vvEPA
United States
Environmental Protection
Agency
Factors to Consider When Using
Toxics Release Inventory Data
HAZARDOUS,
chemicals
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Contents
Factors to Consider When Using TRI Data 1
Contents 1
The Toxics Release Inventory (TRI) 2
Key Factors to Consider When Analyzing TRI Data 4
TRI Covers an Important Subset of Chemicals Managed 8
Additional Factors to Consider for Exposure and Risk Analysis 12
Concern About Pollution in a Neighborhood 15
EPA's Work to Minimize Potential for Harm from Exposure toToxic Chemicals 16
Appendix: Factors in Detail 18
TRI On- and Off-site Disposal or Other Releases 18
On-Site Disposal or Other Releases 19
Off-Site Disposal or Other Releases 21
How Metals and Metal Category Compounds Should be Reported to TRI 22
Duplication of Off-Site Transfers to Disposal or Other Releases 23
TRI Transfers Off-Site for Further Waste Management, Including Transfers for Disposal or
Other Release 25
Off-Site Transfers 25
TRI Chemicals Managed in Waste 27
Waste Management Information in TRI 28
Source Reduction 31
Making Year-to-Year Comparisons 32
Industry Sectors 32
Chemicals 33
Reporting Forms 34
Changes in Facility Amounts Reported 36
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The Toxics Release Inventory (TRI)
The Toxics Release Inventory (TRI) is a dataset compiled by the U.S. Environmental Protection
Agency (EPA). It contains information on toxic chemicals handled by many facilities across the
United States, including details on quantities of chemicals managed through disposal or other
releases, recycling, energy recovery or treatment (Figure 1).
Figure 1: Release and Waste Management Data Available in TRI
On-site Releases and Other Waste Management
Air
Surface
Water
Land
Recycling
Energy
Recovery
Treatment
Off-site Transfers of Toxic Chemicals in Waste
Disposal
Recycling
Energy
Recovery
Treatment
POTWs*
*Publicly owned treatment works
Using TRI data access tools developed by EPA, anyone can explore data for over 53,000 facilities
that have reported at least once in the more than 30 years of the TRI Program's existence.
More information on TRI and the data collected can be found at www.epa.gov/tri/.
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The goal of the TRI Program is to empower citizens and other TRI stakeholders through
information about how toxic chemicals are managed. Using TRI data and EPA's suite of TRI-
related tools, one can:
o Identify potential environmental concerns and gain a better understanding of potential
risks;
o Identify priorities and opportunities to work with industry, government and
communities to reduce toxic chemical releases and potential risks associated withthem;
o Provide the members of your community with information and insights regardingtoxic
chemical releases and waste management practices in the community;
o Make informed decisions on the consequences of such practices and take action; and
o Establish reduction targets and measure progress toward those targets.
Since its inception, the program has grown in several important ways, including expanding the
businesses covered and the chemicals on which they report. Equally important is the number of
creative ways the general public, government agencies and reporting industries use the
available TRI information. This paper introduces and gives background on TRI and identifies a
number of important factors that must be considered when reviewing or using the data.
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Key Fade ider When Analyzing TRI Data
The bulk of TRI data reflect annual quantities (in pounds) of toxic chemicals released from a
facility to the environment, managed by the facility as waste, transferred from the facility to
another facility for release or other waste management.1These data are particularly useful for:
o Determining priorities for facilities based on pounds of toxic chemicals released or
otherwise managed as waste,
o Tracking trends in year-to-year totals of toxic chemicals released or otherwise managed
as waste,
o Comparing toxic chemical releases and other waste management among industry
sectors, for particular chemicals or individual facilities and
o Assessing individual records to learn about specific facilities.
Key factors to consider when analyzing TRI data include:2
o Toxicity - The level of toxicity varies among the covered chemicals; data on amounts of
the chemicals alone are inadequate to reach conclusions on health-related risks.
o Environment and Exposure - The presence of a chemical in the environment must be
evaluated along with the potential and actual exposures and the route of exposures,the
chemical's fate in the environment and other factors before any statements can be
made about potential risks associated with the chemical or a release.
o Regulation by Environmental Statutes - Regulatory controls apply to many of the
releases reported; reporting facilities must comply with environmental standards under
statutes such as the Clean Air Act and the Clean Water Act, in addition to reporting
releases to TRI.
o On-Site Waste Management - Many options for managing wastes are subject to
stringent technical standards and exacting state and federal regulatory oversight.
o Off-Site Waste Management - Some TRI reporters send chemicals off-site in waste to be
managed at specialized waste management facilities that are also subject to TRI
reporting requirements. Since both the facilities sending waste and the facilities
receiving waste report to TRI, adjustments must be made to avoid double counting (see
Box 5 for additional detail).
1 Specifics on TRI terminology and data for release, transfer and waste management can be found in Boxes 2-9 in
the Appendix.
2 Additional detail on factors to consider concerning the use of specific TRI data elements and the interpretation of
trend data can be found in the Appendix.
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o Context - It is also important to consider how the toxicity and exposure associated with
a TRI-reported quantity compares to the toxicity and exposure of other chemicals that
are not in TRI, such as chemicals not on the list (e.g., certain criteria air pollutants),
unreported releases (e.g., below the threshold or from a non-TRI-reportable industry
sector) and chemicals from other sources (e.g., area and mobile sources).
o TRI continues to evolve with ongoing advances in information technology, needs of the
public and EPA priorities. Since 1991, EPA has made many changes to the program
(Figure 2).
Figure 2 shows how TRI data trends and total production related waste have changed over time
with changes to the TRI Program. The horizontal axis displays reporting year, starting with the
second year for which data are reported. The left vertical axis displays the number of pounds
of chemicals reported to TRI (in billions); it corresponds to the bars that show releases and
disposal and total production-related waste in each year, as reported by manufacturers. The
right vertical axis displays the number of TRI reporters (in thousands); it corresponds to the red
line that shows the number of facilities reporting to TRI in each year. Major changes to the TRI
Program are listed on the chart in words within the bars and further explained below the chart,
by reporting year. Quantities of chemicals reported to TRI in response to program changes are
color coded on the bar graph, as indicated in the legend (Note: in 1991, additional waste
management information is reported to TRI (e.g., quantities treated, recycled or burned for
energy recovery) as required by the Pollution Prevention Act of 1990 (PPA).
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Figure 2: TRI Data Trends and Program Expansion: 1988 - 2017
TRI Trends: 1988-2017
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a^ai£hoiaicj>CT)£hcncno>CTioooooooooooo(z>ooooo
i-T-rrT-ri-^rrrT-|MI\IN(N(NMMM(N(N(NMINIMhlM(NI\
Manufacturers: Total Production-related Waste Other Sectors: Total Production-related Waste
^¦Manufacturers: Releases and Disposal other Sectors: Releases and Disposal
^Number of Reporters
1988: Second year3 of TRI reporting under Emergency Planning and Community Right-to-Know Act (EPCRA).
1991: Additional waste management information is reported to TRI (e.g., quantities treated, recycled or burned
for energy recovery) as required by the Pollution Prevention Act of 1990 (PPA). Light blue indicates waste
management information reported to TRI under the PPA, total production-related waste4.
1995: Chemical expansion rule adds nearly 300 chemicals to the TRI chemical list. Hydrogen Sulfide was added
with the expansion of the chemical risk however an administrative stay was issued to evaluate issues
brought to the Agency's attention after promulgation of the final rule so it was not reported under the
rulemaking.
1998: Seven additional industry sectors ("Other Sectors") are added to TRI. Dark orange indicates releases and
disposal from these seven sectors; light orange indicates total production-related waste from these seven
sectors4.
3The first year of TRI (1987) was not included in the figure above because the manufacturing and production
thresholds were higher, 75,000 lbs for manufacturing and 10,000 lbs for otherwise using TRI reportable chemicals,
therefore making comparisons to later years problematic. In 1988 the threshold was 50,000 lbs for manufacturing
and 10,000 lbs for otherwise using TRI reportable chemicals (this is included for illustrative purposes). All other
years the threshold for reporting was 25,000 lbs for manufacturing and 10,000 lbs for otherwise using TRI
reportable chemicals.
4 For most facilities, release and disposal (dark blue and dark orange bars) may be considered a subset of the total
production related waste (light blue and light orange bars). However, if there was a non-production related
release at a facility (e.g., remedial actions or catastrophic events), it would be counted as release and disposal, but
not as total production related waste (light blue and light orange bars). In this case, the release and disposal at a
facility would not be included in the facility's total production related waste.
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2000: Several persistent bioaccumulative toxic (PBT) chemicals are added to TRI chemical list, the reporting
thresholds are lowered for these and PBT chemicals already on the list.
2001: Lead and Lead Compounds are designated as PBTs and TRI reporting thresholds lowered.
2011:16 chemicals classified as "reasonably anticipated to be a human carcinogen" by the National Toxicology
Program (NTP) in their Report on Carcinogens (RoC) are added to TRI.
2012: The Administrative Stay of the TRI reporting requirements for hydrogen sulfide is lifted.
2014: ortho-Nitrotoluene is added to TRI. This chemical has been classified as "reasonably anticipated to be a
human carcinogen" by the National Toxicology Program (NTP) in their Report on Carcinogens (RoC) document.
ortho-Nitrotoluene reporting will be required beginning in the 2014 TRI reporting year.
2015: Nonylphenol is added to the TRI list.
2016:1-bromopropane is added to the TRI list.
2017: Hexabromocyclododecane (HBCD) is added to the TRI list.
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pkV i^tT[<"'r * bsH f emicals Managed
Reports must be filed by owners and operators of facilities that meet the following criteria:
o The facility falls within a TRI-reportable industry sector or is federally-owned or
operated;
o The facility has 10 or more full-time (or equivalent) employees; and
o The facility manufactures, processes or otherwise uses (MPOU) a TRI-listed chemical in
an amount above the TRI reporting threshold during a calendar year (thresholds vary
depending upon chemical).5
If a facility meets all three of these criteria, it must submit a TRI report for each chemical for
which it exceeded an MPOU threshold.6
If a facility does not meet all these criteria, it is not required to report to TRI.
Information on facilities exempt from TRI reporting might be available in EPA databases compiled
by other programs that regulate the facilities. Other EPA databases with release and waste
management information include:
o RCRAInfo7- contains hazardous waste management information;
o PCS and ICIS-NPDES 8- contains monthly measurements of chemicals released to water
at facilities with discharge permits;
o National Emissions Inventory (NEl)9 contains air release estimates for stationary and
mobile sources;
o Risk Management Plan (RMP)10- contains risk management plans that state the amount
of chemicals facilities have in on-site processes; and
5 Manufacture is to produce, prepare, compound or import a chemical. Process is to prepare a chemical, after its
manufacture, for distribution in commerce. Processing is usually the incorporation of a chemical into a product.
However, a facility may process an impurity that already exists in a raw material. Otherwise use is any use of a
chemical that is not covered by the terms manufacture or process. Chemicals that are otherwise used include
chemical processing aids like solvents and manufacturing aids like lubricants, refrigerants or catalysts. Otherwise
use often includes ancillary activities, for example, to remediate wastes or to clean process equipment.
6 For details, see TRI Reporting Forms and Instructions:
https://ofmpub.epa.gov/apex/guideme ext/f?p=guideme:rfi-home:2096522329119
7 Resource Conservation and Recovery Act Information (RCRAInfo) database; available through
http://echo.epa.gov and www.epa.gov/enviro/facts/rcrainfo/search.html. RCRA Biennial Report (BR) data, a
subset of RCRAInfo, are available through
https://rcrapublic.epa.gov/rcrainfoweb/action/modules/br/summarv/view
8 Permit Compliance System (PCS) and Integrated Compliance Information System for the National Pollutant
Discharge Elimination System (ICIS-NPDES); available through http://echo.epa.gov/ and
www.epa.gov/enviro/facts/pcs-icis/search.html.
9 Available through https://www.epa.gov/air-emissions-inventories
10 Available in EPA Federal Reading Rooms. For details, see: https://www.epa.gov/dockets/epa-docket-center-reading-room
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o Greenhouse Gas Reporting Program (GHGRP)11- contains greenhouse gas emissions
estimates for facilities and suppliers.
Each of these programs has different requirements for who must report and the data and
frequency of the reporting; however, there is overlap between the facilities in these databases
and the facilities that report to TRI (Figure 3).
Users who want to find information that is not available in TRI can check these other databases.
For example, NEI can be used to find estimates of air releases for facilities that do not report to
TRI or for mobile sources, which are not covered by TRI.
Figure 3 below shows the degree of overlap, in terms of facilities that report, between TRI and
the RCRA info, ICIS-NPDES, RMPs, NEI and GHGRP databases.
nGHG Reporting Program data are available through
https://www.epa.gov/ghgreporting/ghg-reporting-program-data-sets
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Figure 3: TRI Overlap for Air, Water and Waste Programs at EPA
Toxics
Release
Inventory
(TRI)
National
Emissions
Inventory (NEI)
Toxics
Release
Inventory
(TRI)
Risk
Management
Plan -
CAA
Toxics
Release RCRAInfo
Inventory - RCRA
(TRI)
Approximately 6,300 facilities reported hazardous
waste generation to RCRA BR* and also reported to
TRI in 2013. That is, 24% of about 25,900 facilities
reporting hazardous waste generation to RCRA BR
also reported to TRI and 29% of about 21,600 TRI
filers in RY2013 also reported hazardous waste
generation to RCRA BR."
Approximately 10,500 facilities reported to TRI in 2013
and were listed as stationary sources in NEI in 2011
That is, 11% of about 97,200 stationary sources in NEI
reported to TRI, and 49% of about 21,600TRI
filers were stationary sources in NEI in 2011.
Approximately 2,600 facilities were RMP registered
and also reported to TRI in 2013. That is, 20% of
about 13,000 RMP-registered facilities reported to
TRI and 12% of about 21,600 TRI filers also were
RMP-registered facilities in RY2013.
Permit
Compliance
System and
ICIS-NPDES-
CWA
Approximately 6% of facilities that reported releases
to TRI in RY2013 were also NPDES permittees. Among
active NPDES permittees, 19% reported discharges to
both TRI and ICIS-NPDES.
Approximately 2,400 facilities reported direct
emissions of greenhouse gases to the atmosphere
under EPA's Greenhouse Gas Reporting Program
(GHGRP) and also reported to TRI in 2013. 30% of
almost 7,900 direct emitters reporting to GHGRP also
reported to TRI and 11% of about 21,600 TRI filers also
reported as direct emitters in GHGRP in RY2013.
Toxics
Release
Inventory
(TRI)
* Resource Conservation and Recovery Act (RCRA) Biennial Report (BR)
" "RY 2012" refers to Reporting Year 2012. The "Reporting Year" is the calendar year to which the reported
information applies
Toxics
Release
Inventory
(TRI)
GHG
Reporting
Program
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Note that toxic chemical release and other waste management quantities tend to be higher for
facilities in TRI than facilities exempt from TRI reporting. For example, although only a small
percentage of the stationary sources in NEI are also found in TRI, 79% of the hazardous air
pollutant releases found in the 2002 NEI dataset were also in TRI.
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Additional Fac p '1 nsider for Expos t ^.ibls Valysis
TRI provides information about releases of toxic chemicals from facilities throughoutthe United
States; however, TRI data do not reveal whether or to what degree the public is exposed to
listed chemicals. TRI data can, in conjunction with other information, be used as a starting
point in evaluating such exposures and the risks posed by such exposures. The determination of
potential risk to human health and/or the environment depends upon many factors, including
the toxicity of the chemical, the fate of the chemical in the environment, and the amount and
duration of human or other exposure to the chemical. Box 1 highlights some of the factors that
should be considered when reviewing TRI data for exposure and risk analysis.
An example to illustrate how consideration of exposure pathways can influence analysis and
interpretation of TRI data comes from the chemical manufacturing industry (NAICS 325). Using
TRI Explorer, in RY2013, the chemical manufacturing facilities with the highest on- and off-site
disposal or other releases were Ascend Performance Materials LLC, Ascend Performance
Materials - Chocolate Bayou Facility, Basin Electric, Monsanto Luling, and Dupont Delisle Plant.
If releases to RCRA Subtitle C landfills and Class I underground injection wells - waste
management options with lower probabilities of exposure - are excluded, a different set of top-
five facilities would be identified: Basin Electric, Tronox LLC, Dupont Johnsonville Plant, CF
Industries Nitrogen LLC, and Weylchem US Inc. Table 1 provides the rankings of these chemical
manufacturing facilities based on total on- and off-site disposal or other releases (column 3)
compared to rankings when RCRA Subtitle C landfills and Class I underground injection wells are
excluded (right-hand column). Chemical manufacturing facilities, with the highest rankings for
total disposal or other releases, rank much lower when only looking at the disposal or other
releases that are more likely to migrate beyond the fence line. When evaluating potential risks
from exposure to toxic chemicals, disposal and other releases that are more likely to migrate
beyond the fence line might be of greater concern than disposal in more physically controlled
RCRA Subtitle C landfills and Class I underground injection wells.
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Table 1: Top Chemical Manufacturing Facilities, RY2013
Rank based on
Rank based on Total On- and
Facility
Location
Total On- and
Off-site Disposal or Other
(City, State)
Off-site Disposal
or Other Releases
Releases More Likely to Migrate
Beyond the Fence Line*
Facilities with Top On- and Off-site Disposal or Other Releases
Ascend Performance
Materials LLC
Cantonment, FL
1
321
Ascend Performance
Materials - Chocolate Bayou
Alvin, TX
2
251
Facility
Basin Electric
Beulah, ND
3
1
Monsanto Luling
Luling, LA
4
258
Dupont Delisle Plant
Pass Christian, MS
5
37
Facilities with Top On- and Off-site Disposal or Other Releases More Likely to Migrate Beyond the
Fence Line"
Basin Electric
Beulah, ND
3
1
Tronox LLC
Hamilton, MS
7
2
Dupont Johnsonville Plant
New Johnsonville,
TN
8
3
CF Industries Nitrogen LLC
Donaldsonville, LA
11
4
Weylchem US Inc
Elgin, SC
12
5
* Rank based on Total On- and Off-site Disposal or Other Releases Excluding RCRA Subtitle C Landfills and Class I
Underground Injection Wells
" Facilities with Top On- and Off-site Disposal or Other Releases Excluding RCRA Subtitle C Landfills and Class I
Underground Injection Wells
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Box 1. Factors to Consider in Using TRi Data for Exposure and Risk Analysis
Toxicity of the Chemical: TRI chemicals vary widely in toxicity. High volume releases of less toxic
chemicals may appear to be a more serious problem than lower volume releases of highly toxic
chemicals, when just the opposite may be true.
Exposure Considerations: The potential for exposure may be greater the longer the chemical
remains unchanged in the environment. Sunlight, heat or microorganisms may or may not
decompose the chemical. For example, microorganisms readily degrade some chemicals, such as
methanol, into less toxic chemicals, whereas metals are persistent and will not degrade in the
environment.
Bioconcentratiori of the Chemical In the Food Chain: As a chemical becomes incorporated in the
food chain, it may concentrate or disperse.
o Some chemicals, such as mercury, accumulate and magnify in concentration in organisms as
they move up the food chain.
o Small amounts of a chemical that bioaccumulate may result in significant exposures to
consumers.
Type of Disposal or Release (Environmental Medium): The extent to which chemical exposure of a
population occurs depends on the environmental medium (air, water, land) to which a chemical is
either disposed or otherwise released. The medium also affects the types of exposures possible,
such as inhalation, dermal exposure or ingestion. For example, disposal in underground injection
wells is regulated by EPA's Underground Injection Control Program to provide safeguards so that
injection wells do not endanger current and future underground sources of drinking water. When
wells are properly sited, constructed and operated, underground injection is an effective and
environmentally-safe method to dispose of wastes.
Type of Off-Site Facility Receiving the Chemical and the Efficiency of its Waste Management
Practices: The amount of a toxic chemical that ultimately enters the environment depends on how
the chemical was handled during treatment, energy recovery or recycling activities. Several factors
to keep in mind when considering amounts sent off-site are presented below:
o The efficiency of recycling operations varies depending on the method of recycling andthe
chemical being recycled.
o Use of a combustible toxic chemical for energy recovery typically results in the destruction
of 95% to 99% or more of the toxic chemical. The remaining quantity may be either released
to air or disposed of in ash to land.
On-Site Waste Management of the Toxic Chemical: As with off-site waste management, the
amount of the toxic chemical disposed of or otherwise released to the environment depends on how
the chemical was handled during treatment, energy recovery or recycling activities. However, since
the waste management is on-site, any amount of the chemical that enters the environment after
waste management is reported to TRI as part of that facility's disposal or other releases.
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Concern About PoIIutic ;ighborhood
People often want to use TRI to assess the vulnerability of their communities to the hazards
posed by TRI chemicals released in their neighborhoods. When conducting exposure and risk
analysis for a community, it is important to keep in mind that:
1. TRI releases do not necessarily constitute cause for concern,
2. EPA works to decrease the potential for harm from exposure to toxic chemicals, and
3. Additional resources and information for assessing releases to a community are
available.
TRI provides useful information on the quantity of a toxic chemical that is being released from a
facility. However, it does not provide all the information necessary to answer questions about
health risks. The two main considerations to keep in mind when exploring TRI release
information and health risks are:
o TRI data only provide information on releases of certain chemicals from certain
sources. While facilities that report to TRI often represent major sources of releases or
discharges of toxic chemicals to the environment, they are not responsible for all
releases or discharges of chemicals to the environment, even for all releases of
chemicals included on the TRI list of toxic chemicals. For example, releases of TRI or
other chemicals from natural sources, releases of TRI or other chemicals from facilities
not subject to TRI reporting requirements and even releases of chemicals from
consumer products may contribute to one's total exposure to a given chemical. Users of
TRI data should be aware that the TRI database represents only a portion of total
chemical releases.
However, given that TRI generally collects a large portion of the total quantities of
releases of TRI chemicals nationwide, it provides useful information. One tool that is
useful in examining chemical releases in your neighborhood is called myRTK, which
combines chemical release data from TRI with information from other EPA programs.
More information on using myRTK can be found at www.epa.gov/tri/myrtk/. Another
useful tool is EPA's Risk-Screening Environmental Indicators (RSEI) tool, which combines
chemical releases reported in TRI with other factors to compare location specific risks of
chemicals, facilities and industries. More information on using RSEI can be found at
www.epa.gov/rsei/.
o More information and analyses are needed to determine an individual's risk
associated with TRI releases. The release of a chemical in a neighborhood is not by itself
cause for concern. Even though chemicals may be stored at, used by or released from a
particular facility, an individual may or may not be exposed to any of the chemicals or
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may not be exposed to the extent needed to cause adverse health effects. Figure 4
below displays the typical sequence of investigating known chemical emissions and
estimated health risks. For additional information on the range of factors associated
with health risks, visit EPA's risk assessment portal at www.epa.gov/riskassessment/.
Figure 4: Overview of Factors that Influence Risk
A
WHWA
Fa
Exposure
Risk of
Toxicity Adverse
Effect
TRI
Air
Inhalation
Chemical Individual
Non-TRI
Water
Ingestion
Concentration Exposed
Land
Absorption
Chemical Timing of
Properties exposure
Duration of
Exposure
There are several online TRI data tools,12 as noted above, that retrieve the set of facilities
within a specific neighborhood and characterize information on the quantities of toxic
chemicals those facilities release or otherwise manage as waste. This information gives an idea
of the potential magnitude of exposure, most likely pathways of exposure (i.e. air, water or
land), and exposure routes (i.e., inhalation, oral ingestion or dermal). To estimate the adverse
health effects associated with releases in a community, it is important to consider the fate,
exposure and toxicity of the chemicals that were released, as well as the factors that contribute
to individuals' vulnerabilities to chemical releases in their neighborhoods.
EPA's Work to Minimize Potential for Harm from Exposure to Toxic Chemicals
EPA compiles facilities' TRI reports and provides them to the public. By making information
about industrial management of toxic chemicals available to the public, TRI creates a strong
incentive for companies to improve environmental performance.
Information dissemination is not the only approach EPA uses to help communities understand
and reduce the potential risks to human health and the environment associated with the use of
toxic chemicals. EPA also:
1. Regulates how and to what extent facilities use, handle, release and dispose of toxic
chemicals;
2. Collects additional environmental information regarding toxic chemicals; and
3. Encourages pollution prevention.
12 For details on available TRI data tools, see www.epa.gov/tri/tri-data-and-tools
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EPA issues regulations that require facilities and their owners to make process changes, install
and operate pollution controls, and undertake other environmental management activities
under the authority granted by federal environmental laws. These laws and the industrial
processes they regulate are summarized in Figure 5 below. How each environmental statute
applies to a facility depends on the chemicals the facility handles, the industrial processes
requiring the regulated chemical(s), and the environmental pathways by which the chemicals
are released to the environment. Chemicals may be released to the environment directly from
the facility (e.g., air emissions through stacks; water discharges through pipes) or indirectly
(e.g., chemicals transferred to a waste treatment facility may be released during or after
treatment; chemicals incorporated into a product are purchased and may be released during
consumer use or at product disposal).
Figure 5: EPA's Role in Protecting Public Health
Toxic Substances Control
Act (TSCA)
Federal Insecticide,
Fungicide, and Rodenticide Act
(FIFRA)
1
Clean Air Act (CAA)
Products Air Emissions
Resource Conservation
and Recovery Act (RCRA)
Waste
I Transfers
Water
Discharges
Clean Water Act (CWA)
Ocean Dumping Act (PDA)
Land Disposal
Underground
injection
Comprehensive
Environmental Response,
Compensation, and Liability
Act (CERCLA)
Resource Conservation and
Recovery Act (RCRA)
Safe Drinking Water Act
(SDWA)
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Appendi)
This section addresses a few factors to consider in greater detail. A better understanding of
these factors can enhance the overall use of TRI data in complex analyses. These factors are:
TRI On- and Off-site Disposal or Other Releases
TRI Transfers Off-site for Further Waste Management, including transfers for Disposal or
Other Releases
Source Reduction
Making Year-to-Year Comparisons
Note: This section frequently refers to TRI Form R. The Form R is the form that most facilities
fill out and submit to EPA when they report to TRI.13 It is used to collect release, other waste
management and source reduction information.
TRI On- and Off-site Disposal or Other Releases
The following section describes the categories of on- and off-site disposal or other releases
that are reportable to TRI. Box 2 describes reportable disposal or other releases that may
occur on-site at the facility and identifies types of activities that may contribute to the
disposal or other releases to various media.
Box 3 describes disposal or other releases that may result from a facility's transferring
chemicals off-site. As noted in Box 3, off-site disposal or other releases include additional
details about off-site transfers of metals and metal compounds. How metals and metal category
compounds are reported to TRI is explained in Box 4.
For analyses that present all on- and off-site disposal or other releases categories together,
consideration must be given to off-site transfers reported by one facility that are reported as
on-site disposal or releases by another facility. To avoid double counting, the off-site transfers
should be omitted in these analyses. The methodology used to avoid duplication of off-site
transfers to disposal or other releases is found in Box 5.
13 Under certain circumstances, and only for non-PBT chemicals, facilities required to report to TRI have the option
of using the Form A in place of the Form R. Facilities using Form A report only facility and chemical identifying
information, so Form A requires less time to complete than Form R and reduces the burden ordinarily associated
with filing a Form R. For additional details on how data are reported to TRI, see https://www.epa.gov/toxics-
release-inventorv-tri-program/basics-tri-reporting
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On-Site Disposal or Other Releases
Box 2. An Explanation of On-Site Disposal or Other Releases
On-site disposal or other releases include emissions to the air, discharges to bodies of water,
disposal to land including disposal in underground injection wells at the facility. Disposal or other
releases are reported to TRI by media type. On-site disposal or other releases are reported in
Section 5 of Form R.
Fugitive Air Emissions {Section 5.1). All releases to air that are not released through a confined air
stream. Fugitive air emissions include equipment leaks, evaporative losses from surface
impoundments and spills, and releases from building ventilation systems.
Point Source Air Emissions (Section 5.2J. Air emissions, also referred to as stack emissions that
occur through confined air streams, such as stacks, vents, ducts or pipes.
Surface Water Discharges {Section 5.3). Discharges to streams, rivers, lakes, oceans and other
bodies of water. This includes releases from contained sources, such as industrial process outflow
pipes or open trenches. Releases due to runoff, including storm water runoff, are also reported to
TRI as surface water discharges.
On-Site Disposal in Underground Injection Class I wells {Section 5.4.1). Disposal in Class I wells
includes the emplacement of hazardous and nonhazardous fluids (industrial and municipal wastes)
into isolated formations beneath the lowermost underground source of drinking water (USDW).
Because they may inject hazardous waste, Class I wells are the most strictly regulated under the Safe
Drinking Water Act (SDWA) and are further regulated under the Resource Conservation and
Recovery Act (RCRA).
Disposal in Underground Injection Class ll-₯ Wells {Section 5.4.2J. The subsurface emplacement of
fluids through wells. TRI chemicals associated with manufacturing, the petroleum industry, mining,
commercial and service industries, and federal and municipal government-related activities may be
injected into Class I, II, III, IV or V wells, if they do not endanger underground sources of drinking
water (USDW), public health or the environment. Disposal in Class I wells (see above) are reported
separately from disposal in Class ll-V wells.
o Class II wells are used for injection of brines and other fluids associated with oil and gas
production.
o Class III wells are used for injection of fluids associated with solution mining of minerals.
o Class IV wells are used for injection of hazardous or radioactive wastes into or above a
USDW and is banned unless authorized under ground water remediation laws.
o Class V wells inject nonhazardous fluids into or above a USDW and are typically shallow, on-
site disposal systems, such as floor and sink drains which discharge directly or indirectly to
ground water, dry wells, leach fields and similar types of drainage wells.
Beginning with the 1996 reporting year, facilities report amounts injected into Class I wells
separately from amounts injected into all other wells (Class ll-V). This change was made to reflect
the difference in management standards and regulatory oversight provided by the Underground
Injection Control Program for Class I wells as distinguished from other forms of injection reportable
to TRI.
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Box 2. An Explanation of On-site Disposal or Other Releases (Continued)
RCRA Subtitle C Landfills (Section 5.5.1A). Disposal in RCRA Subtitle C landfills in which wastes are
buried. These are landfills that are subject to stringent requirements for liners, leak detection
systems and groundwater monitoring.
Other Landfills {Section 5.5.IB). Disposal of toxic chemicals in landfills other than RCRA Subtitle C
landfills.
Beginning with the 1996 reporting year, facilities report amounts disposed of in RCRA Subtitle C
landfills separately from amounts disposed of in other on-site landfills. This change was made to
recognize the difference in management and regulatory oversight provided for RCRA Subtitle C
landfills.
Land Treatment/Application Farming {Section 5.5.2). Management techniques in which a waste
containing a listed chemical is applied to or incorporated into soil.
RCRA Subtitle C Surface Impoundments {Section 5.5.3A). The total amount of the EPCRA Section
313 chemical that was placed in and remained in (did not volatilize from the impoundment during
the reporting year) the RCRA Subtitle C surface impoundments. A surface impoundment is a holding
area used to volatilize and/or settle waste materials. Examples of surface impoundments include
holding, settling, storage and elevation pits; ponds and lagoons.
Other Surface Impoundments {Section 5.5.3B). The total amount of the EPCRA Section 313
chemical that was placed in surface impoundments other than RCRA Subtitle C surface
impoundments.
Beginning with the 2003 reporting year, facilities report amounts disposed of in RCRA Subtitle C
surface impoundments separately from amounts disposed of in other on-site surface
impoundments. This change was made to recognize the difference in management and regulatory
oversight provided for RCRA Subtitle C surface impoundments.
Other Disposal {Section 5.5.4). Other disposal methods including waste piles, spills or leaks. Most of
the toxic chemical waste reported as other disposal to TRI is from waste rock at metal mines. Rock
removed from a mine is called ""waste rock" if it does not contain economically recoverable
amounts of targeted metals (e.g., copper, gold). TRI chemicals naturally present in waste rock in
small concentrations are almost all reported to TRI as "other disposal."
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Off-Site Disposal or Other Releases
Box 3. An Explanation of Off-Site Disposal or Other Releases
An off-site disposal or other release is a discharge of a toxic chemical to the environment that occurs
as a result of a facility's transferring a waste containing a TRI chemical off-site for disposal or other
release, as reported in Section 6 of Form R. Certain other types of transfers are also categorized as
off-site disposal or other release because, except for location, the outcome of transferring the
chemical off-site is the same as disposing of it or releasing it on-site. For each transfer, the amount
of the chemical in the waste, type of management activity (chosen from a list of codes referred to as
"M" codes) undertaken by the receiving facility and the address of the receiving site is reported.
Off-site Disposal to Underground Injection to Ciass i Wells (Section 6.2, M81). Toxic chemicals in
waste may be transferred off-site to sites that inject the wastes underground. Class I wells are the
most strictly regulated under the SDWA. (See discussion of on-site underground injection for a
description of these disposal types in Box 2.)
Off-Site Disposal to Underground Injection to Class il-V Wells {Section 6,2, M82). Toxic chemicals in
waste may be transferred off-site to sites that inject the wastes underground, including into Class II,
III, IV or V wells. (See discussion of on-site underground injection for a description of these disposal
types in Box 2.)
Off-Site Disposal to RCRA Subtitle £ Landfills fSection 6.2, M65). Toxic chemicals in waste may be
transferred off-site for disposal in RCRA Subtitle C landfills. (See discussion of on-site disposal to
RCRA Subtitle C landfills for a description of these disposal types.) Beginning with the 2002 reporting
year, facilities report amounts transferred off-site for disposal in RCRA Subtitle C landfills separately
from those sent to other landfills. This change was made to recognize the difference in management
and regulatory oversight provided for RCRA Subtitle C landfills as distinguished from other landfills.
The Section 6.2 code for off-site disposal in landfills prior to the 2002 reporting year was M72.
Off-Site Disposal in Other Landfills fSection 6.2, M64). Toxic chemicals in waste may be transferred
off-site for disposal in landfills other than RCRA Subtitle C landfills. (See Box 2 for a discussion of on-
site disposal to other landfills for a description of these disposal types.) Prior to the 2002 reporting
year, off-site transfers to landfills/disposal surface impoundments were all reported in Section 6.2
under code M72. Any transfers reported erroneously under M72 for 2002 are included in this
category.
Storage Only fSection 6.2, M10). On occasion, a toxic chemical is sent off-site for storage if there is
no known disposal method. One example is toxic chemicals in mixed hazardous and radioactive
waste. EPA considers this an off-site disposal or release because this method is being used as a form
of disposal and the toxic chemical will remain there indefinitely.
Solidification/Stabilization (metals only) (Section 6.2, M41 or M40 (metals and metal category
compounds only)). Waste solidification/stabilization is a physical or chemical process used to
either reduce the mobility of the chemical or to eliminate free liquids in a hazardous waste. A
waste stabilization process includes mixing the hazardous waste with binders or other materials,
and curing the resulting hazardous waste and binder mixture.
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Box 3. An Explanation of Off-Site Disposal or Other Releases (continued)
Transfers to POTWs (Section 6.1, limited to amounts designated as releases!. Transfers to publicly-
owned treatment works (POTWs) that are ultimately released (e.g., to surface waters). For RY 2013
and earlier, this includes metals and metal category compounds only, because metals are not
destroyed by sewage treatment processes. For RY 2014 and subsequent years, this also includes
amounts of non-metals that a facility indicates are ultimately released at the POTW. Facilities make
this determination based on their best readily available information; as guidance, EPA publishes
default chemical-specific removal and destruction rates based on experimental and estimated data
from POTWs.
Wastewater Treatment (metais only) (Section 6.2, M62 or M61 (metals and metal category
compounds only)). Transfers to wastewater treatment facilities (excluding to facilities that are
publicly-owned treatment works (POTWs)) of metals and metal category compounds only.
Subti rface Impoundment (Section 6.2, M66). Subtitle C Surface impoundments are holding
areas used to volatilize and/or settle waste materials that are regulated under RCRA Subtitle C.
Other Surface Impoundments (Section 6.2, M67). Surface impoundments are holding areas used to
volatilize and/or settle waste materials. M67 is limited to surface impoundments other than RCRA
Subtitle C surface impoundments.
Land Treatment (Section 6.2, M73). Management techniques in which a waste containing a listed
chemical is applied to or incorporated into soil.
Other Land Disposal (Section 6.2, M79). Other land disposal methods include waste piles, spills or
leaks.
Other Off-site Management (Section 6.2, M90). Chemicals in waste sent to sites where the waste is
managed by techniques not specifically listed in Section 6.2.
Transfers to Waste Broker (Section 6.2, M94). Chemicals in waste sent to a broker where the broker
sends the waste for disposal, but the facility sending the waste does not know the location of the
disposal site and, therefore, reported the name of the waste broker instead. The Section 6.2 code
for transfers to waste broker prior to the 1991 reporting year was M91.
Unknown (Section 6.2, M99). The "unknown" category of disposal indicates that a facility is not
How Metais and Metal Category Compounds Should be Reported to TRI
Transfers of metals and metal category compounds to solidification/stabilization, to publicly
owned treatment works (POTWs or municipal sewage treatment) and wastewater treatment
facilities (excluding POTWs) also result in disposal or other releases and are classified as off-site
disposal or other releases. How such transfers should be reported to TRI is described in Box 4.
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I Box 4. How Metals and Metal Category Compounds Should be Reported to TRi
I In Section 6.2 of the Form R, facilities report the amounts sent to each off-site location to which the
I facility transfers wastes containing the reported toxic chemical for the purposes of recycling, energy
I recovery, treatment or disposal or other release. Metals and metal category compounds are
I managed in waste either by being disposed of or otherwise released or by being recycled. The metal
I has no heat value and thus cannot be combusted for energy recovery and cannot be treated
I because it cannot be destroyed regardless of whether the stream containing the metal is sent for
I energy recovery or treatment. Thus, transfers of metals and metal category compounds for further
I waste management should be reported as either a transfer for recycling or a transfer for disposal or
I other release. The applicable waste management codes for transfers of metals and metal category
I compounds for recycling are M24, M26 or M93. Applicable codes for transfers for disposal or other
releases include M10, M41, M62, M66, M67, M64, M65, M81, M82, M73, M79, M90, M94 andM99.
I Two codes, M41 and M62, were new for the 1997 reporting year. These codes are for transfers to
I waste management in which the waste stream may be treated but the metal contained in the waste
I stream is not treated and is ultimately disposed of or otherwise released. For example, M41 would
I be used for a metal or metal category compound which is stabilized in preparation for disposal.
I Prior to the 1997 reporting year, some facilities reported transfers of metals and metal category
I compounds for further waste management using two waste treatment codes, M40 and M61.
I Beginning in reporting year 1997, metals and metal category compounds must be reported under
I Section 6.2 using one of the disposal or other release codes or the applicable recycling code (M24
I for metals recovery, M26 for other reuse or recovery or M93 for transfers to waste broker -
I recycling).
1 In Section 8.1 of the Form R, facilities report quantities of listed chemicals disposed of or
1 otherwise released on- and off-site (excluding one-time catastrophic or remedial releases). Except
1 for those quantities recycled, metals and metal category compounds should be reported in
1 Section 8.1 of the Form R. This includes those quantities of metals and metal category
1 compounds reported in:
1 o Section 5 as on-site disposal or other releases,
I o Section 6.1 as discharges to POTWs.
I o Section 6.2 as sent off-site for stabilization/solidification (M41) or wastewater treatment
I (excluding POTWs) (M62) and/or,
I These quantities should not be reported in Section 8.7 of the Form R.
Duplication of Off-Site Transfers to Disposal or Other Releases
TRI facilities transfer chemicals in waste off-site to other facilities for disposal or other releases.
These recipient facilities can place the wastes in on-site landfills, disposal surface
impoundments, land treatment facilities or other types of land disposal methods. They may
also dispose of wastes in underground injection wells or, if metals and metal category
compounds are sent to a wastewater treatment facility, they may be discharged to surface
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waters. The recipient facilities generally are treatment, storage and disposal (TSD) facilities
regulated under the federal Resources Conservation and Recovery Act (RCRA). TSD facilities are
one of the added industries that must, beginning with the 1998 reporting year, report their
disposal and other releases, transfers and other waste management to TRI. Thus, the facility
that transfers chemicals to a TSD facility would report to TRI the quantities transferred as
transfers to disposal or other releases and the TSD facility that receives the chemicals would
report the amounts managed as on-site disposal or other releases to underground injection,
land or surface waters. Box 5 describes EPA's methodology for avoiding duplication of amounts
reported in off-site transfers that are also reported as on-site disposal or other releases by
facilities that received such transfers.14
Box 5. Duplication of Off-Site Transfers to Disposal or Other Releases
To avoid double counting the transfers off-site to the TSD facilities that are also reported to TRI as
on-site disposal or other releases by the TSD facilities, the off-site transfer quantities should be
omitted from statistics that compare or summarize on-site and off-site disposal or other releases
for all industries. Only the on-site disposal or other releases from the TSD facilities are included in
analyses.
Facilities' RCRA ID numbers are used to identify such transfers and match them to on-site disposal
or other releases reported by TSD facilities. A TRI facility must report the RCRA ID number of the
TSD facility receiving the transfer; each amount of off-site transfer to TSDs should have the RCRA ID
number of the receiving facility. RCRA IDs are then identified for the facilities that report to TRI
using EPA's Facility Registry System (FRS).
If a facility is listed as receiving a waste transfer from another TRI reporter (based on RCRA ID), and
reports to TRI on-site disposal or other releases of the same chemical (or the metal and its
compounds in the case of metals) that were greater than or equal to the sum of the off-site
transfers reported as transferred, then the amount of chemicals transferred from other TRI facilities
should be omitted from the analysis. If the TRI facility receiving the waste reported an amount of
on-site disposal or other releases of the chemical less than the total amount reported as transferred
to the facility, then the amount omitted from the analysis should be reduced proportionally. For
example, if Facility A reported 20,000 pounds transferred to Facility C and Facility B reported 80,000
pounds transferred to Facility C, but Facility C only reported 90,000 pounds disposed of or otherwise
released on-site (which is 90 percent of the total amount of 100,000 pounds reported as
transferred), then the amount of transfers omitted from the analysis for Facility A is 18,000 pounds
(or 90 percent of 20,000 pounds) and for Facility B is 72,000 pounds (or 90 percent of 80,000
pounds).
14 EPA's National Analysis and several of EPA's TRI data access tools omit duplicate off-site transfer quantities as
appropriate. However, "early release" data, published prior to the National Analysis, do not omit duplicate off-site
transfer quantities. For more information on the National Analysis, see www.epa.gov/trinationalanalysis. For
more information on TRI data access tools, see www.epa.gov/tri/tri-data-and-tools
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Box 5. Duplication of Off-Site Transfers to Disposal or Other Releases (Continued)
In analyses that present off-site transfers but not on-site disposal or other releases, these amounts
should not be omitted in order to present complete data on off-site transfers for analysis. Also,
analyses that present data on waste managed should not omit any reported data in order to
present complete data on how waste is being managed. In addition, analyses that do not include all
TRI facilities (for example, data for one state or one industry sector) should not omit any reported
data because the transfers may be sent to facilities not included in the analysis.
The following table shows which types of off-site transfers to disposal or other releases are
matched with which types of on-site disposal or other releases to determine if the transfers should
be omitted.
Off-site Section 5 Checked for Recipient TRI Facilities
Transfer Based on Matching Chemical or, if Metal,
M Code Metal plus Metal Category Compounds (Section 6.2)
M10 5.5.4
M41* 5.5.1 A and B
M62*
5.5.1 A and B, 5.5.3 and 5.3
M64
5.5.IB
M65
5.5.1A
M66
5.5.3A
M67
5.5.3B
M73
5.5.2
M79
5.5.4
M81
5.4.1
M82
5.4.2
M90
All Section 5
M99
All Section 5
includes metals and metal category compounds reported under codes M40 and M61.
M94 (transfer to waste broker) is not included since a waste broker does not dispose of or release
the chemical.
TRI Transfers Off-Site for Further Waste Management, Including Transfers for
Disposal or Other Release
Off-S risfers
Off-site transfers of TRI chemicals in waste include, in addition to transfers to disposal or other
releases described above, transfers to treatment, publicly-owned treatment works (POTWs),
recycling and energy recovery. These transfers are reported in Section 6.1 and 6.2 of Form R.
Analyses that focus specifically on types of off-site transfers include transfers to disposal or
other releases as well as the other types of transfers. Box 6 describes the various categories of
transfers off-site for further waste management including for disposal or other releases.
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Box 6. An Explanation of Transfers Off-site for Further Waste Management, including
Transfers for Disposal or Other Release
An off-site transfer, reported in Section 6 of Form R, is the transfer of toxic chemicals in waste to a
facility that is geographically or physically separate from the facility reporting under TRI. Chemicals
reported to TRI as transferred are sent to off-site facilities for purposes categorized as recycling,
energy recovery, treatment, or disposal or other release. The amounts reported represent a
movement of the chemical away from the reporting facility. Except for off-site transfers to disposal
or other release, these amounts do not necessarily represent entry of the chemical into the
environment.
Transfers to Publicly Owned Treatment Works (POTWs) (Section 6.1). A POTW is a wastewater
treatment facility that is owned by a state or municipality. Wastewaters from facilities reporting
under TRI are transferred through pipes or sewers to a POTW. Treatment or removal of a chemical
from the wastewater depends upon the nature of the chemical, as well as the treatment methods
present at the POTW. In general, chemicals that are easily utilized as nutrients by microorganisms or
have a low solubility in water, are likely to be removed to some extent. Chemicals that are volatile
and have a low solubility in water may evaporate into the atmosphere. Not all TRI chemicals can be
treated or removed by a POTW. Some chemicals, such as metals, may be removed, but are not
destroyed and may be disposed of in landfills or discharged to receiving waters; these chemical
quantities are categorized as off-site disposal or other releases, as explained in Box 3.
Transfers Off-Site to Recycling (Section 6.2, M20, M24, M26, M28, M93). Toxic chemicals in waste
that are sent off-site for the purposes of recycling are generally recovered by a variety of recycling
methods, including solvent recovery and metals recovery. The choice of the recycling method
depends on the toxic chemical being sent for recycling. Once they have been recycled, these
chemicals may be returned to the originating facility for further processing or made available for use
in commerce.
Transfers Off-Site to Energy Recovery (Section 6.2, M56, M92). Toxic chemicals in waste sent off-
site for purposes of energy recovery are combusted off-site in industrial furnaces (including kilns) or
boilers that generate heat or energy for use at that location. Treatment of a chemical by incineration
is not considered to be energy recovery.
Transfers Off-Site to Treatment. (Section 6.2, M40 (except metais and meta! category
compounds), M50, M54, M61 (except metals and metal category compounds), M69, M95). Toxic
chemicals in waste that are transferred off-site may be treated through a variety of methods,
including biological treatment, neutralization, incineration and physical separation. These methods
typically result in varying degrees of destruction of the toxic chemical.
Other Off-Site Transfers (Section 6.2, invalid or no codes). Toxic chemicals in waste that were
reported as transferred off-site but for which the off-site activity (i.e., recycling, energy recovery,
treatment or disposal) was not specified or was not an accepted code are considered as "other off-
site transfers."
Other Transfers Off-Site for Disposal or Other Releases. See Box 3, except does not include any
transfers to POTWs.
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TRI Chemicals Managed in Waste
The Pollution Prevention Act of 1990 (PPA) requires facilities to report information about the
quantities of TRI chemicals they manage in waste, both on- and off-site. The PPA established as
national policy that source reduction is the preferred approach to managing waste. Source
reduction is defined as an activity that prevents the generation of waste (see Box 9). The PPA
also established as national policy a hierarchy of waste management options, illustrated in
Figure 6, for situations where source reduction cannot be implemented feasibly.
Although source reduction is the preferred method of reducing risk, environmentally sound
recycling shares many of its advantages. Like source reduction, recycling reduces the need for
treatment or disposal of waste and helps conserve energy and natural resources. Where source
reduction and recycling are not feasible, waste can be treated. Disposal or other releases of a
chemical is viewed as a last resort, to be employed only if the preferred methods of waste
management cannot be implemented. The PPA did not specifically address the combustion of
waste for energy recovery as a waste management option. However, because energy recovery
shares aspects of recycling and treatment, EPA chose to list this activity separately in the waste
management hierarchy.
Figure 6: Waste Management Hierarchy
Source Reduction
Recycling
Energy Recovery
Treatment
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Waste Management Information in TRI
Box 7 describes the waste management information facilities must report to TRI. The amountof
TRI chemicals in waste reported includes both waste generated by the facility and waste
received by the facility for the purpose of waste management. Facilities report these data in
Section 8 of the Form R as estimates for the current reporting year, the previous year and
projections for the two following years. The PPA requires this data projection, which
encourages facilities to consider their future waste generation, opportunities for source
reduction and potential improvements in waste management options as presented in the
hierarchy. Future-year estimates are not commitments that facilities reporting to TRI must
meet.
Box 7. An Explanation of On- and Off-site Waste Management Information
On-site and off-site waste management activities are reported in Section 8 of Form R. In this
section, amounts due to one-time events not associated with production processes are reported
separately and are not included in the amounts reported as recycled, burned for energy recovery,
treated or disposed of or otherwise released on- or off-site.
Quantity Disposed of or Otherwise Released On-arid Off-site (Section 8.1). This is the total
quantity of the toxic chemical that was released to the environment or disposed of at the facility
(discharged to air, land, water and injected underground on-site) or sent off-site for disposal or
other release. This quantity is the sum of the amounts reported in Sections 5 and 6 of Form R (on-
site disposal or other releases plus off-site transfers to disposal or other releases and transfers to
POTWs of chemicals such as metals and metal compounds that are not destroyed at the POTW) less
any amount(s) associated with one-time events. Beginning in the 2003 reporting year, Section 8.1
was divided into four Subsections:
o Total on-site disposal to Class I, Underground Injection Wells, RCRA Subtitle C landfills and
other landfills (Section 8.1a),
o Total other on-site disposal or other releases (Section 8.1b),
o Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills and
other landfills (Section 8.1c) and
o Total other off-site disposal or other releases (Section 8.1d).
Combusted for Energy Recovery On-site (Section 8.2J. This is the quantity of the toxic chemical
that was combusted in some form of energy recovery device, such as a furnace (including kilns) or
boiler. The toxic chemical should have a heating value high enough to sustain combustion. To avoid
double-counting, the amount reported represents the amount destroyed in the combustion
process, not the amount that entered the energy recovery unit. For example, 100,000 pounds of
toluene entered a boiler that, on average, combusted 98% of the toluene. Any remaining toluene
was discharged to air. A total of 98,000 pounds is reported as combusted for energy recovery (the
remaining 2,000 pounds is reported as disposed of or otherwise released).
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Box 7. Ail Explanation of On- and Off-Site Waste Management Information (continued)
Combusted for Energy Recovery Off-Site (Section 8.3). This is the quantity of the toxic chemical
that left the facility boundary for energy recovery, not the amount combusted at the off-site
location. The toxic chemical must have a significant heating value and the off-site location must
have some form of energy recovery unit in place. This quantity includes the amount(s) reported in
Section 6 of Form R as transferred off-site for energy recovery, less any amount(s) associated with
non-routine events.
Recycled On-Site (Section 8.4). This is the quantity of the toxic chemical recovered at the facility
and made available for further use. To avoid double-counting, the amount reported represents the
amount exiting the recycling unit. It is not the quantity that entered an on-site recycling or recovery
operation. For example, 3,000 pounds of a listed chemical enters a recycling operation. Of this, 500
pounds of the chemical are in residues from the recycling operation that are subsequently sent off-
site for disposal. The quantity reported as recycled on-site would be 2,500 pounds.
Recycled Off-Site (Section 8.5). This is the quantity of the toxic chemical that left the facility
boundary for recycling, not the amount recovered at the off-site location. This quantity includes the
amount(s) reported in Section 6 of Form R as transferred off-site for recycling, less any amount(s)
associated with non-routine events.
Treated On-Site (Section 8.6}. This is the quantity of the toxic chemical destroyed in on-site waste
treatment operations, not the amount that entered a treatment operation. For example, if 100,000
pounds of benzene were combusted in an incinerator that destroyed 99% of the benzene, the
facility would report 99,000 pounds as treated on-site (the remaining 1,000 pounds would be
reported as disposed of or otherwise released).
Treated Off-Site (Section 8.7). This is the quantity of the toxic chemical that left the facility
boundary and was sent to POTWs or other off-site locations for treatment, excluding quantities sent
to POTWs but not actually destroyed (such as quantities of metals and metal category compounds).
This quantity includes the amount(s) reported in Section 6 of Form R as transferred to POTWs or
other off-site locations for treatment, less any amount(s) associated with non-routine events and
not including quantities not destroyed at POTWs.
Non-Production-Related Waste Managed - Released to the Environment Due to One-Time Events
(Section 8.8). This amount is referred to as non-production-related waste and is the quantity
disposed of or otherwise released to the environment or sent off-site for recycling, energy recovery,
treatment, or disposal or other release due to one-time events not associated with routine
production practices. Such events include catastrophic events, such as accidental releases, as well as
remedial actions (clean-up). Separating this quantity from the quantities recycled, used for energy
recovery, treated, and disposed of or otherwise released, allows data users to distinguish between
quantities that are routinely associated with production operations and are more amenable to
source reduction and those that are not routinely associated with production processes and are not
so amenable to source reduction because they are not readily anticipated (e.g., releases due to
damage from a tornado). This separation is important in assessing progress in source reduction at
facilities.
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The individual waste management quantities reported in Sections 8.1 through 8.8 are mutually
exclusive to avoid double-counting. For example, an incinerator may destroy 99% of a chemical
in waste; in this case, the amount reported as treated on-site would be the amount destroyed
by the incinerator, not the amount that entered the incinerator. The amount not destroyed in
incineration (1%) would be reported as disposed of or otherwise released. The sum of the
individual quantities in Sections 8.1 through 8.7 in a given year equals the total quantity of TRI
chemicals in waste resulting from routine production operations at a facility during that year.
Facilities must also report the quantity of waste disposed of or otherwise released as a result of
activities other than routine production operations during the reporting year. This quantity
appears in data tables as "non-production-related waste managed." It includes waste disposed
of or otherwise released to the environment at the facility or transferred off-site because of
catastrophic events or remedial (clean-up) actions at the facility. Non-production-related waste
is considered less amenable to source reduction because facilities cannot always anticipate
these quantities.
It is important to note that facilities may vary in how they interpret some of the reporting
requirements under the PPA. Differences in estimation or calculation techniques may cause a
difference in the quantity of a chemical reported to TRI for the same amount of the chemical
managed.
Box 8 explains the differences between "total on- and off-site disposal or other releases" and
"quantity disposed of or otherwise released on- and off-site."
Bom 8. Differences Between Amounts Reported in Sections 5 ai J in Section 8 of Form R
"Total on- and off-site disposal or other releases" (amounts reported in Sections 5 and 6) and
"quantity disposed of or otherwise released on- and off-site" (amounts reported in Section 8) are
not the same. This difference arises primarily from the types of disposal or other releases reported
on different sections of the Form R.
o "Total on- and off-site disposal or other releases" reflects all on-site disposal or other
releases as collected in Section 5 of the Form R and transfers off-site for disposal or other
releases as reported in Section 6. The amounts included from Section 6.2 are for codes M10,
M41, M62, M64, M65, M66, M67, M73, M79, M81, M82, M90, M94 and M99 and from
Section 6.1 for metals and metal category compounds only.
o "Quantity disposed of or otherwise released on- and off-site" is limited to production-related
on- and off-site disposal or other releases as collected in Section 8.1 of the Form R. This
quantity is the sum of the amounts included from Section 6.2 for codes M10, M41, M62,
M64, M65, M66, M67, M73, M79, M81, M82, M90, M94 and M99 and from Section 6.1 for
chemicals such as metals and metal category compounds that are not destroyed at the
POTW minus the amount for one-time events not related to production as reported in
Section 8.8 and reported under each of these parts of Sections 5 and 6.
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Box 8. Differences Between Amounts Reported in Sections 5 a i in Section 8 of Form R
(continued)
Although total amounts analyzed in these two categories are often the same, they may differ to the
extent that disposal or other releases associated with catastrophic events, remedial actions or other
onetime events not related to production occur. That is, Production-related disposal or other
releases reported in Section 8.1 do not include the amounts associated with the one-time events
while disposal and other releases in Section 5 and Section 6 (those codes listed above) do include
them.
For the same reason, the quantity used for energy recovery offsite (Section 8.3), quantity recycled
offsite (Section 8.5) and quantity treated offsite (Section 8.7) do not include transfers for
recycling, energy recovery and treatment (including POTWs for non-metals) reported in Section 6
to the extent that amounts from one-time events are reported. Once again, the relevant parts in
Section 8 include only production-related wastes and not amounts from one-time events whereas
Section 6 includes all off-site waste management amounts.
o The amounts in Section 8.3 (quantity used for energy recovery offsite) correspond to the
amounts reported in Section 6.2 under codes M56 and M92 minus amounts for one-time
events not related to production as reported in Section 8.8.
o The amounts in Section 8.5 (quantity recycled offsite) correspond to the amounts reported
in Section 6.2 under codes M20, M24, M26, M28 and M93 minus amounts for one-time
events not related to production as reported in Section 8.8.
o The amounts in Section 8.7 (quantity treated off-site) correspond to the amounts reported
in Section 6.1 excluding metals and metal category compounds or other chemicals not
destroyed at the POTW and Section 6.2 under codes M40, M50, M54, M61, M69 and M95,
minus amounts for one-time events not related to production as reported in Section 8.8.
The amounts from one-time events not related to production are reported in Section 8.8.
Other reasons also contribute to the different quantities reported in different sections of the
Form R. For example, an amount of less than 1,000 pounds may be reported in ranges in Section 5
and 6 whereas an exact amount must be included in Section 8. Furthermore, facilities may round
off amounts, except those for PBT chemicals, to two significant digits.
Source Reduction
As noted above, the Pollution Prevention Act (PPA) of 1990 requires facilities to report the
quantities of TRI chemicals they manage in waste, both on- and off-site. The PPA also requires
facilities to provide information about the efforts they have made to reduce or eliminate those
quantities. With the 1991 reporting year, facilities began reporting to TRI information about any
source reduction activities they implemented during the year.
Source reduction activities are undertaken to reduce the amount of a toxic chemical which
enters a waste stream or is otherwise released to the environment. By reducing the generation
of toxic chemicals in waste, source reduction activities reduce the need to recycle, treat or
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dispose of toxic chemicals. Box 9 explains source reduction as defined by the PPA.
Box 9. What Is Source Reduction?
Source reduction is defined in the Pollution Prevention Act of 1990 as any practice that:
o Reduces the amount of any hazardous substance, pollutant or contaminant entering any
waste stream or otherwise released into the environment (including fugitive emissions) prior
to recycling, treatment or disposal; and
o Reduces the hazards to public health and the environment associated with the release of
such substances, pollutants or contaminants.
Through source reduction, risks to people and the environment can be reduced, financial and natural
resources can be saved that would otherwise have to be expended on environmental clean-up or
pollution control and industrial processes can become more efficient. Source reduction practices can
include modifications in equipment, process, procedure or technology, reformulation or redesign of
products, substitution of raw materials and improvements in maintenance and inventory controls.
Under this definition, waste management activities, including recycling, treatment, and disposal or
other releases, are not considered forms of source reduction. The term also does not include any
practice which alters the physical, chemical, biological characteristics or the volume of a hazardous
substance, pollutant or contaminant through a process or activity which itself is not integral to and
necessary for the production of a product or the providing of a service.
Making Ye r Comparisons
Users of TRI information making year-to-year comparisons should be careful to consider only
data that were reported under consistent requirements. Using comparable data will ensure
that any changes in the data over time are driven by actual changes in toxic chemical use,
release or management and do not simply reflect modifications in reporting requirements.
Since TRI data were first collected in Reporting Year (RY) 1987, EPA has made a number of
changes to the TRI Program, such as expanding the list of industrial sectors required to report,
adding and removing chemicals for which facilities must report, introducing new reporting
forms and revising the data elements facilities must fill out on those forms.
Industry Sectors
Since RY 1987, EPA has expanded the list of industries required to report to TRI (Table 2).
For RY 2006, EPA switched the industry classification system used to determine whether
facilities fall into reportable sectors from the Standard Industrial Classification (SIC) to the North
American Industry Classification System (NAICS). To make sector-based trend analysis possible,
many TRI data tools include NAICS codes that were assigned to pre-RY 2006 TRI records, based
on the SIC code for that record.
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Apparent increases and decreases among industries can also result when facilities change the
industry they report from one year to another, reflecting new or discontinued facility
operations or indicating a different understanding of how industry classification codes relate to
the facility's business.
Table 2: Industry Expansions
Reporting Year Industry Expansion
RY 1994 Federally owned or operated facilities were required to report regardless of
industrial sector.
RY 1998 Seven new industry sectors were required to report to TRI:
o Metal mining,
o Coal mining,
o Electric utilities,
o Chemical wholesale distributors,
o Petroleum bulk storage/terminals,
o Hazardous waste management facilities and
o Solvent recovery facilities.
Chemicals
Since RY 1987, EPA has added many chemicals to the TRI chemical list and has lowered the
reporting thresholds for persistent bioaccumulative toxic (PBT) chemicals (Table 3). EPA has
also deleted and modified several chemicals on the TRI chemical list. For precise details on
changes to the TRI list of toxic chemicals, see the full list of TRI Chemical List Changes posted on
www.epa.gov/tri/tri-listed-chemicals.
Table 3: Chemical Additions and Changes to Reporting Thresholds
Reporting Year Changes Made to the List of TRI Reportable Chemicals
RY 1990
Nine chemicals were added to the list.
RY 1991
Seven chemicals were added to the list.
RY 1994
34 chemicals and chemical categories were added to TRI
RY 1995
Close to 300 chemicals were added to TRI under EPA's chemical expansion
initiative.
RY 2000
The reporting thresholds for most PBT chemicals were lowered.
New PBT chemicals were added to the list.
Vanadium compounds were added to the list.
RY 2001
The reporting thresholds for two additional PBT chemicals, lead and lead
compounds, were lowered.
RY 2011
EPA added 16 chemicals reasonably anticipated to be human carcinogens to
the TRI list of reportable chemicals, including 12 individually listed chemicals
and 4 chemicals that fall within the Polycyclic Aromatic Compounds (PACs)
category.
RY 2012
EPA reinstated TRI reporting requirements for hydrogen sulfide.
RY 2014
EPA added o-Nitrotoluene to the list.
RY 2015
A Nonylphenol chemical category was added to the list, composed of six
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chemicals.
RY 2016
1-Bromopropane was added to the list.
RY 2017
A Hexabromocyclododecane chemical category was added to the list,
composed of two chemicals.
RY 2019
A Nonylphenol Ethoxylates chemical category was added to the list,
composed of 13 chemicals.
Several TRI data tools have options for selecting core chemical groups for trends analysis. Using
core chemical groups ensures that there were consistent reporting requirements for chemicals
in the analysis across all reporting years; core chemical groups exclude any chemicals that were
added to or removed from the TRI list during a specified time period.
Reporting Forms
EPA has added, deleted and modified the data elements on TRI reporting forms over the history
of the TRI Program. Changes affecting the collection of release and waste management data
are outlined in Table 4.
Table 4: Changes to TRI Form R Affecting Release and Waste Management Data
Reporting Year Data Elements Changes
RY 1991 Waste management information was added to TRI under the Pollution
Prevention Act of 1990. Data elements added include sections
o 8.1 Quantity released,
o 8.2 Quantity used for energy recovery onsite,
o 8.3 Quantity used for energy recovery offsite,
o 8.4 Quantity recycled onsite,
o 8.5 Quantity recycled offsite,
o 8.6 Quantity treated onsite,
o 8.7 Quantity treated offsite,
o 8.8 Quantity released to the environment as a result of remedial actions,
catastrophic events or one-time events not associated with production
processes (pounds/year),
o 8.9 Production ratio or activity index,
o 8.10 Source reduction activities and
o 8.11 Additional optional information on source reduction, recycling or
pollution control activities.
Waste transfer code M91, Transfer to Waste Broker, was replaced by
o M92, Transfer to Waste Broker-Energy Recovery,
o M93, Transfer to Waste Broker-Recycling,
o M94, Transfer to Waste Broker-Disposal and
o M95, Transfer to Waste Broker-Waste Treatment.
Five waste transfer codes were added
o M24, Metals Recovery,
o M26, Other Reuse or Recovery,
o M28, Acid Regeneration,
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o M54, Incineration/Insignificant Fuel Value and
o M56, Energy Recovery.
RY 1996
Section 5.4, Underground Injection onsite, was split into sections
o 5.4.1, Underground Injection onsite to Class 1 wells and
o 5.4.2, Underground Injection onsite to Class ll-V Wells
Section 5.5.1, Landfills, was split into sections
o 5.5.1a, RCRA Subtitle C landfills and
o 5.5.1b, Other landfills.
Reporting Year
Data Elements Changes
RY 1997 Two waste transfer codes were added
o M41, Solidification/Stabilization-Metals and Metal Compounds only and
o M62, Wastewater Treatment (Excluding POTW)-Metals and Metal
Compounds only.
RY 2002 Waste transfer code M72, Landfill/Disposal Surface Impoundment, was
replaced by
o M64, Other Landfills,
o M65, RCRA Subtitle C Landfills and
o M63, Surface Impoundment.
Section 5.5.3, Surface Impoundments was split into sections
o 5.5.3A, RCRA Subtitle C surface impoundments and
o 5.5.3B, Other surface impoundments.
Section 8.1, Quantity Released, was split into sections
o 8.1a Total on-site disposal to Class I, Underground Injection Wells, RCRA
Subtitle C landfills and other landfills,
o 8.1b, Total other on-site disposal or other releases,
o 8.1c, Total off-site disposal to Class I Underground Injection Wells, RCRA
Subtitle C landfills and other landfills, and
o 8.1d, Total other off-site disposal or other releases.
Waste transfer code M63, Surface Impoundment, was replaced by
o M66, RCRA Subtitle C Surface Impoundment and
o M67, Other Surface Impoundment.
Waste transfer code M71, Underground Injection, was replaced by
o M81, Underground Injection to Class I Wells and
o M82, Underground Injection to Class ll-V Wells.
RY 2005 Section 8.11 was modified so reporters can use an optional text box to
submit information on source reduction, recycling, or pollution control
activities.
RY 2011 Section 9.1 was added to the Form R to provide a free-text option for
miscellaneous information not related to pollution prevention.
The form now clearly states that TRI reporters should only report on newly
implemented source reduction activities in section 8.10.
Separate fields for the quantity of a toxic chemical transferred to each POTW
added to section 6.1.
RY 2003
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Reporting Year Data Elements Changes
RY 2012
RY 2014
RY 2017
Six source reduction codes were added to more closely represent
green chemistry practices implemented at TRI facilities:
o W15, Introduced in-line product quality monitoring or other process
analysis system,
o W43, Substituted a feedstock or reagent chemical with a different
chemical,
o W50, Optimized reaction conditions or otherwise increased efficiency
of synthesis,
o W56, Reduced or eliminated use of an organic solvent,
o W57, Used biotechnology in manufacturing process, and
o W84, Developed a new chemical product to replace a previous
chemical product.
Quantities transferred to POTWs that a facility indicated were
ultimately released off-site (e.g., to surface water) are now counted
in off-site releases and in total releases for nonmetals as well as
metals
Facilities reporting water releases may now enter the reach code of
the receiving stream or water body. A reach code is a unique
identifier for a continuous stretch of surface water.
If a facility files one combined report for a parent metal and
compounds of that same metal, a facility must now indicate that it is
filing a combined report.
Part II, Sections 3.2 and 3.2 were modified to now require a facility to
indicate more specific subcategories for certain processing and
otherwise use activities.
Part II, Section 3.2 now lists "Recycling" as an option under "Process
the toxic chemical."
Part II, Section 5.5 now allows a facility to indicate whether its
reported Section 5.5 quantities were managed in "waste rock piles"
and to indicate the quantities managed in such a way.
Part II, Section 6.1 now requires the use of waste management codes
for transfers of waste to POTWs.
Part II, Section 9.2 was added to the Form A Certification Statement
to allow a facility to provide optional information on each chemical
listed.
The addition of an alternate TRI reporting form also has affected the collection of release and
waste management data under TRI. Starting in RY 1995, facilities with very low releases and
disposal quantities were able to choose between reporting using TRI Form R and the
abbreviated Form A. For RY 2006, the Form A reporting criteria were changed to allow more
facilities to use the Form A in place of the Form R. For RY 2008, the Form A reporting criteria
reverted to the original RY 1995 criteria and fewer facilities were able to use the Form A in
place of the Form R. These changes affected both counts of Form As filed and totals of release
and waste management quantities across facilities; no release, transfer, waste management,
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source reduction and recycling information is required to be reported on the Form A.
Changes in Facility Amounts Reported
Box 10 provides reasons that a facility's reported amounts may change from one year to
another. Explanations for changes in reported amounts include actual source reduction projects
undertaken to reduce a facility's generation of waste of a particular chemical, increases or
decreases in production levels, changes in a facility's methods of estimating or calculating
reportable amounts (which does not indicate a corresponding change in actual disposal or
other releases and waste management), reporting errors in previous years for which the facility
has not filed a revised submission and others.
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Box 10. Reasons Facility Reported Amounts May Change
Some reported increases and decreases are realthat is, they reflect changes in the amounts of TRI
chemicals actually disposed of or released or otherwise managed in waste. Other reported increases
and decreases are accounting or "paper" changes that do not reflect change in disposal or releases
or other waste management. Some examples follow.
Real Changes
Source reduction activities, such as process changes, elimination of spills and leaks, inventory
control, improved maintenance, chemical substitution, and alternative methods of cleaning and
degreasing can eliminate or reduce the generation of chemical waste so that there is no need to
manage the waste in the first place. Though the installation of pollution control equipment does not
reduce the amount of waste generated, it may lead to real reductions in TRI chemicals disposed of
or released.
Production changes can cause real changes in the quantities of TRI chemicals disposed of or released
or otherwise managed as waste by facilities. Production-related waste is likely to increase when
production increases and decrease when production decreases, although the relationship is not
necessarily linear.
One-time events unrelated to normal production processes, such as accidental releases or clean-up
operations, can cause a real but anomalous increase in the reporting year in which they occur and
then a decrease from that abnormally high level the following year.
"Paper" Changes
Changes in estimation or calculation techniques can cause a change in the amount reported without
a corresponding change in actual quantities of the chemical disposed of or released or otherwise
managed as waste.
Clarifications of reporting instructions or changes in the way a facility interprets those instructions
may cause a change in reported amounts without an actual change in quantities of the chemical
disposed of or released or otherwise managed as waste.
Changes in the reporting definition of a particular chemical may cause a change in the reported
amounts without an actual change in quantities disposed of or released or otherwise managed as
waste. For example, revising the definitions of sulfuric acid and hydrochloric acid to include only
aerosol forms, as occurred in reporting years 1994 and 1995, resulted in lower reports of releases,
when non-aerosol forms were no longer reported.
Similarly, a reported decrease without an actual reduction in disposal or releases may result from a
facility switching from reporting with the Form R to reporting with the Form A. This change would
affect the facility's reported release and waste management quantities; no release, transfer, waste
management, source reduction and recycling information is required to be reported on the Form A.
Apparent increases or decreases can occur if a facility makes a reporting error one year and does not
submit a revision for that year, but does not repeat the error the following year.
Apparent increases or decreases can occur due to facilities' eligibility to use regulatory exemptions
when reporting to TRI. For example, a facility may be eligible to apply the de minimis exemption one
year but not the next as the concentration of TRI chemicals changes in its raw materials. If a non-PBT
chemical in raw materials meets the de minimis exemption requirements, releases and other waste
management activities associated with the chemical in that that raw material may be exempt from
reporting to TRI.
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