Compliance Briefing — February 15, 2024
U.S. facilities covered by the Toxics Release Inventory must finalise 2023 data quality checks, new PFAS additions, and e-reporting workflows before Form R and Form A submissions reach the July 1, 2024 deadline.
Executive briefing: EPA’s Toxics Release Inventory (TRI) reporting window for the 2023 calendar year is underway. Covered manufacturing, mining, utility, and waste facilities must certify Form R or Form A submissions through TRI-MEweb by July 1, 2024. The 2023 cycle expands per- and polyfluoroalkyl substances (PFAS) subject to section 313 reporting, so compliance teams should reconcile release calculations, supplier notifications, and documentation against the latest chemical list.
Key compliance checkpoints
- Applicability screening. Validate NAICS codes, full-time employee counts, and chemical thresholds to confirm facilities remain in scope for section 313 reporting.
- PFAS additions. EPA’s 2023 update removes the de minimis exemption for 189 PFAS and adds nine new substances, requiring comprehensive tracking of materials above 100 pounds.
- E-reporting integrity. TRI-MEweb submissions must include responsible official certification, release quantities, off-site transfers, and optional pollution prevention narratives backed by auditable calculations.
Control alignment
- Data governance. Align inventory, procurement, and waste management systems to maintain auditable chemical usage logs and supplier notifications under 40 CFR 372 Subpart B.
- Cross-check emissions. Reconcile stack testing, continuous emissions monitoring (CEMS), and mass balance calculations with prior-year filings to catch anomalies before certification.
- Document calculations. Store worksheets, engineering assumptions, and third-party sampling reports in retention systems meeting the three-year requirement of 40 CFR 372.10.
Enablement moves
- Lock reporting calendars with plant managers and environmental coordinators, assigning deadlines for activity data, waste manifests, and QA sign-offs.
- Refresh PFAS training for EHS and procurement teams so new reportable chemicals trigger timely supplier notifications and purchase order flags.
- Prepare executive summaries outlining release trends, pollution prevention investments, and community engagement updates for July board packets.
Sources
- EPA: TRI reporting deadlines and submission process
- EPA: 2023 TRI chemical list including PFAS additions
Zeph Tech helps environmental teams automate TRI data aggregation, PFAS tracking, and TRI-MEweb certification so filings withstand EPA and shareholder scrutiny.