The EPA’s Office of Inspector General (IG) recently issued a management alert related to inaccuracies in EPA’s publicly-available toxic substance release data. The IG discovered discrepancies between EPA’s public data and the internal data that the agency submitted to the IG related to the total number of pounds of toxic chemicals released between 2013 and 2017.
EPA collects data on toxic substance releases in part through the Toxic Release Inventory (TRI) program, through which industrial facilities report on their emissions and releases of chemicals and other hazardous substances.
Companies that submit TRI reports should take note of the IG’s audit and subsequent actions. In recent years, we’ve seen EPA take a more proactive approach in identifying and flagging errors found in TRI reports. With the IG’s audit ongoing and EPA itself facing scrutiny, the agency will likely increase its efforts to ensure that the data it receives via TRI Reports is accurate and sufficient.
In many cases, EPA has compared TRI reports to other submitted reports like emissions inventories and SARA 312 reports. When EPA comes across discrepancies in the pollutants emitted and/or the rate or volume of the pollutant, the agency will often give the source time to explain the discrepancy. However, oftentimes this investigation turns up more questions, so it’s best to stay ahead of the game and off of EPA’s radar.
It’s commonplace to treat annual reporting as a status quo procedure, which can lead to out-of-date emissions factors and faulty calculations. A third-party audit of your TRI report can help unearth these issues and ensure that you are meeting the latest regulatory requirements related to toxic substances. Have a third party look at the emissions factors to ensure they are the most accurate to use. Consultants can also compare all of your reports to ensure that process changes, changes to raw materials, and regulatory updates are all captured to ensure your facility is reporting the most accurate information.
SoundEarth frequently assists industrial facilities through the full process for TRI reporting. We help clients determine if a facility meets the requirements to submit a report, manage report preparation and data calculations, and review existing reports to ensure they stand up to recent regulatory changes.
If you have an existing TRI report or are currently working through your 2019 report, or if you’re unsure if you need a TRI report in the first place, contact Chris Kitchen or Annika Wallendahl. As a reminder, the deadline to submit 2019 TRI Reports is July 1.