RY 2011 Form R Submissions Due July 2nd this Year
One “Extra” Day
The federal USEPA Toxic Release Inventory (TRI) Report under EPCRA Section 313 (commonly referred to as “Form R”) are normally due on July 1 of each calendar year. However, since July 1 falls on a Sunday this year, the USEPA will accept Reporting Year (RY) 2011 TRI forms that are posted and/or postmarked by Monday, July 2, by 11:59:59 PM Eastern Time.
What’s New for RY 2011?
According to the USEPA there are a few changes for RY 2011. They are as follows:
-Addition of national Toxicology Program (NTP) Carcinogens to the TRI Chemical list. There are a total of 16 new chemicals on this list that are required to be included on the RY 2011 submission. For a copy of the full list, refer to the RY 2011 reporting instructions published by the USEPA
-Certain questions on the Form R report have changed to reflect the TRI Information Collection Request that was approved in October 2011. In particular, Sections 5.1, 5.3, 6.1, 6.2, 8.10, 8.11 and 9.1 have been changed
-On October 17, 2011 the USEPA lifted the administrative stay for TRI reporting of hydrogen sulfide. Facilities that manufacture, process or otherwise use hydrogen sulfide need to track usage during calendar year 2012 and report it on their Form R submission for RY 2012 (which is due on July 1, 2013).
-USEPA will only accept TRI-Meweb or paper submissions for RY 2011 and the USEPA is strongly encouraging everyone to use the electronic system. The USEPA will no longer except submissions on CD ROM.
Surviving Form R Reporting
Form R is one of the more difficult reports to prepare and if you haven’t started yet, you still have enough time to get it done. Here are some things to consider to increase your odds of successfully surviving Form R reporting season:
-Are any of the chemicals you use at your facility on the USEPA EPCRA 313 list? – be sure to check all of your mixtures, formulations, and by-products, as the list is CAS number based.
If you do, you need to determine how the SARA 313 chemical is used at your facility because you will need to check it against the Form R reporting definitions of: “manufactured,” “processed,” and “otherwise used” categories. These three categories have specific thresholds that determine if reporting is necessary.
-Do any of your EPCRA 313 chemicals have special reporting requirements such as lower thresholds or certain chemical qualifiers?
If so, you need to make sure that you take special care in your threshold determination calculations.
-Do you have copies of your annual air emissions report, NPDES reporting, hazardous waste manifests, recycling records and other documentation that may help you determine what chemicals were released to the environment?
-Do you have a CDX account with the USEPA so that you can file electronically?
The USEPA actually has several tools that can assist you this year as you go through your Form R calculation. Here are some tools that I have found to be particularly helpful:
Basic Training: http://www.epa.gov/tri/training/RY11/EPA_RY11_Basic/index.html
Advanced Training: http://www.epa.gov/tri/training/RY11/EPA_RY11_Advanced/index.html
TRI Threshold Screening Tool: http://www.epa.gov/tri/threshold/index.htm
Reporting Instructions & Forms: http://www.epa.gov/tri/report/index.htm
Don’t be Afraid to Ask for Help!
When in doubt, reach out to an expert for help. Safetec is here to help you manage your chemicals and to provide you with tools that will assist you in determining what materials you have at your location that are potentially subject to EPCRA 313 reporting. We also have EHS Professional Services if you need a consultant to help you with getting your report competed on time. Contact us today to find out how we can best serve you.