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The Discussion Forum Is Now Closed

2011 July 6

The Discussion Forum collected comments up through July 1, 2011. Thank you very much for your participation.

Comments received have been posted to the docket identified as EPA-HQ-TRI-2011-0174.

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

The Discussion Forum is Open

2011 May 19

EPA’s Toxics Release Inventory (TRI) Program plans to issue a proposed rule to require the electronic reporting of TRI data.  Under this proposed rule, facilities would be required to use the TRI Made Easy Web (TRI-MEweb) application to report TRI data to EPA.  EPA invites you to comment on its plans to issue a TRI electronic reporting rule.  EPA will not respond directly to any comments received in this forum.

This online discussion forum will remain open and available for comment until 5:00 p.m. on July 1, 2011.  Once the discussion forum closes, EPA will place the entire discussion forum, with comments included and attached to their associated post, into the docket identified as EPA-HQ-TRI-2011-0174, which is accessible via regulations.gov.

Please review the Comment Policy and Frequently Asked Questions pages and then consider the topics posted below.

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

Use of TRI-MEweb by Reporting Facilities

2011 May 19

For Reporting Year (RY) 2009, approximately 94% of TRI facilities used the Toxics Release Inventory Made Easy Web (TRI-MEweb) application to report TRI data.  EPA believes  that each regulated facility can, or could potentially, gain access to the application since it is available at no charge over the Internet.

Informal feedback from facilities that are currently using TRI-MEweb to submit TRI data has generally been positive.  EPA is not aware of any problems inherent in the TRI-MEweb application that would prevent a facility from using it to submit TRI data.  If facilities have experienced any major problems in using TRI-MEweb, EPA would be interested in hearing about them.

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

Expected Benefits of using TRI-MEweb

2011 May 19

TRI-MEweb includes a number of data entry and validation features that help facilities prepare and submit accurate TRI data more easily and efficiently.  In addition, facilities that have previously used TRI-MEweb can compare their most recent year’s data to the prior year’s data, which may help them identify potential data errors.  In addition, the submission of electronic TRI reports using TRI-MEweb helps EPA process and make the data available to the public soon after the July 1st reporting deadline, since the data have already undergone a number of data quality checks in TRI-MEweb and EPA does not have to enter the data manually into the TRI database.  EPA would be interested in hearing about facilities’ experiences in using TRI-MEweb – particularly any benefits they have experienced by using TRI-MEweb.

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

Potential Impacts Associated with a Requirement to use TRI-MEweb

2011 May 19

EPA believes that if a facility has used TRI-MEweb in the past to report any portion of its TRI data – including original submissions, revisions, or withdrawals – then the facility would likely continue its use of electronic reporting rather than use paper TRI reporting forms.  Thus, EPA expects that only those facilities that have not yet begun using TRI-MEweb (i.e., ~6% of facilities) would be affected by a requirement to use TRI-MEweb (except for trade secret information)EPA would be interested in hearing facilities’ views on the potential impacts they might experience – if any – if EPA were to require all facilities to utilize electronic reporting and TRI-MEweb (except for trade secret information).

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

Facility Experiences with EPA’s Electronic Reporting Process

2011 May 19

EPA expects that the use of TRI-MEweb to prepare and submit TRI data will ultimately reduce the burden associated with reporting TRI data.  At the same time, EPA acknowledges that there are currently requirements regarding facility registration with EPA’s Central Data Exchange (CDX), the designation of a facility’s TRI form Preparer and Certifying Official in TRI-MEweb, and the submission of Electronic Signature Agreements (ESAs) that a facility must address before utilizing electronic reporting.   To assist reporting facilities, particularly those that are less familiar with electronic reporting, EPA provides step-by-step guides and online tutorials regarding the TRI electronic reporting process on the TRI website.

EPA does not expect that the initial electronic reporting registration requirements and ESA process will pose a significant burden on TRI reporting facilities. The Agency would be interested in feedback on facilities’ experiences with the CDX registration process, the ESA process, or other aspects of the TRI-MEweb electronic reporting process.

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

General Comments

2011 May 18

EPA plans to publish a proposed rule in late calendar year 2011 which would require TRI facilities to submit TRI data electronically to EPA using TRI-MEweb.  The final electronic reporting rule could potentially be effective beginning with RY 2012 (reports due July 1, 2013).

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.