Download Toxic Release Inventory - Iowa

Toxic Release Inventory
Iowa-Illinois Safety Council
64th annual Professional Development
Conference & Expo
April 19-21, 2017
Where it Started
• In 1986, Congress passed the Emergency
Planning and Community Right-to-Know Act
(EPCRA) to support and promote
emergency planning and to provide the
public with information about releases of
toxic chemicals in their community. Section
313 of EPCRA established the Toxics
Release Inventory.
What was the intent
• TRI was part of a new approach to
environmental protection. By making
information about industrial management of
toxic chemicals available to the public
• In general, chemicals covered by the TRI
Program are those that cause:
• Cancer or other chronic human health effects
• Significant adverse acute human health effects
• Significant adverse environmental effects
The Regulation
• Section 313 of EPCRA requires facilities to file a TRI report
annually for each Section 313 chemical exceeding an activity
threshold (manufacturing, processing or otherwise using)
• Section 313 chemical list contains over 650 chemicals
and chemical categories
• Facilities exceeding an activity threshold must report if they
are:
• In a “covered sector” (defined by NAICS codes); and
• Have 10 or more employees, 20,000 hours worked per
year
• Submit TRI reports to U.S. EPA, and either
• designated state officials, or
• designated tribal office
…….by July 1st following the calendar year’s activities
New Users
• New to TRI?
• Determine applicability
• Listed industry
• 10 or more fte
• Manufacture, processes, or other wise uses
• Threshold quantities
• Electronic certifying
• Preparer, certifier
Employee Determination
• Worked for the facility
• Includes operational staff, administrative staff,
contractors, dedicated sales staff, company
drivers, off-site direct corporate support
• Does NOT include contract drivers or
contractors performing intermittent service
functions such as janitorial
• Add all hours from part-time and full-time
employees
• Multiple sites, each site must meet criteria
Covered Industries
• Not all industry sectors are covered by the TRI
Program, and not all facilities in covered sectors
are required to report to TRI.
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TRI-Covered Industries
212 mining
221 utilities
31-33 manufacturing
All other misc manufacturing (1119,1131,2111,4883,5417,
8114)
424 Merchant wholesalers, non-durable goods
425 Wholesale electronic markets and agents Brokers
511, 512, 519 Publishing
562 Hazardous Waste
Federal Facilities
Aplicability
• Manufacture: The term “manufacture”
means to produce, prepare, compound, or
import an EPCRA Section 313 chemical.
• The term “manufacture” also includes
coincidental production of an EPCRA
Section 313 chemical (e.g., as a byproduct
or impurity) as a result of the manufacture,
processing, otherwise use or disposal of
another chemical or mixture of chemicals.
Applicability
• “Process” means the preparation of a listed
EPCRA Section 313 chemical, after its
manufacture, for distribution in commerce.
• Processing is usually the incorporation of
an EPCRA Section 313 chemical into a
product. Processing includes preparation of
the EPCRA.
• The term also applies to the processing of a
mixture or other trade name product that
contains a listed EPCRA Section 313
chemical as one component.
Applicability
• The term “otherwise use” means any use of
an EPCRA Section 313 chemical, including
an EPCRA Section 313 chemical contained
in a mixture or other trade name product or
waste, that is not covered by the terms
manufacture or process.
• Otherwise use of an EPCRA Section 313
chemical does not include disposal,
stabilization, or treatment for destruction
unless……………
Reporting Process
• Determine applicability
• Review SDS for listed chemicals
• Request Chemical or environmental data
sheets
• Consider de-minimis concentrations
• Develop a user friendly spreadsheet
• Track your assumptions
• Keep your electronic responses in a safe
place.
Reporting Process
• Gathering data
• Keep ongoing records
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Monthly
Build a comprehensive spreadsheet
Be consistent
Document assumptions
• On-line data entry
• Have your records ready
• Previous submittal
• Spreadsheet
• Share your log-in data with someone in-house
Reporting Process
• CDX, Central Data Exchange
• Password reset, every 90 days
• https://www.epa.gov/toxics-releaseinventory-tri-program
• ESA electronic signature agreement
• TRI Facility Identifier and access key
• Tri-me web
• Help desk 888-890-1995
2017 Update
• Last update on January 9, 2017
• Streamlined the process
• Easier access for inputting data
• Change to the “look” of the site
• Many more drop downs
• https://www.epa.gov/toxics-release-inventory-triprogram/tri-meweb-enhancements-ry-2016
• Due July 3rd at midnight
2017 Update
• User data is to automatically transfer,
quantity data may or may not, you may
need to find the data and transfer it
personally
• Check after submittal and certification to
see if errors are present
• Keep your calculations and copies of forms
submitted.
Self Disclosure
• Just determined you should have reported a
previous year?
• Under CDX use “eDisclosure”
• Log on similar to TriMeweb
Questions
Donn Stone, P.E.
3240 99th St. Urbandale, IA 50322
Office: (316) 260-2460
Mobile: (515) 689-7701