Toxic Release Inventory: AIMCAL Urges Members that Report Deadline Imminent

Published: June 10, 2002, By PRESS RELEASE

FT MILL, SC, USA—AIMCAL is prompting its member companies to be aware (and in compliance with) the federal government's requirement for filing a Toxics Release Inventory (TRI) report. According to AIMCAL, the deadline for reporting is July 1, 2002. Following is the information released by AIMCAL late last month.

• …[The following message] is courtesy of Dr. Doreen Monteleone of the Flexographic Technical Assn. (FTA). Our thanks to Dan [Bemi, AIMCAL chair for regulatory committee] and Dr. Monteleone for this important reminder.

  Lead and TRI Reporting Deadline
  Many companies that have not had to file Toxic Release Inventory (TRI) reports in the past will have to start in 2002, because of changes in the reporting rules. July 1, 2002, is the deadline. This is a federal requirement. Companies that have missed TRI deadlines in the past have faced substantial penalties. Don't wait until June 30!
  The purpose of the TRI reporting requirement is to inform the public and government officials about routine releases of toxic chemicals to the environment. It is also used to assist in the development of regulations, guidelines, and standards. Reports are sent to US EPA and designated state agencies. US EPA records the information from the reports in the TRI database. The public—including communities living around facilities, researchers, and government officials—is able to access this database using the Internet and other means.
  New rules apply to companies that handled more than 100 pounds of lead or lead compounds during any calendar year, starting 2001. That weight requirement is a substantial reduction from the old rules, which started at 10,000 pounds. Many companies, in many industry sectors, use lead in some form. With the new rules, all sources of lead count, no matter how low the concentration may be.
  Here are some suggestions to get you organized for reporting:

• Designate someone at your facility to be responsible for TRI reporting. That person should obtain reporting forms with instructions and should be aware of the reporting deadline, which is July 1 of each year.

• Develop a system for capturing the information you will need on an ongoing basis. Don't wait until June 30 to start pulling it all together. You will need to track reportable materials from the time they enter your facility until the time they leave. You will have to be able to say how much goes where in order to report your releases. You should also keep track of your source reduction and recycling activities, since there is a section on Form R to report these activities, which provides an opportunity to put positive steps you have taken in the public record.

• Maintain a well-organized record-keeping system. Form Rs and any supporting information must be retained for a period of three years after the due date of the report. Supporting information should include any assumptions that you are making and references for any background information you have used. You should document your thought processes clearly enough that you can explain them in the future if you are ever called upon to do so. You may need to produce these records during inspections. Your records will also help you maintain an accurate and consistent approach to estimating releases in future years.

• 
  

  The following information is required on Form R:

• Name, location, and type of business;

• Off-site locations to which the facility transfers toxic chemicals in waste for recycling, energy recovery, treatment, or disposal;

• Whether the chemical is manufactured (including importation), processed, or otherwise used and the general categories of the use of the chemical;

• An estimate (in ranges) of the maximum amount of the toxic chemical present at the facility at any time during the preceding year;

• The quantity of the chemical released to each medium (air, land, and water) or transferred off-site during the reporting year;

• Waste treatment or disposal methods used and the efficiency of each method for each waste stream;

• Source reduction and recycling activities; and

• A certification by a responsible facility official the report is complete and acccurate.

• You can download the current Form R instructions from EPA's site at epa.gov/tri/report/rfi2001.pdf. You also can obtain the reporting form from your regional US EPA office, or you can call the EPCRA information hotline at 800/424-9346.

More information about AIMCAL is available at aimcal.org. More about the FTA can be found at flexography.org.