Questions and Answers

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Alternate Threshold; Form A; Form R; Reporting Criteria1. Determining Whether or Not to Report: Facility >
1.A. Types of Facilities That Must Report
<div style="visibility:hidden">19003 19-003 3 2019 Questions and Answers Consolidation1. Determining Whether or Not to Report: Facility 1.A. Types of Facilities That Must Report Alternate Threshold (Form A); Form A; Form R; Reporting Criteria 3. If a facility triggers TRI reporting thresholds for a listed toxic chemical (i.e., it meets the employee and toxic chemical activity thresholds and is in a covered NAICS code), is it required to report if it had no releases of the toxic chemical during the reporting year?Yes, even if it releases no toxic chemicals into the environment and does not conduct any other waste management activities involving the listed toxic chemical, the facility must submit a TRI reporting form. If the facility meets the employee and chemical activity thresholds and is in a covered NAICS code, but its annual reportable amount of a non-PBT chemical does not exceed 500 pounds and the facility has not manufactured, processed, or otherwise used more than one million pounds of the toxic chemical, the facility may submit the Form A (Alternate Threshold Certification Statement). If the facility exceeds either the 500- or one million-pound limits, it must report on the Form R (40 CFR Section 372.85 and 372.95).</div></b><div style="visibility:hidden"></div></b>-
Establishment; Facility; Form A; Form R; NAICS1. Determining Whether or Not to Report: Facility >
1.A. Types of Facilities That Must Report
<div style="visibility:hidden">19010 19-010 10 2019 Questions and Answers Consolidation1. Determining Whether or Not to Report: Facility 1.A. Types of Facilities That Must Report Establishment (Multi-Establishment; Multiestablishment); Facility; Form A; Form R; NAICS (Industry Code) 10. What is the definition of primary NAICS code? How can there be more than one NAICS code for a facility?A primary NAICS code generally represents those goods produced or services performed by an establishment that have the highest value added. Form R and the Alternate Certification Statement (Form A) provide space for more than one NAICS code because a facility may be made up of several establishments each of which may have a different primary NAICS code. Additional information on NAICS codes can be found on the NAICS TRI website.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; NAICS; Process1. Determining Whether or Not to Report: Facility >
1.C. Persons Responsible for Reporting
<div style="visibility:hidden">19091 19-091 91 2019 Questions and Answers Consolidation1. Determining Whether or Not to Report: Facility 1.C. Persons Responsible for Reporting Facility; Form A; Form R; NAICS (Industry Code); Process (Processing; Processed; Processes) 91. Company A purchases a facility from Company B between January 1 and June 30, of the same year. For the reporting forms covering the prior year, which company’s name and identification number should appear on the Form R or Form A submission?In the case that a facility is purchased between January 1 and June 30, the form submitted for the previous year must reflect the name used by the facility on December 31 of that reporting year (Monthly Call Center Report Question, EPA530-R-98-005; October 1998). In this example, Company B’s name should appear on the form because it owned the facility for the duration of the reporting year. The TRI identification number is location-specific; thus, the identification number will stay the same even if the facility changes names, production processes, or NAICS codes. With regard to reporting, the owner or operator of the facility on the annual July 1 reporting deadline (Company A) is primarily responsible for reporting the data for the previous year’s operations at that facility. However, all prior owners and operators back to January 1 of the year covered in the report may also be held responsible if the current owner or operator does not submit a report.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; NAICS; Parent Company; Process1. Determining Whether or Not to Report: Facility >
1.C. Persons Responsible for Reporting
<div style="visibility:hidden">19092 19-092 92 2019 Questions and Answers Consolidation1. Determining Whether or Not to Report: Facility 1.C. Persons Responsible for Reporting Facility; Form A; Form R; NAICS (Industry Code); Parent Company; Process (Processing; Processed; Processes) 92. In October, Facility X changes ownership and is purchased by Company Y. For that reporting year, which facility is obligated to submit the Form R or Form A, and whose name and what TRI identification number should be on the form?The owner or operator of the facility on the annual July 1 reporting deadline (i.e., Company Y) is primarily responsible for reporting the data for the entire previous year’s operations at that facility. Any other owner or operator of the facility before the reporting deadline may also be held liable. The form submitted for a given reporting year must reflect the names used by the facility and its parent company on December 31 of that reporting year, even if the facility changed its name or ownership at any time during the reporting year (Monthly Call Center Report Question, EPA530-R-98-005j; October 1998). In this scenario, because Facility X changed ownership before December 31 of the reporting year, Company Y’s name should appear on the form. The TRI identification number is location-specific; thus, the identification number will stay the same even if the facility changes names, production processes, or NAICS codes.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Form A; Form R; Recycling; Releases; Waste; Waste Management Activities5. Form A and Form R Submissions >
5.B. Form R Submissions
<div style="visibility:hidden">19713 19-713 713 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.B. Form R Submissions Activity Threshold (Threshold Determination); Form A; Form R; Recycling (Recycle); Releases (Released); Waste; Waste Management Activities 713. Facilities subject to EPCRA section 313 are required to report all releases and other waste management activities involving toxic chemicals for which the facility has exceeded an activity threshold. Specifically, in Section 8, Column A of the Form R, facilities must report quantities of a toxic chemical released or managed as waste for the prior year. Must a facility report on quantities of a toxic chemical released or managed as waste for the prior year if the facility was not required to file a Form R or Form A for that toxic chemical in the prior year?The owner or operator of a facility may put "NA" in Column A of Sections 8.1 through 8.7 of the Form R if the toxic chemical was not present at the facility in the prior year. "NA" is also appropriate for Column A if the toxic chemical was present at the facility in any amount during the prior year, but there was no possibility for a release or other waste management activity of that toxic chemical to occur during the prior year. For example, if the facility did not have an on-site recycling operation for the waste stream containing the toxic chemical in the prior year, the facility may put "NA" in Column A of Section 8.4 (on-site recycling). Otherwise, the owner or operator should provide a reasonable estimate for prior year release and other waste management activities of a toxic chemical in Column A of Sections 8.1 through 8.7.</div></b><div style="visibility:hidden"></div></b>-
Form A; Form R; PBT Chemicals; Releases; Reporting Requirements; Waste5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19727 19-727 727 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Form A; Form R; PBT Chemicals; Releases (Released); Reporting Requirements; Waste 727. How did the 2009 Omnibus Appropriations Act change the TRI Form A reporting requirements?The 2009 Omnibus Appropriations Act returned TRI reporting requirements back to the rules in effect prior to December 22, 2006. These changes affect TRI reports due July 1, 2009 and beyond. The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals (as listed in 40 CFR 372.28) be submitted on "Form R," the more detailed form. For all other chemicals the shorter form, "Form A," may be used only if the "annual reporting amount" (i.e., the sum of production-related releases and other waste management) does not exceed 500 pounds and the amount manufactured, processed, or otherwise used does not exceed 1 million pounds during the reporting year. </div></b><div style="visibility:hidden"></div></b>-
Form A5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19728 19-728 728 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Form A 728. What is the Form A and who may submit this form?The Form A provides certain covered facilities the option of submitting a substantially shorter form with a reduced reporting burden. Facilities which meet the NAICS code, employee, and chemical activity thresholds but who do not exceed one million pounds manufactured, processed, or otherwise used and the facility’s total annual reportable amount does not exceed 500 pounds for the non-PBT chemical, may submit an annual certification statement (Form A) instead of a Form R for the toxic chemical.</div></b><div style="visibility:hidden"></div></b>-
Form A5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19729 19-729 729 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Form A 729. What is the Form A and when may it be used?The Form A provides certain covered facilities the option of submitting a substantially shorter reporting form. For non-PBT chemicals, reporters are eligible to use Form A if they have an annual reportable amount (i.e., the sum of production-related releases and other waste management) of the chemical that does not exceed 500 lb/yr and the amount manufactured, processed, or otherwise used does not exceed 1,000,000 lb as of Reporting Year 2008, Form A may no longer be used to report PBT chemicals.</div></b><div style="visibility:hidden"></div></b>-
Alternate Threshold; Form A5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19730 19-730 730 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Alternate Threshold (Form A); Form A 730. If I meet the criteria for filing a Form A for one non-PBT chemical, may I use it for all of the non-PBT chemicals covered at my facility?No. Eligibility for use of Form A is toxic chemical specific. However, more than one toxic chemical can be reported on a single Form A. To be eligible for reporting a toxic chemical using Form A, a facility must not manufacture, process, or otherwise use more than one million pounds of the specific non- PBT chemical and the total annual reportable amount for the non-PBT chemical must be less than 500 pounds. In some instances, a facility may submit the Form A for some chemicals and the Form R for other chemicals. Although all non-PBT toxic chemicals that meet the eligibility criteria for use of Form A may now be reported together on a single Form A, each eligible toxic chemical must be individually listed on the Form. </div></b><div style="visibility:hidden"></div></b>-
Alternate Threshold; Form A5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19731 19-731 731 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Alternate Threshold (Form A); Form A 731. EPA published a final rule in the Federal Register on November 30, 1994 (59 FR 61488), which created an alternate threshold of one million pounds for certain facilities. How can a facility that exceeds one of the original thresholds qualify for the alternate threshold?Facilities which have a total annual reportable amount of no greater than 500 pounds for a listed non-PBT chemical may qualify for the one-million-pound alternate threshold for that chemical, beginning with the 1995 reporting year. For purposes of the alternate threshold, the total annual reportable amount includes non-PBT chemicals listed at 40 CFR Section 372.65 which are released (including disposed), treated, recycled, and burned for energy recovery at the facility and amounts transferred from the facility to off-site locations for the purposes of recycling, energy recovery, treatment, and/or disposal. These amounts correspond to column B, Sections 8.1 through 8.7 of the reporting Form R. If a facility’s combined total annual reportable amount does not exceed 500 pounds for a specific non- PBT chemical, the facility can qualify for reduced reporting requirements unless the amount of that non-PBT chemical manufactured, processed, or otherwise used within the reporting year exceeds one million pounds. Covered facilities that qualify for the alternate threshold are not exempt from reporting, but must fulfill certain requirements. In lieu of submitting a Form R, the owner/operator of a facility must submit an annual certification statement (Form A) indicating that the facility met the requirements for use of the alternate threshold for a specific chemical. The facility must also maintain, and make available upon request, records substantiating the claim. The Form A includes basic information regarding the facility’s identification, the chemical in question, and a statement of accuracy to be signed by a senior management official of the facility.</div></b><div style="visibility:hidden"></div></b>-
Form A; Release Reporting5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19734 19-734 734 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Form A; Release Reporting 734. What is the total annual reportable amount and is it the same as an RQ (Reportable Quantity)?No, they are not the same. The total annual reportable amount applies to EPCRA section 313 listed toxic chemicals and is facility specific. A facility's total annual reportable amount is equal to the combined total quantities released at the facility (including disposed), treated for destruction at the facility (as represented by amounts destroyed or converted by treatment processes), recovered at the facility as a result of recycle operations, combusted for the purpose of energy recovery at the facility, and amounts transferred from the facility to off-site locations for the purpose of recycle, energy recovery, treatment, and/or release (including disposal). The total annual reportable amount is not the same as a reportable quantity (RQ). An RQ is chemical specific and applies to Extremely Hazardous Substances (EHS) or CERCLA Hazardous Substances. In the case of an accidental release, a facility owner/operator would refer to a chemical's RQ to determine if the facility has released enough such that reporting to a Local Emergency Planning Committee, SERC, and the National Reporting Center is required under EPCRA Section 304 and CERCLA Section 103.</div></b><div style="visibility:hidden"></div></b>-
Alternate Threshold; De minimis Exemption; Establishment; Facility; Form A; Form R5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19735 19-735 735 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Alternate Threshold (Form A); De minimis Exemption; Establishment (Multi-Establishment; Multiestablishment); Facility; Form A; Form R 735. In lieu of submitting a TRI Form R, facilities are given the option of submitting a Form A provided that it is a non-PBT chemical, they do not exceed 500 pounds for the total annual reportable amount, and that the amounts manufactured, processed, or otherwise used of the chemical do not exceed one million pounds. When determining if a facility meets the one-million-pound alternate threshold and the 500-pound annual reporting amount, is the facility permitted to consider exemptions, such as the article or de minimis exemption, and exclude those quantities from their calculations?A facility is permitted to take exemptions, if applicable, when determining whether the facility has met the one-million-pound alternate threshold. Additionally, a facility does not have to count exempted activities towards the annual reportable amount. The alternate threshold and annual reportable amount determinations for an individual chemical must be based upon a whole facility determination and account for all establishments within a facility; therefore, an individual activity may be exempt but the facility may exceed the alternate threshold or annual reportable amount at the facility level.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.F. TRI-MEweb
<div style="visibility:hidden">19737 19-737 737 2019 Questions and Answers Consolidation8. Electronic Reporting 8.F. TRI-MEweb Facility; Form A; Form R 737. What is TRI-MEweb?The Electronic Reporting Rule requires facilities to submit, revise, and withdraw non-trade secret TRI forms electronically via TRI-MEweb, a web-based reporting application for electronic filing of TRI Form R and Form A Certification Statement reports. The TRI-MEweb application is hosted in EPA's Central Data Exchange (CDX) system. Users must access, create, and load facility accounts in TRI-MEweb to begin reporting. TRI reporting requires two user roles to be created in CDX: a preparer role and a certifying official role. Preparers and certifying officials must register for the application at: https://cdx.epa.gov/. To learn more about TRI-MEweb, please visit https://www.epa.gov/toxics-release-inventory-tri-program.</div></b><div style="visibility:hidden"></div></b>-
Form A; Form R5. Form A and Form R Submissions >
5.B. Form R Submissions
<div style="visibility:hidden">19738 19-738 738 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.B. Form R Submissions Form A; Form R 738. Can commercially developed electronic versions of the Forms be submitted for compliance with Section 313?The Agency encourages submission of Forms using the EPA software provided with the Form R package. The Agency has also approved the facsimile outputs of certain privately developed software packages. A list of the providers of software packages is made available by EPA. Contact the EPCRA Information Hotline for more information ((800) 424-9346 or (703) 412-9810). </div></b><div style="visibility:hidden"></div></b>-
Form A; Recordkeeping; Reporting Requirements5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19746 19-746 746 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Form A; Recordkeeping; Reporting Requirements 746. If I qualify and file a Form A, must I submit any other documentation to EPA and the state or tribal authority?No. If a covered facility meets the criteria and files the Form A, the owner/operator need not submit any other documentation to EPA and the state or tribal authority. However, the facility must maintain all documentation supporting their Form A submission. </div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; Recordkeeping8. Electronic Reporting >
8.F. TRI-MEweb
<div style="visibility:hidden">19749 19-749 749 2019 Questions and Answers Consolidation8. Electronic Reporting 8.F. TRI-MEweb Facility; Form A; Form R; Recordkeeping 749. Will facilities be able to print paper copies of reports using TRI-MEweb?The Electronic Reporting Rule, effective January 21, 2014, requires facilities to submit, revise, and withdraw non-trade secret TRI forms electronically via TRI-MEweb application. Facilities cannot use TRI-MEweb to print federal paper submissions to submit to EPA. However, TRI-MEweb does allow facilities to print a copy of the submitted TRI form for recordkeeping purposes (this form is clearly marked as not allowed to be filed manually to EPA). Facilities may print a copy of a Form R or Form A Certification Statement for recordkeeping purposes via the “Submission History” tab. The “Submission Summary” page will display only the forms which have been certified and submitted to EPA. Select “View Reports” to access your Copy of Record of your Form R or Form A Certification Statement. </div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.F. TRI-MEweb
<div style="visibility:hidden">19750 19-750 750 2019 Questions and Answers Consolidation8. Electronic Reporting 8.F. TRI-MEweb Facility; Form A; Form R 750. Are there any TRI-MEweb tutorials available?The TRI-MEweb tutorials are designed to demonstrate how different tasks are performed within the Web-based application reporting tool. These tutorials are designed for new users, as well as experienced users. These tutorials are available to watch within TRI-MEweb.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.A. Central Data Exchange
<div style="visibility:hidden">19751 19-751 751 2019 Questions and Answers Consolidation8. Electronic Reporting 8.A. Central Data Exchange Facility; Form A; Form R 751. Who can I contact if I need to troubleshoot a CDX or TRI-MEweb technical issue?Users may request assistance from the CDX hotline on issues like how to obtain access keys, load facility accounts, and verify status of submissions in TRI-MEweb. Users may also request assistance from the CDX helpdesk to reset passwords, address issues with the CDX registration process, and add the TRI-MEweb application to the CDX user account. These technical application issues can be resolved if you can contact the CDX hotline at (888) 890-1995.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.A. Central Data Exchange
<div style="visibility:hidden">19752 19-752 752 2019 Questions and Answers Consolidation8. Electronic Reporting 8.A. Central Data Exchange Facility; Form A; Form R 752. I am having problems opening the CDX login webpage to launch TRI-MEweb.If the CDX login webpage is down for a legitimate reason (i.e., maintenance, system update), an announcement should be posted on the main CDX login webpage and on the TRI website. However, if the CDX login webpage is operational, but the webpage appears broken on your computer, you should check to ensure that your browser’s TLS 1.0 security setting is enabled.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.F. TRI-MEweb
<div style="visibility:hidden">19755 19-755 755 2019 Questions and Answers Consolidation8. Electronic Reporting 8.F. TRI-MEweb Facility; Form A; Form R 755. Can I use the TRI-MEweb application if I have my own TRI software?Some facilities have their own software or use private software to assist in collecting chemical release data. This "third party software" is often designed to produce output data files that match EPA's electronic data structure specifications. Facilities may upload their data files in extensible markup language (XML) format via the Upload Tool in TRI-MEweb. The facility’s information can also be updated in TRI-MEweb using the Upload Tool. All data uploaded must be checked for errors and certified. For more information, please view the “Using the Upload/Download Data Tool” tutorial, which can be found on TRI’s website: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials. </div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; Signature8. Electronic Reporting >
8.B. Certifying Official
<div style="visibility:hidden">19757 19-757 757 2019 Questions and Answers Consolidation8. Electronic Reporting 8.B. Certifying Official Facility; Form A; Form R; Signature 757. How do I add the certifier role for TRI-MEweb to my CDX user account?To add the TRI-MEweb Certifying Official role to an existing CDX user account, follow these steps: 1) Log in to your CDX account at https://cdx.epa.gov/ to open your MyCDX account page and click on "Manage Your Program Services" link. 2) Under TRI-MEweb, request a new role by selecting and adding “certifying official.” 3) Verify your identity. This is either done online by correctly answering personal identifying information or by printing, signing, and mailing in a paper Electronic Signature Agreement (ESA) form to EPA’s Data Processing Center (DPC). Completing the online process will provide you immediate access to TRI-MEweb. If you submit a paper ESA then the TRI-MEweb link will remain deactivated and inaccessible until the ESA is processed and approved by the DPC. Additional information is available in a series of TRI-MEweb tutorials available on the TRI website at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; States; Tribes3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.A. General Questions
<div style="visibility:hidden">19758 19-758 758 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.A. General Questions Facility; Form A; Form R; States (Tribes); Tribes 758. Are there any fees associated with submitting the Form R?Under EPCRA section 313 and its implementing federal regulations, there are no federal fees or taxes for submitting a Form R or Form A to EPA or the state. However, states and tribes may have similar reporting programs or other state/tribe requirements that associate fees or taxes with the submission of TRI forms. A directory of state and tribe TRI program contacts is available at: https://www.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts. </div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; Reporting Requirements8. Electronic Reporting >
8.B. Certifying Official
<div style="visibility:hidden">19768 19-768 768 2019 Questions and Answers Consolidation8. Electronic Reporting 8.B. Certifying Official Facility; Form A; Form R; Reporting Requirements 768. How does the new certification module work in TRI-MEweb?EPA has developed a new certification component within the TRI-MEweb application that will allow a facility to prepare any reporting year TRI Form R or Form A Certification Statement and transition directly into the certification process without leaving the TRI-MEweb application. New RY 2012 TRI-ME-web users: There are two user roles involved in the reporting process to EPA of your TRI data; a preparer role and a certifying official role. Both of these TRI roles require creating/having a Central Data Exchange (CDX) user account and adding the TRI-MEweb application to their MyCDX profile. All new certifying officials will need to apply for an Electronic Signature Agreement (ESA) before they are allowed to certify any pending TRI forms. There are now two options to obtain an ESA. A single link will take both roles to open the TRI-MEweb application to a landing page to begin managing their facility accounts. All existing certifying officials: In prior reporting years, the certifying officials had to certify TRI forms in a separate module in their MyCDX account. The new certification module is now available within the TRI-MEweb application. This will require all our existing certifying officials to add their TRIFID(s) for their facilities into the application. All pre-approved certifying officials will be prompt upon logging into CDX and opening for the first time the TRI-MEweb application in the RY 2012 reporting season to proceed to the “Manage TRIFIDs” section under the “Certify” tab. All TRIFID(s) assigned in prior years should already be listed. The certifying official may add any missing TRIFIDs that will transmit TRI forms (without needing to process a new ESA for each) with only digitally signing a verification statement. If any TRI forms have been previously sent, they will appear under the “Pending Submission” subtab.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Facility; Form A; Form R8. Electronic Reporting >
8.C. Not Reporting?
<div style="visibility:hidden">19770 19-770 770 2019 Questions and Answers Consolidation8. Electronic Reporting 8.C. Not Reporting? Activity Threshold (Threshold Determination); Facility; Form A; Form R 770. If a facility previously submitted a TRI reporting form but no longer meets the applicability criteria (e.g., the facility closed and did not exceed activity thresholds), how does the facility notify EPA that the facility is no longer subject to TRI?The facility can use TRI-MEweb to indicate that your facility will no longer be reporting to TRI, or will not be submitting a form for one or more specific TRI-listed chemicals for the current reporting year. The facility can submit this information without filing a TRI form or certifying this information. In TRI-MEweb’s “Facilities Management” page, the “Not Reporting?” option can indicate if the facility will not be submitting one or more TRI reporting forms for the current reporting year. Alternatively, facilities may submit an e-mail to the TRI Data Processing Center (DPC). The e-mail should include the facility name; TRI facility identification number (TRIFID); facility address; technical contact name and telephone number; and, the reason why the facility is not submitting a TRI reporting form (e.g., failed to trigger a reporting threshold) or is no longer subject to TRI (e.g., facility closed, process modifications, production changes, product elimination or substitution). If the facility closed, the e-mail should also specify the date of closure. Contact information for the TRI DPC is available here: https://www.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.F. TRI-MEweb
<div style="visibility:hidden">19772 19-772 772 2019 Questions and Answers Consolidation8. Electronic Reporting 8.F. TRI-MEweb Facility; Form A; Form R 772. How do I import data from the previous year into my current year TRI forms? Is this function done automatically?TRI-MEweb allows users to import data from the previous year into their current reporting year forms in TRI-MEweb. However, this function is not automatically performed by the application. When creating a new form, a preparer can select the “Import Data” option to pre-populate the prior year's reported data into the current year forms. The preparer must select the individual chemical name(s) to import and report to EPA for the current year form. Note that there are some limitations to the data that will be imported from the prior reporting year. Any “Not Applicable” checkboxes will not be checked on any section of the form. Section 8.8 of the Form R (catastrophic quantities) and the Schedule 1 (dioxin and dioxin-like compounds) will not be imported. Data pertaining to numeric basis estimates or rounding values will also not be imported. </div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R8. Electronic Reporting >
8.F. TRI-MEweb
<div style="visibility:hidden">19773 19-773 773 2019 Questions and Answers Consolidation8. Electronic Reporting 8.F. TRI-MEweb Facility; Form A; Form R 773. How can I update information about my facility (e.g., new facility name or new technical contact) for TRI purposes?Facility information, including name and contact information, must reflect the facility on December 31st of that reporting year. If information for the facility has changed, the preparer will need to update the information in TRI-MEweb. Navigate to the “Facilities Management” page in TRI-MEweb to choose the “Not Reporting” option for the facility and update the facility’s information. Preparers can also edit facility names while preparing a Form R or Form A Certification Statement, in the “Edit Facility” page. Alternatively, facilities may submit an e-mail to the TRI Data Processing Center. The e-mail should include: the facility name; TRI facility identification number (TRIFID); facility address; technical contact name and telephone number; and, the reason for the change (if necessary). Contact information for the TRI DPC is available at the following website: https://www.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; Reporting Requirements3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.A. General Questions
<div style="visibility:hidden">19784 19-784 784 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.A. General Questions Facility; Form A; Form R; Reporting Requirements 784. Section 4.6 of Part I of the TRI Form R and Form A asks for the facility’s Dun & Bradstreet number. What is a Dun & Bradstreet number? How can someone completing the Form R or Form A find the Dun & Bradstreet number for the facility?A Dun & Bradstreet number, commonly referred to as a DUNS number, is a nine-digit, location-specific, business code assigned by Dun & Bradstreet. The DUNS number is a unique number that financially identifies individual businesses, while linking them with their corporate family structures. The Dun & Bradstreet number may be available from the facility’s treasurer or financial officer. Facilities can also contact Dun & Bradstreet directly at 800-234-3867 or https://www.dnb.com to obtain a facility’s number, or to create a new number if the facility does not currently have a number. Please note for Reporting Years 1991-2004, Section 4.6 of Part I requested a facility’s latitude and longitude. During this time, the DUNS number was located in Section 4.7 of Part I of the Forms.</div></b><div style="visibility:hidden"></div></b>-
Form A; Form R; Withdrawal8. Electronic Reporting >
8.D. Revisions and Withdrawls
<div style="visibility:hidden">19806 19-806 806 2019 Questions and Answers Consolidation8. Electronic Reporting 8.D. Revisions and Withdrawls Form A; Form R; Withdrawal 806. How do I withdraw my data using TRI-MEweb?Facilities that filed a TRI Form R or Form A Certification Statement may submit their requests to EPA to withdraw the data from EPA's database (i.e., the Toxics Release Inventory Processing System (TRIPS)) and public versions of the database (e.g., Envirofacts and TRI Explorer) for a form that was previously submitted. If EPA withdraws the submission, the chemical release record will be permanently deleted from the public databases and cannot be restored afterwards. Some specific types of form revisions require a withdrawal of the facility’s submission. For example, if a facility wishes to change the chemical name and CAS number of a previously certified report, they must first withdraw the submission that has the incorrect chemical name and then prepare a new report with the correct chemical name and CAS number associated with it. For only this type of revision, a withdrawal and subsequent revision of a chemical name and CAS number on a TRI form will result in the loss of the original submission date. In order to have a submission deleted from the TRI database, facilities must use TRI-MEweb to submit their withdrawal request to EPA and the appropriate state/tribal agency. To submit a TRI form withdrawal request, enter the “Form Submitted” section to select the form you would like to be withdrawn. You can also provide optional information for what prompted the withdrawal. All withdrawal requests need to be certified by the certifying official. TRI-MEweb will notify you that the form has been sent to CDX for processing. After a request for withdrawal has been submitted, an e-mail will be sent to both the certifying official and the preparer with instructions for certifying the pending submission. Additional information on how to withdraw TRI submissions, including a list of withdrawal codes, is provided in the Reporting Forms and Instructions. A tutorial on withdrawing submitted forms (“Form Review, Revise, or Withdraw”) is available at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials.</div></b><div style="visibility:hidden"></div></b>-
Form A; Form R; Withdrawal5. Form A and Form R Submissions >
5.C. Form R Withdrawals
<div style="visibility:hidden">19807 19-807 807 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.C. Form R Withdrawals Form A; Form R; Withdrawal 807. What is the procedure for requesting a withdrawal of a Form R or Form A submission?In order to have a submission deleted from the TRI database, facilities must use TRI-MEweb to submit their withdrawal request to EPA and the appropriate state/tribal agency. To submit a TRI form withdrawal request, enter the "Form Submitted" section to select the form you would like to be withdrawn. You can also provide optional information for what prompted the withdrawal. All withdrawal requests need to be certified by the certifying official. Additional information on how to withdraw TRI submissions, including a list of withdrawal codes, is provided in the Reporting Forms and Instructions. A tutorial on withdrawing submitted forms ("Form Review, Revise, or Withdraw") is available at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials.</div></b><div style="visibility:hidden"></div></b>-
Form A; Form R; Form R Revisions5. Form A and Form R Submissions >
5.C. Form R Withdrawals
<div style="visibility:hidden">19816 19-816 816 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.C. Form R Withdrawals Form A; Form R; Form R Revisions 816. What is the procedure for voluntarily revising previously submitted Forms R or Form A reports?Voluntary revisions (as opposed to revisions required to correct errors that prohibit further Form R/Form A processing) must be submitted to the EPCRA Reporting Center and the appropriate state agency. EPA requires covered facilities to submit all revisions using TRI-MEweb, even if the original submission was on hard copy. Standard revisions (i.e., revising a Form R with another Form R, or revising a Form A with another Form A) may be completed through TRI-MEweb. See the mini-tutorials webpage for more information on revising submitted TRI forms: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials.</div></b><div style="visibility:hidden"></div></b>-
Form A; Form R; Withdrawal5. Form A and Form R Submissions >
5.C. Form R Withdrawals
<div style="visibility:hidden">19818 19-818 818 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.C. Form R Withdrawals Form A; Form R; Withdrawal 818. What is the procedure for replacing a Form A with a Form R and vice versa?A Form R submitted after a Form A for the same chemical and reporting year is considered to be a late submission of a Form R and a request for a withdrawal of the previously filed Form A. A Form A submitted to replace a previously filed Form R is treated as both a withdrawal request and a replacement for the original Form R, and is subject to EPA review and approval. See the TRI-MEweb mini-tutorials webpage for more information on withdrawing submitted TRI forms: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials.</div></b><div style="visibility:hidden"></div></b>-
Form A5. Form A and Form R Submissions >
5.B. Form R Submissions
<div style="visibility:hidden">19819 19-819 819 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.B. Form R Submissions Form A 819. If my facility meets the Form A criteria on reporting years prior to 1995, may I withdraw my Form Rs and submit Form As instead?No. Facilities may use the Form A beginning with the 1995 reporting year. Facilities may not use this form for prior years. </div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R; Revisions8. Electronic Reporting >
8.D. Revisions and Withdrawls
<div style="visibility:hidden">19820 19-820 820 2019 Questions and Answers Consolidation8. Electronic Reporting 8.D. Revisions and Withdrawls Facility; Form A; Form R; Revisions 820. How do I revise my data using TRI-MEweb?For step-by-step instructions on how to revise forms in TRI-MEweb, please view the “Form Review, Revise, Withdraw” tutorial on TRI’s website at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-meweb-mini-tutorials. EPA no longer accepts hard copy revisions of TRI Form R and Form A Certification Statements. Any revisions of TRI reporting forms should also be submitted to the state, tribe, or territory that received the initial TRI report.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A; Form R5. Form A and Form R Submissions >
5.A. Form A (Alternate Threshold Reporting)
<div style="visibility:hidden">19821 19-821 821 2019 Questions and Answers Consolidation5. Form A and Form R Submissions 5.A. Form A (Alternate Threshold Reporting) Facility; Form A; Form R 821. For EPCRA section 313 TRI reporting, if a covered facility determines that it erroneously submitted a Form A in a given reporting year, can the facility change the Form A to a Form R by submitting a revision?A TRI-covered facility that submitted a Form A for a given reporting year but later determines that it should have submitted a Form R must withdraw its Form A and submit a Form R for that reporting year as soon as possible. In this case, the withdrawal of the Form A and subsequent submission of a Form R will result in the loss of the original submission date of the Form A. If the Form R is submitted after the deadline for the applicable reporting year, then the Form R is considered a late submission. Additionally, the facility may wish to consult the Environmental Protection Agency’s (EPA) Audit Policy, a policy offering incentives to promote self-disclosure and expeditious correction of violations, to see whether it is applicable to the facility’s situation. Information on the Audit Policy and EPA Audit Policy Contacts is accessible at: https://www.epa.gov/compliance/epas-audit-policy. The TRI Regional Coordinator for your facility should also be able to assist you should you have any questions on TRI reporting or the Audit Policy.</div></b><div style="visibility:hidden"></div></b>-
Facility; Form A3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.A. General Questions
<div style="visibility:hidden">19890 19-890 890 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.A. General Questions Facility; Form A 890. What has the TRI program done to reduce the TRI reporting burden?Over the years, EPA has been mindful of the reporting burden that the TRI Program imposes on covered facilities and has sought to reduce that burden through modifications to the reporting forms. In 1994, EPA introduced an alternate reporting form, "Form A," to streamline reporting for smaller releases. In July 2005, a rule was finalized that revised the TRI reporting forms by eliminating unnecessary information, simplifying reporting codes, and no longer requiring facilities to submit locational data, which are already available from EPA's Facility Registry System (FRS). EPA also released TRI-MEweb, a web-based version of the TRI-ME reporting software. EPA will continue to examine ways to reduce the TRI reporting burden while maintaining the TRI Program's commitment to providing information on toxic chemical releases to the public.</div></b><div style="visibility:hidden"></div></b>-
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