TRI/ SARA 313/ Form R Reporting

Regardless of what you call it, the next 7/1/19 deadline for this environmental report is quickly approaching! Are you one of the companies required to file a TRI report under the Emergency Planning and Community Right-to-Know Act (EPCRA).?

If you are not certain: Compare your SIC code to the EPA regulation 40 CFR 372.23(a) which is very clearly summarized at  Then, if you employ 10 or more full-time equivalent employees and your SIC code appears on this list of industry sectors, you may be required to file a TRI Report (but read on…).

The deciding factor is whether your facility either manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above threshold levels during the previous calendar year (i.e., 2018 for the July 1, 2019 reports).  Note that Persistent Bioaccumulative Toxic chemicals (PBTs) have lower thresholds than other TRI chemicals.

Facilities that meet all of these criteria must:

  • Submit a TRI Form R for each TRI-listed chemical it manufactures, processes, or otherwise uses in quantities above the reporting threshold. (Note: Facilities may be eligible to submit the shorter Form A if they meet certain criteria. See the TRI Reporting Forms and Instructions for details.)
  • Submit each TRI form to both EPA and the state in which the facility is located (or to the appropriate tribe, if located in Indian country).
  • Submit each reporting form using TRI-MEweb, EPA’s online TRI reporting application.

But where can I get help since these lists and calculations are confusing?

 CTI has the know-how and CDX (electronic TRI-MEweb) account to complete and file your TRI Report for you, with your authorization to do so. But, start early and contact CTI now.


Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

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