­
1­
Stakeholder
Dialogue
Phase
II
­
Burden
Reduction
Options
EPA
initiated
a
Stakeholder
Dialogue
process
in
September
2002,
to
identify
improvements
to
the
Toxics
Release
Inventory
(
TRI)
and
to
develop
opportunities
to
reduce
the
burden
on
reporting
facilities.
A
primary
goal
of
this
effort
by
EPA
is
to
reduce
burden
associated
with
TRI
reporting
while
at
the
same
time
continuing
to
provide
valuable
information
to
the
public
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.

This
paper
discusses,
in
broad
overview,
a
number
of
burden
reduction
options
associated
with
TRI
reporting.
EPA
is
looking
to
more
fully
explore
these
broadly
outlined
options
with
the
intention
of
identifying
a
specific
burden
reduction
initiative
that
effectively
lessens
the
burden
on
facilities
but
at
the
same
time
ensures
that
TRI
continues
to
provide
communities
with
the
same
high
level
of
significant
chemical
release
and
other
waste
management
information.

While
the
Agency
is
genuinely
interested
in
pursuing
burden
reduction,
the
mere
inclusion
of
an
option
in
this
paper
does
not
mean
that
the
Agency
has
already
determined
the
option
to
be
technically,
practically,
and
legally
feasible.
Instead,
each
option
included
in
this
paper
is
intended
to
encourage
thoughtful
comment
that
develops
a
meaningful
burden
reduction
initiative
that
is
technically,
practically,
and
legally
feasible.

EPA
is
requesting
comment
on
the
following
options:

$
Higher
reporting
thresholds
for
small
businesses;

$
Higher
reporting
thresholds
for
a
category
of
facilities
or
class
of
chemicals
with
small
reportable
amounts;

$
Expanded
eligibility
requirements
for
the
Form
A
Certification
Statement,
through
either
a
higher
alternate
reporting
threshold,
a
higher
annual
reportable
amount
threshold,
and/
or
a
revised
definition
of
the
annual
reportable
amount
threshold.
This
option
could
be
combined
with
an
enhanced
Form
A
that
provides
range
estimates
for
a
subset
of
the
full
release
and
other
waste
management
information
included
on
the
Form
R;

$
A
new
short
form
for
facilities
that
are
able
to
certify
that
they
have
had
no
significant
change
in
releases
and
other
waste
management
quantities
relative
to
a
designated
baseline
year;

$
Use
of
range
reporting
for
Section
8
of
the
Form
R.

EPA
is
also
engaged
in
an
effort
to
improve
the
Toxics
Release
Inventory
­
Made
Easy
(
TRI­
ME)
software,
and
is
soliciting
comments
on
specific
enhancements
that
would
reduce
the
burden
of
TRI
reporting.
Finally,
EPA
is
soliciting
suggestions
for
any
other
options
that
could
reduce
burden,
while
continuing
to
provide
the
public
with
valuable
information.
­
2­
General
Background
on
TRI:

The
TRI
is
a
publicly
available
EPA
database
that
contains
information
on
toxic
chemical
releases
and
other
waste
management
activities
reported
annually
by
certain
covered
industry
groups
as
well
as
federal
facilities.
This
inventory
was
established
under
section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA)
of
1986
and
expanded
by
section
6607
of
the
Pollution
Prevention
Act
(
PPA)
of
1990.
Among
the
requirements
of
the
PPA
is
a
mandate
to
expand
TRI
to
include
additional
information
on
toxic
chemicals
in
waste
and
to
include
information
on
source
reduction
and
other
waste
management
methods.
Beginning
in
1991,
covered
facilities
were
required
to
report
quantities
of
TRI
chemicals
recycled,
combusted
for
energy
recovery,
and
treated
on­
and
off­
site.
Under
Executive
Orders
12856
and
13148,
federal
facilities
were
required
to
report
under
EPCRA
section
313
and
the
PPA
starting
with
the
1994
reporting
year.

Facilities
that
meet
all
of
the
following
criteria
are
required
to
report
to
TRI:

The
facility
has
10
or
more
full­
time
employee
equivalents
(
i.
e.,
a
total
of
20,000
hours
or
greater;
see
40
CFR
372.3);
and
The
facility
is
included
in
Standard
Industrial
Classification
(
SIC)
Codes
10
(
except
1011,
1081,
and
1094),
12
(
except
1241),
20B39,
4911
(
limited
to
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce),
4931
(
limited
to
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce),
4939
(
limited
to
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce),
4953
(
limited
to
facilities
regulated
under
RCRA
Subtitle
C,
42
U.
S.
C.
section
6921
et
seq.),
5169,
5171,
and
7389
(
limited
to
facilities
primarily
engaged
in
solvents
recovery
services
on
a
contract
or
fee
basis),
or,
under
Executive
Order
13148,
federal
facilities
regardless
of
their
SIC
code;
and
The
facility
manufactures
(
defined
to
include
importing),
processes,
or
otherwise
uses
any
EPCRA
section
313
(
TRI)
chemical
in
quantities
greater
than
the
established
threshold
in
the
course
of
a
calendar
year.

Facilities
that
meet
the
above
criteria
must
file
a
Form
R
report
or
in
some
cases,
may
submit
a
Form
A
Certification
Statement
(
see
below)
for
each
listed
toxic
chemical
for
which
the
criteria
are
met.
As
specified
in
EPCRA
section
313(
a),
the
report
for
any
calendar
year
must
be
submitted
on
or
before
July
1
of
the
following
year.
For
example,
reporting
year
2002
Form
Rs
should
have
been
postmarked
on
or
before
July
1,
2003.

The
list
of
toxic
chemicals
subject
to
TRI
can
be
found
at
40
CFR
section
372.65.
This
list
is
also
published
every
year
as
Table
II
in
the
current
version
of
the
Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions.
The
current
TRI
chemical
list
contains
582
individually
listed
­
3­
chemicals
and
30
chemical
categories
(
including
3
delimited
categories
containing
58
chemicals).
Under
EPCRA
section
313(
d)
chemicals
may
be
added
to
or
deleted
from
the
list
of
reportable
toxic
chemicals.
EPA
has
added
chemicals
to
the
TRI
list,
including
286
chemicals
and
chemical
categories
added
to
the
TRI
chemical
list
in
a
1994
rulemaking.
More
recently,
in
the
1999
persistent
bioaccumulative
toxic
(
PBT)
chemical
rulemaking
EPA
added
seven
chemicals
and
two
chemical
compound
categories,
including
dioxin
and
dioxin­
like
compounds,
to
the
list
of
toxic
chemicals
subject
to
TRI
reporting
under
EPCRA
section
313.

The
1999
PBT
chemical
rule
and
the
subsequent
2001
TRI
lead
rule
also
classified
chemicals
already
on
the
TRI
list
as
PBT
chemicals.
As
part
of
these
rulemakings,
the
Agency
lowered
the
reporting
thresholds
for
manufacture,
process,
and
otherwise
use
of
the
PBT
chemicals
listed
at
40
CFR
section
372.28.

As
discussed
above,
to
determine
if
compliance
with
EPCRA
section
313
is
required
a
facility
must
determine
if
it
meets
three
criteria.
With
regard
to
the
activity
threshold
criterion,
the
facility
must
determine
if
it
manufactures
(
defined
to
include
importing),
processes,
or
otherwise
uses
any
EPCRA
section
313
chemical
in
quantities
greater
than
the
established
threshold
in
the
course
of
a
calendar
year.
For
non­
PBT
chemicals
the
thresholds
for
manufacturing
and
processing
are
25,000
pounds
and
the
otherwise
use
threshold
for
non­
PBT
chemicals
is
10,000
pounds.
Section
313(
f)(
2)
of
the
statute
also
provides
the
Agency
with
the
authority
to
change
reporting
thresholds.
Pursuant
to
the
1999
and
2001
PBT
chemical
rules,
the
reporting
thresholds
for
those
TRI
chemicals
classified
as
PBT
chemicals
at
40
CFR
section
372.28
were
lowered.
Specifically,
for
those
listed
PBT
chemicals
found
to
be
persistent
and
bioaccumulative
the
reporting
thresholds
were
lowered
to
100
pounds
for
manufacture,
100
pounds
for
process,
and
100
pounds
for
otherwise
use.
The
thresholds
for
the
subset
of
PBT
chemicals
found
to
be
highly
bioaccumulative
and
highly
persistent
were
lowered
to
10
pounds
for
manufacture,
10
pounds
for
process,
and
10
pounds
for
otherwise
use.
For
dioxin
and
dioxin­
like
compounds
the
thresholds
were
lowered
to
0.1
gram
for
manufacture,
0.1
gram
for
process,
and
0.1
gram
for
otherwise
use.
Additionally,
for
those
chemicals
listed
at
section
372.28
the
1999
and
2001
PBT
chemical
rules
eliminated
the
de
minimis
exemption
(
except
for
supplier
notification
purposes),
range
reporting,
and
the
Form
A
Certification
option.

Note
that
any
revision
to
the
manufacture,
process,
or
otherwise
use
threshold
amounts
that
trigger
TRI
reporting
must
follow
the
requirement
of
section
313(
f)(
2)
that
"[
s]
uch
revised
threshold
shall
obtain
reporting
on
a
substantial
majority
of
total
releases
of
the
chemical
at
all
facilities
subject
to
the
requirements
of
this
section.
The
amounts
established
under
this
paragraph
may,
at
the
Administrator's
discretion,
be
based
on
classes
of
chemicals
or
categories
of
facilities."
42
U.
S.
C.
§
11023(
d)(
2).

With
regard
to
the
SIC
Code
criterion,
Congress
initially
required
the
manufacturing
sector
(
Standard
Industrial
Classification
(
SIC)
Codes
20
­
39)
to
report
to
TRI.
However,
at
EPCRA
section
313(
b),
Congress
provided
EPA
with
authority
to
add
or
remove
industry
sectors.
In
1997,
EPA
issued
a
final
rule
that
added
seven
industry
groups
to
the
list
of
facilities
subject
to
­
4­
the
reporting
requirements
of
section
313.
The
industry
groups
that
were
added
by
that
rule
are:
metal
mining;
coal
mining;
electric
utilities;
commercial
hazardous
waste
treatment,
chemicals
and
allied
products­
wholesale;
petroleum
bulk
terminals
and
plants­
wholesale;
and
solvent
recovery
services.

Under
the
employee
threshold
criterion,
EPCRA
section
313(
b)
provides
that
"[
t]
he
requirements
of
this
section
shall
apply
to
owners
or
operators
of
facilities
that
have
10
or
more
full­
time
employees.
.
.
."
There
is
no
provision
in
the
statute
that
allows
the
Agency
to
modify
the
employee
threshold.

History
of
Burden
Reduction
Efforts
in
the
TRI
Program:

Throughout
the
history
of
the
TRI
Program
the
Agency
has
implemented
measures
to
reduce
the
TRI
reporting
burden
on
the
regulated
community.
Through
a
range
of
compliance
assistance
activities,
such
as
the
Toxic
Chemical
Release
Inventory
Reporting
Forms
&
Instructions
(
which
is
published
and
mailed
every
year),
the
industry
training
workshops,
the
chemical­
specific
and
industry­
specific
guidance
documents,
and
the
EPCRA
Call
Center
(
a
call
hotline),
the
Agency
has
shown
a
commitment
to
enhancing
the
quality
and
consistency
of
reporting
and
assisting
those
facilities
that
must
comply
with
EPCRA
section
313.

EPA
has
also
tried
to
reduce
the
burden
associated
with
the
reporting
requirements.
Two
examples
are
the
Toxics
Release
Inventory
­
Made
Easy
(
TRI­
ME)
software
and
the
Form
A
Certification
Statement.

EPA's
award­
winning
Toxics
Release
Inventory
­
Made
Easy
software,
otherwise
known
as
"
TRI­
ME"
(
http://
www.
epa.
gov/
tri/
report/
trime/),
is
an
interactive,
intelligent,
user­
friendly
software
tool
that
guides
facilities
through
the
TRI
reporting
process.
By
leading
prospective
reporters
through
a
series
of
logically
ordered
questions,
TRI­
ME
facilitates
the
analysis
needed
to
determine
if
a
facility
must
complete
a
Form
R
report
for
a
particular
chemical.
For
those
facilities
required
to
report,
the
software
provides
guidance
for
each
data
element
on
the
Form
R.
TRI­
ME
also
has
a
one­
stop
guidance
feature,
the
TRI
Assistance
Library,
that
allows
keyword
searches
on
the
statutes,
regulations,
and
many
EPCRA
section
313
guidance
documents.
Finally,
TRI­
ME
checks
the
data
for
common
errors
and
then
prepares
the
forms,
on
paper,
on
magnetic
media,
or
electronically
sends
the
information
to
EPA
over
the
Internet
via
EPA's
Central
Data
Exchange
(
CDX).
In
the
spring
of
2003,
EPA
distributed
approximately
25,000
copies
of
TRI­
ME
in
preparation
for
the
2002
reporting
year
deadline
of
July
1,
2003.
Approximately
90%
of
the
roughly
84,000
Form
Rs
filed
in
2003
were
prepared
using
the
TRI­
ME
software.

In
1994,
as
a
means
to
reduce
burden,
EPA
established
through
rulemaking
the
Form
A
Certification
Statement
based
on
a
1
million
pound
alternate
threshold.
This
burden
reducing
measure
is
based
on
an
alternate
manufacture,
process,
or
otherwise
use
threshold
for
those
facilities
with
low
annual
reportable
amounts
of
a
listed
toxic
chemical.
Specifically,
a
facility
may
apply
an
alternate
manufacture,
process,
and
otherwise
use
threshold
of
1
million
pounds
per
year
­
5­
to
a
toxic
chemical
if
the
facility
has
an
annual
reportable
amount
of
that
toxic
chemical
not
exceeding
500
pounds
for
the
combined
total
quantity
released
at
the
facility,
treated
at
the
facility,
recovered
at
the
facility
as
a
result
of
recycle
operations,
combusted
for
the
purpose
of
energy
recovery
at
the
facility,
and
transferred
offBsite
for
recycling,
energy
recovery,
treatment,
and/
or
disposal.
This
combined
total
corresponds
to
the
quantity
of
the
toxic
chemical
in
production­
related
waste,
i.
e.,
the
sum
of
sections
8.1
through
and
including
section
8.7
on
the
Form
R.
This
burden
reducing
measure
was
established
in
response
to
petitions
received
from
the
U.
S.
Small
Business
Administration
Office
of
Advocacy
and
the
American
Feed
Industry
Association.

EPA
is
interested
in
continuing
to
reduce
reporting
burden
associated
with
TRI
reporting
obligations.
The
following
options
are
intended
to
promote
discussion
on
burden
reduction
opportunities
aimed
at
developing
an
initiative
that
both
provides
meaningful
burden
reduction
and
is
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.

Option
#
1
­
Higher
Reporting
Thresholds
for
Small
Businesses
Discussion
and
Questions:

One
option
for
reducing
burden
on
the
regulated
community
would
be
to
modify
the
reporting
thresholds
for
small
businesses.
Congress
has
recognized
through
the
Regulatory
Flexibility
Act
and
other
statutes
that
small
businesses
often
bear
a
disproportionate
burden
for
complying
with
regulatory
requirements.
Recognizing
this
potential
burden
and
the
possibility
that
smaller
businesses
may
have
smaller
reportable
amounts,
the
Agency
is
exploring
the
option
of
providing
small
businesses
with
higher
reporting
thresholds.

Note
that
the
statute
itself
already
contains
a
type
of
small
business
exemption
insofar
as
reporting
is
only
required
of
facilities
with
the
equivalent
of
10
or
more
full­
time
employees.
According
to
the
US
Census'
County
Business
Patterns,
40
­
50%
of
facilities
in
most
covered
industries
have
fewer
than
10
employees
(
http://
www.
census.
gov/
prod/
www/
abs/
cbptotal.
html).

Under
this
burden
reduction
option
consideration
would
have
to
be
given
to
the
specific
criteria
to
be
used
to
define
"
small
business"
as
well
as
the
actual
revised
reporting
thresholds
that
would
apply.
Small
business
might
be
defined
based
on
number
of
employees
(
e.
g.,
<
20),
annual
production
(
e.
g.,
<
$
5
million),
and/
or
SBA's
size
standards
for
different
industry
classifications
(
http://
www.
sba.
gov/
size).
Under
this
approach
to
burden
reduction
the
category
of
facilities
identified
would
not
have
to
report
to
TRI
if
the
revised,
higher
activity
thresholds
were
not
exceeded.

One
issue
raised
by
this
approach
involves
the
relationship
between
the
size
of
the
business
and
the
quantities
released
or
otherwise
managed
as
waste.
While
in
general,
small
facilities
may
have
less
waste
and
smaller
reportable
quantities
than
larger
ones,
not
all
small
facilities
will
have
proportionally
smaller
releases
and
other
waste
management
of
toxic
chemicals
than
large
­
6­
facilities.
Thus,
in
determining
the
revised
reporting
thresholds,
EPA
may
need
to
consider
factors
other
than
the
number
of
employees
or
production
level
at
the
facility.
In
addition,
large
companies
may
have
small
facilities
(
in
terms
of
employees
or
production
levels)
that
still
have
access
to
the
resources
of
the
parent
company.
In
other
words,
changes
in
thresholds
solely
based
on
number
of
employees
or
production
levels
at
the
facility
may
provide
burden
reduction
to
businesses
that
are
not
necessarily
small.
This
concern
could
be
addressed
by
providing
an
alternate
threshold
to
facilities
based
on
the
size
of
their
parent
company,
rather
than
the
facility
itself.
Appendix
A
provides
information
on
numbers
of
companies,
facilities,
and
forms
and
on
quantities
released
and
otherwise
managed
as
waste
for
various
definitions
of
"
small
business."
It
shows,
for
example,
that
providing
higher
reporting
thresholds
for
facilities
owned
by
a
parent
company
meeting
the
SBA
small
business
definition
for
its
industry
category
could
eliminate
reporting
by
31%
of
facilities
accounting
for
4%
of
total
releases
and
11%
of
total
productionrelated
waste.

Questions:
EPA
is
seeking
comment
on
whether
it
should
consider
raising
the
chemical
reporting
thresholds
for
small
businesses,
and
on
how
small
businesses
should
be
identified
for
purposes
of
this
option.
EPA
is
looking
for
comment
on
all
aspects
of
this
approach
to
burden
reduction.
Commenters
are
encouraged
to
include
data
and
other
supporting
information.
In
particular,
EPA
is
requesting
comment
on
the
specific
criteria
to
be
used
in
defining
the
"
small
business"
eligible
for
this
option
as
well
as
the
actual
revised
reporting
thresholds
that
would
apply.
With
regard
to
the
criteria
for
defining
small
businesses,
EPA
is
seeking
comment
on
whether
number
of
employees,
annual
production,
SBA
small
business
definition
by
industry
classification
(
http://
www.
sba.
gov/
size)
or
some
other
criterion
should
be
used.
EPA
is
requesting
that
comments
include
a
rationale
for
the
specific
small
business
definition
and
the
higher
reporting
thresholds
proposed.
EPA
is
also
interested
in
comment
on
whether
there
are
specific
sectors
or
categories
of
small
businesses
that
tend
to
have
large
releases
or
other
waste
management
quantities
relative
to
employment
or
production
levels
and
should
thus
not
be
eligible
for
this
option.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
affect
the
practical
utility
of
the
TRI
data,
and
the
complexity
of
the
reporting
requirements,
and
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.

Option
#
2
­
Higher
Reporting
Thresholds
for
a
Category
of
Facilities
or
Class
of
Chemicals
with
Small
Reportable
Amounts
Discussion
and
Questions:

One
option
for
reducing
burden
on
the
regulated
community
would
be
to
modify
the
reporting
thresholds
for
a
category
of
facilities
and/
or
class
of
chemicals
with
small
reportable
amounts.
The
focus
would
be
on
some
identifiable
category
of
facilities
that
generally
have
small
release
and
other
waste
management
quantities,
either
for
all
toxic
chemicals
or
for
some
class
of
toxic
chemicals.
­
7­
With
regard
to
a
category
of
facilities,
EPA
is
specifically
interested
in
whether
there
is
a
particular
industry
sector
(
or
some
other
category
of
facilities)
that
lends
itself
to
burden
reduction
through
higher
reporting
thresholds
because
the
majority
of
facilities
in
the
sector
or
category
do
not
report
significant
release
and
other
waste
management
quantities.
This
might
be
true
for
toxic
chemicals
generally,
or
only
for
a
specific
chemical
or
class
of
chemicals.
In
such
a
situation,
there
might
be
significant
burden
reduction
with
relatively
little
loss
of
information
by
providing
a
higher
reporting
threshold
for
the
specific
sector(
s)
or
sector/
chemical
combination(
s).
Similarly,
there
may
be
a
specific
class
of
chemicals
for
which
a
few
large
reporters
account
for
the
great
majority
of
releases
and
other
waste
management,
and
the
remaining
reporters
account
for
only
a
small
percent
of
the
national
totals.
In
such
a
case,
higher
reporting
thresholds
might
provide
significant
burden
reduction
with
relatively
little
loss
of
information.

Questions:
EPA
is
seeking
comment
on
whether
it
should
consider
raising
the
chemical
reporting
thresholds
for
a
specific
category
of
facilities
and/
or
a
specific
class
of
chemicals.
EPA
is
looking
for
comment
on
all
aspects
of
this
approach
to
burden
reduction.
Commenters
are
encouraged
to
include
data
and
other
supporting
information.
In
particular,
EPA
is
requesting
comment
on
the
specific
category
of
facilities
and/
or
class
of
chemicals
proposed
for
this
option
as
well
as
the
actual
revised
reporting
thresholds
that
would
apply
to
such
category
and/
or
class.
EPA
is
requesting
that
comments
include
a
rationale
for
the
specific
category
of
facilities
and/
or
class
of
chemicals
and
the
higher
reporting
thresholds
proposed.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
affect
the
practical
utility
of
the
TRI
data
and
the
complexity
of
reporting
requirements,
and
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.

Option
#
3
­
Expanding
Eligibility
for
the
Form
A
Certification
Statement
Discussion
and
Questions:

On
November
30,
1994,
EPA
published
a
final
rule
(
59
FR
61488)
that
provides
qualifying
facilities
an
alternate
threshold
of
1
million
pounds.
Eligible
facilities
wishing
to
take
advantage
of
this
option
may
certify
on
a
simplified
two­
page
form
referred
to
as
the
Form
A
Certification
Statement
that
they
meet
the
eligibility
requirements
and
they
then
do
not
have
to
submit
a
Form
R.
The
"
Alternate
Threshold
for
Facilities
with
Low
Annual
Reportable
Amounts,"
provides
facilities
otherwise
meeting
EPCRA
section
313
reporting
thresholds
but
that
do
not
exceed
500
pounds
for
the
total
"
annual
reportable
amount"
(
defined
below)
for
a
chemical,
an
optional
threshold
for
the
amounts
manufactured
or
processed
or
otherwise
used
of
1
million
pounds
for
that
chemical.
If
facilities
in
this
category
do
not
exceed
1
million
pounds
for
a
specific
toxic
chemical
they
may
certify
that
they
meet
the
Form
A
Certification
Statement
criteria
and
may
file
for
the
chemical
a
Form
A
Certification
Statement
in
lieu
of
a
Form
R.
The
total
"
annual
reportable
amount"
is
equal
to
the
combined
total
quantity
released
at
the
facility
(
including
disposed
within
the
facility),
treated
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
1
The
Form
A
Certification
Statement
does
not
include
information
on:
actual
quantities
of
TRI
chemicals
released
to
the
environment
or
transferred
off­
site,
information
on
releases
to
specific
environmental
media,
the
use
of
on­
site
waste
management
methods,
and
whether
the
TRI
chemical
is
manufactured,
processed
or
otherwise
used
at
the
facility.

­
8­
facility
to
off­
site
locations
for
the
purpose
of
recycling,
energy
recovery,
treatment,
and/
or
disposal.
This
combined
total
corresponds
to
the
quantity
of
the
toxic
chemical
in
productionrelated
waste,
i.
e.,
the
sum
of
sections
8.1
through
and
including
section
8.7
on
the
Form
R.

The
Form
A
Certification
Statement
provides
identifying
information
about
the
facility
and
indicates
that
the
total
production­
related
waste
for
the
specific
toxic
chemical
is
not
greater
than
500
pounds.
Detailed
breakdowns
of
releases
and
other
waste
management
activities,
including
specific
environmental
media,
and
specific
quantities,
which
are
included
on
the
Form
R,
are
not
included
in
the
Form
A
Certification
Statement.
1
Over
the
years,
commenters
have
questioned
whether
the
eligibility
criteria
for
the
Form
A
Certification
could
be
expanded
without
significantly
compromising
the
utility
of
the
TRI
data.
For
example,
the
eligibility
requirements
for
the
Form
A
could
be
expanded
by:
(
1)
raising
the
1
million
pound
alternate
threshold;
and/
or
(
2)
modifying
the
500
pound
"
annual
reportable
amount"
criterion
used
to
define
the
category
of
facilities
eligible
for
the
alternate
threshold.
Table
3
of
Appendix
B
of
this
paper
contains
several
alternative
"
annual
reportable
amount"
thresholds
(
i.
e.,
1,000
pounds,
2,000
pounds,
and
5,000
pounds)
and
for
each
alternative
provides
the
quantities
of
both
total
production­
related
waste
and
total
releases
nationwide
that
would
no
longer
be
reported
on
the
Form
R.
Another
way
to
modify
the
"
annual
reportable
amount"
criterion
is
to
change
the
waste
management
activities
included
in
this
criterion.
For
example,
the
annual
reportable
amount
could
be
modified
to
only
include
releases
but
not
the
other
waste
management
activities
(
e.
g.,
recycling,
energy
recovery).
Tables
4
and
5
in
Appendix
B
show
the
effects
of
using
alternate
definitions
of
the
annual
reportable
amount,
for
several
different
threshold
levels,
on
Form
A
eligibility
and
on
the
quantities
of
both
total
production­
related
waste
and
total
releases
nationwide
that
would
no
longer
be
reported
on
the
Form
R.
EPA
notes
that
changing
the
definition
of
annual
reportable
amount
in
this
way
might
affect
facility
choices
regarding
waste
generation
and
management,
and
this
could
have
implications
(
both
positive
and
negative)
for
pollution
prevention
efforts
at
facilities.

One
possibility
to
partially
compensate
for
the
detailed
information
that
would
no
longer
be
reported
on
Form
R
if
the
eligibility
requirements
for
the
Form
A
Certification
were
expanded
would
be
to
develop
a
modified
Form
A
Certification
Statement,
with
all
of
the
same
facilityspecific
identification
information,
but
that
also
includes
some
additional
range
estimate
information
on
releases
to
specific
environmental
media
and/
or
other
specific
waste
management
activities,
such
as
treatment,
recycling,
and
energy
recovery.
This
could
enhance
the
utility
of
the
Form
A,
by
providing
more
detailed
information
on
the
releases
and
other
waste
management
­
9­
activities
of
eligible
facilities
while
still
not
requiring
the
level
of
detail
required
on
the
Form
R.

Finally,
in
considering
burden
reduction
options
associated
with
the
Form
A
Certification
Statement,
one
should
note
that
the
Form
A
is
underutilized
by
reporting
facilities
under
the
current
eligibility
requirements.
EPA
has
estimated
that
there
are
potentially
4,633
facilities
that
are
eligible
to
use
this
1
million
pound
alternate
threshold
but
that
nevertheless,
file
a
Form
R
instead.
If
those
facilities
were
to
fully
utilize
the
Form
A
Certification
Statement
there
could
potentially
be
an
additional
10,580
Form
A
Certification
Statements
filed
rather
than
Form
Rs.
(
see
Appendix
B).
With
full
use
of
the
Form
A
option
under
the
current
500
pound
threshold,
about
24%
of
reports
would
be
eligible
for
Form
A,
and
about
45%
of
all
facilities
could
use
Form
A
for
at
least
one
report.
EPA
recognizes
that
there
are
several
reasons
why
eligible
facilities
might
not
choose
to
use
Form
A.
Some
facilities
may
wish
to
provide
information
to
the
public
beyond
what
is
required,
either
out
of
a
sense
of
environmental
responsibility
or
in
order
to
show
that
they
have
minimal
releases.
Other
facilities
may
find
that
the
Form
A
does
not
really
save
much
burden
because
they
have
to
undertake
detailed
calculations
to
determine
eligibility.
However,
there
may
also
be
facilities
that
are
not
using
Form
A
simply
because
they
are
not
aware
of
this
option,
or
do
not
realize
that
they
could
save
significant
burden
by
using
it.
There
may
also
be
"
barriers"
to
the
use
of
Form
A
that
have
not
been
readily
apparent
to
EPA
in
the
past.
EPA
is
considering
ways
to
further
increase
awareness
of
Form
A
and
its
burden
reduction
potential,
and
to
remove
barriers
to
its
use,
where
appropriate.
Of
course,
EPA
welcomes
facilities
providing
full
information
on
Form
R,
even
when
eligible
to
file
the
Form
A
Certification
Statement
instead.

Questions:
EPA
would
like
comment
on
whether
it
should
revise
the
1
million
pound
alternate
threshold
and
if
so,
to
what
amount.
Commenters
should
explain
the
basis
of
their
proposed
revisions.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
how
they
would
affect
the
practical
utility
of
the
TRI
data,
and
how
they
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.
EPA
is
looking
for
comment
on
all
aspects
of
this
approach
to
modifying
Form
A
Certification
Statement
eligibility
and
specifically
requests
data
and
other
supporting
information
for
modifying
the
1
million
pound
alternate
threshold.

EPA
would
also
like
comment
on
whether
it
should
revise
the
500
pound
total
annual
reportable
amount
eligibility
threshold
and
what
the
revised
threshold
should
be
for
Form
A.
Commenters
should
explain
the
basis
of
their
proposed
revisions.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
how
they
would
affect
the
practical
utility
of
the
TRI
data,
and
how
they
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.
EPA
is
looking
for
comment
on
all
aspects
of
this
approach
to
modifying
Form
A
Certification
Statement
eligibility
and
specifically
requests
data
and
other
supporting
information
for
modifying
the
total
annual
reportable
amount.

EPA
would
also
like
comment
on
whether
it
should
change
the
basis
of
the
eligibility
threshold
from
the
current
"
total
annual
reportable
amount"
to
releases
only
or
to
a
combination
of
­
10­
quantity
released
and
some
but
not
all
of
the
other
waste
management
quantities.
Commenters
should
explain
the
basis
of
their
proposed
revisions.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
how
they
would
affect
the
practical
utility
of
the
TRI
data,
and
how
they
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.
EPA
is
looking
for
comment
on
all
aspects
of
this
approach
to
modifying
Form
A
Certification
Statement
eligibility
and
specifically
requests
data
and
other
supporting
information
for
excluding
certain
waste
management
activities
from
the
total
annual
reportable
amount.
In
particular,
EPA
is
interested
in
comment
on
how
modification
to
the
waste
management
activities
included
in
the
total
annual
reportable
amount
might
affect
facility
choices
regarding
waste
generation
and
management
and
impact
pollution
prevention
efforts
at
facilities.

EPA
would
also
like
comment
on
whether
it
should
develop
an
enhanced
Form
A
Certification
Statement
that
includes
some
additional
information
on
specific
environmental
media
or
waste
management
activities
in
the
form
of
range
estimates.
Commenters
should
indicate
what
specific
data
they
would
include
on
the
Form
A,
including
specific
ranges
if
range
reporting
is
used.
EPA
would
also
like
comment
on
the
additional
burden
of
range
reporting
to
those
facilities
that
presently
qualify
for
the
current
Form
A
Certification
Statement.
Commenters
should
explain
the
basis
of
their
proposed
revisions.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
how
they
would
affect
the
practical
utility
of
the
TRI
data,
and
how
they
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.
EPA
is
looking
for
comment
on
all
aspects
of
this
approach
to
modifying
the
Form
A
Certification
Statement
and
specifically
requests
data
and
other
supporting
information
for
developing
an
enhanced
Form
A
Certification
Statement
that
includes
additional
waste
management
information
in
the
form
of
range
estimates.

Further,
EPA
is
also
interested
in
receiving
comment
on
ways
to
increase
awareness
of
the
option
to
use
the
Form
A
Certification
Statement
and
its
burden
reduction
potential
(
e.
g.,
through
outreach
efforts).
In
addition,
the
Agency
would
like
comment
on
why
some
facilities
that
are
eligible
to
use
the
Form
A
Certification
Statement
are
not
currently
doing
so
and
any
suggestions
for
eliminating
barriers
to
its
use.

Option
#
4
­
Creating
a
new,
"
No
Significant
Change"
Certification
Statement
Discussion
and
Questions:

Another
burden
reduction
option
involves
the
development
of
a
new
form
that
would
allow
facilities
to
certify
to
"
no
significant
change"
in
TRI
reporting
as
measured
against
a
designated
baseline
year.
Facilities
that
qualify
for
this
no
significant
change
certification
would
be
relieved
of
their
obligation
to
complete
either
the
Form
R
or
Form
A
Certification
Statement,
but
instead,
would
file
a
certification
statement
that
there
has
been
no
significant
change
at
the
facility.
Submission
of
the
no
significant
change
certification
would
result
in
EPA
posting
the
same
information
provided
by
the
facility
to
EPA
in
the
designated
baseline
year
for
the
year(
s)
in
which
­
11­
the
facility
submitted
a
no
significant
change
statement.

The
baseline
year
could
be
selected
by
EPA
and
could
apply
to
all
facilities
reporting
to
TRI
that
year
and
thereafter,
for
a
specified
number
of
years.
Because
a
submission
of
no
significant
change
would
result
in
the
posting
of
the
facility's
baseline
year
data,
facilities
that
are
new
to
TRI
would
have
to
wait
until
their
second
year
of
reporting
to
consider
using
this
no
significant
change
certification
statement
option.

The
criteria
for
determining
which
facilities
could
qualify
for
this
option
could
be
based
on
a
specific
percentage
change
in
total
releases,
a
specific
percentage
change
in
total
quantity
managed
as
waste,
a
specific
percentage
change
in
total
production,
a
specific
set
of
qualitative
criteria
(
e.
g.,
"
no
significant
change
in
material
inputs,
production
processes,
pollution
prevention,
and
waste
handling
or
management
practices"),
or
some
combination
of
these.
In
addition,
a
specified
absolute
quantity
could
be
used
to
define
a
threshold
below
which
any
change
in
releases
or
total
quantity
managed
as
waste
would
be
considered
not
significant,
regardless
of
its
percentage
relative
to
the
designated
baseline
year.
For
example,
changes
in
releases
or
total
quantity
managed
as
waste
of
no
greater
than
100
pounds
for
non­
PBT
chemicals
could
be
eligible
for
this
option
regardless
of
whether
such
a
change
represented
more
than
the
specified
percentage.
Conversely,
a
specified
absolute
quantity
could
also
be
used
to
define
a
threshold
above
which
any
change
in
releases
or
total
quantity
managed
as
waste
would
be
considered
significant,
regardless
of
its
percentage
relative
to
the
designated
baseline
year.

Note
that
the
burden
reduction
associated
with
this
option,
will
depend
significantly
on
how
the
option
is
structured.
For
example,
if
facilities
are
required
to
calculate
releases
or
quantities
associated
with
other
waste
management
activities,
there
may
not
be
significant
burden
reduction,
though
the
option
to
define
any
change
below
a
specified
threshold
as
non­
significant
might
still
reduce
burden
for
facilities
with
very
small
quantities.
Conversely,
a
qualitative
criterion
may
provide
significant
burden
reduction
but
less
certainty
that
the
facility
really
has
experienced
no
significant
change.
Further,
the
actual
completion
of
the
Form
R
or
Form
A
Certification
Statement
under
circumstances
where
no
significant
change
has
taken
place
may
not
entail
significant
burden
under
the
current
requirements.
For
example,
the
load
module
in
TRI­
ME
enables
facilities
to
populate
almost
every
data
element
on
the
current
year
form
with
data
from
the
prior
year.
The
facility
can
then
alter
those
data
elements,
if
there
are
any,
that
may
have
changed
under
circumstances
where
there
was
no
significant
change
at
the
facility.
However,
one
possible
advantage
of
the
no
significant
change
certification
might
be
that
it
would
allow
the
public
to
note
the
facility's
certification
to
"
no
significant
change"
to
the
reportable
amounts
instead
of
having
to
compare,
across
reporting
years,
each
of
the
Form
R
data
elements
reported
by
the
facility.

Questions:
EPA
would
like
comment
on
whether
it
should
consider
the
development
of
a
new
form
that
would
allow
facilities
to
certify
to
"
no
significant
change"
in
TRI
reporting
as
measured
against
a
designated
baseline
year.
EPA
is
seeking
comment
on
how
to
designate
the
baseline
year
and
on
how
many
consecutive
years
a
facility
should
be
permitted
to
use
this
­
12­
option
before
being
required
to
establish
a
new
baseline
year
by
filing
a
new
Form
R.
EPA
is
looking
for
comment
on
all
aspects
of
a
"
no
significant
change"
certification
and
specifically
requests
data
and
other
supporting
information
for
determining
the
baseline
year
and
the
number
of
consecutive
years
permitted
between
baseline
years.

Further,
EPA
is
requesting
comment
on
the
eligibility
criteria
that
should
be
used
to
determine
when
no
significant
change
has
taken
place
at
a
facility.
EPA
is
looking
for
comment
on
whether
a
specific
percentage
change
in
total
releases,
a
specific
percentage
change
in
total
quantity
managed
as
waste,
a
specific
percentage
change
in
total
production,
a
specific
set
of
qualitative
criteria
(
e.
g.,
"
no
significant
change
in
material
inputs,
production
processes,
pollution
prevention,
and
waste
handling
or
management
practices"),
some
combination
of
these,
or
some
other
criteria
should
serve
as
the
criteria
for
determining
when
no
significant
change
has
taken
place.
EPA
is
also
interested
in
suggestions
regarding
what
documentation
would
be
needed
for
facilities
to
demonstrate
compliance
with
the
eligibility
criteria,
whether
qualitative
or
quantitative.
Further,
EPA
is
asking
for
comment
on
whether
the
criteria
should
also
include
a
specified
quantity
such
as
100
pounds
for
non­
PBT
chemicals
that
would
be
considered
not
significant
regardless
of
whether
such
a
change
represented
more
than
the
specified
percentage
change
between
the
year
under
consideration
and
the
designated
baseline
year.
EPA
is
also
requesting
comment
on
whether
the
criteria
should
include
a
specified
quantity
that
would
always
be
considered
a
significant
change,
regardless
of
the
quantity
in
the
baseline
year.
EPA
also
requests
comment
on
how
this
option
should
be
structured
to
most
appropriately
balance
burden
reduction
while
continuing
to
maintain
the
practical
utility
of
the
data.
EPA
also
requests
comment
on
whether
the
current
option
to
use
TRI­
ME
to
initially
populate
the
Form
R
with
the
previous
year's
data
affects
the
value
and
potential
burden
reduction
associated
with
this
option.
Finally,
EPA
requests
comment
on
whether
this
option
should
be
available
for
PBT
chemicals,
and
if
so,
what
the
criteria
for
"
no
significant
change"
for
these
chemicals
should
be.

Commenters
should
explain
the
basis
of
their
proposed
revisions.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
how
they
would
affect
the
practical
utility
of
the
TRI
data,
and
how
they
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.
EPA
is
looking
for
comment
on
all
aspects
of
a
"
no
significant
change"
certification
and
specifically
requests
data
and
other
supporting
information
for
the
criteria
that
could
be
used
to
determine
when
no
significant
change
has
taken
place
at
the
facility.

Option
#
5
­
Use
of
Range
Reporting
for
Section
8
of
the
Form
R
Discussion
and
Questions:

EPA
currently
allows
range
reporting
for
non­
PBT
chemicals
in
Sections
5
and
6
of
the
Form
R.
For
each
of
the
specific
data
elements
in
these
two
sections,
if
the
reportable
amount
is
less
than
1,000
pounds,
the
amount
may
be
reported
either
as
an
estimate
or
by
using
the
following
range
­
13­
codes:
A
(
1
­
10
pounds);
B
(
11
­
499
pounds);
or
C
(
500
­
999
pounds).
For
releases
to
any
medium
that
amount
to
1,000
pounds
or
more
for
the
year,
the
facility
must
provide
an
estimate
in
pounds.
Range
reporting
is
not
currently
employed
in
Section
8
of
the
Form,
which
is
derived
from
the
information
in
Sections
5
and
6.
Facilities
reporting
in
ranges
in
Sections
5
and
6
still
must
report
numbers
for
the
same
information
in
calculating
the
data
items
in
Section
8.
Under
this
option,
EPA
would
apply
the
current
use
of
range
reporting
in
Sections
5
and
6
of
the
Form
R
to
Section
8
of
the
Form
R.

Questions:
EPA
would
like
comment
on
whether
it
should
allow
for
use
of
range
reporting
in
Section
8
of
the
Form
R.
Specifically,
should
EPA
apply
the
current
use
of
range
reporting
in
Sections
5
and
6
of
the
Form
R
to
Section
8
of
the
Form
R.
Commenters
should
explain
the
basis
of
their
position
on
this
option.
Commenters
are
also
encouraged
to
discuss
how
this
option
would
provide
meaningful
burden
reduction,
how
it
would
affect
the
practical
utility
of
the
TRI
data,
and
how
it
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.
EPA
is
looking
for
comment
on
all
aspects
of
applying
range
reporting
to
Section
8
and
specifically
requests
data
and
other
supporting
information
on
whether
range
codes
should
be
used
in
Section
8.

Option
#
6
­
Other
Options
for
Burden
Reduction
Discussion
and
Questions:

EPA
considered
other
options
which
it
decided
not
to
include
as
specific
options
in
this
paper.
For
example,
EPA
considered
an
option
that
would
afford
reporting
relief
to
those
facilities
that
report
zero
releases
on
their
Form
R
reports.
The
Agency
decided
not
to
include
this
approach
as
one
of
the
specific
options
in
this
stakeholder
dialogue
paper
because
EPA
questions
whether
such
an
approach
would
result
in
significant
burden
reduction
given
that
facilities
would
first
have
to
determine
that
there
were
no
releases
in
order
to
qualify.
Further,
EPA
is
concerned
that
relief
from
reporting
based
solely
on
zero
releases
would
result
in
the
loss
of
reporting
on
other
waste
management
activities
taking
place
at
the
facilities.
The
Agency
believes
that
some
of
the
other
options
discussed
above
may
provide
more
meaningful
burden
relief
to
facilities
that
report
zero
releases,
while
better
maintaining
the
practical
utility
of
the
data.
However,
EPA
will
consider
comments
received
on
an
approach
to
burden
reduction
based
on
zero
releases.
The
Agency
is
particularly
interested
in
how
such
an
approach
reduces
burden
and
whether
there
would
be
a
significant
loss
in
reporting
of
other
waste
management
activities.

EPA
also
considered
but
decided
not
to
include
alternate
year
reporting
as
a
specific
option
in
this
paper.
The
Agency
decided
not
to
include
this
approach
because
we
believe
that
the
"
no
significant
change"
option
discussed
above
may
be
a
better
way
of
providing
a
similar
form
of
burden
reduction.
Like
the
zero
releasers
option,
while
the
Agency
decided
not
to
include
alternate
year
reporting
as
a
specific
option
in
this
paper,
the
Agency
will
consider
comments
received
on
such
an
approach
to
burden
reduction.
­
14­
Finally,
some
reporters
have
indicated
that
updates
to
guidance
documents
have
required
facilities
to
devote
additional
time
to
training
and
program
familiarization,
which
contributes
to
the
overall
burden
of
complying
with
TRI.
EPA
is
interested
in
how
it
can
best
address
these
concerns.

Questions:
EPA
would
like
comment
on
any
other
burden
reduction
options
in
addition
to
those
discussed
in
this
stakeholder
dialogue
paper.
Commenters
should
explain
the
basis
of
their
proposed
revisions.
Commenters
are
also
encouraged
to
discuss
how
the
proposed
revisions
would
provide
meaningful
burden
reduction,
how
they
would
affect
the
practical
utility
of
the
TRI
data,
and
how
they
would
be
consistent
with
the
goals
and
statutory
requirements
of
the
TRI
program.

Request
for
Comment
on
the
Ongoing
Toxics
Release
Inventory
­
Made
Easy
(
TRI­
ME)
Software
Initiative;
Enhancing
the
TRI­
ME
Software
Discussion
and
Questions:

As
noted
above,
one
of
EPA's
burden
reduction
initiatives
is
its
award­
winning
TRI­
ME
software.
Preliminary
statistics
indicate
that
about
90%
of
the
2003
reports
were
prepared
using
TRI­
ME.
As
part
of
EPA's
on­
going
commitment
to
enhance
and
improve
TRI­
ME,
EPA
is
soliciting
feedback
on
the
strengths
and
weaknesses
of
the
current
software.
EPA
will
continue
to
update
and
enhance
the
TRI­
ME
software.

A
number
of
enhancements
could
potentially
be
added
to
the
TRI­
ME
software.
For
example,
release
estimation
tools
could
be
incorporated
into
the
software.
Enhanced
validation
logic
could
also
be
included
in
the
software
making
it
less
likely
for
errors
to
be
submitted
to
EPA.
In
addition,
interfaces
between
TRI­
ME
and
facility
spreadsheets
and
databases
could
be
included,
enabling
facilities
to
load
into
the
threshold
determination
portion
of
TRI­
ME
large
amounts
of
chemical
information
about
the
mixtures
and
materials
used
at
the
facility.
Another
possibility
is
that
the
submission
module
in
TRI­
ME,
which
allows
facilities
to
submit
their
forms
electronically
to
EPA
over
the
Internet
via
CDX,
could
be
extended
to
allow
simultaneous
submission
to
the
appropriate
State
agency
as
required
by
the
statute.
Some
of
these
enhancements
would
be
technically
challenging
and
demand
significant
resources.
EPA
is
still
exploring
how
they
could
be
implemented.

Questions:
EPA
would
like
comment
on
ways
to
improve
the
TRI­
ME
software.
EPA
is
requesting
that
commenters
describe
both
the
recommended
improvement
and
its
burden
reduction
potential.
EPA
would
specifically
like
comment
on
the
enhancements
discussed
above,
as
well
as
any
others
that
commenters
may
wish
to
suggest.
Commenters
should
describe,
in
detail,
how
they
would
like
the
enhancement
to
work
and
explain
how
it
would
reduce
the
burden
associated
with
reporting,
or
improve
the
accuracy
of
the
data.
EPA
also
requests
comment
on
any
problems
or
limitations
users
have
encountered
with
the
current
software,
along
with
specific
suggestions
for
addressing
them.
­
15­
Appendix
A
SUMMARY
STATISTICS
FOR
TRI
REPORTERS
(
RY
2001)

Facilities
with
<
20
employees1
Parent
Companies
with
<
20
employees1
Facilities
with
<
50
employees1
Parent
Companies
with
<
50
employees1
Estimated
Number2
Percent
of
Total3
Estimated
Number2
Percent
of
Total3
Estimated
Number2
Percent
of
Total3
Estimated
Number2
Percent
of
Total3
Facilities
2,924
12%
826
3%
6,947
28%
2,598
10%

Parent
Companies
1,754
17%
696
7%
4,194
41%
2,412
24%

Form
R's
9,605
12%
1,721
2%
19,686
24%
4,962
6%

Form
A's
2,024
16%
551
4%
4,884
40%
1,786
15%

Total
On­
Site
Releases
398,766,614
7%
19,055,036
0.3%
597,442,353
11%
45,852,223
0.8%

Total
Production
Related
Waste
2,982,491,462
11%
275,091,086
1%
4,487,844,194
17%
494,335,475
2%

Average
Revenue
of
Parent
$
1,952,950,969
$
6,152,320
$
953,364,481
$
6,842,023
Median
Revenue
of
Parent
$
15,000,000
$
1,300,000
$
7,096,453
$
2,700,000
1
When
employment
was
shown
in
D&
B
as
"
0"
it
was
classified
as
<
20
or
<
50
employees.

2
Derived
by
multiplying
the
percentage
(
based
on
non­
missing
values)
*
estimated
total
number.

3
The
percentage
is
based
on
non­
missing
values
only.
­
16­

SUMMARY
STATISTICS
FOR
TRI
REPORTERS
(
RY
2001)

Facilities
with
<
100
employees1
Parent
Companies
with
<
100
employees1
Small
Parent
Companies
(
Based
on
SBA
Definitions)
Not
Small
Parent
Companies
(
Based
on
SBA
Definitions)

Estimated
Number2
Percent
of
Total3
Estimated
Number2
Percent
of
Total3
Estimated
Number2
Percent
of
Total3
Estimated
Number2
Percent
of
Total3
Facilities
10,938
44%
4,321
17%
7,674
31%
17,222
69%

Parent
Companies
5,468
54%
3,956
39%
6,493
64%
3,629
36%

Form
R's
30,816
37%
8,639
10%
16,239
20%
66,979
80%

Form
A's
7,056
57%
2,749
22%
4,207
34%
8,088
66%

Total
On­
Site
Releases
991,240,140
18%
71,684,870
1.3%
209,042,984
4%
5,371,285,698
96.3%

Total
Production
Related
Waste
7,752,073,997
29%
1,574,936,115
6%
2,880,103,010
11%
23,855,934,292
89%

Average
Revenue
of
Parent
$
710,441,263
$
9,202,578
$
22,923,844
$
1,691,884,055
Median
Revenue
of
Parent
$
9,150,000
$
4,500,000
$
9,369,339
$
197,000,000
1
When
employment
was
shown
in
D&
B
as
"
0"
it
was
classified
as
<
100
employees.

2
Derived
by
multiplying
the
percentage
(
based
on
non­
missing
values)
*
estimated
total
number.

3
The
percentage
is
based
on
non­
missing
values
only.
­
17­
Appendix
B
The
tables
below
present
impacts
from
increasing
the
levels
of
the
production­
related
waste
threshold
for
Form
A
Certification
Statement
eligibility.
These
analyses
are
based
on
data
received
for
TRI
reporting
year
2001
(
submitted
in
calendar
year
2002).
Table
1
presents
the
2001
use
and
potential
use
of
the
Form
A.
Table
2
presents
the
estimated
potential
impacts
on
reporting
facilities
when
the
production­
related
waste
threshold
is
increased
from
the
current
level
of
500
lbs.
to
1000,
2000
and
5000
lbs.
Table
3
presents
the
estimated
impacts
in
terms
of
data
lost
under
the
same
scenarios
presented
in
Table
2.
Table
4
presents
the
estimated
impacts
in
terms
of
data
lost
under
the
500,
1000,
2000,
and
5000
pound
scenarios
when
the
threshold
is
modified
from
8.1
through
8.7
to
8.1
only.
Table
5
presents
the
estimated
impacts
in
terms
of
data
lost
under
the
500,
1000,
2000,
and
5000
pound
scenarios
when
the
threshold
is
modified
from
8.1
through
8.7
to
the
aggregate
of
8.1,
8.6
and
8.7.

Table
1.
Reporting
Year
2001
Use
and
Potential
Use
of
the
Form
A
Certification
Statement
Number
of
Chemicals
Reported
on
Form
A
Percent
of
Total
Forms
Number
of
Facilities
Percent
of
All
Facilities
Submitted
12,356
12.8
5,156
20.6
Submitted
plus
Potential
Form
As
22,936
23.9
9,789
39.1
Notes:

1.
"
Number
of
Facilities"
refers
to
the
number
of
facilities
that
submitted
at
least
1
Form
A
Certification
Statement.

2.
"
Potential
Form
As"
are
Form
Rs
that
have
a
total
of
current
year
section
8.1
through
8.7
of
500
lbs.
or
less
(
it
does
not
exclude
those
facilities
that
may
have
exceeded
the
1
million
pound
reporting
threshold
since
EPA
does
not
have
a
method
to
make
that
estimate).
­
18­

Table
2:
Estimated
Impacts
of
Various
Options
on
Reporting
Facilities
(
based
on
2001
data)

Scenario
Level
(
lbs)
Number
of
Form
Rs
Lost
Number
of
Facilities
Potentially
Affected
At
Least
1
Form
A
Percent
of
Total
Facilities
All
Reports
on
Form
A
(
No
Form
R)
Percent
of
Total
Facilities
Current
Basis
(
8.1
thru
8.7)
500­
full
use
10,649
9,789
44.6
4,607
21.0
1000
13,920
10,705
48.7
5,177
23.6
2000
17,626
11,662
53.1
5,960
25.7
5000
23,128
13,255
60.3
7,275
33.1
­
19­

Table
3:
Estimated
Impacts
of
Various
Options
(
based
on
2001
data)

(
1)
(
1a)
(
2)
(
2a)
Chemicals
on
Form
A
Only
(
3)

Option
Level
(
lbs)
Production­

Related
Waste
(
8.1.
thru
8.7)

Pounds
not
reported
on
Form
R
Percentage
of
Production
­

Related
Waste
(
8.1
thru
8.7)
Releases
(
8.1
+
8.8)

Pounds
not
reported
on
Form
R
Percentage
of
Releases
(
8.1
+
8.8)
No.
of
chemicals
for
which
all
reporting
qualifies
for
Form
A
No.
of
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Quantity(
lbs)

(
8.1­
8.7)
associated
with
the
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Quantity
(
lbs)

(
8.1
+
8.8)

associated
with
the
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Current
Basis
(
8.1
thru
8.7)
500­
Full
Use
1,311,453
.005
3,516,808
.0006
46
32
3,927
1,720
1000
3,700,992
.0141
5,174,818
.0009
51
40
8,082
3,303
2000
9,115,790
.0348
8,538,883
.0015
60
58
26,040
12,354
5000
27,392,449
.1046
18,065,218
.0031
72
93
84,490
19,171
Notes:

1.
Total
Production­
Related
Waste
(
sum
8.1
through
8.7)
for
reporting
year
2001
is
26,190,183,752
pounds
(
PBTs
were
excluded
from
this
total).

2.
Total
"
Releases"
including
releases
from
non­
production
related
activities
(
sum
8.1
plus
8.8)
for
reporting
year
2001
is
5,775,846,359
(
PBTs
were
excluded
from
this
total).

3.
Chemicals
for
which
all
submissions
may
be
limited
to
Form
As
(
523
toxic
chemicals
were
active
in
the
TRI
program
in
reporting
year
2001.
Total
chemicals
reported
in
2000
was
529).
­
20­

Table
4:
Estimated
Impacts
of
Various
Options
(
based
on
2001
data)

(
1)
(
1a)
(
2)
(
2a)
Chemicals
on
Form
A
Only
(
3)

Option
Level
(
lbs)
Production­

Related
Waste
(
8.1.
thru
8.7)

Pounds
not
reported
on
Form
R
Percentage
of
Production
­

Related
Waste
(
8.1
thru
8.7)
Releases
(
8.1
+
8.8)

Pounds
not
reported
on
Form
R
Percentage
of
Releases
(
8.1
+
8.8)
No.
of
chemicals
for
which
all
reporting
qualifies
for
Form
A
No.
of
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Quantity
(
lbs)

(
8.1­
8.7)
associated
with
the
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Quantity
(
lbs)

(
8.1
+
8.8)

associated
with
the
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Modified
Basis
for
Threshold
(
8.1)
500­
Full
Use
2,803,815,713
10.7
7,658,493
.0013
166
375
13,039,409
23,029
1000
3,419,890,789
13.0
11,745,444
.0020
184
467
26,039,794
158,432
2000
4,146,167,834
15.3
18,922,856
.0033
207
660
53,606,110
274,021
5000
5,548,546,646
21.1
39,590,428
.0069
237
1072
166,113,887
519,621
Notes:

1.
Total
Production­
Related
Waste
(
sum
8.1
through
8.7)
for
reporting
year
2001
is
26,190,183,752
pounds
(
PBTs
were
excluded
from
this
total).

2.
Total
"
Releases"
including
releases
from
non­
production
related
activities
(
sum
8.1
plus
8.8)
for
reporting
year
2001
is
5,775,846,359
(
PBTs
were
excluded
from
this
total).

3.
Chemicals
for
which
all
submissions
may
be
limited
to
Form
As
(
523
toxic
chemicals
were
active
in
the
TRI
program
in
reporting
year
2001.
Total
chemicals
reported
in
2000
was
529).
­
21­

Table
5:
Estimated
Impacts
of
Various
Options
(
based
on
2001
data)

(
1)
(
1a)
(
2)
(
2a)
Chemicals
on
Form
A
Only
(
3)

Option
Level
(
lbs)
Production­

Related
Waste
(
8.1.
thru
8.7)

Pounds
not
reported
on
Form
R
Percentage
of
Production
­

Related
Waste
(
8.1
thru
8.7)
Releases
(
8.1
+
8.8)

Pounds
not
reported
on
Form
R
Percentage
of
Releases
(
8.1
+
8.8)
No.
of
chemicals
for
which
all
reporting
qualifies
for
Form
A
No.
of
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Quantity
(
lbs)

(
8.1­
8.7)
associated
with
the
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Quantity
(
lbs)

(
8.1
+
8.8)

associated
with
the
Form
Rs
for
those
chemicals
for
which
all
reporting
qualifies
for
Form
A
Modified
Basis
for
Threshold
(
8.1,
8.6,
and
8.7)
500­
Full
Use
1,391,929,734
5.31
6,034,870
.0010
52
43
363,567
1,785
1000
1,687,335,594
6.44
8,735,162
.0015
60
57
591,767
5,919
2000
2,002,411,486
7.64
13,799,575
.0024
69
79
616,800
15,129
5000
2,551,464,744
9.74
27,704,162
.0048
82
121
864,684
41,708
Notes:

1.
Total
Production­
Related
Waste
(
sum
8.1
through
8.7)
for
reporting
year
2001
is
26,190,183,752
pounds
(
PBTs
were
excluded
from
this
total).

2.
Total
"
Releases"
including
releases
from
non­
production
related
activities
(
sum
8.1
plus
8.8)
for
reporting
year
2001
is
5,775,846,359
(
PBTs
were
excluded
from
this
total).

3.
Chemicals
for
which
all
submissions
may
be
limited
to
Form
As
(
523
toxic
chemicals
were
active
in
the
TRI
program
in
reporting
year
2001.
Total
chemicals
reported
in
2000
was
529).
