Correcting Errors and Updating TRI Submissions

Correcting minor errors early is not just good practice—it is an expectation under EPCRA. Facilities should not wait for EPA to flag issues. When a mistake is identified, action should be taken quickly to correct it.

How to Revise a Submission

The proper procedure is to submit a revised Form R through EPA’s TRI-MEweb system as soon as the error is discovered. When preparing the submission, select the “Revision” option to indicate that the filing corrects a prior report. Enter the corrected information directly into the appropriate fields so that it replaces the erroneous data. TRI-MEweb automatically maintains a record of both the original and the revised submission, ensuring transparency and leaving EPA with a clear audit trail of the change.

Revisions Triggered by New Information

Not all revisions come from mistakes. Sometimes, they are triggered by new information. For example, if a supplier issues a revised waste profile that indicates a higher concentration of a listed toxic chemical, the facility must redo threshold determinations and waste management calculations. Crucially, these recalculations must cover the entire reporting year—not just the period after the new information was received. EPCRA requires facilities to always use the best available information when making reporting decisions.

Facilities may also revise reports for prior years if updated data provides a more accurate basis for calculations. In these cases, the facility should document why the change was made, recalculate using the new data, and submit revised forms along with supporting records.

How TRI Toolkit Can Help

The TRI Toolkit reduces the burden of revisions by identifying potential issues before submission. Built-in completeness and consistency checks catch gaps early, minimizing rework. When new data affects thresholds or exemptions, the tool automatically reassesses obligations and generates an EPA-ready Form R XML for TRI-MEweb import.

References

1. 2024 QA Consolidation #812 — If a covered facility finds that it has submitted the forms with minor errors (e.g., boxes incorrectly checked, NA in the wrong place, all pages were not sent for each toxic chemical even if the pages should be blank), should the forms be resubmitted or should the facility wait for EPA to send error notices requesting revisions?

2. 2024 QA Consolidation #829 — A covered treatment, storage, and disposal (TSD) facility receives a corrected waste profile in September for a type of waste that the facility has been receiving since January 1. The corrected waste profile indicates that a listed toxic chemical is in the waste stream at a higher concentration than was indicated on previous waste profiles. Must the TSD facility revise its threshold determinations and release and other waste management calculations back to the beginning of the reporting year or only from the date (September) that the corrected information was received?