TRI and Beyond

The Toxics Release Inventory (TRI) is a powerful resource that provides the public with
information about how TRI chemicals are managed by industrial facilities in the United States.
However, there are many other programs at EPA that collect information about chemicals and
the environment.

The next figure is an overview of some of the laws that EPA implements, and the industrial
activities or processes EPA regulates under these laws. While many programs at EPA focus on
one area, TRI covers releases of chemicals to air, water, and land; waste transfers; and waste
management activities. As a result, TRI data are especially valuable, as they can be utilized with
many other datasets to provide a more complete picture of national trends in chemical use,
chemical management, environmental release and other waste management practices, and
environmental performance.

-	Toxic Substances
Control Act (TSCA)

-	Federal Insecticide.
Fungicide, and
Rodenticide Act (F1FRA)

- Resource Conservation
Recovery Act fRCRAl

-	Clean Water Act (CWA)

-	Ocean Dumping Act
(PDA)

- Safe Drinking Water
Act fSDWA)

Comprehensive Environmental

Response. Compensation.
Liability Act 1CERCLA)
- Resource Conservation
and Recovery Act (RCRA)

and

Note: The Emergency Planning and Community Right-to-Know Act (EPCRA) establishes requirements
for emergency planning, preparedness, and reporting on hazardous and toxic chemicals involving
air releases, water releases, land disposal, waste transfers, and waste management.

Throughout tPA, offices use TRI data to support their mission to protect human health and the
environment. These uses include analyzing TRI data to inform decisions such as when setting

1


-------
program priorities, providing information to stakeholders such as when working with
communities toward a common goal, and many other applications as shown in the table below.

Current Uses of TRI Data by EPA Offices and Regions

EPA Office

Promote
Pollution
Prevention

Make
Decisions

Add
Context

Identify
Potential
Violators

Inform
Stakeholders

Air and Radiation



y

y





Land and
Emergency
Management

y

y

y

y

y

Enforcement and
Compliance
Assurance



y

y

y



International and
Tribal Affairs



y





y

Chemical Safety and
Pollution Prevention

y

y

y

y

y

Water

y

y

y

y



Inspector General





y





Environmental
Information







y

y

Regions

1, 2, 3, 5, 6, 7,
8,9

2, 3, 4, 5, 6,
7, 8,9

2, 3, 4, 5,
6,9

1, 2, 3, 4, 6,
7, 9, 10

1, 3, 4, 5, 6, 8,
9

This section of the National Analysis highlights how TRI data complement TSCA data and
evaluations, and how TRI has served as a model for other pollutant release inventories around
the world.

2


-------
TSCA and TRI

In June 2016, the amended Toxic Substances Control Act (TSCA1 was signed into law with
bipartisan support in both the U.S. House of Representatives and the Senate. As the nation's
primary chemicals management law, existing chemicals in commerce and new chemicals
intended for use in commerce will be reviewed for safety through a risk-based process with
increased public transparency. EPA has since finalized a rule to establish a process and criteria
for identifying high priority chemicals for risk evaluation and low priority chemicals for which
risk evaluation is not needed. Additionally, EPA released scope documents for the initial ten
chemicals undergoing risk evaluation under the amended TSCA. Most of these chemicals are
included on the Toxics Release Inventory (TRI) list of chemicals, for which TRI data are
available, as shown in the table below.

Chemicals to be Evaluated

TRI-listed Chemical?

1,4-Dioxane

Yes

1-Bromopropane

Yes

Asbestos

Partially; reportable only if in the friable form

Carbon Tetrachloride

Yes

Cyclic Aliphatic Bromide Cluster

Partially; HBCD reporting starts in 2018

Dichloromethane (also called Methylene Chloride)

Yes

N-methyl-2-pyrrolidone (NMP)

Yes

Pigment Violet 29

No

Trichloroethylene (TCE)

Yes

Tetrachloroethylene

Yes

TRI provides valuable information to the TSCA assessment process and serves as a tool for
tracking the nation's progress toward reduced environmental releases of these chemicals and
most of the other chemicals that EPA has identified for further assessment under TSCA. This
figure shows the trend over time in releases of the TSCA priority chemicals that are TRI-listed

3


-------
Releases of TSCA Priority Chemicals that are TRI-listed

/

N-methyl-2-pyrrolidone
Dichloromethane
Trichloroethylene
Tetrachloroethylene
1,4-Dioxane
Carbon tetrachloride
~ 1-Bromopropane*

	1	1	1	1	1	1	1	1	1	1	

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

*l-Bromopropane was reported for the first time in 2016.

4


-------
Source Reduction Activities for Chemicals to be Evaluated under TSCA

TRI can provide valuable information to TSCA evaluations such as the types of source reduction
activities that TRI reporting facilities have implemented to reduce the quantity of the chemical
generated as waste, as shown in the figure below.

Newly Implemented Source Reduction Activities
for TRI Chemicals to be Evaluated under TSCA,

2012-201G

Click on legend items below to customize items displayed in the chart

¦ Good Ope rating P ractices

¦ Process Madficationt

¦ Spill and leak Prevention

¦ Raw Material hforfficatiarE

¦ Inventory Control

¦ Product Mod if i gj*i a re;

¦ Surface Preparation and Finishing

¦ Cleaning and D egress ing

"O
•i

o

S 500

QC

.si
¦1

| 300

e 200

j?

w 100

E

I

0

% of Forms
with Source
Reduction

423
activities

337
activities



154

a

N-Methyl-2-Fyrralidan-	DicH a rone thine	TricHaraethy1aie	Tetra di toroeth ^ ne	1,4-Dim an e	Carbo n T etrach la ride	l-Brcmaprapane

•Reperted fer the first time
in 2016

16%

17%

17%

3%

6%

3%

15%

Note: Facilities report their source reduction activities by selecting codes that describe their activities. These
codes fall into one of eight categories listed in the graph legend and are defined in the TRI Reporting Forms and
Instructions.

5


-------
Barriers to Source Reduction for Chemicals to be Evaluated under TSCA

Since 2014, facilities that report to TRI have the option to report barriers they encountered to
source reduction. The barriers reported to TRI are shown in the figure below for the seven
chemicals that are fully TRI-listed among the first chemicals that EPA will evaluate for potential
risks to human health and the environment under the amended Toxic Substances Control Act
(TSCA).

Reported Barriers t o Source Red uction for T Rl
Chemicalsto be Evaluated under TSCA, 2014-2016

CJicJc on legend items below to customize

items displayed in the chart

¦ |pr5uffo«ent Capital

¦ Require Techi*cal Information

¦ Concern for Product Qualrty

¦ Source Reduction Unsuccessful

Regulatory Burden

¦ Previously Implemented

¦ No Known Substitutes

¦ Other

5 tjo

£ too

9iof

Forr*5

with





in



m





































IS
barriers

>i







_





¦¦¦

banian ba,n"!









	

N-M <4 ty I-2-P vrr oM a n a

Dtfttoronrieihare

TrtcMoraaihvfena	Taty*cMoraa!hvtone

l-firomoprivdfla
ported far tho Vst t>rt
»U

Cjibori TatracMorid®

Note: Facll it lei options lly report thei r barriers by checking boxes that descri be barriers to source red uction that
they faced. They may also provide text I nformation related to the barrier.

6


-------
Comparing TRI and Chemical Data Reporting

In addition to the chemical release and management data collected through the TRI Program,
EPA collects information about the manufacture (including import) and use of chemicals in U.S.
commerce through the Chemical Data Reporting (CDR) rule implemented under TSCA.
Combining the chemical information reported to both TRI and CDR provides a more complete
picture of a chemical's lifecycle from sources of import and domestic manufacture to final
deposition in the environment or products.

For calendar year 2015 activities (the most recent reporting year common to both TRI and
CDR), 8,707 individual chemicals were reported to the TSCA Chemical Data Reporting (CDR),
which tracks production and imports. 499 individual chemicals and chemical categories were
reported to TRI. Of the chemicals reported to TRI, 250 (50%) were also reported to CDR. The
remaining 249 chemicals reported to TRI are either not subject to Chemical Data Reporting
under TSCA (such as pesticides, pharmaceuticals, polymers, and TRI-specific chemical
categories); the facility is exempt from CDR reporting based on business size thresholds; the
chemicals are produced in amounts below the CDR reporting thresholds; or the chemicals are
processed or used by facilities that report to TRI, but not manufactured or imported, which are
the activities required to be reported to CDR.

To illustrate how TRI information complements the TSCA chemical assessments, one chemical,
1-bromopropane (1-BP), is presented as an example.

CDR and TRI Information for 1-Bromopropane

MANUFACTURE AND IMPORT

On-site	Off-site

Recycled

Used for Energy Recovery

Volume Used: 25.9 Million Pounds'

138-393 CDR sites
CDR Industrial Processing and Use Scenarios:

•	Use as an Intermediate

•	Processing into formulations

•	Processing into articles

•	Non-incorporative industrial Uses

•	Repackaging

COMMERCIAL AND CONSUMER USES

1 Cleaning and furnishing care products

¦	Adhesives and sealants

¦	Electrical and electronic products

<§3

91%



On-sttt OA-site

68%









Air

Land Off site

78%

7% 14%

TRI does not collect
data on waste from
the use of commercial
and consumer products

322,000 Pounds

326,000 Pounds

Water

<1%

* Production volume based on value from EPA's 2017 Scope of ttie
Risk Evaluation for 1-Bromopropane

7


-------
In 2015 (the most recent year of CDR data, which was published in 2016), ten manufacturers,
including importers, reported a total production volume of 25.9 million pounds of 1-BP
manufactured/imported. Industrial activities reported include use as an intermediate in chemical
manufacturing, processing into chemical product formulations (e.g., solvents for cleaning and
degreasing and adhesives), processing into articles (e.g., insulation), non-incorporative uses
(e.g., solvent degreasing), and repackaging. Commercial and consumer uses reported include
adhesives and sealants, cleaning and furnishing care products, and electrical and electronic
products. In 2016 (the first year 1-BP was a TRI-listed chemical), 55 facilities filed a TRI form
for 1-BP, reporting a total of 1.56 million pounds of waste, most of which (51%) was released.

8


-------
TRI Around the World

In 1986, the TRI Program was established as the first national Pollutant Release and Transfer
Register (PRTR) in the world. Since then, environmental agencies around the world have been
increasingly implementing their own PRTR programs with the Toxics Release Inventory (TRI)
serving as a model. Currently, at least 50 countries have fully established PRTRs or have
implemented pilot programs, as shown in the map below. More are expected to be developed
over the coming years, particularly in Asian and South American countries.

Active PRTRs

PRTR activities Initiate*) or pilot project
Expressed interest on PRTR
No information

Source: Inited Nations Economic Commission for Europe. 2116

As a role model, TRI participates in activities to inform and support the development and
implementation of PRTRs throughout the world by working with the following organizations:

«

Organization for Economic Co-operation and Development

. . ,	, .	J_.	,	ORGANISATION

fQECm is an intergovernmental organization made up of 35

, ,	CO-OPERATION

member countries. The OECD PRTR Working Group enables
countries with PRTRs to share experiences, and to improve PRTR
information and its use by working collaboratively on activities of mutual interest and
global importance. Current PRTR-related activities include: developing methods to make
PRTR data from different countries more comparable to enable the use of the data on a
global scale, developing and cataloging techniques for estimating emissions, and
promoting the use of PRTR information to assess progress toward global sustainability.
United Nations Institute for Training and Research fUNITARI works with
developing countries to implement new environmental programs and
transfer knowledge and technologies to them from nations with
established environmental programs. Currently, UNITAR is working with

I unitar


-------
several partners to institute PRTRs in Belarus, Cambodia, Ecuador, Kazakhstan, Moldova,
and Peru.

The North American Commission for Environmental Cooperation fCEC) addresses
North American environmental concerns, helps prevent potential trade and
environmental conflicts, and promotes the effective enforcement of
environmental law. With established PRTRs in all three North American
countries, the CEC publishes an integrated dataset through its Taking Stock
Online website-

Read more about the TRI Around the World.

10


-------