Question # 3

3. If a facility triggers TRI reporting thresholds for a listed toxic chemical (i.e., it meets the employee and toxic chemical activity thresholds and is in a covered NAICS code), is it required to report if it had no releases of the toxic chemical during the reporting year?
Yes, even if it releases no toxic chemicals into the environment and does not conduct any other waste management activities involving the listed toxic chemical, the facility must submit a TRI reporting form. If the facility meets the employee and chemical activity thresholds and is in a covered NAICS code, but its annual reportable amount of a non-PBT chemical does not exceed 500 pounds and the facility has not manufactured, processed, or otherwise used more than one million pounds of the toxic chemical, the facility may submit the Form A (Alternate Threshold Certification Statement). If the facility exceeds either the 500- or one million-pound limits, it must report on the Form R (40 CFR Section 372.85 and 372.95).

Additional Details

Question # 3 Source EPCRA Section 313 Questions & Answers 2019 Consolidation Document (PDF)(413 pp, 2.4 MB, April 2019)
ID 19-003 Status Current
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.A. Types of Facilities That Must Report
Keyword(s) Alternate Threshold (Form A), Form A, Form R, Reporting Criteria
Prior Q&A [Archived] Question Number 1, 2004 Q&A Addendum
Updated SIC codes to NAICS codes; Updated citations or URL