1
TRI
Program­
Related
Burden
Reduction
Options
and
Public
Comment
Summary
October
19,
2004
Kevin
Donovan
TRI
Program
Division
donovan.
kevin­
e@
epa.
gov
2
Option
1
 
Higher
Reporting
Thresholds
for
Small
Businesses
°
Description:
EPA
asked
for
comment
on
whether
it
should
consider
raising
the
reporting
thresholds
for
small
businesses.
EPA
also
requested
comment
on
how
small
businesses
should
be
identified
for
purposes
of
this
option.

°
Public
Comment:
Most
commenters
did
not
express
support
for
this
option.
Some
commenters
noted
that
small
businesses
do
not
always
have
small
release
and
other
waste
management
amounts.

Others
said
this
option
would
create
too
much
complexity
in
the
program.

Of
those
in
favor
of
this
option,
some
suggested
using
the
SBA
definitions
to
define
"
small
business"
while
others
suggested
using
a
specific
number
of
employees
to
define
"
small
businesses."
3
Option
2
 
Higher
Reporting
Thresholds
for
a
Category
of
Facilities
or
a
Class
of
Chemicals
with
Small
Reportable
Amounts
°
Description:
EPA
asked
for
comment
on
whether
it
should
consider
raising
the
reporting
thresholds
for
a
specific
category
of
facilities
and/
or
a
specific
class
of
chemicals.

°
Public
Comment:
A
number
of
commenters
expressed
concern
that
targeting
specific
sectors
or
chemicals
for
increased
thresholds
would
only
add
greater
complexity
to
the
TRI
program
and
adversely
affect
data
quality.
Some
commenters
supported
this
option,
and,
in
particular
suggested
raising
thresholds
for
lead
and
lead
compounds
and
revisiting
the
classification
of
lead
and
lead
compounds
as
PBT
chemicals.
4
Option
3
 
Expanding
Eligibility
for
the
Form
A
Certification
Statement
°
Description:
EPA
asked
for
comment
on
whether
it
should
consider
expanding
Form
A
eligibility
by:

 
(
1)
raising
the
1
million
pound
alternate
threshold
 
(
2)
raising
the
500
pound
"
total
annual
reportable
amount"

threshold
and/
or
removing
certain
waste
management
activities
from
the
"
total
annual
reportable
amount"
calculation.

°
EPA
also
requested
comment
on
whether
it
should
consider
developing
an
enhanced
Form
A
that
includes
information
on
specific
environmental
media
or
waste
management
activities
in
the
form
of
range
estimates
5
Option
3
 
Expanding
Eligibility
for
the
Form
A
Certification
Statement
°
Public
Comment:
Those
opposed
to
this
option
said
that
it
is
not
ideal
for
burden
reduction
because
facilities
still
need
to
perform
calculations
to
determine
eligibility.
Some
commenters
also
felt
that
the
expanded
use
of
Form
A
would
result
in
the
loss
of
too
much
data.
Those
in
favor
of
expanding
the
use
of
Form
A
recommended
the
following:

 
Remove
or
increase
the
1
million
pound
alternate
threshold
 
Modify
"
total
annual
reportable
amount"
 
both
the
500
pound
amount
and
the
waste
management
activities
that
are
used
to
calculate
this
amount
 
Allow
PBT
reporters
to
use
Form
A
 
Alter
the
enforcement
approach
toward
good­
faith
errors
in
which
a
Form
A
is
filed
when,
in
fact,
a
Form
R
should
have
been
filed
 
Do
more
outreach
to
highlight
Form
A
 
Enhance
Form
A
through
the
addition
of
range
estimates,
thereby
creating
a
shorter,
less
burdensome
version
of
the
Form
R
(
e.
g.,
a
Form
"
EZ")
6
Option
4
 
Creating
a
New,
"
No
Significant
Change"
Certification
Statement
°
Description:
EPA
asked
for
comment
on
whether
it
should
consider
developing
a
new
form
that
would
allow
facilities
to
certify
to
"
no
significant
change"
as
measured
against
a
designated
baseline
year.

Specifically,
EPA
requested
comment
on:

 
How
to
designate
the
baseline
year
and
the
number
of
years
between
baselines
 
Whether
"
no
significant
change"
should
apply
to
total
releases,

total
waste
management,
a
set
of
qualitative
criteria,
or
some
other
criteria
 
Whether
the
criteria
should
be
based
on
a
percentage
of
change
or
a
percentage
and
a
specified
quantity,
amounts
below
which
a
facility
could
consider
as
"
no
significant
change,"
and
a
specified
quantity,
amounts
above
which
the
no
significant
change
option
would
not
apply
 
Whether
this
option
should
be
available
for
PBT
chemicals
7
Option
4
 
Creating
a
New,
"
No
Significant
Change"
Certification
Statement
°
Public
Comment:
This
option
received
many
supportive
comments,

however,
the
comments
provided
few
details
on
how
to
actually
implement
the
option.
Some
comments
addressed
various
aspects
of
this
option,
including:

 
How
often
to
require
TRI
reporting
with
a
no
significant
change
option
(
i.
e.,
the
baseline
year
issue).
Some
suggested
3
years,

some
5
years,
and
others
no
baseline
limit,
etc.

 
The
criteria
type
that
should
apply
(
e.
g.,
quantitative,
qualitative,
or
some
combination).
Some
suggested
a
percentage
(
e.
g.,
5%,
10%,

15%),
while
others
suggested
whole
amounts
or
a
combination
of
a
percentage
and
whole
amounts.
Still
others
were
in
favor
of
a
qualitative
approach
(
e.
g.,
a
narrative
statement
regarding
no
significant
change).

 
The
variable
of
change
that
should
apply.
Some
advocated
the
use
of
production
ratio,
others
said
total
quantity
managed
as
waste,
or
total
releases.
8
Option
5
 
Use
of
Range
Reporting
for
Section
8
of
the
Form
R
°
Description:
EPA
asked
for
comment
on
whether
it
should
consider
applying
to
Section
8
of
the
Form
R
the
current
use
of
range
reporting
for
less
than
1,000
pounds
of
non­
PBT
chemicals
reported
in
Sections
5
and
6
of
the
Form
R.

°
Public
Comment:
While
this
option
received
both
supportive
and
critical
comments,
there
seemed
to
be
general
agreement
that
this
option
would
not
afford
a
lot
of
burden
relief
as
compared
to
other
options
discussed
in
the
stakeholder
paper.
Those
opposed
to
this
option
expressed
concern
over
its
impact
on
data
quality.
Those
in
favor
of
this
option
said
it
would
reduce
burden
and
make
the
form
more
consistent
as
Sections
5
and
6
of
the
Form
R
already
allow
the
use
of
range
codes.
