2019 TRI National Analysis	Asked Questions

Table of Contents

Overview of the 2019 Data	2

Q: What are the highlights of the data analysis for 2019?	2

Q: Is the change in disposal or other release quantities comparable to that of prior years?	2

Q: What is EPA doing to help sectors decrease the quantities of TRI chemicals they dispose of or
otherwise release to the environment?	2

Q: What is production-related waste and why does EPA include information about this quantity as well
as total disposal or other releases?	3

Q: How many facilities reported for 2019? Is it different from prior years?	3

General	4

Q: What is new in this year's TRI National Analysis?	4

Q: What factors should I consider when using TRI data?	4

Q: Should I worry about releases in my community?	5

Q: Were any chemicals newly added to the TRI chemical list for Reporting Year 2019?	5

Q: What Per- and Polyfluoroalkyl Substances (PFAS) does TRI cover and what is TRI doing to help address
PFAS concerns?	5

Q: What is the usual schedule for the TRI National Analysis?	5

Q: Does TRI include information on releases not related to production, such as from remedial actions or
natural disasters?	5

Q: Does TRI cover greenhouse gases?	6

Q: Do the TRI data reflect releases from hydraulic fracturing?	6

Q: Was the 2019 TRI National Analysis affected by the COVID-19 pandemic?	6

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Overview of the 2019 Data

Q; What are the highlights of the data analysis for 2019?

TRI chemical wastes that are generated at facilities from ongoing, routine production operations are
called production-related wastes. These wastes are managed by any of several methods including:
releases to the environment, recycling, treatment for destruction, or combustion for energy recovery.
Total production-related waste managed is the combined total quantity of production-related TRI
chemical waste that was released to the environment, treated, combusted for energy recovery, and
recycled by facilities that report to TRI. The total quantity of production-related TRI chemical wastes
managed by facilities during 2019 was 30.7 billion pounds, a 4% decrease from 2018. Most (89%) of the
30.7 billion pounds of TRI chemical waste was managed through preferred waste management practices
such as recycling and was not released to the environment.

From 2018 to 2019, the total quantity of TRI chemicals disposed of or otherwise released to the
environment also decreased:

•	Total releases decreased by 9% (329 million pounds). Excluding the metal mining sector, disposal
or other release quantities decreased by 5% (104 million pounds) from 2018.

•	Releases to air decreased by 4% (23 million pounds).

•	Releases into surface waters increased by 3%.

•	On-site disposal to land decreased by 13% since 2018, primarily due to decreased land disposal
from the metal mining sector.

Q: Is the change in disposal or other release quantities comparable to that of prior
years?

Total disposal or other release quantities of TRI chemicals decreased by 9% from 2018 to 2019. From 2017
to 2018, the total quantities disposed of or otherwise released decreased by 5%. Much of the change from
year to year is due to reporting from the metal mining sector, which accounted for 44% of all disposal or
other releases for 2019. Disposal or other release quantities reported by the metal mining sector can vary
significantly from year to year. Mining wastes containing TRI chemicals include waste generated during the
extraction, beneficiation, and processing of minerals, and are subject to applicable federal environmental
statutes and regulations (such as the Clean Air Act, the Clean Water Act, the Comprehensive
Environmental Response, Compensation, and Liability Act, and the Emergency Planning and Community
Right-to-Know Act) and applicable state regulations.

Since 2007, disposal or other release quantities of TRI chemicals have decreased by 19% (766 million
pounds). Most industry sectors covered by TRI reduced the total quantities of TRI chemicals they disposed
of or otherwise released into the environment over the 2007 to 2019 timeframe. This long-term decrease
is driven mainly by declining releases of TRI chemicals to air, down 57% (756 million pounds) since 2007.
Reductions in air emissions are driven by decreases in the electric utilities sector. (Using 2007 as the base
year for trend analyses provides both a sufficient number of years of comparison to draw meaningful
conclusions about the direction of any trends in the data, and allows for an end-to-end comparison
between economically similar years, prior to the impacts of the 2008-2010 recession.)

Q: What is EPA doing to help sectors decrease the quantities of TRI chemicals they
dispose of or otherwise release to the environment?

EPA's Pollution Prevention Program helps identify pollution prevention (P2) options for industry sectors

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through a variety of assistance and information-sharing programs, such as P2 grants , the Safer Choice
Program, and other programs. Learn more at EPA's P2 webpage. In addition, the TRI program makes its
pollution prevention information accessible to promote the implementation of effective P2 practices
through the TRI P2 webpage.

Q; What is production-related waste and why does EPA include information about this
quantity as well as total disposal or other releases?

Production-related waste is TRI chemical waste generated from normal operations at a facility and
managed by the facility through recycling, combustion for energy recovery, treatment (i.e., destruction),
and/or disposal or other releases to the environment. It does not include TRI chemical wastes resulting
from accidents, remedial actions, catastrophic events, or other one-time events not associated with
normal or routine production processes. Facilities can manage waste on site or ship it off site. The quantity
of production-related waste of a TRI chemical or TRI chemicals is the sum of the quantities of the TRI
chemical (or chemicals) managed as waste on-site or off-site. Including information on the management
of production-related waste provides a greater understanding of how TRI chemicals are managed, rather
than focusing only on their final disposition through disposal or other release.

EPA encourages facilities to strive to eliminate waste at its source. In other words, facilities should avoid
generating the waste in the first place whenever feasible. For waste that is generated, the preferred
management methods are recycling, followed by combusting for energy recovery, treating and, as a last
resort, disposing of or otherwise releasing the waste. The percent of the quantities of production-related
waste managed through each of these management methods has changed overtime, with a larger
proportion recycled and a smaller proportion disposed of or otherwise released in recent years. The table
below shows the percent of the production-related waste quantities for each waste management method
in 2007, 2018 and 2019.

Percent of production-related waste recycled, combusted for energy recovery, treated or
disposed of or otherwise released



2007

2018

2019

Quantity Recycled

38%

52%

53%

Quantity Combusted for Energy Recovery

11%

10%

10%

Quantity Treated

33%

26%

26%

Quantity Disposed of or Otherwise Released

18%

12%

11%

Note that the proportion of production-related waste that was recycled increased to 53% in 2019, and
recycling is a more preferable way to manage TRI chemical wastes than disposal or otherwise releasing the
chemical waste into the environment.

Q; How many facilities reported for 2019? Is it different from prior years?

A total of 21,393 facilities reported to TRI for 2019, which was similar to the number of facilities that
reported for 2018. The number of facilities reporting to TRI has decreased by 9% since 2007.

There are many reasons why a facility may report to TRI one year but not report the next year. Each of the
following reasons may account for some portion of the annual changes in facilities reporting to TRI:

• Each year a facility must evaluate whether it meets the criteria to report to TRI. A facility must file
a TRI report if it: is a federal facility and/or in an industry sector that is within the scope of sectors

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subject to TRI reporting; has at least 10 full-time equivalent employees; and if within a calendar
year manufactures, processes or otherwise uses a TRI-listed chemical in quantities above a
threshold amount.

•	Some facilities had a reduction in employees that causes them to drop below the employee
threshold.

•	Some facilities stopped production, either temporarily or because the facility closed, and did not
exceed a TRI reporting threshold during the reporting year.

•	Some facilities changed their processes so that they no longer use any chemicals on the TRI list or
have reduced their use of TRI chemicals below the reporting thresholds for those chemicals.

•	Some facilities may have failed to report to TRI even though they fit the criteria. EPA will review
these facilities to determine if follow-up action is appropriate.

General

Q; What is new in this year's TRI National Analysis?

This year's National Analysis includes:

•	A profile highlighting the fabricated metals sector.

•	New infographic on the Emergency Planning and Community Right-to-Know Act (EPCRA).

•	New trend analysis of ethylene oxide releases.

•	New comparisons of production-related wastes and releases across EPA regions.

Q; What factors should I consider when using TRI data?

Users of TRI information should be aware that one cannot estimate human exposure to TRI chemicals or
predict risks to human health and the environment from just the quantities disposed of or released to the
environment. Also, different TRI chemicals can pose different health hazards including cancer, neurological
hazards, respiratory hazards, and developmental hazards, to name a few. In addition, chemicals can cause
these different effects at different levels and durations of exposure.

TRI data, in conjunction with other information, can be used as a starting point to evaluate exposures and
potential risks that may result from releases of TRI-listed chemicals. Factors that users of TRI data should
consider include:

•	Toxicity of the chemical

•	Properties of the chemical

•	Proximity of populations to where releases or disposal occur

•	Type of disposal or release (environmental medium), and magnitude of the release quantity

•	Fate and transport of the chemical in the environment

•	Waste management of the chemical, which may be subject to state, tribal, and/or federal
regulatory oversight

More information related to understanding and using TRI data is available on the TRI webpage in the
Factors to Consider document.

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Q; Should I worry about releases in my community?

Large release quantities do not necessarily mean there is need to be concerned, nor do small releases
necessarily mean there is a low risk. "Disposal or other releases" represent a wide variety of management
methods. These range from highly controlled disposal, such as in hazardous waste landfills, to releases due
to accidental leaks or spills. Many releases reported to TRI are subject to permits and/or environmental
standards that establish emissions limits under Federal or State laws such as, for example, air permits
issued under the Clean Air Act. These limits on releases are intended to prevent or at least minimize
exposure to the TRI-listed chemical and potential risks to human health and the environment. Factors
such as the properties of the TRI chemical, extent of exposure to the TRI chemical following its release,
route(s) of exposure (e.g., inhalation, dermal), bioavailability from the exposure route, and sensitivity of
exposed individuals to effects caused by the TRI-listed chemical must be considered before specific
conclusions about risk can be made.

Q; Were any chemicals newly added to the TRI chemical list for Reporting Year 2019?
Nonylphenol ethoxylates (NPEs) were newly added to the TRI chemical list with the first reports due for
reporting year 2019. NPEs are nonionic surfactants used in adhesives, wetting agents, emulsifiers,
stabilizers, dispersants, defoamers, cleaners, paints, and coatings. Some NPEs are toxic to aquatic
organisms, while others are less toxic but break down into more toxic forms when released to the
environment. 245 facilities reported releasing 307,000 pounds of NPEs in 2019. Most releases of NPEs
were from the chemical manufacturing and hazardous waste management sectors.

Q; What Per- and Polyfluoroalkyl Substances (PFAS) does TRI cover and what is TRI
doing to help address PFAS concerns?

Section 7321 of the National Defense Authorization Act for Fiscal Year 2020 (NDAA) added 172 per- and
polyfluoroalkyl substances (PFAS) to the list of chemicals covered by TRI. These PFAS additions are
effective as of January 1, 2020. TRI reports for these chemicals will be due to EPA by July 1, 2021, for
calendar year 2020 data. The NDAA established a manufacture, processing, and otherwise use reporting
threshold of 100 pounds for each listed PFAS. The TRI Program will make the information submitted by
facilities available to the public through its tools for accessing and analyzing TRI data. In doing so, the TRI
program will keep the public informed on the releases and other waste management practices of PFAS
that take place in their communities.

Q; What is the usual schedule for the TRI National Analysis?

TRI data for a given calendar (reporting) year are to be reported to EPA by facilities by July 1 of the year
following manufacture, processing, use, or other type of release. These data are posted online by the end
of July, as a preliminary dataset. The data then undergo extensive data quality analyses by the TRI
Program, and the dataset is refreshed throughout the fall to incorporate any revisions or late submissions
received by EPA. The dataset used to create the TRI National Analysis is locked down in mid-October, and
the report is developed from October to January. The National Analysis report is then typically published in
January.

Q; Does TRI include information on releases not related to production, such as from
remedial actions or natural disasters?

Yes. Releases of TRI-listed chemicals not related to production at facilities, such as those that might occur
from remedial actions or natural disasters, are reported to TRI as "non-production-related waste,"
meaning that the released TRI chemical waste was not associated with normal production processes.

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These are wastes resulting from remedial actions, catastrophic events (e.g., natural disasters such as
hurricanes), or one-time events otherwise not associated with production processes. Note that this
information is only reported to TRI if the facility met all three of the TRI reporting criteria of 1) exceeding
the chemical activity threshold; 2) exceeding the employment threshold; and 3) is operating within a TRI-
covered sector.

Q; Does TRI cover greenhouse gases?

TRI covers a wide range of chemicals, and some of these chemicals, such as some fluorinated chemicals,
are also regulated by EPA's Greenhouse Gas Reporting Program.

Q; Do the TRI data reflect releases ft fdraulic fracturing?

No. Under Section 313 of the Emergency Planning and Community Right-to-Know Act, the TRI reporting
requirements apply only to facilities in industrial sectors designated by certain North American Industrial
Classification System (NAICS) codes. Facilities that extract crude petroleum or natural gas from the earth
and companies that extract natural gas through hydraulic fracturing are not within the scope of sectors
subject to TRI reporting requirements. For a list of all TRI-covered NAICS categories please see the North
American Industry Classification System (NAICS) Codes as described on the TRI webpage.

Q; Was the 2019 TRI National Analysis affected by the i!0\ ro andemic?

The 2019 National Analysis reflects data on the TRI chemical waste managed by facilities in calendar
year 2019, before disruptions due to the novel coronavirus began in the U.S. As noted earlier, facilities
are required to submit reports to TRI by July 1 of the following year (i.e., reports for 2019 data were
due on July 1, 2020). This statutory deadline was not changed in 2020 and the publication of the
National Analysis proceeded according to the usual schedule. Pandemic-related disruptions to
industrial activities that occurred in 2020 may be evident in the TRI reporting for 2020; TRI forms for
2020 are due July 1, 2021.

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