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:
SRM can help you with your TRI determination. USEPA also has resources to help you at their website.
TRI-Me Web Access
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.