­
1­
TRI
COMPLIANCE
ASSISTANCE
PAPER
for
Stakeholder
Outreach
I.
BACKGROUND
This
is
one
of
three
papers
which
describe
aspects
of
the
Toxics
Release
Inventory
(
TRI)
Program
and
raise
issues
for
stakeholder
input.
The
scope
of
each
paper
corresponds
to
a
phase
of
the
annual
TRI
reporting
cycle.
TRI
data
for
a
calendar
year
must
be
reported
to
EPA
each
year
by
July
1st
after
the
end
of
the
year.
Therefore,
reporting
years
are
the
same
as
calendar
years.
The
"
reporting
cycle"
begins
with
EPA's
compliance
assistance
(
CA)
activities,
including
the
development
of
its
reporting
forms
and
instructions
package.
A
courtesy
copy
of
the
reporting
forms
and
instructions
package
is
generally
mailed
to
facilities
in
March
of
each
year.
Once
EPA
receives
the
forms,
it
enters
the
data
from
the
forms
(
more
than
91,000
in
2000)
in
its
TRI
database.
After
entry
into
the
database,
EPA
runs
a
number
of
data
quality
checks
on
both
the
facility
identification
information
and
on
the
chemical­
specific
data.
After
the
data
entry
and
data
quality
steps
are
completed,
the
TRI
database
is
"
frozen"
for
analysis
and
development
of
data
products
for
release
to
the
public.
Generally,
EPA
announces
the
annual
release
of
the
TRI
data
by
holding
a
press
event
or
issuing
a
press
release,
and
simultaneously
notifying
a
wide
range
of
stakeholders.

The
first
background
paper
for
this
stakeholder
process
is
entitled
TRI
Data
Collection,
Processing
and
Management,
and
addresses
the
TRI
data
process
beginning
with
submission
of
the
forms
and
ending
at
the
data
"
freeze."
The
TRI
Data
Release
Issue
Paper
is
the
second
of
the
three;
it
discusses
TRI
data
products,
the
process
for
analyzing
and
releasing
the
TRI
data,
uses
of
the
data,
and
issues
and
considerations
associated
with
these
aspects
of
the
TRI
Program.
This
paper,
TRI
Compliance
Assistance
Paper,
which
addresses
TRI
CA
activities
is
the
third
paper.
TRI
CA
activities
are
carried
out
throughout
the
year
with
certain
activities
being
closely
aligned
with
the
reporting
cycle.

II.
TRI
COMPLIANCE
ASSISTANCE
ACTIVITIES
CA
includes
activities,
tools,
or
technical
assistance
that
provides
clear
and
consistent
information
to
help
the
regulated
community
understand
and
meet
its
environmental
regulatory
obligations.
By
definition,
CA
includes
finding
cost­
effective
ways
to
comply
with
regulations
and/
or
go
beyond
compliance
through
the
use
of
pollution
prevention,
environmental
management
systems
(
EMS),
and
innovative
technologies,
thus
improving
environmental
performance.
CA
is
a
core
function
of
the
TRI
Program
and
is
critical
to
helping
facilities
understand
regulatory
requirements,
and
the
submission
­
2­
of
accurate
and
high
quality
data.
The
key
parts
of
the
TRI
CA
program
include:

Reporting
Forms
&
Instructions
Every
year
the
TRI
Program
publishes
the
Toxic
Chemical
Release
Inventory
Reporting
Forms
&
Instructions
guidance
document
(
http://
www.
epa.
gov/
tri/
report/
rfi2001.
pdf)
to
provide
the
regulated
community
clear
and
concise
information
on
how
to
accurately
report
their
toxic
chemical
releases
and
other
waste
management
activities
to
EPA
pursuant
to
EPCRA
section
313.
This
document
is
key
in
providing
the
regulated
community
with
an
overview
of
TRI
reporting
requirements
and
updates
to
reporting
requirements
from
previous
reporting
years.

EPA
would
like
comments
on
the
TRI
Reporting
Forms
and
Instructions,
including
how
it
meets
the
regulated
communities'
information
and
reporting
needs,
and
suggestions
for
changes.

TRI
Made
Easy
(
TRI­
ME)/
TRI
Assistance
Library
TRI­
ME
(
http://
www.
epa.
gov/
tri/
report/
software/)
is
an
interactive,
intelligent,
user­
friendly
software
tool
that
guides
facilities
through
the
TRI
reporting
experience.
By
leading
prospective
reporters
through
a
series
of
logically
ordered
questions,
TRI­
ME
streamlines
the
user's
analysis
needed
to
determine
if
a
facility
must
complete
a
Form
R
report
or
Form
A
Certification
Statement
for
a
particular
chemical.
For
those
facilities
required
to
report,
the
software
provides
the
user
with
guidance
for
each
data
element
on
the
reporting
forms.
Additionally,
TRI­
ME
has
a
one­
stop
guidance
feature,
the
TRI
Assistance
Library
(
which
is
also
available
separately
(
http://
www.
epa.
gov/
tri/
report/
index.
htm#
guidance)
that
allows
users
to
do
keyword
searches
on
the
statutes,
regulations,
and
many
EPCRA
section
313
guidance
documents.
For
the
more
experienced
reporter,
TRI­
ME
allows
for
direct
data
entry
onto
electronic
versions
of
the
Form
R
and
Form
A
Certification
Statement.
TRI­
ME
checks
the
data
for
common
errors
and
then
prepares
the
forms,
on
paper,
magnetic
media,
or
electronically
over
the
Internet
via
the
EPA's
Central
Data
Exchange
(
CDX)
for
submission
to
EPA.
In
the
spring
of
2002,
EPA
distributed
more
than
23,000
copies
of
TRI­
ME
in
preparation
for
the
2001
reporting
year,
and
is
working
with
facilities
to
continue
to
improve
and
upgrade
this
compliance
tool
for
the
2002
reporting
year.
EPA
works
with
TRI­
ME
users
to
incorporate
comments
and
suggestions
on
how
subsequent
versions
can
be
made
more
helpful
and
easier
to
use.

EPA
would
like
comments
on
both
TRI­
ME
and
the
TRI
Assistance
Library
including
how
they
meet
the
regulated
communities'
reporting
and
information
needs,
and
suggestions
for
­
3­
changes.

Industry
Training
Workshops
The
TRI
Industry
Training
Workshops
(
provided
by
both
headquarters
and
the
EPA
regions)
(
http://
www.
epa.
gov/
tri/
report/
training/
index.
htm)
provide
the
regulated
community
with
live
training
on
the
TRI
regulatory
requirements,
guidance
on
how
to
complete
the
reporting
Form
R
and
the
Form
A
Certification
Statement,
as
well
as
an
update
on
new
program
requirements
and
changes.
In
preparation
for
the
2001
reporting
year,
there
were
approximately
75
one­
and
two­
day
workshops
held
throughout
the
US
and
attended
by
more
than
3,000
participants.
Certain
workshops
have
been
designed
for
specific
industry
sectors
(
e.
g.,
mining,
electric
utilities,
federal
facilities),
while
others
have
been
designed
for
the
reporting
of
specific
chemicals
(
e.
g.,
there
were
nine
lead
and
lead
compounds
workshops
which
had
more
than
700
participants
in
preparation
for
the
first
year
of
reporting
of
lead
and
lead
compounds
at
a
lower
threshold
in
2001).

The
intent
of
the
training
workshops
is
to
familiarize
facilities
with
the
reporting
obligations
they
may
have
under
section
313
of
EPCRA
and
section
6607
of
the
PPA.
Sessions
present
basic
reporting
requirements
and
a
variety
of
hands­
on
exercises
using
the
reporting
forms
and
supporting
materials
that
assist
participants
in
understanding
their
reporting
obligations.
Workshops
have
been
designed
for
persons
from
facilities
that
operate
in
the
industry
sectors
subject
to
EPCRA
Section
313
and
PPA
Section
6607,
persons
from
facilities
that
may
be
affected
by
the
recent
changes
to
the
EPCRA
section
313
and
PPA
section
6607
regulations,
and
persons
from
federal
facilities
and
private
sector
facilities
responsible
for
completing
EPCRA
section
313
reporting
form(
s),
and
consulting
firms
who
may
be
assisting
them.

EPA
would
like
comments
on
all
aspects
of
the
TRI
Industry
Training
Workshops,
including
how
they
meet
the
regulated
communities'
training
and
information
needs,
and
suggestions
for
changes.
In
addition,
EPA
would
like
comments
on
the
possibility
of
other
venues
for
providing
the
training,
such
as
developing
computer­
based
training
modules
or
privatizing
TRI
training
in
the
future.

Guidance
Documents
EPA
provides
industry­
specific,
chemical­
specific
and
general
guidance
to
assist
the
regulated
community
in
fulfilling
their
reporting
obligations
under
section
313
of
EPCRA
(
http://
www.
epa.
gov/
tri/
guide_
docs/
index.
htm).
Industry­
specific
guidance
provides
general
statutory
­
4­
and
regulatory
guidance
for
specific
industry
sectors,
in
addition
to
industry­
specific
reporting
recommendations
and
emission
factors.
Chemical­
specific
guidance
explains
the
EPCRA
Section
313
reporting
requirements,
and
provides
guidance
on
how
to
estimate
annual
releases
and
other
waste
management
quantities
of
a
particular
chemical
from
certain
industries
and
industrial
activities.

In
addition,
EPA
has
made
available
the
"
EPCRA
Section
313
Questions
and
Answers"
(
Q&
A)
document
(
http://
www.
epa.
gov/
tri/
guide_
docs/
1998/
1998qa.
pdf).
The
latest
version
of
this
document
was
published
in
1998
and
the
Agency
anticipates
releasing
an
updated
version
in
the
summer
of
2002.
This
document
has
been
developed
to
clarify
reporting
requirements
in
conjunction
with
the
statute
and
TRI
regulations,
including
topics
related
to
reporting
requirements,
exemptions,
Form
R
calculations
and
submissions,
supplier
notification,
trade
secrets,
and
policy
directives.
EPA
is
currently
in
the
process
of
updating
the
Q&
A
document.
EPA
has
also
developed
guidance
that
assists
facilities
with
specific
aspects
of
the
reporting
process
such
as
in
revising/
withdrawing
TRI
submissions
(
http://
www.
epa.
gov/
tri/
guide_
docs/
index.
htm#
general).

EPA
would
like
comments
on
all
guidance
documents,
including
how
they
meet
the
regulated
communities'
reporting
and
information
needs,
and
suggestions
for
changes.
Suggestions
and
comments
can
relate
to
specific
guidance
documents
(
e.
g.,
lead
and
lead
compounds
guidance
document,
metal
mining
guidance
document),
or
general
comments
on
the
overall
presentation
of
material
(
e.
g.,
understandable,
accessible,
appropriate
reference
information,
helpful,
etc.).

Interpretive
Guidance
(
IG)

Facilities
are
encouraged
to
and
do
write
to
the
TRI
Program
directly,
asking
site­
specific
questions
relating
to
TRI
reporting
requirements.
The
TRI
Program
responds
directly
to
facility
questions
through
a
formal
interpretive
guidance
(
IG)
process
established
by
the
TRI
Program.

EPA
would
like
comments
on
the
IG
process,
including
how
it
meets
the
regulated
communities'
information
needs,
and
suggestions
for
changes
(
e.
g.,
is
there
a
need
for
public
access
to
the
IG
database,
can
the
Q&
A
guidance
document
be
updated
immediately
with
IG
policy
decisions).

Compliance
Assistance
Outreach
Activities
At
both
EPA
headquarters
and
the
regional
offices,
the
TRI
Program
spends
a
significant
­
5­
amount
of
time
providing
outreach
to
assist
the
regulated
community
in
fulfilling
their
reporting
obligations
under
section
313
of
EPCRA.
Outreach
activities
(
e.
g.,
meetings,
conferences,
answering
phone
calls,
etc.)
vary
depending
upon
the
needs
of
the
region,
the
year
of
reporting
(
e.
g.,
PBT
chemical
reporting
for
the
first
time
in
RY
2000),
and
other
factors.
Depending
upon
the
needs
of
the
regulated
community,
EPA
works
with
both
individual
facilities
and
industry
groups
to
provided
CA
activities
fore
those
required
to
report
to
TRI.

EPA
would
like
comments
on
the
success
of
TRI
CA
outreach
activities,
including
how
they
meet
the
regulated
communities'
information
needs,
and
suggestions
for
changes
(
e.
g.,
are
there
other
outreach
activities
that
EPA
could
be
doing
to
enhance
CA?).

TRI
Website
In
2002,
the
TRI
Program
redesigned
(
http://
www.
epa.
gov/
tri/
site_
design.
htm)
the
EPA
TRI
website
(
http://
www.
epa.
gov/
tri)
in
an
effort
to
provide
easier
and
faster
access
to
TRI
information.
The
TRI
website
was
redesigned
to
simplify
access
to
TRI
information
for
both
the
public
and
the
regulated
community.
Depending
upon
the
topic,
CA
information
can
be
quickly
accessed
and
downloaded.
If
individuals
have
additional
questions,
contact
information
is
available
(
HQ,
EPA
regional
TRI
coordinators,
state
TRI
coordinators,
EPCRA
Hotline,
TRI
User
Support,
TRIDOCs).

EPA
would
like
comments
on
the
recently
redesigned
TRI
Website,
including
how
it
meets
users'
data
and
information
needs,
and
suggestions
for
changes.

EPCRA
Call
Center
(
EPCRA
Hotline)

The
TRI
Program
also
offers
reporting
assistance
to
the
regulated
community
through
a
telephone
hotline,
called
the
RCRA,
Superfund
and
EPCRA
Call
Center.
As
the
name
implies,
the
call
center
is
a
one­
stop
hotline
that
provides
guidance
on
a
variety
of
regulations.
Operated
Monday
­
Friday
from
9:
00am
to
5:
00pm
(
eastern
standard
time),
the
regulated
community
can
telephone
the
hotline
to
ask
questions
about
how
to
comply
with
EPCRA
section
313.
The
call
center
relies
on
written
guidance,
including
guidance
documents
prepared
by
EPA
and
letters
that
respond
to
regulatory
questions
from
the
regulated
community.
Each
year,
the
call
center
receives
about
30,000
questions.
A
separate
monthly
survey
conducted
by
the
contractor
who
manages
the
call
center
shows
high
satisfaction
with
the
call
center:
63%
of
respondents
indicated
that
they
were
strongly
satisfied;
25%
indicated
they
were
mostly
satisfied;
11%
indicated
they
were
satisfied;
1%
indicated
they
were
dissatisfied.
In
addition,
the
EPCRA
Call
Center
maintains
a
free
electronic
mailing
list
server
that
E­
­
6­
mails
EPCRA
related
documents/
information
as
they
are
published.

EPA
would
like
comments
on
the
EPCRA
Call
Center,
including
how
it
meets
users'
data
and
information
needs,
and
suggestions
for
changes.

TRI­
User
Support
(
TRI­
US)/
TRI
Documents
TRI­
US
provides
a
mechanism
by
which
individuals
who
have
questions
or
need
assistance
can
contact
EPA's
TRI
Program
directly
(
TRI­
US
can
be
contacted
at
(
202)
566­
0250
or
via
E­
mail
tri.
us@
epa.
gov).
In
addition,
all
TRI
Documents
can
be
obtained
free
by
calling
the
TRIDOCS
hotline
(
202)
564­
9554.

EPA
would
like
comments
on
both
TRI­
US
and
the
TRIDOCS
hotline,
including
how
they
meet
the
regulated
communities'
data
and
information
needs,
and
suggestions
for
changes.

III.
EVALUATION
In
general,
the
CA
activities
outlined
above
have
been
implemented
with
very
successful
results.
Many
activities
were
initiated
and
modified
in
response
to
requests
from
the
regulated
community
and
other
TRI
stakeholders.
In
EPA's
continued
effort
to
improve
CA
to
the
regulated
community,
the
TRI
Program
would
like
to
evaluate
the
effectiveness
of
current
CA
activities
with
respect
to
the
following:

C
Effectiveness
for
improving
data
quality;

C
Effectiveness
for
improving
compliance
with
section
313
of
EPCRA
(
40
CFR
§
372)
and
section
6607
of
the
PPA
(
i.
e.,
TRI
requirements);
C
Burden
reduction
(
i.
e.,
the
time/
effort
it
takes
the
regulated
community
to
fulfill
TRI
requirements);
and
C
Identification
of
gaps
for
new
CA
efforts
or
modification
of
existing
tools.

There
are
several
ways
which
this
evaluation
can
be
completed.
For
example:

C
Conduct
a
survey/
interview
of
users
of
the
TRI
CA
tools
and
CA
providers,
and
follow­
up
with
a
focus
group
meeting
going
over
the
results
and
generating
new
ideas;
C
Develop
a
correlation
between
TRI
data
and
the
implementation
of
CA
tools
(
e.
g.,
develop
a
histogram
between
trends
in
TRI
data
and
implementation
of
CA
tools);
and
­
7­
C
Evaluate
use/
demand
for
the
various
CA
tools
(
e.
g.,
number
and
types
of
callers
to
the
EPCRA
Call
Center).

Finally,
EPA
requests
general
comments
on
the
overall
successfulness
of
the
TRI
Program's
CA
activities.
For
example,
which
CA
activities
have
been
the
most
successful?
Which
have
been
the
least
successful,
and
why?
Can
the
Agency
more
effectively
use
enforcement
initiatives
or
targeting
to:
improve
overall
reporting;
encourage
reporting
from
non­
reporters;
and
receive
better
data
(
i.
e.,
focus
not
just
on
CA
activities
but
the
goal
of
better
data).
If
cuts
in
CA
activities
are
necessary,
which
CA
activities
should
EPA
continue
to
invest?
Which
CA
activities
should
EPA
disinvest,
and
why?
Compliance
assistance
is
targeted
and
delivered
both
by
EPA
headquarters
and
EPA
regions.
Is
this
successful?
Is
there
significant
variation
in
quality?
In
addition,
EPA
requests
comments
on
any
aspect
of
CA
that
may
have
not
been
mentioned
above.
For
example,
all
of
the
CA
activities
outlined
above
have
been
provided
by
the
TRI
Program.
Are
there
opportunities
to
develop
CA
activities
through
other
Agency
programs
or
efforts?
For
example,
the
TRI
Program
currently
provides
the
CA
information
that
it
develops
in
a
variety
of
ways,
including
through
the
program's
web
site,
EPA's
Compliance
Assistance
Centers,
on
EPA's
regions
websites,
through
requests
to
the
EPCRA
Call
Center,
TRI­
US,
and
TRI­
DOCS.
What
other
opportunities
exist
to
enhance
CA
for
the
regulated
community
reporting
to
TRI?
