TRI/ Form R Report
Section 313 of the Emergency Planning and Community Right-to-Know Act (Title III of the Superfund Amendments and Reauthorization Act of 1986) requires that the EPA Toxic Chemical Release Inventory Report Form (aka Form R) be filed by owners or operators of facilities that meet these three requirements:
- The facility employees have worked a total of 20,000 hours or more during the reporting year (i.e., equivalent to 10 or more full time people),
- The facility is included in the NAICS codes: 311*, 312*, 313*, 314*, 315*, 316, 321, 322, 323*, 324, 325*, 326*, 327*, 331, 332, 333, 334*, 335*, 336*, 337*, 339* and select other NAICS codes (corresponding to SIC codes 20 through 39),
- The facility manufactured, processed in excess of 25,000 pounds, or otherwise used in excess of 10,000 pounds of any Section 313 Toxic Chemicals during the reporting year or exceeded thresholds for listed Persistent, Bioaccumulative, and Toxic (PBT) Chemicals. Click here for a list of reportable chemicals.
Note: Each year chemicals are added to and deleted from the Form R list. Companies should re-evaluate reportable chemicals each year. Some chemicals have proposed reporting levels as low as 1 pound per year.
There are not many reports that go directly to the US EPA, but the Form R report does. It is important to submit this report on time to avoid penalties. There is no fee for filing this report but there are large penalties for not filing or for filing late.
For further information, assistance in evaluating your facilities reporting requirements or help preparing your Form R, contact our Northern or Southern California office or fill out the form below.