July 1st is right around the corner.  We hope most of you are either done or well on your way to completing your TRI number crunching.  While there is still plenty of time to get the TRI reports completed, keep in mind there are some potential pitfalls that can stop you in your tracks:
 
Due Diligence - TRI Applicability Determination
 
If you are a small but growing company, don’t ignore the TRI reporting again this year because you haven't had to report in the past.  Do your annual Due Diligence and prepare some calculations and analyses that you can keep in a compliance folder for when MDEQ or USEPA come to visit.  This way you can easily demonstrate whether or not your facility is required to report. 

Your facility is required to report if it meets ALL three of these threshold criteria:

1. The facility is included in a TRI-covered NAICS code; and
2. The facility has 10 or more full-time employee “equivalents” (i.e., a total of 20,000 hours or greater; and
3. The facility manufactures (defined to include importing), processes or otherwise uses any EPCRA Section 313 chemical in quantities greater than the established thresholds in the course of a calendar year.

 
SRM can help you with your TRI determination.  USEPA also has resources to help you at their website.
 
TRI-Me Web Access
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USEPA requires companies to update their passwords.  If you are running short on time or the certifying official is going out of town on a long business trip in two days, updating crucial information can pose a problem.  What if you need to change the certifying official due to corporate reorganization?  Changing information in the TRI-ME system can take a week or two to complete and can be disruptive.  So you shouldn’t wait until the last minute to update your information.  A good rule of thumb is to get onto the CDX system sooner rather than later and make sure you and your certifying official can access the CDX system and your TRI forms.  Update your passwords as necessary. 
 
Check Your Formulas
 
If you are like many TRI preparers, you use spreadsheets to estimate chemical usage and emissions.  As we enter or remove data from year to year we can move linked data cells around the worksheet causing errors in the calculations.  In addition, “Fat-Finger Syndrome” is still incurable and people often delete or move links without even knowing it.  So, take some time every year to examine your formulas and links between worksheets to ensure data integrity.
 
Contact SRM if you have questions about TRI applicability or reporting.  We hare happy to help.

​USEPA issued the TSCA Inventory Reset final rule On June 22, 2017 in pre-publication form.  The rule requires every chemical manufacturer and importer to notify USEPA of each chemical substance it manufactured or imported (for a non-exempt commercial purpose) in the US during the 10-year period ending June 21, 2016.  This 10-year period is referred to as the “Lookback Period.” 
 
Each chemical substance for which USEPA receives a notification will be designated as “active” on the TSCA Inventory.  Manufacturers and importers must provide this notification to USEPA within 180 days from the date on which the rule is formally published in the Federal Register.  However, USEPA has not yet published the final rule in the federal register.  If the rule is finalized as proposed it will require the following:

• Within 180 days of the date of publication of the final rule, manufacturers and importers must notify USEPA about all substances they manufactured or imported from June 2006 to June 21, 2016 unless the substance was already reported by another company or was otherwise exempt from reporting.  
• If a substance is not reported, it is considered "inactive" and a notification will need to be submitted 30 days before actual manufacturing or processing begins. 
• Chemicals added to the Inventory on or after June 22, 2016 are automatically designated "active" and are not subject to notification requirements.

 
For more information go to the USEPA TSCA inventory information page.