2021 TRI National Analysis Frequently Asked Questions

Table of Contents

Overview of the 2021 Data	2

Q: What are the highlights of the data analysis for 2021?	2

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

Q: What is new in this year's TRI National Analysis?	2

Q: Why does EPA include information about production-related waste as well as total disposal or other
releases?	2

Q: Were any chemicals newly added to the TRI chemical list for 2021?	3

Q: What information on PFAS was reported in 2021?	3

Q: How many facilities reported for 2021? Is it different from prior years?	3

General	4

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

Q: Should I worry about releases in my community?	4

Q: What is EPA doing to help sectors decrease the quantities of TRI chemicals they release to the
environment?	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: Was the 2021 TRI National Analysis affected by the COVID-19 public health emergency?	5

Q: Does TRI include information on pollution prevention at facilities?	5

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Overview of the 2021 Data

Q; What are the highlights of the data analysis for 2021?

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 waste managed by facilities during 2021 was 29.3 billion
pounds, a 3% increase from 2020. Most (89%) of the 29.3 billion pounds of TRI chemical waste was
managed through preferred waste management practices such as recycling and was not released to the
environment.

From 2020 to 2021, the total quantity of TRI chemicals disposed of or otherwise released to the
environment also increased:

•	Total releases increased by 8% (233 million pounds).

•	Releases into the air increased by 3%.

•	Releases into surface waters increased by 1%.

•	On-site disposal to land increased by 8% since 2020, due to increased land disposal by metal
mining, hazardous waste management, and chemical manufacturing sectors.

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 increased by 8% from 2020 to 2021. From 2019
to 2020, the total quantities disposed of or otherwise released decreased by 10%. Releases in 2021 were
similar to those reported in 2019, indicating that the drop in releases in 2020 may have been a temporary
reduction related to the Covid-19 public health emergency. Since 2012, disposal or other release quantities
of TRI chemicals have decreased by 10% (364 million pounds). This long-term decrease is driven by
declining releases from the electric utilities sector.

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

This year's National Analysis includes:

•	Enhancements to the mapping tool with expanded information on the demographics of
communities where TRI facilities are located

•	The addition of United States Geologic Services watersheds and EPA Regions to Where You Live

•	An analysis of reporting trends for per- and poly- fluoroalkyl substances (PFAS)

•	A profile of the plastics products manufacturing 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

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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 2012, 2020 and 2021.

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



2012

2020

2021

Quantity Recycled

37%

53%

51%

Quantity Combusted for Energy Recovery

11%

10%

10%

Quantity Treated

36%

26%

28%

Quantity Disposed of or Otherwise Released

15%

11%

11%

Q: Were any chemicals newly added to the TRI chemical list for 2021?

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 effective January 1, 2020. An
additional 4 PFAS chemicals were added for reporting year 2021, with reports for these chemicals due to
EPA by July 1, 2022. The NDAA established a framework for the automatic addition of PFAS to the TRI with
a manufacture, processing, and otherwise use reporting threshold of 100 pounds for each listed PFAS.

Q: What information on PFAS was reported in 2021?

In total, facilities managed 1.3 million pounds of PFAS as waste in 2021. This is a 59% increase compared to
2020 and is largely driven by off-site recycling of perfluorooctyl iodide—a newly-listed PFAS—from one
chemical manufacturing facility. In 2021, 105,146 pounds of PFAS were disposed of or otherwise released.
This is about five times the releases from 2020, which is not explained by the addition of new chemicals to
the TRI. One transfer, storage, and disposal facility (TSDF) accounted for 63% of PFAS releases, via disposal
to a RCRA Subtitle C landfill.

The TRI Program received 89 forms from 44 facilities for 44 chemicals for RY2021. Most forms were from
chemical manufacturing facilities or TSDFs. Two federal facilities submitted forms for perfluorooctanoic
acid (PFOA) and perfluorooctane sulfonic acid (PFOS). The TRI program received the most forms for PFOA
(9 forms), hexafluoropropylene oxide dimer acid (HPFO-DA or Gen-X, 7 forms), and PFOS (6 forms). Three
forms were submitted for newly listed PFAS, all for perfluorooctyl iodide.

Q: How many facilities reported for 2021? Is it different from prior years?

A total of 21,087 facilities reported to TRI for 2021, which was a 1% decrease from the number of facilities
that reported for 2020. The number of facilities reporting to TRI has decreased by 5% since 2012.

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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:

•	Some facilities had a reduction in employees that caused 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 for 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.

•	The TRI program sometimes adds chemicals to or changes the reporting thresholds for chemicals
included on the TRI chemical list. This means that, following such Agency actions, some facilities
may now meet the TRI reporting criteria if they manage such chemicals in excess of the reporting
thresholds.

•	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.

General

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

As with any dataset, there are multiple factors to consider when using TRI data. The TRI Factors to Consider
document describes these factors which include:

•	TRI does not include information from all facilities or industry sectors that may manage TRI
chemicals in waste, nor does it cover every chemical.

•	Facilities that manufacture, process, or otherwise use chemicals below the applicable TRI
threshold quantity or employ fewer than ten full-time employee equivalents are not required to
report to TRI.

•	As described in the next question, the quantity of a chemical release alone is not necessarily an
indicator of exposure to the chemical, or the potential health or environmental risks posed by
the chemical.

•	Facilities estimate the quantities they report to TRI based on readily available data. EPA
continually works to optimize the quality of the data through their data quality review process.

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
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 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

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effects caused by the TRI-Iisted chemical must be considered before specific conclusions about risk can be
made.

Q; What is EPA doing to help sectors decrease the quantities of TRI chemicals they
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
Green Chemistry. 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.

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 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 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) 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 reported to EPA's Greenhouse Gas Reporting Program.

Q; Was the 2021 TRI National Analysis affected by the *1-19 public health
emergency?

The 2021 National Analysis reflects data on the TRI chemical waste managed by facilities in calendar
year 2021 and often compares these values to 2020, when disruptions due to COVID-19 were affecting
some facilities in the U.S. Facilities may submit text comments with their TRI reporting forms, and some
facilities noted that apparent increases in waste management from 2020-2021 were because 2020
activity levels were low, and 2021 represented a more typical situation.

Q; Does TRI include information on pol	svention at facilities?

Yes. The Pollution Prevention Act of 1990 requires facilities to submit information on source reduction

(also called pollution prevention) activities they initiated during the reporting year. Facilities report this

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information by selecting one or more of 24 codes sorted into five categories: Material Substitutions and
Modifications, Product Modifications, Process and Equipment Modifications, Inventory and Material
Management, and Operating Practices and Training. Along with the code describing their source reduction
activity, facilities report how they identified the opportunity for pollution prevention.

Facilities are also encouraged to provide optional comments about their most effective source reduction
activities, with details such as what processes are affected, what chemical or material substitutions they
made, and information on new techniques or technologies.

Facilities also have the option to report barriers to implementing source reduction. This information helps
EPA identify areas where innovation and information exchange are most needed.

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