It’s that time again! The annual Toxics Release Inventory (TRI) reports under SARA 313 for the 2023 calendar year must be submitted to the U.S. Environmental Protection Agency (EPA) by July 1, 2024. Now is the time to begin reviewing the amounts your facility used, processed, or manufactured last year. Here are five commonly asked questions we receive about the TRI and what you need to know:
1. Do I need to bother? The short answer is “yes!” The food manufacturing industry is tied as the second highest waste generator among industries (see graph). While most of that waste is non-toxic, there are reportable chemicals at many facilities.
2. I don’t have to report, so am I off the hook? If you don’t have to report, it’s still essential to have annual usage documentation readily available as the EPA also targets non-reporting companies for TRI inspections. Keep the following key items easily accessible:
- Verify your annual usage. You can do this by keeping a record of the inventory of raw materials used over the previous year, and/or by contacting your chemical vendors and requesting the quantity of chemicals sold to you.
- Conduct calculations showing your annual TRI Sara 313 chemicals used. Compare the TRI chemical usage to the proper reporting thresholds (10,000 lbs. – Otherwise Used or 25,000 lbs. – Processed or Manufactured).
- Conduct emission calculations for TRI reportable chemicals. Include calculated air emissions, wastewater emissions based on sampling data, and solid wastes shipped out and characterization sampling results.
3. I do have to submit the TRI, what else do I need to know? If you need to report, we recommend that you also:
- Consider analyzing waste streams for reportable chemicals such as ammonia, chlorine, nitrites, and nitrates. While not required by USEPA, these analyses are fairly inexpensive and can be used to estimate releases more accurately, especially for wastewater, biosolids and solid wastes. We have found that release estimates based upon analyses are typically much less than those based solely upon engineering estimates.
- Don’t forget about nitric acid (HN03), which is used in many cleaning and sanitizing solutions. The EPA assumes that when nitric acid is neutralized, sodium nitrate (NaHN03) is “manufactured“ at a rate of 1.35 lb. NaHNO3 for every 1 lb. HN03. Therefore, if a plant uses more than 18,518 lb. HN03 (~8,050 gallons/yr of 25% nitric acid), it exceeds the 25,000 lb. reporting threshold and must report releases of nitrate compounds to the environment.
4. What’s new this year? Companies who must submit the TRI will see several changes for this year, including the need to disclose a foreign parent company, and the addition of 21 chemicals (nine of which are PFAS chemicals) to the list of reportable substances. See this link for more information.
5. How can I make this process easier? Some tips to simplify TRI reporting include:
- Create background documentation regarding the reasons behind the information, release amounts, and reporting codes. This will provide a repeatable process that will produce a more accurate report in the least amount of time. If you set up this documentation in a spreadsheet format, revising the information and preparing the report each year will be significantly easier.
- Consider using Form A instead of Form R. This very simple form can be used if a chemical is NOT “persistent, bio accumulative, and toxic (PBT),” AND you used, processed, or manufactured less than 1,000,000 pounds, AND the reportable release amount is less than 500 pounds.
- If you are reporting toxic chemicals based upon how much are used, processed, or manufactured, study your chemical usage and determine if there are ways to reduce the amount or to use non-reportable chemicals. For example, if you are using nitric acid-based cleaners/sanitizers, consider using products with other acids or reduced quantities of nitric acid. The benefits to this approach are two-fold: First by reducing the amounts of chemicals used, you can either eliminate reporting through Form R or reduce reporting by using Form A. Additionally, you can claim a reduction in toxic releases.
