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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 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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2 Responses
  1. George Tyrian permalink
    June 28, 2011

    The point that seems to be missed on requiring TRI-MEweb is the requirement to complete and submit an electronic signature agreement to certify the report. This has to be done whenever there is a change in the certifying official, which of course cannot be tracked by CDX (i.e., CDX notes that there is a certifying official on record, not that the certifying official no longer works for the company, and that the company does not allow the official to certify reports any longer). I have several facilities going through reorganization in June, therefore, it seems doubtful that the new ESA will be approved in time. For this reason, we are submitting paper TRI reports while the reorganization is completed. This maintains the facility compliance and allows us to wait on CDX to process the ESA without the threat of penalties that can be occurred due to certifying the report after July 1 caused by the June reorganization and changing of certifying officials. Once the ESA is approved and there is no change in management, I agree the process runs smoothly. I do not agree with deleting the option to submit paper reports, however, if only to cover these type of incidents.

  2. Rav permalink
    June 29, 2011

    We just had a case in which the certifying official became ill. He was having medical issues while trying to re-establish/change his password so that he could certify the forms and leave work to tend to his medical problems (having already been in a hospital for most of the week). It may have been better this year if we would have sent our Form A in paper format even if a processing fee had been required.
    Also it needs contemplating; the possibility of some type of cyber attack taking place that renders either the TRI-ME web site or the reporting facilities systems impractical for reporting online.

    One other point is that it is handy to print off a paper form before stating preparation of reports so that all data fields can be reviewed so as to make sure all reporting data is readily available when the attempting a submission electronically.

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