Improve TRI/Form R and NPRI Reporting with Chemical Ingredient Indexing
May 21, 2019
It’s that time of the year again! Deadlines for National Pollutant Release Inventory (NPRI) reporting in Canada and Toxic Release Inventory Reporting (TRI) reporting in the USA are approaching on June 1 and July 1, respectively. Accurate and timely completion of these reports can be a daunting task, especially if you have a large and continually changing chemical inventory.
Let’s briefly review reporting requirements for NPRI and TRI, with a focus on ways that better management and visibility of your chemical inventory can make your job easier.
The annual TRI reporting requirement covers US facilities with 10 or more employees in specific industries that “manufacture,” “process” or “otherwise use” regulated toxic chemicals in quantities above EPA’s threshold levels in a given year. The reporting thresholds for most chemicals are 10,000 pounds when otherwise used, or 25,000 pounds when manufactured or processed, with smaller thresholds for more dangerous chemicals.
Facilities that meet the reporting requirements must submit their TRI to EPA by July 1 of each calendar year. EPA provides the interface TRI-MEweb for submitting reports electronically.
Facilities in Canada that meet chemical reporting requirements must submit NPRI reports for applicable chemicals each year. Reporting applicability works rather differently than it does for TRI in the US. The list of NPRI-reportable substances is organized into 6 separate parts with different applicability criteria.
For example, substances in Part 1A trigger reporting when the amounts manufactured, processed or otherwise used exceed 1 tonne over the course of the year. However, criteria air contaminants (CACs) in Part 4, such as carbon monoxide and sulphur dioxide, only trigger reporting when quantities released to air exceed specified thresholds for each substance. NPRI reporting applicability also can depend on what type of facility the reporting establishment is, and what kinds of operations it conducts.
Any facility that triggers reporting requirements must complete and submit their reports via Environment and Climate Change Canada’s Single Window reporting system by June 1 of each calendar year.
Both TRI and NPRI reporting regulations include requirements for reporting specific release information for all chemical substances that trigger reporting. This includes amounts emitted to air, discharged to water, disposed, or recycled, including names and addresses of offsite facilities receiving the substances.
The intent behind this requirement is to provide stakeholders such as the general public and the government with better information about the full lifecycle of chemicals once they arrive at a reporting facility. This information enables better awareness of how these chemicals may impact human health and the environment.
Chemical Inventory Challenges
Correct and prompt completion of TRI and NPRI reporting starts with knowing what chemicals you have at your facility. That much is probably obvious. But the reality is that you need to know more than just the identities of the chemical products you have onsite to be able to do this task well, because a given product may have one or more ingredients in it that are NPRI or TRI reportable, and if you don’t have an easy way to make that information visible, you may be in for a tough time.
When I managed TRI reporting as a regulatory consultant, I used to dread this time of the year because of the work involved. I had to go through an establishment’s full SDS library, checking their collection against the “ground truth” of their physical inventory, identifying gaps along the way and hunting down copies of missing documents. Then there was the next and often even longer step of reviewing every one of the SDSs, going through the ingredients and identifying which triggered TRI reporting. And that was all before I could get to the part where I actually calculated usages and determined if they triggered TRI reporting requirements.
I really hope that this way of doing things doesn’t sound at all familiar to you – that it sounds like a story from a bygone era. But if it does ring true, there’s good news. Modern chemical software systems make it much easier to have visibility of your real chemical inventory, consisting of the ingredients in your products, and can even flag those chemicals on specific regulatory lists, such as those containing NPRI and TRI reportable substances. When you combine that with the ability to track the movement of these chemicals through your facility, you’ll be much better prepared to meet your reporting requirements, and to demonstrate compliance.
Looking for more information about TRI and NPRI reporting? Check out our upcoming webinars:
- National Pollutant Release Inventory (NPRI) Reporting: Managing Compliance on 5/23
- Toxic Release Inventory Reporting: How to Ensure Compliance on 5/28, 6/13, and 6/25
Let VelocityEHS Help!
Our award-winning MSDSonline chemical management solutions can give you the help you need to manage your SDS library and chemical inventory, with capabilities available for indexing the ingredients of your products and flagging chemicals on NPRI and TRI reporting lists.
Need extra help getting a handle on your inventory? Let us do the heavy lifting with our on-site chemical inventory audit service. We’ll send a team of experts to your facility to perform a thorough chemical inventory audit, cross-checking your SDS library against your physical inventory and helping you to track down any missing documents identified.
As always, we’re happy to talk more about how we can help you improve your chemical management practices. Contact us today to learn more!