TRI Toolkit Q&A

The separation step is a sequential waste treatment step for one liquid phase (the one with the larger volume, typically the water phase). The other phase must be considered a new waste stream and must be listed separately on the form if treated subsequent to its separation.

Most of the information reported on the Form R is specific to the TRI chemical, rather than the waste stream containing that chemical. However, facilities must report waste treatment methods applied on-site to waste streams that contain the TRI chemical, even if the waste treatment method does not remove the specific TRI chemical being reported. In the event that a facility is reporting a waste treatment that does not destroy, chemically convert, or physically remove the TRI chemical, the efficiency is zero and the facility must report efficiency code E6 (equal to or greater than 0%, but less than or equal to 50%) for that treatment method (see: TRI Reporting Forms and Instructions, Section D.7).

First, list the biological treatment, even though it does nothing to the toxic chemical, and then enter the neutralization treatment, which has a 100 percent efficiency since pH 7.3 is considered complete neutralization for an acid. As for the settling ponds, the toxic chemical ceased to exist upon complete neutralization, so this step does not need to be included in Part II, Section 7A of the Form R for the mineral acid. However, any coincidental manufacture of toxic chemicals during this process should be considered towards the manufacturing threshold determination.

If the threshold is met, the facility must report this liquid waste stream as treated for destruction in Part II, Section 7 of the Form R. The listed toxic chemical remaining after incineration in the gaseous waste stream must be reported as stack or point source air emissions in Part II, Section 5.2 of the Form R. The amount of the listed toxic chemical destroyed is also reported in Part II, Section 8.6 of the Form R, and the stack or point source air emissions are also reported in Part II, Section 8.1 of the Form R.

No. The federal facility does not need to report the gaseous waste stream in Part II, section 7A of the Form R report because no treatment is applied to the gaseous waste stream. However, the amount of the EPCRA section 313 chemical in the gaseous waste stream would be reported as a release to air and in Part II, section 5.2, Stack or Point Air Emissions.

Neutralization is the treatment method for phosphoric acid. If the pH is 6 or above then the efficiency is 100 percent (i.e., no phosphoric acid is released) and no off-site transfer should be reported. If the waste is acidic, (i.e., pH below 6) report the transfer of phosphoric acid sent off-site and calculate efficiency from the input and the remaining acid.

If the acid spilled on the concrete pad is 100 percent neutralized, the facility would only report any non-neutralized air releases of the toxic chemical in Part II, Sections 5 and 8 on the Form R. If the spill were released directly to land before being neutralized, only the amount of the chemical that seeped into the land (i.e., not neutralized) and any air releases occurring as a result of the spill would be reported in Part II, Sections 5 and 8 on the form. Note that if the spill is considered a one-time, non-routine event, the entire amount spilled (that is not neutralized) should be reported in Part II, Section 8.8 of the Form R.

The influent concentration and treatment efficiency of the scrubber as it operates during an emergency event should be reported. The emergency scrubber is not considered to be sequential treatment with a scrubber which treats routine emissions from the same process, unless the two units function in series on a single waste system.

Any releases of a toxic chemical, even during treatment, must be estimated and reported in Part II, Section 5 of the Form R. Part II, Section 7 of the Form R must be completed if a waste stream containing the glycol ethers is treated, regardless of whether the treatment methods actually remove the glycol ethers. If, for whatever reason, glycol ethers are removed during the treatment of a waste stream, the owner or operator should use the best readily available information to determine how much of the glycol ethers are removed during the treatment process and use this information to estimate a 'treatment efficiency' for the toxic chemical.

No. Part II, Section 7 of the Form R is only for the description of waste treatments that occur on-site. In the above scenario, the conservation vent functions as a preventive device. The conservation vent does not function as a waste treatment step. (Another example of a preventative device is a floating roof storage tank, the function of which would not be considered waste treatment).

No. If, for example, a facility combusts a toxic chemical in a waste for energy recovery, the owner or operator would consider the amount combusted for energy recovery towards the otherwise use threshold. If the facility exceeds a threshold for this chemical, the owner or operator would also report the method and amount of energy recovery in Part II, Sections 7 and 8 on the Form R.

Assuming no contaminants are removed during the melting process, the chromium in the metal scraps is not actually being recovered but merely melted and reused. Therefore, the amount of the toxic chemical in the metal scraps would not be reportable in Part II, Sections 6.2 or 8 of the Form R. However, because the facility is repackaging and distributing the toxic chemicals in commerce, it should consider these amounts of the toxic chemical towards the facility's processing threshold. If the covered facility exceeds a chemical activity threshold, it is required to file a TRI Report for that chemical.

In this scenario, EPCRA section 313 chemicals are being burned in the process, not in a waste management activity. Toxic chemicals reported as released or otherwise managed as waste on the Form R, including quantities reported for energy recovery, should not include chemicals consumed during processing activities. Therefore, the PACs combusted as part of the process in a ring furnace, should not be included as combusted for energy recovery under EPCRA section 313. These quantities should, however, be considered when making the facility's otherwise use threshold.

Because metals cannot be destroyed, they should not be reported as treated in Part II, Section 8.6 or 8.7 of the Form R. If you do not know what the POTW does with the metal constituents they receive, you should assume they are released and report the ten pounds sent to a POTW in Part II, Section 8.1 on the Form R.

Facilities should use the best readily available information they have. For example, they may use inventory data, reuse data, engineering reports on process modification, and product development studies.

Section 8.10 of the Form R is for reporting actions or techniques that prevent a toxic chemical from becoming a waste to be disposed, treated, combusted for energy recovery, or recycled. Incineration is considered waste treatment (assuming there is no energy recovery) and is reportable under Part II, Sections 6.2.C or 7A, as well as Section 8.6 or 8.7, depending on whether it is performed on- or off-site. It should not, however, be reported as a source reduction activity in Part II, Section 8.10.

Because the dredging of the lagoon (or surface impoundment) occurs routinely every five years, it is not considered a remedial action under the Pollution Prevention Act, and accordingly, releases from the dredging should not be reported as releases from remedial actions. Instead, releases and other waste management quantities of the toxic chemical resulting from dredging would be reported in Sections 5 or 6 and in Section 8 of the Form R, depending on the ultimate disposition of the chemical.

A one-time processor in its first year of using a listed toxic chemical should report 'NA' in Section 8.9 of the Form R. If a one-time processor uses a toxic chemical on a yearly basis but in different products, applications, and quantities, then a production ratio based on production or application involving the toxic chemical should be calculated as follows: production involving the toxic chemical in the current year divided by production involving the toxic chemical in the prior year.Batch processors should calculate a ratio based on campaigns involving the toxic chemical from year to year as follows: campaign production in the current year divided by the campaign production in the prior year.

The owner or operator of a facility may put "NA" in Column A of Sections 8.1 through 8.7 of the Form R if the toxic chemical was not present at the facility in the prior year. "NA" is also appropriate for Column A if the toxic chemical was present at the facility in any amount during the prior year, but there was no possibility for a release or other waste management activity of that toxic chemical to occur during the prior year. For example, if the facility did not have an on-site recycling operation for the waste stream containing the toxic chemical in the prior year, the facility may put "NA" in Column A of Section 8.4 (on-site recycling). Otherwise, the owner or operator should provide a reasonable estimate for prior year release and other waste management activities of a toxic chemical in Column A of Sections 8.1 through 8.7.

Even if there was a change in facility ownership, release and other waste management quantities for the year prior to the reporting year must be entered in Sections 8.1-8.7, Column A of the Form R. If such information is not available, the TRI-covered facility must use the best readily available data or reasonable estimates of the activities. It is not appropriate to enter NA unless the toxic chemical was not present at the facility during the prior year or if the toxic chemical was present at the facility in any amount during the prior year, but there was no possibility for a particular release or other waste management activity of that toxic chemical to occur.

For reporting year 1998 only, facilities in the seven newly added industries may use 'NA' in Part II, Section 8.9 (Production Ratio or Activity Index) of the Form R. In future years, these newly added facilities may only use 'NA' in this section if the reported toxic chemical was not manufactured, processed or otherwise used in the year prior to the reporting year. All other facilities covered by EPCRA section 313 may only use 'NA' for the 1998 reporting year, and all future years, if the reported toxic chemical was not manufactured, processed or otherwise used in the year prior to the reporting year.

Yes. It is possible that the activity ratio for a chemical equal 1 if the frequency of the activity for which it is used does not change. The activity index is the measure of an operation at a facility, a production index is the measure of the plant’s actual productivity in relation to chemical usage.

No, you may not enter NA in Section 8.9 if the chemical was manufactured, processed, or otherwise used in the year prior to the reporting year, regardless of whether an applicable reporting threshold was exceeded. Entering a value in Section 8.9 allows year-to-year changes in your facility’s release and other waste management quantities to be viewed within the context of production.

No. For only that first reporting year that the industry sector was added to TRI's covered sectors list, covered facilities in a newly added industry sector are not required to provide an estimate for the prior year in column A, Section 8 of the Form R. However, if the facility has information to develop an estimate, then reporting the estimate may provide valuable information that may clarify the facility's yearly estimates.

The owner or operator of a facility should enter “NA” in Columns C and D of Sections 8.1 through 8.7 of the Form R if there will be no on-site or off-site treatment, combustion for energy recovery, or recycling on the waste stream containing the TRI chemical or the chemical will not be present at the facility in either of the following years. It would also be appropriate to enter “NA” if the facility shut down during the reporting year and will not be operating in the following year or second following year.

Yes. You are required to complete Sections 8.1-8.7, Column A for each chemical for which you are required to submit a Form R report. In completing these Sections, you may use your best readily available data (or reasonable estimates if such data are not readily available). Facilities in a covered industry sector that manufacture, process, or otherwise use an EPCRA section 313 chemical are expected to retain any documentation that may be necessary for the purpose of developing estimates for these Sections.

The information populated in the Section 8 table on TRI-MEweb is directly sourced from the preceding corresponding sections in the Form R. For example, Sections 8.6 and 8.7 report the quantity treated on-site and off-site, respectively. Section 8.6 is sourced from Section 7A for quantities treated on-site. Section 8.7 is sourced from Sections 6.1 and 6.2 for off-site transfers associated with P codes P37, P38, or P39 as well as any other off-site treatment.Therefore, if “Not Applicable” (NA) is indicated for the source fields, the “NA” entry will cascade to corresponding subsections in the Section 8 table and be automatically filled with “NA”. The only way to remove the “NA” and enter information is to return to the source sections and enter the quantities in the appropriate field using the appropriate information. For additional information, please see D. Part II, Section 8 of the TRI Reporting Forms & Instructions available at the following URL:https://guideme.epa.gov/ords/guideme_ext/f?p=guideme:rfi-home.

Yes. Any changes that result in less of the listed toxic chemical being generated in waste may be included. Codes are provided to identify changes such as equipment and technology modifications, as well as process changes, procedure modifications, and improved housekeeping.

The facility may voluntarily choose to report the source reduction without filing a Form R by using TRI-MEweb’s “Not Reporting?” feature. If the facility fell below the reporting threshold for one or more chemicals due to source reduction, the facility can provide comments about its source reduction activities when completing this section. The public will be able to access this information using the TRI Pollution Prevention Tool.Additional information about pollution prevention and TRI is available at: https://www.epa.gov/toxics-release-inventory-tri-program/pollution-prevention-p2-and-tri.

In order to classify the kind of source reduction activities in which a facility is engaging, the facility must refer to and identify a code from the “Source Reduction Activity Codes” within Section 8.10. EPA encourages reporters who report NA in Section 8.10 to explain any barriers they encountered while trying to implement source reduction activities on-site in 8.11. Additional information and guidance on source reduction activities is available in the TRI Reporting Forms and Instructions. If a facility wants to submit additional information on its source reduction activities, it may do so in Section 8.11 of the Form R. This section provides an opportunity to publicly comment on the selected source reduction activity codes or highlight any steps the facility took to reduce the amount of toxic chemicals entering the environment. If submitting information in this section, EPA encourages the facility to provide specific, detailed information to encourage other facilities to adopt similar practices and to help TRI data users and the public understand these source reduction activities. For example, facilities could describe how specific release or waste management quantities have changed or might change in the future, which processes and products were affected, and which technologies and materials were used. Facilities can also enter useful URLs such as pollution prevention resources or corporate sustainability pages. For assistance in reporting Pollution Prevention and Production Ratio Data in Sections 8.9-8.11 and 9.1, please visit: https://www.epa.gov/system/files/documents/2025-01/tri-meweb-ry-2024-mini-tutorial-list-01-22-2025.pdf For additional information on identifying effective environmental practices and highlighting pollution prevention successes, please visit https://www.epa.gov/toxics-release-inventory-tri-program/pollution-prevention-p2-and-tri.

Yes. To promote pollution prevention (P2), EPA has increased the prominence and accessibility of the P2 information reported in Sections 8.10 and 8.11 of the Form R. All P2 entries are featured in the TRI P2 Search tool (https://www3.epa.gov/enviro/facts/tri/p2.html). This tool allows you to search by industry sectors, chemicals, chemical groups, reporting years, states, zip codes, cities, or a combination thereof and display the results as Pollution Prevention (P2) activities or as a facility comparison. The search results show source reductions and other environmental practices reported. P2 reports can also be generated for specific facilities. To learn more, visit: https://www.epa.gov/toxics-release-inventory-tri-program/pollution-prevention-p2-and-tri.

Releases reported in Part II, Section 8.8 of the Form R should be the result of a remedial action, a catastrophic event or a one-time release not associated with normal or routine production processes. In general, pipes have an expected life span. If a pipe ruptures during its expected life span for no known reason, the release should be considered a one-time release not associated with normal or routine production processes and should be reported in Section 8.8. However, if the pipe bursts because it was in use after its expected life span it should not be considered a one-time release because it should have been replaced.

If the accidental release of the EPCRA section 313 chemical at a federal facility is a one-time event, then it should be reported in section 8.8 of the Form R report. If the release is routine or frequent, it should be reported in section 8.1 of the Form R. For example, spills that occur as a routine part of production operations and could be reduced or eliminated by improved handling, loading, or unloading procedures are included in the quantities reported in section 8.1 through 8.7 of the Form R report, as appropriate. A total loss of containment resulting from a tank rupture caused by a tornado would be included in the quantity reported in section 8.8.

On April 19, 2012, EPA published a final rule that improves and clarifies certain opportunities allowing tribal governments to participate more fully in the TRI Program (77 FR 23409). First, beginning with Reporting Year 2012 (RY12), facilities located in Indian Country will be required to submit annual TRI reports to EPA and the appropriate tribal representative, rather than to the state in which the facility is geographically located. This rule also clarifies the opportunities available to tribal governments to modify the list of covered chemicals and TRI reporting facilities. In particular, EPA included a provision that provides the following opportunity for the Tribal Chairperson or equivalent elected official to request that EPA apply the TRI reporting requirements to a specific facility located within their respective tribal land. The Tribal Chairperson may also petition EPA to add or delete a particular chemical to or from the list of chemicals covered by TRI. Additional information about TRI reporting in Indian County, including a copy of the final rule, is available at the following URL: https://www.epa.gov/toxics-release-inventory-tri-program/tri-reporting-facilities-located-indian-country.

A list of TRI facilities that may be located in Indian Country is available at: https://edap.epa.gov/public/extensions/TRI_Tribal_Communities_Dashboard/TRI_Tribal_Communities_Dashboard.html. In addition, facilities can contact their designated TRI Tribal Contact to verify whether their location is under the jurisdiction of an Indian Tribe. Contact information for TRI Tribal Contacts is available at:https://www.epa.gov/toxics-release-inventory-tri-program/tri-tribal-contacts.

The 2009 Omnibus Appropriations Act returned TRI reporting requirements back to the rules in effect prior to December 22, 2006. These changes affect TRI reports due July 1, 2009 and beyond. The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals (as listed in 40 CFR 372.28) be submitted on "Form R," the more detailed form. For all other chemicals the shorter form, "Form A," may be used only if the "annual reporting amount" (i.e., the sum of production-related releases and other waste management) does not exceed 500 pounds and the amount manufactured, processed, or otherwise used does not exceed 1 million pounds during the reporting year.

The Form A provides certain covered facilities the option of submitting a substantially shorter form with a reduced reporting burden. Facilities which meet the NAICS code, employee, and chemical activity thresholds but who do not exceed one million pounds manufactured, processed, or otherwise used and the facility’s total annual reportable amount does not exceed 500 pounds for the chemical that is not a chemical of special concern, may submit an annual certification statement (Form A) instead of a Form R for the toxic chemical.

The Form A provides certain covered facilities the option of submitting a substantially shorter reporting form. For non-PBT chemicals, reporters are eligible to use Form A if they have an annual reportable amount (i.e., the sum of production-related releases and other waste management) of the chemical that does not exceed 500 lb/yr and the amount manufactured, processed, or otherwise used does not exceed 1,000,000 lb as of Reporting Year 2008, Form A may no longer be used to report PBT chemicals.

No. Eligibility for use of Form A is toxic chemical specific. However, more than one toxic chemical can be reported on a single Form A. To be eligible for reporting a toxic chemical using Form A, a facility must not manufacture, process, or otherwise use more than one million pounds of the specific chemical that is not ac chemical of special concern and the total annual reportable amount for the chemical that is not a chemical of special concern must be less than 500 pounds. In some instances, a facility may submit the Form A for some chemicals and the Form R for other chemicals. Although all toxic chemicals that are not chemicals of special concern that meet the eligibility criteria for use of Form A may now be reported together on a single Form A, each eligible toxic chemical must be individually listed on the Form.

Facilities which have a total annual reportable amount of no greater than 500 pounds for a listed chemical that is not a chemical of special concern may qualify for the one-million-pound alternate threshold for that chemical, beginning with the 1995 reporting year. For purposes of the alternate threshold, the total annual reportable amount includes chemicals that are not chemicals of special concern listed at 40 CFR Section 372.65 which are released (including disposed), treated, recycled, and burned for energy recovery at the facility and amounts transferred from the facility to off-site locations for the purposes of recycling, energy recovery, treatment, and/or disposal. These amounts correspond to column B, Sections 8.1 through 8.7 of the reporting Form R. If a facility’s combined total annual reportable amount does not exceed 500 pounds for a specific chemical that is not a chemical of special concern, the facility can qualify for reduced reporting requirements unless the amount of that chemical that is not a chemical of special concern manufactured, processed, or otherwise used within the reporting year exceeds one million pounds.Covered facilities that qualify for the alternate threshold are not exempt from reporting, but must fulfill certain requirements. In lieu of submitting a Form R, the owner/operator of a facility must submit an annual certification statement (Form A) indicating that the facility met the requirements for use of the alternate threshold for a specific chemical. The facility must also maintain, and make available upon request, records substantiating the claim. The Form A includes basic information regarding the facility’s identification, the chemical in question, and a statement of accuracy to be signed by a senior management official of the facility.

The facility should report to all appropriate states or local jurisdictions in which the federal facility is fully or partially located.

No, they are not the same. The total annual reportable amount applies to EPCRA section 313 listed toxic chemicals and is facility specific. A facility's total annual reportable amount is equal to the combined total quantities released at the facility (including disposed), treated for destruction at the facility (as represented by amounts destroyed or converted by treatment processes), recovered at the facility as a result of recycle operations, combusted for the purpose of energy recovery at the facility, and amounts transferred from the facility to off-site locations for the purpose of recycle, energy recovery, treatment, and/or release (including disposal). The total annual reportable amount is not the same as a reportable quantity (RQ). An RQ is chemical specific and applies to Extremely Hazardous Substances (EHS) or CERCLA Hazardous Substances. In the case of an accidental release, a facility owner/operator would refer to a chemical's RQ to determine if the facility has released enough such that reporting to a Local Emergency Planning Committee, SERC, and the National Reporting Center is required under EPCRA Section 304 and CERCLA Section 103.

A facility is permitted to take exemptions, if applicable, when determining whether the facility has met the one-million-pound alternate threshold. Additionally, a facility does not have to count exempted activities towards the annual reportable amount. The alternate threshold and annual reportable amount determinations for an individual chemical must be based upon a whole facility determination and account for all establishments within a facility; therefore, an individual activity may be exempt but the facility may exceed the alternate threshold or annual reportable amount at the facility level.

EPA's Central Data Exchange (CDX) is the Agency's point of entry on the Internet-based Environmental Information Exchange Network (Exchange Network) for environmental data exchanges. CDX provides the capability for states, tribes, and facilities to gain access to their data through the use of Web services. CDX enables EPA to work with stakeholders -- including state, tribal, and local governments and regulated industries -- to facilitate the electronic submission of data to the Agency via the Internet. EPCRA section 313 covered facilities access TRI-MEweb through CDX to submit annual toxic chemical release reports to EPA and their state or tribe. You can access the electronic reporting site at: https://cdx.epa.gov/.

The Electronic Reporting Rule requires facilities to submit, revise, and withdraw non-trade secret TRI forms electronically via TRI-MEweb, a web-based reporting application for electronic filing of TRI Form R and Form A Certification Statement reports. The TRI-MEweb application is hosted in EPA's Central Data Exchange (CDX) system. Users must access, create, and load facility accounts in TRI-MEweb to begin reporting. TRI reporting requires two user roles to be created in CDX: a preparer role and a certifying official role. Preparers and certifying officials must register for the application at: https://cdx.epa.gov/. To learn more about TRI-MEweb, please visit https://www.epa.gov/toxics-release-inventory-tri-program.

The Agency encourages submission of Forms using the EPA software provided with the Form R package. The Agency has also approved the facsimile outputs of certain privately developed software packages. A list of the providers of software packages is made available by EPA. Contact the EPCRA Information Hotline for more information ((800) 424-9346 or (703) 412-9810).

The TRI Program has developed a series of TRI-MEweb resources, including online tutorials to assist facilities with using the TRI application, as well as two helpdesks. The TRI-MEweb online tutorials can be found on TRI’s website at https://www.epa.gov/system/files/documents/2025-01/tri-meweb-ry-2024-mini-tutorial-list-01-22-2025.pdf. TRI-MEweb also has links to tutorials, as well as a user guide and link to the CDX Helpdesk Chat. TRI has hotlines to provide CDX/TRI-MEweb technical support and reporting guidance to reporting facilities: TRI Information Center Hotline [(800) 424-9346 - select option 3] and CDX Help Desk (888) 890-1995.

Facilities that use TRI-MEweb and are in a state or tribal territory participating in the TRI Data Exchange (TDX) will have their forms sent simultaneously to EPA and to their respective state or tribal TRI office. TRI-MEweb will inform the preparer during the submission process whether the facility is in a state or tribal territory participating in the TRI Data Exchange. A list of participating states is also available here: https://www.epa.gov/toxics-release-inventory-tri-program/tri-data-exchange.However, if a facility is in a state or within tribal lands that is not participating in the TRI Data Exchange, any forms submitted via TRI-MEweb will not automatically be sent to the state/tribe. After these facilities submit their reports to EPA via TRI-MEweb, they should use the application to prepare a submission for the state/tribe on paper, diskette, CD, or DVD. To verify the preferred method of submission for each state and tribe, go to the TRI State Programs website at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-tribal-contacts.

Facilities that use TRI-MEweb and reside in a state or tribal country participating in the TRI Data Exchange (TDX) will have their forms sent simultaneously to EPA and their respective state/tribe via TDX.Please be aware that if your facility does not reside in a state/tribe participating in TDX, any forms submitted via TRI-MEweb will not automatically be sent to the state/tribe. After these facilities submit their reports to EPA via TRI-MEweb, they can use TRI-MEweb to print a submission for the state/tribe on paper, diskette, CD, or DVD. To verify the preferred method of submission for each state or tribe, go to the TRI State Programs website at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-tribal-contacts.

The Government Paperwork Elimination Act allows Federal agencies to provide for electronic submissions and the use of electronic signatures, when practicable. Similarly, EPA's Cross-Media Electronic Reporting Regulation (CROMERR) states that any requirement to submit a report directly to EPA can be satisfied with an electronic submission that meets certain conditions, once the agency publishes a notice that electronic document submission is available for that requirement.On August 27, 2013, EPA finalized a rule requiring facilities to report non-trade secret TRI forms using software developed by the Agency (78 FR 52860). Currently, EPA provides TRI-MEweb as the online application for submitting TRI reporting forms electronically. Widespread use of TRI-MEweb improves the quality and accuracy of TRI data and allows EPA to get the data to the public faster.Further information about this rule is available: https://www.epa.gov/toxics-release-inventory-tri-program/electronic-reporting-toxics-release-inventory-data.

In TRI-MEweb, there are different steps required to access the history, depending on your knowledge of your facility’s reporting history: You know that your facility reported in prior years: Enter the TRIFID and access key to load the facility account. You know that your facility did not report in prior years: Enter the facility’s location information and select your facility among those that match the search criteria. Save this information using the access key or technical contact information. You do not know if your facility reported in previous years: Enter the facility’s location information and select your facility among those that match the search criteria. Save this information using the access key or technical contact information. Additional information is available in a series of TRI-MEweb tutorials available on the TRI website at https://www.epa.gov/system/files/documents/2025-01/tri-meweb-ry-2024-mini-tutorial-list-01-22-2025.pdf

Some facilities may need to obtain their assigned six or seven-digit "access key" that will uniquely identify the facility’s reporting history record and load it into TRI-MEweb. Access keys are generated for each TRI facility identification designator (TRIFID). Access keys do not change from year to year. TRI-MEweb provides chemical release data that has been reported to EPA back to Reporting Year 1991 in each facility account.If another user at your facility has already loaded the facility into their TRI-MEweb account, they may provide you with the facility access key, which is visible from the “Manage Facilities” page. You can have the access key emailed to you via the TRI-MEweb application after entering and verifying the TRIFID. You can also obtain your facility access key by calling the CDX Helpdesk at 888-890-1995 or emailing the Helpdesk at helpdesk@epacdx.netThe following people may need to request an access key: a) New preparers that have created a new CDX account and will transmit TRI forms for a facility that has reported TRI chemical releases to EPA in the past.b) Preparers that want to add an unlisted facility to their TRI-MEweb account.c) Preparers that have accidentally deleted facility profiles from their TRI-MEweb account.d) If a facility has not previously reported to the TRI Program, a TRIFID and access key will be automatically generated within the TRI-MEweb application.Note: If your facility has changed ownership during the past calendar year, the TRIFID remains the same because this identification number is assigned to the physical location and not to a specific company or proprietor. If the TRIFID remains the same, the access key does not change.

Access keys are sent via email from CDX at the beginning of the year to the prior year’s certifying officials and technical contacts of reporting facilities. TRI filers may also request their access keys be e-mailed to their CDX-registered e-mail within the TRI-MEweb application.If you do not have the facility's access key, TRI-MEweb offers filers another way to add a facility if you have information about that facility from the prior year’s reporting, including your facility's TRI facility identification number (TRIFID), technical contact name from the previous year's report, and technical contact phone number. TRI-MEweb will indicate that it has granted you access to the facility, and you may prepare the submission for that facility. TRI-MEweb will also display the list of individuals that have been granted access to that facility.

No. If a covered facility meets the criteria and files the Form A, the owner/operator need not submit any other documentation to EPA and the state or tribal authority. However, the facility must maintain all documentation supporting their Form A submission.

Facilities must submit a copy of each reporting form sent to EPA to the state or tribe in which that facility is located. TDX allows facilities to submit TRI reporting forms simultaneously to both EPA and the appropriate state or tribe through the Central Data Exchange (CDX). TDX also helps EPA, states, tribes, and territories exchange environmental information efficiently and streamlines the acceptance and processing of TRI data by both EPA and the states/tribes. A filer may check to see if their state or tribe is in the TRI Data Exchange by going to http://www.exchangenetwork.net/data-exchange/toxics-release-inventory-tri/.

TRI-MEweb will inform users whether their state or tribe is participating in the TRI Data Exchange or whether they must submit their forms to their state separately (e.g., diskette, paper submission). However, TRI-MEweb will not inform that user of the preferred method of submissions for filers in states that do not participate in TRI Data Exchange. A filer will need to contact their state directly (https://www.epa.gov/toxics-release-inventory-tri-program/tri-data-exchange. If additional states or tribes join the TRI Data Exchange, TRI-MEweb will be updated accordingly, and facilities located in those states will also have their forms submitted automatically to their state officials via the Internet Note that for submissions, revisions, and withdrawals for Reporting Year 1991 through Reporting Year 2004, all facilities, including those residing in states participating in the TDX, must report to their states separately in the required format specified by the state (e.g., diskette, paper). TRI-MEweb will not electronically transmit forms for these reporting years to state officials.

The Electronic Reporting Rule, effective January 21, 2014, requires facilities to submit, revise, and withdraw non-trade secret TRI forms electronically via TRI-MEweb application. Facilities cannot use TRI-MEweb to print federal paper submissions to submit to EPA. However, TRI-MEweb does allow facilities to print a copy of the submitted TRI form for recordkeeping purposes (this form is clearly marked as not allowed to be filed manually to EPA). Facilities may print a copy of a Form R or Form A Certification Statement for recordkeeping purposes via the “Submission History” tab. The “Submission Summary” page will display only the forms which have been certified and submitted to EPA. Select “View Reports” to access your Copy of Record of your Form R or Form A Certification Statement.

The TRI-MEweb tutorials are designed to demonstrate how different tasks are performed within the Web-based application reporting tool. These tutorials are designed for new users, as well as experienced users. These tutorials are available to watch within TRI-MEweb.

Users may request assistance from the CDX hotline on issues like how to obtain access keys, load facility accounts, and verify status of submissions in TRI-MEweb. Users may also request assistance from the CDX helpdesk to reset passwords, address issues with the CDX registration process, and add the TRI-MEweb application to the CDX user account. These technical application issues can be resolved if you can contact the CDX hotline at (888) 890-1995.

If the CDX login webpage is down for a legitimate reason (i.e., maintenance, system update), an announcement should be posted on the main CDX login webpage and on the TRI website. However, if the CDX login webpage is operational, but the webpage appears broken on your computer, you should check to ensure that your browser’s TLS 1.0 security setting is enabled.

A preparer or certifying official can check the status of an ESA on TRI-MEweb. All facilities that have been added to TRI-MEweb by the preparer are on the “Manage Facilities” page under the “Facility Management” tab. The “ESA Status” column will indicate each person who has been authorized to access that facility’s account through the “View User” link: a) If the status is “Sign CDX ESA”, the facility’s certifying official has not processed the ESA form. b) If the status is “CDX ESA Pending Approval,” then the certifying official has printed their ESA form, but it is on its way via postal mail to the Data Processing Center or is still being processed.c) If the status is “Sign TRIFID Signature Agreement,” then the new certifying official has an approved ESA form but has neither associated the TRI Facility Identification number (TRIFID) nor provided their job title in TRI-MEweb.A preparer or certifying official may also contact the TRI Data Processing Center at (703) 227-7644 to verify the status of an ESA. The certifying official should also verify that the form was properly mailed to the DPC’s current address, which is available under the “Contact Us” page on the TRI website.

EPCRA section 313(a) mandates that covered facilities report to EPA by July 1 of each year. On occasion, however, EPA has extended the date for submitting the Form R. If EPA chooses to extend the deadline, facilities should verify with their state representative that the state will also extend their reporting deadline. No extensions are ever made on an individual facility basis. If EPA extends the deadline a notice of this is published in the Federal Register.

Some facilities have their own software or use private software to assist in collecting chemical release data. This "third party software" is often designed to produce output data files that match EPA's electronic data structure specifications. Facilities may upload their data files in extensible markup language (XML) format via the Upload Tool in TRI-MEweb. The facility’s information can also be updated in TRI-MEweb using the Upload Tool. All data uploaded must be checked for errors and certified. For more information, please view the “Using the Upload/Download Data Tool” tutorial, which can be found on TRI’s website: https://www.epa.gov/system/files/documents/2025-01/tri-meweb-ry-2024-mini-tutorial-list-01-22-2025.pdf.

If the reporting deadline falls on a Saturday or Sunday, the EPA will accept the forms which are postmarked on the following Monday (i.e., the next business day).

To add the TRI-MEweb Certifying Official role to an existing CDX user account, follow these steps: 1) Log in to your CDX account at https://www.epa.gov/system/files/documents/2025-01/tri-meweb-ry-2024-mini-tutorial-list-01-22-2025.pdf.

Under EPCRA section 313 and its implementing federal regulations, there are no federal fees or taxes for submitting a Form R or Form A to EPA or the state. However, states and tribes may have similar reporting programs or other state/tribe requirements that associate fees or taxes with the submission of TRI forms. A directory of state and tribe TRI program contacts is available at: https://www.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts.

No. The final rule (February 16, 1988; 53 FR 4500) states that each unique toxic chemical submission must contain an original signature. The purpose of the requirement is to ensure that the certifying official has reviewed each toxic chemical submission. A photocopied signature or no signature does not fulfill this purpose. An original signature on the certification statement is not required for the copy that is sent to the state. However, if the state requires an original signature under their state Right-To-Know laws, then the facility must comply.

Newly designated certifying officials must create a new Central Data Exchange (CDX) account, add TRI-MEweb to their CDX account, and complete an Electronic Signature Agreement (ESA) and a TRI Facility Identification number (TRIFID) Signature Agreement before any pending forms can be certified. The “Pending Signature” section in TRI-MEweb indicates the facilities for which a certifying official must sign a TRIFID Signature Agreement by following the prompts on TRI-MEweb. Certifying officials may also add additional TRI facilities by clicking on the “Add Facility” button. Returning certifying officials will receive an email from CDX when a form has been submitted and requires their certification. Before certifying pending forms, the certifying official can view the error reports through the “Summary Reports” page. If the certifying official detects that a correction is needed on the form, the certifying official may return the form to the preparer. Note that returning a submission does not remove the data from TRI-MEweb; this just allows the preparer to make any corrections and resubmit the form for certification. Otherwise, the certifying official may certify and submit the form to EPA. A notification will be sent from CDX to the certifying official's registered e-mail account confirming that the form’s certification has been completed, along with the certification time stamp.It is important to ensure that the certifying official's e-mail address associated with their CDX account is kept up to date as correspondence regarding TRI submissions is sent to the certifying official's registered e-mail address. If a certifying official wishes to update their e-mail address or job title, these changes can be made by in the “Profile” window on the My TRI welcome page, or contacting the CDX Helpdesk by phone (888-890-1995) or e-mail (helpdesk@epacdx.net).

EPA must have an original signature on file. A facility must resubmit a completed Form R with an original signature, and this new form should be attached to the NOTE and returned to EPA and to the facility's state contact.

No. Submission of multiple copies of Part II, with only one copy of Part I, would be considered noncompliance. The final rule clearly requires that each completed submission contains all parts of the Form R (including Part II).

An Electronic Signature Agreement (ESA) form is a statement that declares that the registrant understands that any electronic signature executed with the electronic signature device is as legally binding as a handwritten signature and is required by EPA before any certifying official can certify and submit a TRI form created in TRI-MEweb. New certifying officials: An ESA form is needed for certifying officials that have been newly designated for a TRI reporting facility. ESAs are created upon the certifying official creating a new CDX user account, adding the TRI-MEweb application, and applying for a certifying official role. There are two options available to obtain an ESA approval from EPA. Option 1 – LexisNexis real-time ESA approval: EPA now provides an alternative method for certifying officials to process ESAs in real-time using a third-party identity verification vendor named LexisNexis. This real-time approval is possible because personal identifying information including last 4 digits of SSN is provided voluntarily by the certifying official to a third-party vendor (EPA does not collect any personal information from our users) to authenticate their identity. Third party verification and identification widgets are commonly used in the banking system. The most significant benefit from the LexisNexis method is that users will no longer need to wait up to 5 business days for an ESA approval by EPA. This alternate ESA approval method is optional. If the certifying official does not wish to provide personal information to a third-party vendor; they should submit a paper ESA form instead well in advance ahead of the July 1 deadline. Option 2 – Paper ESA form: A printable ESA form can be generated during the CDX user account registration process. The ESA form must be signed and mailed to EPA’s Data Processing Center for approval before the certifying official can begin to certify any TRI forms transmitted by the preparer to CDX using TRI-MEweb. The “TRI-MEweb” link on the My CDX page will remain inactive until EPA processes the paper form ESA at the DPC. Hardcopy ESA approval may take up to five business days, so please plan accordingly or consider the option one, LexisNexis. The “TRI-MEweb” link on the MyCDX page is activated and updated when the paper ESA is approved. Please send hard copy ESA forms through regular mail to:U.S. Environmental Protection Agency Attention: TRI Reporting Center P.O. Box 10163 Fairfax, VA 22038 ESAs sent by certified mail or overnight mail (e.g., FedEx, UPS) should be sent to:Attention: TRI-MEweb ESA CGI Federal, Inc. c/o EPA Reporting Center 12601 Fair Lakes Circle Fairfax, VA 22033TRIFID Signature Agreement(s) required for all certifying officials (preexisting and new): All certifying officials will also need to electronically sign a TRIFID Signature Agreement before obtaining access to any pending submissions to each TRIFID that has been added to the TRI-MEweb application.

No. A representative from a consulting firm preparing a Form R or a Form A for a covered facility cannot sign the certification in Part I, Section 3 of either the Form R or the Form A. The certification must be signed by the owner/operator, or a senior management official employed by the facility subject to EPCRA section 313 toxic chemical release inventory reporting. Senior management official means an official with management responsibility for the person or persons completing the report, or with management responsibility for the manager of environmental programs for the facility or establishments, or with management responsibility for the corporation owning or operating the facility or establishments responsible for certifying similar reports under the other environmental regulatory requirements (40 CFR Section 372.3).

Section 313 requires that a senior official with management authority over the person or persons filling out the form certify the accuracy and completeness of the form. This person could be a plant or facility manager rather than a senior corporate executive and should be the senior person in a position to attest to the accuracy of the information provided.

A TRIFID Signature Agreement authorizes a certifying official to represent a facility that is submitting TRI data to EPA under a specific TRIFID. Therefore, certifying officials with an approved ESA would only need to submit a new TRIFID Signature Agreement if they are going to certify TRI forms for an additional facility. A change in company name, mailing address, phone number, job title, or e-mail address would not require an update to the TRIFID Signature Agreement, if the facility's TRIFID remains the same and has not changed its physical location.

A unique certifying official can certify pending forms for each form and/or establishment. In addition, the same certifying official may submit pending forms for all of the forms and/or establishments. After a preparer has completed a reporting form, the preparer identifies a certifying official. The preparer should select the appropriate certifying official for the form from a list of certifying officials associated with the facility. If the appropriate certifying official is not listed, TRI-MEweb will allow the preparer to add a certifying official.

EPA has developed a new certification component within the TRI-MEweb application that will allow a facility to prepare any reporting year TRI Form R or Form A Certification Statement and transition directly into the certification process without leaving the TRI-MEweb application.New RY 2012 TRI-ME-web users: There are two user roles involved in the reporting process to EPA of your TRI data; a preparer role and a certifying official role. Both of these TRI roles require creating/having a Central Data Exchange (CDX) user account and adding the TRI-MEweb application to their MyCDX profile. All new certifying officials will need to apply for an Electronic Signature Agreement (ESA) before they are allowed to certify any pending TRI forms. There are now two options to obtain an ESA. A single link will take both roles to open the TRI-MEweb application to a landing page to begin managing their facility accounts. All existing certifying officials: In prior reporting years, the certifying officials had to certify TRI forms in a separate module in their MyCDX account. The new certification module is now available within the TRI-MEweb application. This will require all our existing certifying officials to add their TRIFID(s) for their facilities into the application. All pre-approved certifying officials will be prompt upon logging into CDX and opening for the first time the TRI-MEweb application in the RY 2012 reporting season to proceed to the “Manage TRIFIDs” section under the “Certify” tab. All TRIFID(s) assigned in prior years should already be listed. The certifying official may add any missing TRIFIDs that will transmit TRI forms (without needing to process a new ESA for each) with only digitally signing a verification statement. If any TRI forms have been previously sent, they will appear under the “Pending Submission” subtab.

Senior management official means 'an official with management responsibility for the person or persons completing the report, or the manager of environmental programs for the facility or establishments, or for the corporation owning or operating the facility or establishments responsible for certifying similar reports under other environmental regulatory requirements' (40 CFR Section 372.3). Your facility must make the determination regarding who meets this definition.

The facility can use TRI-MEweb to indicate that your facility will no longer be reporting to TRI, or will not be submitting a form for one or more specific TRI-listed chemicals for the current reporting year. The facility can submit this information without filing a TRI form or certifying this information. In TRI-MEweb’s “Facilities Management” page, the “Not Reporting?” option can indicate if the facility will not be submitting one or more TRI reporting forms for the current reporting year.Alternatively, facilities may submit an e-mail to the TRI Data Processing Center (DPC). The e-mail should include the facility name; TRI facility identification number (TRIFID); facility address; technical contact name and telephone number; and, the reason why the facility is not submitting a TRI reporting form (e.g., failed to trigger a reporting threshold) or is no longer subject to TRI (e.g., facility closed, process modifications, production changes, product elimination or substitution). If the facility closed, the e-mail should also specify the date of closure.Contact information for the TRI DPC is available here: https://www.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts.

When ownership of a TRI-covered facility has changed, the certifying official should be an employee of the new owner for the purposes of TRI reporting. However, while the individual who is the owner or operator at the time of the July 1 reporting deadline is primarily responsible for reporting, any other individual who held the owner or operator role during the reporting year or before the reporting deadline for that reporting year may also be held liable. Thus, the certifying official might be employed by a previous owner or operator in some circumstances. For example, if the preparer of the Form R or Form A is employed by a previous owner or operator, then the certifying official is likely also employed by the previous owner or operator.

Report the latitude and longitude for a location central to the operations for which you are reporting. You may find this information on your NPDES permit. See the instructions for completing Form R for a detailed description on how to determine latitude and longitude from United States Geological Survey (USGS) maps of your facility location.

TRI-MEweb allows users to import data from the previous year into their current reporting year forms in TRI-MEweb. However, this function is not automatically performed by the application. When creating a new form, a preparer can select the “Import Data” option to pre-populate the prior year's reported data into the current year forms. The preparer must select the individual chemical name(s) to import and report to EPA for the current year form. Note that there are some limitations to the data that will be imported from the prior reporting year. Any “Not Applicable” checkboxes will not be checked on any section of the form. Section 8.8 of the Form R (catastrophic quantities) and the Schedule 1 (dioxin and dioxin-like compounds) will not be imported. Data pertaining to numeric basis estimates or rounding values will also not be imported.

Facility information, including name and contact information, must reflect the facility on December 31st of that reporting year. If information for the facility has changed, the preparer will need to update the information in TRI-MEweb. Navigate to the “Facilities Management” page in TRI-MEweb to choose the “Not Reporting” option for the facility and update the facility’s information. Preparers can also edit facility names while preparing a Form R or Form A Certification Statement, in the “Edit Facility” page. Alternatively, facilities may submit an e-mail to the TRI Data Processing Center. The e-mail should include: the facility name; TRI facility identification number (TRIFID); facility address; technical contact name and telephone number; and, the reason for the change (if necessary). Contact information for the TRI DPC is available at the following website: https://www.epa.gov/toxics-release-inventory-tri-program/forms/tri-program-contacts.

The facility should report the names used by the facility and parent company during that reporting year. When the owner/operator submits Form Rs for the next reporting year, these reports should reflect the names used by the facility and parent company during the new reporting year. (Note: the TRI Facility identification number will not change.)

A TRIFID is established when a facility owner or operator first submits a TRI Form R or Form A for a particular location. The facility retains this identification number even if the facility changes ownership, name, production processes, or NAICS codes. A facility owner or operator that needs to inquire whether the facility’s location has been assigned a TRIFID in past reporting years should contact the CDX Help Desk at (888) 890-1995 or the Regional TRI Coordinator, or search for the TRIFID or location on the Envirofacts Web site at: https://www3.epa.gov/enviro/. A facility owner or operator filing a first-time submission should request a TRIFID within TRI-MEweb, and a new TRIFID will be assigned automatically. To request a TRIFID, open TRI-MEweb, select the “My Facilities” tab, and click on the “Access/Add Facility” button. From this page, select the “I will be transmitting reports for a facility that has not previously transmitted TRI data” option, click “Next” and follow the instructions. Print the TRI-MEweb page that displays your new TRIFID and access key for future reporting.

No, the TRI identification number is established by the first Form R submitted by the facility. This identification number is retained by the facility even if the facility changes ownership and name. This identification number will stay with this facility as long as the facility location does not change. The TRI identification number remains the same even if the facility changes names, production processes, NAICS codes, etc.

For purposes of reporting on the Form R, the portion of the facility that was not sold during the year would maintain the TRI identification number originally assigned to the facility. The facility under new ownership would, however, indicate in Part I, Section 4.1 that the report is a first time submission by the facility. Once the reports have been submitted by the new facility, a new identification number will be assigned to the facility for use in subsequent years.

Since reporting year 1991, Form R contains a separate field for mailing addresses. The facility should enter its mailing address in this field if it is different from the facility's physical address. The facility must always enter its physical address in the appropriate Section of the Form R. EPA encourages facilities to notify EPA of address changes in advance.

Yes. This information is part of the facility identification section of the Form R and is intended for use in obtaining other information about the facility.

Yes. The public contact listed on Part I, Section 4.4 does not have to be located at the covered facility.

If a public contact is not identified, EPA will enter the technical contact into the database as a public contact. Thus, this person would receive public inquiries. You may, of course, use any person you choose to respond to such inquiries.

Yes. A facility can identify different technical contacts for different toxic chemicals or different establishments within the facility, preferably with one 'technical contact' listed on each form. Up to two names can be entered into the technical contact field on the database, but only one technical contact phone number can be listed.

The facility should report the latitude and longitude for a location central to the operations for which you are reporting. For a large facility, with several major points of activity, the facility should choose a location equidistant from all of the major activity points to determine the latitude and longitude.

A Dun & Bradstreet number, commonly referred to as a DUNS number, is a nine-digit, location-specific, business code assigned by Dun & Bradstreet. The DUNS number is a unique number that financially identifies individual businesses, while linking them with their corporate family structures. The Dun & Bradstreet number may be available from the facility’s treasurer or financial officer. Facilities can also contact Dun & Bradstreet directly at 800-234-3867 or https://www.dnb.com to obtain a facility’s number, or to create a new number if the facility does not currently have a number.Please note for Reporting Years 1991-2004, Section 4.6 of Part I requested a facility’s latitude and longitude. During this time, the DUNS number was located in Section 4.7 of Part I of the Forms.

EPA allows facilities to photocopy certain portions of a prior year's reporting form. However, EPA requires original signatures on each year's report. Prior year reports can and should be used as a basis or gauge for current year reporting, but should not be used as a substitute for current year reporting.

No. If a federal facility uses an EPCRA section 313 chemical in a manner that meets the criteria for a reporting exemption, that amount of the EPCRA section 313 chemical is exempt from threshold determinations and release and other waste management calculations. If a Form R report is required because of other, non-exempt uses, exempted quantities should not be included in calculations for Part II, section 4.1.

Yes. When determining the maximum amount on-site for Part II, Section 4 of the Form R, the facility must aggregate all nonexempt quantities of the toxic chemical. Toxic chemicals present in waste as well as in scrap metal are not exempt from reporting on the Form R and thus must be included when calculating the maximum amount on-site for Part II, Section 4.

To comply with EPCRA’s maximum amount on-site requirement, facilities should report in data element 4.1, Part II, of the Form R, the maximum quantity of the toxic chemical present at the facility during the reporting year. Facilities should include amounts of the chemical in storage tanks, process vessels, on-site shipping containers, and any other amount of the chemical at the facility. However, facilities do not have to count amounts of the toxic chemical that it disposed of in on-site landfills in previous years.

Yes. Covered facilities must indicate the maximum amount of the toxic chemical on-site at any one time during the reporting year. The maximum amount on-site includes raw materials, in-process materials, product inventory, and quantities present in wastes. Owners or operators must total all quantities of the nonexempt amounts of the toxic chemical present at the facility when completing Part II, Section 4.1 of the Form R.

When determining the maximum amount on-site for Part II, Section 4 of the Form R, only the reportable form of a chemical (e.g., aerosol) is to be considered. The quantity of the hydrochloric acid (aerosol) could be estimated by determining the volume of the air stream that could contain hydrochloric acid (aerosol), as well as the concentration of the acid in the air stream. In this case, the volume would be the interior volume of the equipment from where it is manufactured (e.g., boiler) to where it is released (e.g., stack). Keep in mind that the range codes used for the maximum quantity on-site are quite broad, and therefore, a precise calculation may not always be required. Facilities are also directed to refer to the Guidance for Reporting Sulfuric Acid (EPA-745-R-97-007; November 1997).

When determining the maximum amount on-site for Part II, Section 4 of the Form R, only the reportable form of a chemical (e.g., fume or dust) is to be considered.