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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 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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13 Responses
  1. Rod Millhof permalink
    May 26, 2011

    I have no issue myself, since we have been reporting electronically for years now, but is it fair to mandate that all the small mom and pop businesses around the country have to have computers and internet access to perform this reporting? Just food for thought.

  2. Judy Schnaath permalink
    May 26, 2011

    I too have no issue since I too have been using it since it was made available. I too agree with Rod Millhof that the small mom and pop businesses should not be made to use Tri-MEweb. Maybe you make it mandatory for business with over a certain amount of employees.

  3. May 26, 2011

    TRI-ME works fine except if the company official who is authorized to sign the electronic reports is unable to electronically sign (sick, no longer employed, etc.) the requirements for getting a new person authorized are too difficult and can not be done quickly. If this occurs the last week in June the electronic submital may not be possible under the current system.

  4. James Smith permalink
    May 27, 2011

    Comment #1 – using an online forum to solicit input about the required use of electronic reporting automatically biases the results. Only computer users and those familiar with the system will know that the forum is available and have ready access to it. Those typically smaller entities that do not have daily access or use of computers, who are the most likely to be opposed, are much less likely to respond to the forum.
    Comment #2 – Use of TRI-ME is relatively simple and the process is helpful once you are familiar with it.
    Comment #3 – Use of the CDX is not so simple and could use some improvements in moving through the system with improved ability to move forward and backward in the process. Overall a good program.
    Comment #4 – It should be disclosed on the CDX program that it is used as a screening tool by the enforcement group at US EPA. I know this is done as companies have been fined for failing to report under one program that had been cross-referenced from reporitng of another program in CDX.

  5. Sheri Peterson permalink
    May 27, 2011

    I support every word in the posting already made below.

    BZ says:

    May 26, 2011 at 10:35 pm

    TRI-ME works fine except if the company official who is authorized to sign the electronic reports is unable to electronically sign (sick, no longer employed, etc.) the requirements for getting a new person authorized are too difficult and can not be done quickly. If this occurs the last week in June the electronic submital may not be possible under the current system.

  6. May 27, 2011

    TRI-ME and TRI-MEweb have worked well for me over the past nine years. Unfortunately it is diffiicult for the certifying official to to use. Most of our General Managers have been “computer challenged”. Even the one or two who are “computer-literate” must start early in order to get their certifications – I usually start the process early in May. Every year over the past 4 years, we have had a new General Manager. One general manager could not get the process completed until AUGUST – he had a very hard time with TRI-MEweb. I hope that I never get a new general manager in June – the report will not be certified on time.

    • Douglas permalink
      June 21, 2011

      I recommend having a backup for the certifying official and for the technical contact.

  7. Roger Harmon permalink
    May 27, 2011

    Tri Me is a good tool. Works fine for me. No issues and have been using for several years.

  8. Dave Like permalink
    June 2, 2011

    The certifying official process is not user friendly. In our industry certifying officials move around in the organization. While the ESA process sounds simple, it takes time, and requires a mill manager to go on line. In order to get the ESA and the certification they will need to have done it several times, or the technical contact (me) has to go to the site and help them. When there are multiple sites this is difficult. In smaller organizations that do not have a technical contact person the mill manager becomes the certifying official, contact, and when you put those together, it creates a very time consuming process.

  9. Eric Steffensen permalink
    June 10, 2011

    Let me start with: I do prefer electronic submittals. It seems that every year I prepare a TRI, the system has changed just slightly enough that I end up in a quandry and have to call the help desk for something. Once I’ve finally completed the 1st TRI the next one is much smoother. The amount of effort to get the Certifying Official set up is usually a challange because most year’s it’s a new person. The Certifying Official is usually unfamiliar with the system, so it also involves a significant amount of time holding that individuals hand through the process. I encourage EPA to leave the hardcopy option available to those facilities who need this last minute option due to last minute IT problems or Certifying Official changes. This will continue to help us ensure compliance with the submittal deadline.

  10. rupert permalink
    June 15, 2011

    I have reported electronically for years, but the last modifications made in the CDX apparently has wiped out all my previous years information or has made it inaccessible to me. This requires that I go back and begin input from scratch. I have chosen to go back to paper reporting. I do not want this option to go away.

  11. Mike Albers permalink
    June 21, 2011

    The web application is easy to use. If electronic filing is required for facilities, then I would hope that all states would be required to accept TRI reports through the TRI-ME web as well.

  12. Miles Koppersmith permalink
    June 21, 2011

    I have used the TRI-ME and TRI-MEweb for our TRI reporting in the past, but have learned that because we only have one Form R to prepare each year and sometimes an occasional Form A it is much simpler and easier to just fill in the form or forms and mail them.

    The reason for this is likely because since we only use the TRI software once each year for one or two forms, we have to go through a steep and time consuming learning curve every year.

    Facilities that only have one or a few forms to prepare each year would likely be much better served by being allowed to continue using the electronically fillable forms currently provided by the EPA which can be completed using a computer and then printed, signed, and mailed.

Comments are closed.