Toxics Release Inventory (TRI) Form R Reporting

The Toxics Release Inventory (TRI) is EPA's annual reporting requirement for toxic chemical releases, established under the Emergency Planning and Community Right-to-Know Act (EPCRA). Facilities that meet certain criteria must file by July 1 for the preceding calendar year.

Form R is the full report. It shows how much of a listed chemical was released to air, water and land, and how much was transferred off site, treated or recycled. Form A is a shorter form that some facilities may use. Just over 21,000 facilities file nationwide, so this is a narrow obligation.

Three criteria decide whether you must file a Toxics Release Inventory (TRI) report, and you have to file only if you meet all three.

First, the facility has ten or more full-time employees, counted in hours and not in heads. One full-time employee equals 2,000 hours a year, so ten is 20,000 hours, and contractor hours count. Second, you are in a covered industry sector, such as manufacturing, which in practice is decided by your 6-digit NAICS industry code. Third, you exceeded the annual reporting threshold for a listed chemical.

Most facilities that get this determination wrong get it wrong on the third criterion, so if you are unsure, it is worth settling. See the full applicability test.

For most chemicals on the Toxics Release Inventory (TRI) list, the reporting threshold is 25,000 pounds a year if you manufacture or process the chemical. It is 10,000 pounds a year if you otherwise use it. How an activity is classified therefore moves your threshold by 15,000 pounds, and it is one of the determinations that gets questioned in an inspection.

Certain chemicals, designated chemicals of special concern, have far lower thresholds and additional restrictions. The threshold is 100 pounds for lead and lead compounds, and for each listed PFAS chemical, and it is 10 pounds for mercury and mercury compounds. Lead contained in a stainless steel, brass or bronze alloy keeps the ordinary thresholds.

You may. The reporting thresholds are based on how much of a chemical you manufacture, process or otherwise use in a year. A facility that reuses nearly all of its solvent can still owe the full Form R, the Toxics Release Inventory (TRI) report, even though it emits very little.

Low quantities may allow you to use the shorter Form A, but its 500-pound cap counts more than releases. It also counts what you dispose of, treat, recycle, burn for energy recovery or transfer off site. Consider a facility with 180 pounds of air releases and 4,000 pounds of spent solvent shipped off site for recycling. Its total is 4,180 pounds, so it cannot use Form A.

It means a product you purchase contains a chemical on EPA's Toxics Release Inventory (TRI) list. Some suppliers are required to send this notification with the first shipment of each calendar year. It identifies each listed chemical and gives its percent by weight in the product. If the exact percentage or the chemical's identity is a trade secret, the notification may give an upper limit or a generic name instead.

The notification matters because a facility cannot report what it does not know it received. Whether you have to file still depends on the three applicability criteria: employee count, industry sector and chemical quantities. If you sell mixtures yourself, you may owe supplier notifications of your own. More on supplier notification.

Form R, the annual Toxics Release Inventory (TRI) report, is due July 1 each year and covers the calendar year that closed six months earlier. Form A has the same deadline. The report goes to EPA and to your state, and you file it through TRI-MEweb, EPA's online reporting system. EPA does not accept these reports on paper, except for trade secret filings.

No extension is available. In years when July 1 fell on a weekend, EPA has accepted filing on the next business day, but nothing in the rule grants that, so treat July 1 as the deadline. An Arizona facility that has to file also owes a state report on the same day.

Yes. An Arizona facility that had to file Form R or Form A, the federal Toxics Release Inventory (TRI) forms, also owes the state a Toxic Data Report. It is a separate filing, due the same day, July 1, through myDEQ, the state's online portal. The federal form does not cover it, and filing Form A does not remove the obligation.

The state also has a pollution prevention plan requirement. A facility that uses more than 10,000 pounds of a listed toxic substance in a calendar year must file a plan with ADEQ, the Arizona Department of Environmental Quality, by December 31 of the following year. The law excludes materials from mining and metallurgical operations. More on Arizona's requirements.

Form R is the full Toxics Release Inventory (TRI) report, with all of your release, off-site transfer and waste management quantities. Form A is a short certification statement filed in its place, and it reports no quantities.

You may use Form A for a chemical only if two conditions are both met. You did not manufacture, process or otherwise use more than 1,000,000 pounds of it that year, and your annual reportable amount is 500 pounds or less. Form A is never allowed for chemicals of special concern, such as PFAS and mercury.

Form A saves data entry but almost none of the calculation work, and the July 1 deadline is the same. Form A and Form R compared.

Most facilities do not have stack test data for every release point, and the law does not require it. For a Toxics Release Inventory (TRI) report you may use data you already have, and where you have none, you may use reasonable estimates.

We select the method that fits each release point. If you have monitoring data, we use it. If not, we may use a mass balance, which compares what came in with what went out, a published or site-specific emission factor, or an engineering calculation. We then document the method, the inputs and every assumption, because that documented basis is what gets examined, more than the number itself. How releases are calculated.

To prepare a Form R, the Toxics Release Inventory (TRI) report, we need your purchasing and inventory records, your throughput figures, your waste shipping papers and your safety data sheets. We also need a walk-through of the facility, because purchasing never sees everything.

For the release estimates, we need enough process detail to select the right method for each quantity, and to document why that choice was appropriate. Sending records ahead reduces the work.

SECA is a small Arizona firm, and you deal directly with the person doing the work. Ron Fleming has been walking plant floors since 1993. He holds a master's degree in the management of hazardous materials, and he plans every project himself. His son Marcus has joined the business and is learning it on site with him.

We are sized for manufacturers with one facility or a few, and we work across manufacturing, metal finishing and the semiconductor supply chain. If you want to know how many Toxics Release Inventory (TRI) reports we have prepared, and in which industries, ask and we will tell you the number.

Often, after the first year. At a small facility with two reportable chemicals and a stable process, an environmental coordinator can genuinely manage the Toxics Release Inventory (TRI) report, once someone has set up the methodology properly and documented the reasoning.

We are glad to prepare that first year and then step back to a review each spring. We would rather do that than sell you the same job every year.

You receive three deliverables: the Toxics Release Inventory (TRI) forms as filed, the calculations and basis behind every release estimate, and a list of the chemicals you evaluated and ruled out, with the reasons for each.

If someone asks how you arrived at a number, the answer is already documented. EPA's rules require you to keep these records for 3 years from the date you file, and to keep them at the facility itself, available for an EPA inspection. That requirement catches multi-site companies that keep everything at the head office.

Penalties are assessed per violation, per day. The maximum penalty the law allows is $71,545 per violation, which is the figure after EPA's inflation adjustment that took effect January 8, 2025. Each day a violation continues counts as a separate violation, so a late Form R, the Toxics Release Inventory (TRI) report, starts accruing penalties on July 2 for each chemical. EPA adjusts the figure each year, so check the current one.

If you disclose promptly, you may pay nothing, but if you wait to be found, the penalty builds daily. Whether to disclose is a legal decision that belongs with your attorney, and we do the technical work behind it. What to do after a missed deadline.

The problem can be corrected, and it is far better corrected by you than discovered by someone else. Missed Toxics Release Inventory (TRI) reporting years do not expire, and past reports can still be filed, back to reporting year 1991.

EPA has a policy for companies that self-disclose violations. If you meet all nine of its conditions, EPA waives 100% of the punitive (gravity-based) portion of the penalty. Two of the conditions are deadlines: you must notify EPA in writing within 21 calendar days of discovering the violation, and correct it within 60 calendar days of discovery.

We determine which years you actually exceeded a threshold, prepare the back reports and document the basis for each one.

The cost of preparing a Form R, the Toxics Release Inventory (TRI) report, depends on the size of the job. Three factors set that: how many facilities you have, how many chemicals are involved, and the condition of your records. A facility with one chemical and clean records is a different project from a facility with many chemicals that has to reconstruct four past years.

Each year after the first usually takes less work, because the methodology carries forward. The first conversation costs nothing, and we give you a written scope of work before anything starts. Penalties are assessed per violation, per day, and the cost of determining whether you have to file is a fraction of that.