shipment of each calendar year, and it must give:

• A statement that the product contains a chemical subject to TRI reporting (a “Section 313 chemical”)
• The name and CAS number of each chemical
• The percent by weight

Where the percent by weight is a trade secret, the rule lets you state an upper bound concentration instead. Since the 2023 rule, there is no de minimis level for chemicals of special concern, so lead or PFAS content triggers the notice at any concentration.

If you sell plated parts, the question is the article exemption. An article is formed to a specific shape, its end use depends on that shape, and it does not release a listed chemical under normal processing or use. A plated part that a customer will weld, grind or machine tests that boundary.

→ Supplier notification rules

Arizona's state filing on the same deadline

Form R is due July 1. Arizona plating and finishing shops that file a Form R or Form A also owe a state Toxic Data Report on the same date (A.R.S. § 49-962(C)). It is a separate filing in myDEQ, the state's online portal, and filing Form A does not exempt you from it.

→ Missed the July 1 deadline?

The related Pollution Prevention Plan runs on a different schedule. You must prepare the plan, implement it and maintain it. A facility that uses more than 10,000 lb/yr of a listed toxic substance must file the plan by December 31 of the following year (A.R.S. § 49-963(D)), and an annual progress report goes inside the Toxic Data Report.

→ Arizona's Pollution Prevention Plan and Toxic Data Report · → Our Form R reporting service

A caution we will keep repeating: whether you have to file depends on your actual bath volumes, drag-out rates and throughput. This page is general information, not a threshold determination for your shop.