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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 here 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.

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11 Responses
  1. Michael Broder permalink
    May 26, 2011

    Electronic submittal has saved time and effort. We operate electrical generation facilities in three states. Two of the states participate in the TRI Data Exchange. The state where most of our plants are located, still requires signed hard copies of Form Rs for each chemical. This is quite burdensome. Please encourage or require all states to participate in this data exchange program.

  2. Tom Spalding permalink
    May 26, 2011

    Sometimes it is not clear that we have actually “delivered the goods” so to speak. I may think I am finished, I can print various documents but I cannot be sure my clicks have honored the correct place in your database.

  3. Shelley permalink
    May 26, 2011

    I believe that I had an issue with using Mozilla Firefox for registration and using TRIMe, Don’t remember if they get that fixed or not.

    If there is going to be a mandate that the software be used, then the EPA will need to make sure that it “can” be used on “all” browser platforms not just Explorer, Even you Apple People.

    The registration process was at best confusing and I think made more difficult than it needed to be. I did not see why they needed to make it an entire separate process.

    It seems every year when I go to file – I have to come up with a new really super Human impenetrable Super hero password that even I can not remember (Even if I wrote it down, somehow I can’t use it again) I believe that it has to be 99 characters with a combination of letters, Numbers and one character that your key board can not make, followed by the name of your elementary school teachers name!…. Really, I could not think of a scenario where some one would want to hack into my EPA account and fill out my TRI reporting for me. Should I ever leave this company or this earth, no one will ever be able to access the TRI account I mean no one. <—Humor people, Hope it's ok to still have some.

    The truth, I know from experience that I get all stressed out in the beginning with the hassles of trying to get into the program then once I am in… It really is pretty easy. It it not designed that well – You have no idea if you are done, not done, could be done before Lunch or before quitting time. Then once you submit – you wonder if it went ( I do not think that they use "Submit or "Send" I think they used some really sophisticated word like press here if you would like to activate the "unseen intergalactic messaging to the EPATRIMeCDX ESA" … Its kind of weird – it is not layed out like other programs where you hit an OK button, don't know how to explain it except it is not like a windows program. It's much more unclear what you are supposed to do after entering something. Really an "OK" button is good – we all know what that means and does.

    Ok, It really is a Good program and I am all for making it mandatory, Don't mind my humor about the program, You will see it is easy and you will also see I am correct about somethings, But nothing to stress about…. Smile and remember you read it here first.

    Making Waste Management and reporting Fun!

    Oh, I just receive this message when pressing the "Post Comment" button
    Error: please enter a valid email address.

  4. Mr. Wilson permalink
    May 27, 2011

    Having used & submitted both paper and electronic versions of the Form R report, I much prefer the “e” version. The help provided on the TRI Me software is terrific. It’s much quicker to complete each report on line and the registration process is simple enough. I can’t believe many companies that process enough of a 313 chemical to report on Form R don’t have internet access so make it mandatory.

  5. Mina Oler permalink
    May 27, 2011

    Electronic reporting is so easy!!! Don’t have to print all the papers involved and worry about getting them mailed.

  6. Tim Sheehan permalink
    May 27, 2011

    I work for a very small company that is required to file these reports. In small companies, people wear multiple hats. We do our best to be accurate and to stay current, but we’re not experts in all of the jobs that have to be done for regulatory reasons. We can’t always afford to hire high priced experts to do these things for us either. We want to comply with all of the laws and regulations that pertain to our businesses, and we try very hard to do so, but that is a difficult task for small businesses. To say the least. Staying current with all of the regulatory changes coming from multiple agencies is very time consuming.
    Like other government agency designed user interfaces that I have used, I find the Tri-Me software difficult to navigate and use. I’m sure that it’s less expensive overall for the agencies to handle less paper, but frankly, the reporting process was easier to follow and complete when it was an all paper process. I’m all for saving taxpayer money. I just wish the software was more intuitive. How to make it more user friendly? I don’t know. I’m not a software writer. But I’m sure there are plenty of experts who could assist the EPA in that regard.

  7. John E. Horn permalink
    May 31, 2011

    TRI is great in theory. Even the software navigation can be figured out after a few tries. One year the CDX went down during the last month of reporting but no extensions were given. The reliability of the CDX is the weak link in the process followed by the help desk. I have, on occasion reported problems or asked questions only to be funneled to an answering machine which did not trigger a response at all in one case and a response days later in others. It appears that one is on their own with the CDX. Any improvement in reliability would be appreciated and a better help response is needed. I would like to see all states required to take the TRI electronically, I have one state that still wants floppy disks !!

  8. Corporate Representative permalink
    June 8, 2011

    We have multiple facilities that report for TRI each year. For the larger facilities the electronic reporting is a great tool. For the small facilities, many that report one chemical, the TRI-ME part is okay, but the CDX registration is VERY cumbersome, time consuming, and frustrating. Our small facilities frequently change plant managers, and we have to go through that whole process of getting a new certifiying official approved. It’s much easier to send in a paper TRI report than to go through the CDX approval process every year. Also, we have one plant manager that we have been trying for 5 YEARS to get properly designated as “approved” for certifying, but the HelpDesk can not fix the problem.

    Bottom line — If there were an easier method of certifying the report, TRI-ME would be a good tool.

    We have three new plant managers this year for facilities that report ONE chemical. We can print off the TRI paper form (which we fill out anyway, just to be sure we have all the necessary information), and have the plant manager sign two copies and mail them off all in less than 30 minutes. Or, we can print off the CDX form and have them sign it, mail it in, and wait to get confirmation that they have been approved. Then we can link them to the facility, and get them set up as the certifying official. Then we can go on line, and fill in the TRI information electronically. Then we can notify the plant manager, and warn them not to delete the email saying that the form is ready to certify (and to check their spam folder in case they can’t find the email.) Then they can sign off on the form, and we can go BACK into the system to print of copy the final certified version of the form. All of this takes about three weeks, and countless hours of “babysitting” to be sure everything is done on time.

  9. Steve Woock for Weyerhaeuser Company permalink
    June 13, 2011

    We believe EPA should maintain availability of additional reporting paths, and at least the editable pdf electronically submittable (e-pdf) form version which the Agency added this year as an option. While many of our facilities have mastered the TRI-MEweb reporting tool, as others have stated here the CDX registration system can be problematic and that means non-flexibility, added costs, and significant unproductive time. That system requires that both the preparer and the certifier establish accounts with CDX, and the certifying official has to submit an electronic signature agreement some two weeks in advance of the reporting deadline in order to be able to make a timely certification. Others on this blog have provided greater detail of the steps. However, with the e-pdf, a complete report can be prepared and submitted in a short amount of time. This is a critical feature for reporting flexibility, for example, when personnel change at facilities during or just prior to the reporting window. Such flexibility in reporting methods is important since to our knowledge EPA does not have provisions for TRI reporting extensions.

  10. Lori permalink
    June 21, 2011

    The TRI Me reporting tool was just ok to use. Not as user friendly as it could be. I had issues with using Google Chrome as my browser. I would choose the code for Part C in Section 6.2 and would then proceed to save it. I would go back to it later and there would be no data there. Very frustrating. I had to redo that section several times.
    Overall, there could be improvements made to the tool but I got through it.

  11. Diane permalink
    June 22, 2011

    Electronic reporting is burdensome for certifying officials who have to go into the CDX website and fiddle around. If the TRI reports need to be signed at a coporate officer level, there should be a paper option. In my opinion, TRI reports should be submitted by the preparer, without an additional step for certification.

    The CDX system is not user-friendly, and the user should at least be able to change their email address without calling the help desk.

Comments are closed.