TRI reporting requirements apply only to some sources of toxic chemical pollution. The 2001 TRI data utilized in Scorecard are based on reports filed by three kinds of pollution sources:
1) Facilities engaged in manufacturing operations in specific industries (Standard Industrial Classification Codes 20 through 39) (the "original" industries covered by TRI since 1988).
2) Facilities in the following industries: metal mining, coal mining, electrical utilities, RCRA Subtitle C hazardous waste treatment and disposal facilities, chemicals distributors, petroleum terminals, and solvent recovery services (the "new" industries covered by TRI beginning in the 1998 reporting year).
3) Federal facilities such as military bases.
TRI REPORTING EXEMPTIONS AND THRESHOLDS
Facilities in industries covered by TRI are not required to report on chemical releases or waste generation if they are small businesses or use less than certain threshold quantities of TRI chemicals. Facilities are only required to report if they have ten or more full-time employees.
Facilities only need to report if they manufacture or process over 25,000 pounds of at least one listed TRI chemical, or use more than 10,000 pounds of at least one TRI chemical. Facilities are not
required to report if a listed chemicals is present at concentrations of less than 1.0% (or, if a toxic chemical is classified by the U.S. Occupational Safety and Health Administration as a carcinogen, 0.1%) in products received or manufactured by facilities.
In October 1999, EPA modified TRI regulations to lower the reporting threshold for some persistent bioaccumulative compounds. Thresholds have been lowered to 10 pounds a year for a dozen chemicals, 100 pounds for five others, and 0.1 grams for dioxin. These lower thresholds became effective with TRI data for reporting year 2000.
See EPA's Guidance on TRI for complete details on how specific industrial sectors or chemicals are reported.
WHICH MAJOR POLLUTION SOURCES ARE MISSING FROM TRI?
The TRI data included in Scorecard does not include pollution released by:
Service businesses like dry cleaners or auto service stations
Sewage treatment plants
Agricultural application of pesticides
Releases from contaminated sites like landfills or abandoned industrial facilities (such as Superfund or "brownfields" sites)
LIMITS OF TRI CHEMICAL RELEASE AND WASTE MANAGEMENT DATA
Pollution sources that are not covered by TRI probably account for the vast majority of environmental releases of most chemicals. EPA's National Toxics Inventory, which estimates pollution releases from mobile and area sources as well as the point sources covered by TRI, indicates that 90% of hazardous air pollutants are released to air by mobile and area sources.
TRI's reporting requirements apply to only a small part of the total life-cycle of toxic chemical production, use and disposal in the U.S. While the 2002 TRI reported that 4.3 billion pounds of toxic chemicals were released to the environment, a thousand times more than that - approximately 6 trillion pounds of chemicals - are produced in the U.S. annually. The fraction of these that are toxic or that are released into the environment is presently unknown.