Toxic Chemical Release Reporting — also known as Toxic Release Inventory (TRI) Reporting — is part of the Emergency Planning and Community Right-to-Know Act (EPCRA) regulations at 40 CFR Part 372. TRI Reporting does not apply to recycled materials facilities operating fully under SIC/NAICS Codes 5093/423930 (Recyclable Material Merchant Wholesalers) and/or 5015/423140 (Motor Vehicle Parts (Used) Merchant Wholesalers). However, TRI Reporting may apply to some of your suppliers.
TRI reports are due by July 1, 2024 for reportable TRI chemicals in Calendar Year 2023, and you should know what to expect.
TRI Reporting includes “waste management” of reportable TRI chemicals. TRI chemicals include some recyclable metals. EPA decided years ago to include off-site recycling as a form of waste management to allow reporters to demonstrate their pollution prevention activities via TRI Reporting (EPA clearly did not consider that this would equate recycling with both waste management AND a toxic release). Off-site recycling of a TRI chemical includes, for instance, industrial recyclable copper sent to a recycled metals facility.
TRI reporters are required to provide the EPA ID number of each off-site facility receiving a TRI chemical (EPA ID number is the same as RCRA ID number, often issued by a state environmental authority). While recyclers are not required to have an EPA/RCRA ID number, they may have one for other reasons (e.g., being a large quantity handler of Universal Waste).
If your supplier asks you for your EPA/RCRA ID number, it is almost certainly a legitimate request for TRI Reporting purposes. If you do not have EPA/RCRA ID number, tell your supplier to “enter ‘NA’ in the box for the off-site location EPA Identification Number” (see EPA’s on-line TRI Reporting Forms & Instructions). If you do have an EPA/RCRA ID number, provide it to your supplier. If you are not sure whether you have one, you can search for your own facility at EPA’s ECHO Database website to see whether an EPA/RCRA ID number is associated with your facility. If you need further assistance, please contact David Wagger, ReMA’s Chief Scientist / Director of Environmental Management at DWagger@recycledmaterials.org or 202-662-8533.
