TRI Data Considerations
As with any dataset, there are several factors to consider when reviewing results or using Toxics Release Inventory (TRI) data. Key factors associated with the data presented in the TRI National Analysis are summarized below; for more information see Factors to Consider When Using Toxics Release Inventory Data.
TRI reporting is required for facilities that meet the reporting criteria under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). EPA investigates cases of EPCRA non-compliance and may issue civil penalties, including monetary fines. Since the TRI Program’s creation, EPA has taken more than 3,400 TRI-related enforcement actions. For more information, see the TRI Compliance and Enforcement webpage.
- Covered chemicals and sectors. Many industry sectors report information about the management of certain toxic chemicals as waste to TRI. However, TRI does not include information on every chemical, nor does it collect information from all facilities or industry sectors that may manage TRI chemical wastes. A list of the chemicals reportable to the TRI Program as well as a list of the sectors covered by the TRI Program is available on the TRI webpage. Facilities in covered sectors that manufacture, process, or otherwise use TRI-listed chemicals above listed threshold quantities and employ at least ten full-time equivalent employees are required to report to the TRI Program. For most TRI chemicals, the threshold quantities are 25,000 pounds of the chemical manufactured or processed, or 10,000 pounds of the chemical otherwise used during a calendar year.
- TRI trends. The TRI chemical list has changed over the years. To make sure year-to-year data are optimized for comparison, trend graphs in the TRI National Analysis include only chemicals that were reportable for the entire time period presented. Results which focus only on the year 2020 include all chemicals reportable for 2020. Thus, quantities mentioned in 2020-only analyses may differ slightly from the quantities shown for the year 2020 in multi-year trend analyses.
- Data quality. Facilities use their best available data to determine the quantities of chemicals they report to TRI. Each year, EPA conducts an extensive data quality review that includes contacting facilities about potential errors in reported information. This data quality review process helps ensure that the TRI National Analysis is based on accurate and complete information.
- Risk. TRI data can be a useful starting point to evaluate whether chemical releases may pose potential risks to human health and the environment. However, the quantity of a chemical release alone is not necessarily an indicator of exposure to the chemical, or the potential health or environmental risks posed by the chemical. In particular, note that:
- TRI-listed chemicals vary in their toxicity; and
- The extent of exposure to a chemical depends on many factors such as where the chemical is released, how it is released (i.e., to air, water, or land), the chemical’s properties, and what happens to the chemical in the environment.
- COVID-19. The most recent TRI data reflect chemical waste management activities, including releases, that occurred during calendar year 2020. The COVID-19 public health emergency began in the U.S. in early 2020 and may have affected industrial operations throughout the year. Facilities may submit comments about their industrial activities, and for 2020, many facilities chose to include information on how COVID-19 impacted their operations. Some descriptions of such comments are provided below.
- Impacts on facility-wide operations. Many facilities noted COVID-19-related shutdowns or reduced operations during 2020.
- Impacts on waste management activities. Facilities commented on how the public health emergency changed their processes. For example, a food manufacturer noted that they used more sanitizing chemical than in the past to meet COVID-related industry requirements. An antibacterial wipe manufacturer reported that increased demand for their product led to an increase in their production and the associated amount of chemical waste generated.
- Impacts on pollution prevention activities. As an example, an abrasive product manufacturer reported that COVID-19 resulted in less capital available to pursue source reduction projects.
- Late submissions, revisions and withdrawals. TRI reporting forms submitted to EPA or revised after the July 1 reporting deadline may not be processed in time to be included in the National Analysis. After EPA’s data quality review, the TRI data are frozen in October and this dataset is used to develop the National Analysis. Any revisions or late submissions received after this date, or withdrawals made after this date, may not be reflected in the National Analysis but are incorporated into the TRI dataset during the spring data refresh and will be reflected in next year’s National Analysis where the data for that reporting year are referenced.
Impact of Late Submissions and Revisions
To assess the impact of late submissions and revisions on the TRI National Analysis, the 2019 TRI data available in October 2021 were compared to the data that were available a year earlier, which were used to develop the 2019 TRI National Analysis. The difference between these two datasets is due to facilities that submitted late or revised TRI reporting forms.
With the updated data, waste managed quantities are slightly higher and release quantities are slightly lower than originally reported: releases are 0.3% lower and waste managed is 0.2% higher than was shown in the 2019 TRI National Analysis.
In this figure, the value for “Disposal or Other Releases” in the production-related waste managed pie chart (3.08 billion lb) is greater than the value for “Total Disposal or Other Releases” (3.04 billion lb). There are several reasons that these quantities differ slightly, including:
- Double counting. Total disposal or other releases (3.04 billion pound value in the figure) removes "double counting" that occurs when a facility reports transfers of TRI chemicals in waste to another TRI-reporting facility. For example, when Facility A transfers a chemical off site for disposal to Facility B, Facility A reports the chemical as transferred off site for disposal while Facility B reports the same chemical as disposed of on site. In processing the data, the TRI Program recognizes that this is the same quantity of the chemical and includes it only once in the total disposal or other releases metric. The production-related waste managed metric in TRI, however, considers all instances where the TRI chemical in waste is managed (first as a quantity sent off site for disposal and next as a quantity disposed of on site), and reflects both the off-site transfer and the on-site disposal. Typically, double counting accounts for most of the difference between the two release quantities in the 2020 TRI Quick Facts figure.
- Non-production related waste. Non-production-related waste refers to TRI chemical waste that result from one-time events, rather than standard production activities. These events may include remedial actions, catastrophic events, or other events not associated with normal production processes. Non-production-related waste is included in a facility’s total disposal or other releases but is not included in its production-related waste managed.
For more information on TRI, the chemicals and industry sectors it covers, the reporting requirements, and to access TRI data, visit the TRI website.
This page was published in March 2022 and uses the 2020 TRI National Analysis dataset made public in TRI Explorer in October 2021.