2020 TRI National Analysis Frequently Asked Questions Table of Contents Overview of the 2020 Data 2 Q: What are the highlights of the data analysis for 2020? 2 Q: Is the change in disposal or other release quantities comparable to that of prior years? 2 Q: Why does EPA include information about production-related waste as well as total disposal or other releases? 2 Q: How many facilities reported for 2020? Is it different from prior years? 3 Q: What is EPA doing to help sectors decrease the quantities of TRI chemicals they dispose of or otherwise release to the environment? 4 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? 4 Q: Were any chemicals newly added to the TRI chemical list for Reporting Year 2020? 5 Q: What is the 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? 5 Q: Do the TRI data reflect releases from hydraulic fracturing? 6 Q: Was the 2020 TRI National Analysis affected by the COVID-19 pandemic? 6 1 ------- Overview of the 2020 Data Q: What are the highlights of the data analysis for 2020? 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. The total quantity of production-related TRI chemical wastes managed by facilities during 2020 was 28.3 billion pounds, a 7% decrease from 2019. Most (89%) of the 28.3 billion pounds of TRI chemical waste was managed through preferred waste management practices such as recycling and was not released to the environment. From 2019 to 2020, the total quantity of TRI chemicals disposed of or otherwise released to the environment also decreased: • Total releases decreased by 10% (343 million pounds). Excluding the metal mining sector, disposal or other release quantities decreased by 12% (225 million pounds). • Releases into the air decreased by 9%. • Releases into surface waters decreased by 4%. • On-site disposal to land decreased by 10% since 2019, 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 10% from 2019 to 2020. From 2018 to 2019, the total quantities disposed of or otherwise released decreased by 9%. 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 reported for 2020. 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 2011, disposal or other release quantities of TRI chemicals have decreased by 27% (1.10 billion 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 2011 to 2020 timeframe. This long-term decrease is driven mainly by declining releases of TRI chemicals to land, down 27% (728 million pounds) since 2011. Reductions in land releases are driven by decreases in the metal mining sector. Q: Why does EPA include information about production-related waste as well as total disposal or other releases? Production-related waste is TRI chemical waste generated from normal or routine 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 2 ------- 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 over time, 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 2011, 2019 and 2020. Percent of production-related waste recycled, combusted for energy recovery, treated or disposed of or otherwise released 2011 2019 2020 Quantity Recycled 38% 53% 54% Quantity Combusted for Energy Recovery 11% 10% 10% Quantity Treated 33% 26% 25% Quantity Disposed of or Otherwise Released 18% 11% 11% Note that the proportion of production-related waste that was recycled increased to 54% in 2020, and recycling is a preferable way to manage TRI chemical wastes than disposal or otherwise releasing the chemical waste into the environment. Q: How many facilities reported for 2020? Is it different from prior years? A total of 21,022 facilities reported to TRI for 2020, which was a 3% decrease from the number of facilities that reported for 2019. The number of facilities reporting to TRI has decreased by 4% since 2011. There are many reasons why a facility may report to TRI one year but not report the next year. The COVID- 19 pandemic likely caused changes in production or employment at some facilities that meant they were not required to report to TRI for 2020. Each of the following reasons may account for some portion of the annual changes in facilities reporting to TRI: • Some facilities had a reduction in employees that causes them to drop below the employee threshold. • Some facilities reduced or 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 meet the criteria. EPA will review these facilities to determine if follow-up action is appropriate. • The TRI program sometimes adds chemicals or changes the reporting thresholds for existing chemicals. For example, 172 per- and poly- fluoroalkyl substances (PFAS) were added for 2020. The addition of these PFAS did not have a significant impact on the number of facilities reporting to TRI for 2020. For more information on PFAS, see the question below on newly added chemicals. 3 ------- 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 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 the pollution prevention information submitted by facilities easily accessible through its TRI P2 webpage to showcase facilities advances in environmental performance and promote the implementation of effective P2 practices. General Q: What is new in this year's TRI National Analysis? This year's National Analysis includes: • New map including the demographics of communities where TRI facilities are located • Analysis of reporting for newly-added PFAS • A profile highlighting the cement manufacturing sector • Greenhouse Gas Reporting included in sector profiles • Added cross-border waste transfers to data exploration dashboard tool 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. 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 4 ------- 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 2020? 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 were effective as of January 1, 2020. TRI reports for these chemicals were 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. Thirty-eight facilities submitted forms for 43 of these chemicals. In total, 794,000 pounds of PFAS were managed as production-related waste at these facilities, and 9,100 pounds were released. The most frequently reported PFAS chemicals were perfluorooctanoic acid (PFOA), perfluororooctane sulfonic acid (PFOS), and hexafluoropropylene oxide dimer acid (HFPO- DA).1 Q: What is the schedule for the TRI National Analysis? Each year, TRI data are due by July 1 and cover waste management activities that occurred during the previous calendar year. 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 February. The National Analysis report is typically published by early March. 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 TRI chemical waste was not associated with normal or routine production processes. 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, 1 Note: This analysis excludes PFAS releases reported from one facility that has withdrawn its report. 5 ------- are also reported to EPA's Greenhouse Gas Reporting Program. Q: Do the TRI data reflect releases from hydraulic 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 2020 TRI National Analysis affected by the COVID-19 pandemic? The 2020 National Analysis reflects data on the TRI chemical waste managed by facilities in calendar year 2020, when disruptions due to COVID-19 began in the U.S. Facilities may submit text comments with their TRI reporting forms. Some facilities reported changes due to the COVID-19 pandemic, such as temporary facility closures or reduced operations. Other facilities reported impacts on waste management and source reduction activities, such as increased usage of sanitizing chemicals, and less capital being available to pursue source reduction. 6 ------- |