EPA Toxics Release Inventory (EPCRA Section 313) explained: which facilities must report, chemical thresholds, the July 1 deadline and Form R.
Regulatory citation: Emergency Planning and Community Right-to-Know Act, Section 313; 40 CFR Part 372
Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) requires certain facilities to report annually on releases and waste management of listed toxic chemicals. The data is published in EPA's Toxics Release Inventory (TRI), which the public can search.
TRI gives communities, regulators and investors insight into how facilities manage toxic chemicals. Because the data is public, accurate and timely reporting also affects a company's reputation.
A facility generally must report if it is in a covered industry sector, has 10 or more full-time employee equivalents, and manufactures or processes more than 25,000 pounds, or otherwise uses more than 10,000 pounds, of a listed chemical in a calendar year. Persistent, bioaccumulative and toxic (PBT) chemicals have much lower thresholds.
Covered facilities submit a Form R for each chemical above threshold, or may use the shorter Form A certification if they meet certain criteria.
TRI reports covering the previous calendar year are due by July 1 each year, submitted electronically.
Reports include quantities released to air, water and land, transferred off site, recycled, treated or burned for energy recovery, along with source reduction activities.
Facilities must keep supporting records for three years.
Build TRI tracking into purchasing and inventory systems so threshold calculations are accurate.
EPA periodically adds chemicals to the TRI list, including certain PFAS, so review the list each year.
Record how release quantities were estimated to support accuracy and consistency.
A plastics manufacturer with 120 employees processes 40,000 pounds of styrene in a year, which exceeds the 25,000-pound processing threshold. The environmental manager calculates air emissions using monitoring data and emission factors, prepares a Form R, and submits it electronically before July 1.
Related regulations: EPA Tier II Reporting, EPA release reporting, EPA Hazardous Waste Generators.
Note: This summary reflects federal EPA requirements. Many states run authorized programs with additional or stricter rules. Always check the current regulation text and your state environmental agency's requirements.
Facilities generally must report if they are in a covered industry, have 10 or more full-time employee equivalents, and exceed reporting thresholds for a listed chemical: 25,000 pounds manufactured or processed, or 10,000 pounds otherwise used. PBT chemicals have lower thresholds.
TRI reports are due by July 1 each year and cover the previous calendar year.
Tier II, under EPCRA Section 312, reports hazardous chemical inventories stored on site to local emergency planners. TRI, under Section 313, reports annual releases and waste management of listed toxic chemicals to EPA.
This guide is for general information only and is not legal advice. Always check the current text of the regulation with the relevant regulator.
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