Compliance Briefing — July 1, 2025
The 1 July 2025 TRI filing for 2024 releases demands auditable environmental data governance, facility attestations, and escalation-ready reporting workflows covering PFAS, contract manufacturer inputs, and justice screening obligations.
Executive briefing: Form R and Form A submissions under the U.S. Environmental Protection Agency’s Toxics Release Inventory (TRI) are due 1 July 2025 for 2024 operations. The 2024 reporting year captures expanded per- and polyfluoroalkyl substances (PFAS) listings, supplier-managed waste streams, and the new environmental justice screening questionnaire. Boards should expect regulators, investors, and communities to test data provenance and governance. This briefing details the control framework, evidence packs, and reporting workflow needed for a defensible filing.
Governance structure and accountability
Confirm a governance charter that assigns TRI accountability to the chief sustainability officer (or equivalent) with oversight from the board’s ESG or risk committee. Map reporting responsibilities across EHS, procurement, supply chain, finance, and legal. Document facility-level accountable executives who certify data completeness and controls. Ensure the governance map links to Sarbanes-Oxley disclosure controls if TRI data feeds sustainability reports or SEC filings.
Inventory scope and applicability assessments
Maintain an applicability register covering all U.S. facilities and federal contractor sites. For each facility, document NAICS code confirmation, employee thresholds, and chemical activity evaluations for manufacture, processing, or otherwise use. Track contract manufacturers handling the company’s chemicals and verify data-sharing agreements. Include PFAS additions, diisocyanates, and natural gas processing chemicals introduced in recent rulemakings. Evidence that applicability assessments were independently reviewed and signed off before calculation work began.
Data collection controls
Build a data model capturing material throughput, release factors, treatment methods, and waste disposition. For each data point, log the source system, extraction method, quality checks, and reviewer sign-off. Where estimates are used, document calculation methods, emission factors, and engineering judgement. Implement automated validation scripts comparing year-on-year variances, throughput balances, and mass closure checks. Maintain a data issues log that records anomalies, corrective actions, and approval of adjustments.
PFAS-specific governance
The 2024 year is the first full cycle in which most PFAS no longer qualify for the de minimis exemption. Update chemical inventories, supplier questionnaires, and procurement contracts to capture PFAS content and quantities. Document laboratory analytical methods, detection limits, and chain-of-custody for samples. Develop PFAS-specific dashboards showing quantities released to air, water, and land, along with treatment or destruction technologies used. Provide the board with a PFAS risk briefing covering regulatory trends, litigation exposure, and community outreach plans.
Supplier and contractor coordination
TRI data often requires information from toll manufacturers, waste vendors, and recyclers. Establish contractual clauses mandating timely data delivery, quality certifications, and audit rights. Implement a supplier portal or secure workspace for data submissions, including validation scripts and instructions. Track supplier compliance through scorecards that feed into procurement governance committees. Escalate late or incomplete submissions through predefined workflows to legal, procurement leadership, and the board committee if risk of non-compliance arises.
Environmental justice screening
The TRI program now integrates EPA’s Screening Level Environmental Justice (EJ) Index. Prepare an evidence file showing how facilities assessed EJ impacts, engaged communities, and considered mitigation. Document public meeting minutes, correspondence with local stakeholders, and translated materials provided. Capture board deliberations on EJ findings, resource allocations for community investments, and oversight of grievance mechanisms.
Calculation and quality assurance
Document the calculation methodology for each Form R: production ratios, by-product determinations, release estimation methods, and waste treatment efficiencies. Require dual review—technical expert prepares, independent reviewer validates, and facility manager certifies. Internal audit or an external engineering firm should perform spot checks on high-risk facilities, with reports stored in the evidence pack. Maintain a variance log explaining significant changes versus prior years, referencing operational shifts, process improvements, or incident impacts.
Reporting workflow and attestations
Build a detailed timeline from January data collection through 1 July submission. Include milestones for data extraction, facility certifications, corporate consolidation, legal review, board committee briefing, and e-filing. Establish a secure document management system to archive drafts, comments, and approvals. Ensure the TRI coordinator completes e-filing readiness checks (CDX access, signature credentials) and conducts a dry run upload two weeks before deadline. Directors should receive a pre-filing pack summarising key metrics, variances, PFAS insights, EJ conclusions, and outstanding risks.
Integration with sustainability and financial reporting
Many entities cross-reference TRI figures in sustainability reports, climate disclosures, or capital allocation plans. Align TRI data with greenhouse gas inventories, water stewardship metrics, and SEC climate rule disclosures. Maintain traceability matrices linking TRI numbers to published statements, verifying consistent units, boundaries, and assumptions. If TRI data influences asset retirement obligations or environmental reserves, coordinate with finance and external auditors to document impacts.
Technology enablement and controls
Evaluate whether existing EHS software, data historians, and laboratory information systems provide sufficient audit trails and role-based access controls. Configure workflow automation so facility submissions cannot advance without required attachments—calculation workpapers, chain-of-custody forms, and sign-off checklists. Implement data lineage tracking that documents extraction scripts, transformation logic, and reconciliation checks. Where spreadsheets remain in use, apply version control, change logs, and independent verification routines. Capture screenshots, system logs, and user access reviews in the evidence pack to demonstrate reliable technology governance supporting TRI disclosures.
Incident response and post-filing controls
Establish a post-filing monitoring plan covering potential data corrections, public feedback, and EPA inquiries. Define incident escalation protocols if errors are discovered, including notification timelines, corrective filings, and stakeholder communication. Capture lessons learned workshops, assign remediation actions, and schedule control enhancements for the next reporting cycle. Keep the evidence room updated with final filings, acknowledgement receipts, correspondence, and board reports to demonstrate a complete audit trail.
Key actions for the next 60 days
Complete facility applicability confirmations, finalise PFAS inventories, and close gaps identified in dry run calculations. Secure board committee time in May and June for governance reviews, and line up independent assurance on high-risk facilities. Test disclosure controls linking TRI data to sustainability or SEC climate reporting to ensure consistency. By mid-June, lock the evidence pack, complete sign-off checklists, and obtain executive certifications so the 1 July submission proceeds without surprises.
Schedule a post-submission controls review for August 2025 to verify ongoing data governance, retest supplier data feeds ahead of the 2025 cycle, and brief the board on regulatory developments affecting TRI applicability.
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