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Indiana Department of Environmental Management

Pollution Prevention

Pollution Prevention > Toxics Release Inventory Toxics Release Inventory

The Toxics Release Inventory (TRI) is required under the federal Emergency Planning and Community Right to Know Act (EPCRA), Section 313. It comprises a publicly available database that contains detailed information on the 683 chemicals and chemical categories that thousands of industrial and other facilities manage through disposal or other releases, recycling, energy recovery, or treatment.

The primary function of the TRI is to provide information about potential chemical releases and environmental waste generated and managed by local facilities. Only facilities that meet certain criteria must report. If you are unsure if your company or facility needs to report, there is a TRI Threshold Screening Tool available on the U.S. EPA website to help determine if the report is required for your industry.

What does the Toxics Release Inventory provide?

TRI includes information about:

  • On-site releases and other disposal of toxic chemicals to air, surface water and land
  • On-site recycling, treatment and energy recovery associated with TRI chemicals
  • Off-site transfers of toxic chemicals from TRI facilities to other locations
  • Pollution prevention activities at facilities
  • Releases of lead, mercury, dioxin and other persistent, bioaccumulative and toxic (PBT) chemicals
  • Facilities in a variety of industry sectors (including manufacturing, metal mining, and electric power generation) and some federal facilities.

The Toxics Release Inventory dataset is available on the U.S. EPA website.

TRI: Who Must Report?

TRI Reporting Criteria

A facility must report to TRI if it:

  • Is in a specific industrial sector (e.g., manufacturing, mining, electric power generation);
  • Employs 10 or more full-time equivalent employees; and,
  • Manufactures or processes >25,000 lbs. of a TRI-listed chemical or otherwise uses >10,000 lbs. of a listed chemical in a given year.

Additionally, Persistent, Bioaccumulative, Toxic chemicals (PBTs) have lower reporting thresholds:

  • >100 lbs. of Aldrin, Lead, Lead Compounds, Methoxychlor, PACs, Pendimethalin, Tetrabromobisphenol A, Trifluralin
  • >10 lbs. of Benzo(g,h,i)perylene, Chlordane, Heptachlor, Hexachlorobenzene, Isodrin, Mercury, Mercury Compounds, Octachlorostyrene, Pentachlorobenzene, PCBs, Toxaphene
  • >0.1 grams of Dioxin and Dioxin-like Compounds

Please note that these are only general criteria. The U.S. EPA offers additional guidance on what chemicals and activities are subject to TRI reporting requirements.

Method of Reporting

The Electronic Reporting Rule, effective January 21, 2014, requires facilities to submit, revise, and withdraw non-trade secret TRI forms viaTRI-MEweb, U.S. EPA's online TRI reporting application. Training is available for basic and advanced TRI reporting concepts.

Facilities making Trade Secret Submissions will still be completed on paper forms, including TRI forms R and A.

Indiana participates in the TRI Data Exchange and the TRI Report that is submitted to the U.S. EPA will simultaneously be sent to Indiana, therefore no paper or electronic reports should be sent to the state. Indiana does not impose additional requirements on facilities beyond what is required by federal law and regulations.

Not All Pollution Generated By Manufacturers And Industry Is Reported On TRI. However, TRI Does Have Certain Advantages:
  1. It is multi-media. Facilities must report the amounts they release to air, land, water, and underground injection, and must report how much they send off-site;
  2. All quantities are reported in pounds. This reporting has an advantage compared to other databases, which often report releases as concentrations, or other databases which report releases by volume of waste. These measures are often impossible to convert into pounds;
  3. This means that it's relatively easy to obtain TRI data, that the data is well-known, and that it is becoming a "yardstick" for measuring progress in pollution prevention and waste generation.

To better understand Indiana TRI data, it is recommended that you contact IDEM's Office of Program Support toll-free at (800) 998-7901.

Common TRI Reporting Errors

Do Not Overlook Coincidental Manufacture!

The term manufacture also includes coincidental production of an EPCRA Section 313 chemical (e.g., as a byproduct or impurity) as a result of the manufacture, processing, otherwise use, or treatment of other chemical substances. In the case of coincidental production of an impurity (i.e., an EPCRA Section 313 chemical that remains in the product that is distributed in commerce), the de minimis ("concerning minimal things") exemption applies. The de minimis exemption does not apply to byproducts (e.g., an EPCRA Section 313 chemical that is separated from a process stream and further processed or disposed). Certain EPCRA Section 313 chemicals may be manufactured as a result of wastewater treatment or other treatment processes. For example, neutralization of acid wastewater can result in the coincidental manufacture of ammonium nitrate (solution), reportable as a member of the nitrate compound category.

A Coincidental Manufacture Example

Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system to neutralize an acidic wastewater stream containing nitric acid. The reaction of ammonia and nitric acid produces a solution of ammonium nitrate. Ammonium nitrate is reportable under the nitrate compounds category and is manufactured as a byproduct. If the ammonium nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the facility must report under the nitrate compounds category.

The aqueous ammonia is considered to be otherwise used and 10% of the total aqueous ammonia would be counted towards the 10,000-pound otherwise use threshold. Reports for releases of ammonia must also include 10% of the total aqueous ammonia from the solution of ammonium nitrate (see the qualifier for the ammonia listing).

The De Minimis Exemption

The de minimis exemption allows facilities to disregard certain minimal concentrations of chemicals in mixtures or other trade name products they process or otherwise use when making threshold determinations and release and other waste management calculations. The de minimis exemption does not apply to the manufacture of an EPCRA Section 313 chemical except if that EPCRA Section 313 chemical is manufactured as an impurity and remains in the product distributed in commerce, or if the EPCRA Section 313 chemical is imported below the appropriate de minimis level.

The de minimis exemption does not apply to a byproduct manufactured coincidentally as a result of manufacturing, processing, otherwise use, or any waste management activities. When determining whether the de minimis exemption applies to an EPCRA Section 313 chemical, the owner/operator should consider only the concentration of the EPCRA Section 313 chemical in mixtures and other trade name products in process streams in which the EPCRA Section 313 chemical is undergoing a reportable activity.

If the EPCRA Section 313 chemical in a process stream is manufactured as an impurity, imported, processed, or otherwise used and is below the appropriate de minimis concentration level, then the quantity of the EPCRA Section 313 chemical in that process stream does not have to be applied to threshold determinations nor included in release or other waste management determinations.

If an EPCRA Section 313 chemical in a process stream is below the appropriate de minimis level, all releases and other waste management activities associated with the EPCRA Section 313 chemical in that stream are exempt from EPCRA Section 313 reporting. It is possible to meet an activity (e.g., processing) threshold for an EPCRA Section 313 chemical on a facility-wide basis, but not be required to calculate releases or other waste management quantities associated with a particular process because that process involves only mixtures or other trade name products containing the EPCRA Section 313 chemical below the de minimis level.

Once an EPCRA Section 313 chemical concentration is at or above the appropriate de minimis level in the process stream, threshold determinations and release and other waste management calculations must be made, even if the chemical later falls below the de minimis level in the same process stream. Thus, all releases and other quantities managed as waste that occur after the de minimis level has been met or exceeded are subject to reporting. If an EPCRA Section 313 chemical in a mixture or other trade name product at or above de minimis is brought on-site, the de minimis exemption never applies.

De minimis levels for EPCRA Section 313 chemicals and chemical categories are set at concentration levels of either at 1% or 0.1%. The 0.1% de minimis levels are dictated by determinations made by the National Toxicology Program (NTP), Annual Report on Carcinogens, the International Agency for Research and Cancer (IARC) Monographs, or 29 CFR part 1910, subpart Z. Therefore, once a chemical's status under NTP, IARC, or 29 CFR part 1910, subpart Z indicates that the chemical is a carcinogen or potential carcinogen, the reporting facility may disregard levels of the chemical below the 0.1% de minimis concentration provided that the other criteria for the de minimis exemption are met.

De minimis levels for chemical categories apply to the total concentration of all chemicals in the category within a mixture, not the concentration of each individual category member within the mixture.

For more information about the Toxics Release Inventory, call the Compliance and Technical Assistance Program toll-free at (800) 988-7901.

TRI Reporting Resources

Additional Resources