What Are the Thresholds for TRI Reporting?

For most SARA 313 toxic chemicals - those not identified as persistent, bioaccumulative and toxic (PBT) chemicals - the requirements for annual TRI reporting on Form R or Form A apply if the facility:

• manufactured 25,000 pounds or more of the toxic chemical in the reporting year;

• processed 25,000 pounds or more of the toxic chemical in the reporting year; or

• otherwise used 10,000 pounds or more of the toxic chemical in the reporting year.

Special, lower thresholds apply for the manufacture, processing or other use of certain PBT chemicals and chemical categories. Among these are:

• lead and lead compounds, 100 pounds or more manufactured, processed or otherwise used in the reporting year (except if contained in stainless steel, brass, and bronze alloys, for which standard thresholds apply);

• mercury and mercury compounds, 10 pounds or more;

• polycyclic aromatic compounds, such as benzo(a)anthracene, benzo(b)fluoranthene, indeno(1,2,3-c,d)pyrene and similar compounds associated with fossil fuels combustion, 100 pounds or more (except for benzo(g,h,i)perylene with a threshold of 10 pounds or more);

• polychlorinated biphenyls (PCBs), 10 pounds or more;

• dioxins and dioxin-like compounds, 0.1 grams or more manufactured and processed or otherwise used if present as contaminants in a chemical and created during manufacture of the chemical.

A full list of PBT chemicals and their reporting thresholds can be found at the US Environmental Protection Agency website. The current reporting year list of TRI chemicals can be downloaded here.

Have a question about TRI reporting requirements? Please contact us for assistance.

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