A business must meet ALL of the following criteria for any particular year to be subject to EPCRA TRI requirements:
- The facility is in one of the covered industries:
- Manufacturing
- Federal Facilities
- Metal and Coal Mining
- Electric Utilities (burning coal and/or oil for commercial distribution)
- Commercial Hazardous Waste Treatment facilities (regulated under RCRA Subtitle C)
- Chemical and Allied Products - Wholesale
- Petroleum Bulk Terminals and Plants
- Solvent Recovery Services (fee or contract basis)
- The facility manufactured (including imported) or processed or otherwise used a toxic chemical in excess of the threshold quantity during the calendar year.
- Threshold quantities that trigger reporting are 25,000 pounds manufactured or processed or 10,000 pounds otherwise used, except for certain Persistent Bioaccumulative Toxic (PBT) Chemicals. The threshold for the PBT chemicals was lowered to 100 pounds or less depending on the chemical beginning with the 2000 reporting year. Reporting thresholds for PBT Chemicals are available at EPA’s website.
EPA has developed a list of more than 600 toxic chemicals subject to EPCRA Section 313 reporting requirements. Reporting thresholds are available at EPA’s website.
EPA offers a TRI Threshold Determination Tool to help facilities determine if they meet the threshold requirements for reporting to TRI. This audio visual tool will take approximately 6 to 8 minutes.
Notice To TRI Reporters
The EPA has amended 40 CFR Part 372 to include the North American Industry Classification System (NAICS) codes. Facilities are now required to use NAICS codes on Form R reports and Form A Certification Statements. Common NAICS codes for TRI reporting can be found at EPA’s website at http://www.epa.gov/tri/lawsandregs/naic/ncodes.htm.
This new requirement was published in the Federal Register June 6, 2006 and can be viewed here.
Coming in July 2009 -- Facilities that report to EPA and the Washington State Emergency Response Commission will be required to use 2007 NAICS codes on reporting forms for releases and other waste management quantities at the facility for the 2008 reporting year.
Further information on using NAICS Codes for Toxics Release Inventory (TRI) Reporting can be found on the EPA website: http://www.epa.gov/tri/lawsandregs/naic/naic%20_update%2003_12.html.
Additional information on NAICS can be found at www.census.gov/epcd/www/naics.html.
Contact Diane Fowler dfow461@ecy.wa.gov by email or by phone at (360) 407-6171.
