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Ask the Expert Question-and-Answer Archive (TRI)

by Joelie Zak, Scientific Control Labs, Inc.
March, 2002

What Is TRI?

Q. What is TRI? Is 100 lbs. referring to bath total or shop total? How do you comply? Do we have to comply? As you can tell we dont have a clue as to what this is!!!! Please help

A. Because I dont know what type of process you have, my answer will have to be relatively generic.

TRI is an acronym for Toxic Release Inventory, otherwise known as Form R reporting. This reporting is required under federal law, Section 313 of the Emergency Planning & Community Right-To-Know Act, promulgated in 1986.

The Form R reports are due annually on July 1st for the prior calendar year (i.e, the report due this July is for activities in 2001). There are a number of criteria to determine whether or not your facility is subject to reporting. Basically, if you have 10 or more full-time employees, fall under SIC codes 10, 12, 20-39, 4911 (metal finishing is 3471), and manufacture, process or "otherwise use" any of the chemicals on the TRI list over the EPA thresholds, you are subject to reporting. Most of the thresholds that plating companies fall under are 10,000 lbs or 25,000 lbs, however , the new threshold for manufacturing, processing or otherwise using Lead & Lead Compounds is 100 lbs. for a calendar year. This threshold is for an entire facilitys activities, not per process bath.

If you are doing plating with lead anodes or using lead as an alloy, you would need to determine how much lead you processed and also how much lead you "coincidentally manufactured" as a byproduct. If these quantities equal or exceed 100 lbs., you would need to file a Form R for Lead and/or Lead Compounds by July 1.

There are a few articles on this subject regarding calculating thresholds that can be found on the NMFRC website, as well as general guidance on EPAs website at www.epa.gov/tri .

Please provide me with additional information about your operations and I will be able to answer your question in better detail.



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