TRI Data Considerations
As with any dataset, there are multiple factors to consider when reviewing results or using Toxics Release Inventory (TRI) data. Key factors associated with the data presented in the TRI National Analysis are summarized below; for more information see Factors to Consider When Using Toxics Release Inventory Data.
TRI reporting is required for facilities that meet the reporting criteria under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). EPA investigates cases of EPCRA non-compliance and may issue civil penalties, including monetary fines. Since the TRI Program’s creation, EPA has taken more than 3,500 TRI-related enforcement actions. For more information, see the TRI Compliance and Enforcement webpage.
- Covered chemicals and sectors: TRI does not include information from all facilities or industry sectors that may manage TRI chemicals in waste, nor does it cover every chemical manufactured, processed or otherwise used by facilities in the United States. The complete TRI chemical list and a list of the sectors covered by the TRI Program are available on TRI’s GuideME website.
- Reporting thresholds: Facilities in covered sectors that manufacture, process, or otherwise use TRI-listed chemicals above listed threshold quantities within a calendar year and employ at least ten full-time equivalent employees are required to report to the TRI Program. For most TRI chemicals, the threshold quantities are 25,000 pounds of the chemical manufactured or processed, or 10,000 pounds of the chemical otherwise used during a calendar year.
- TRI trends: The TRI National Analysis presents trends for the last ten years (2013-2022). While the TRI chemical list has changed since 2013, the quantities of the newly added chemicals released account for less than 0.1% of national totals. To simplify the trend presentations and to enable reproducibility, all chemicals are included in the trend figures, including those that have not been on the TRI chemical list for all ten years of the trend.
- Risk: TRI data can be a useful starting point to help evaluate whether chemical releases may pose potential risks to human health and the environment. However, the quantity of a chemical release alone is not necessarily an indicator of exposure to the chemical, or the potential health or environmental risks posed by the chemical. Note that:
- Chemicals on the TRI list vary in toxicity; and
- The extent of exposure to a chemical depends on many factors such as where the chemical is released, how it is released (i.e., into the air, water, or land), the chemical’s properties, and what happens to the chemical in the environment.
- For more information on the use of TRI data in exposure and risk evaluations, see the TRI and Estimating Potential Risk webpage and Potential Risks from TRI Chemicals in the Releases section.
- Data quality: Facilities use their best available data to determine the quantities of chemicals they report to TRI. Each year, EPA conducts an extensive data quality review that includes contacting facilities about potential errors in reported information. This data quality review process helps ensure that the TRI National Analysis is based on accurate and complete information.
- Data presentation: The National Analysis is intended to convey key messages from the TRI data submitted by facilities. At times, the National Analysis may simplify certain technical details when they don't have a significant impact on the information presented.
- Late submissions, revisions and withdrawals: TRI reporting forms submitted to EPA or revised after the July 1 reporting deadline may not be processed in time to be included in the National Analysis. After EPA’s data quality review, the TRI data are frozen in October and this dataset is used to develop the National Analysis. Any revisions, late submissions, or withdrawals made after this date are not reflected in the National Analysis but are incorporated into the TRI dataset during the spring data refresh and will be reflected in the next year’s National Analysis.
Impact of Late Submissions and Revisions on the National Analysis
EPA compared the data released in October 2022 and used for the 2021 National Analysis to the updated version of these data released in October 2023. This allowed EPA to assess how late submissions and revisions to submitted data might have changed the information presented in the 2021 National Analysis, had they been included in the dataset. National waste management and release quantities were 0.1% and 1.5% different, respectively, than what was shown in the 2021 National Analysis.
Quick Facts for 2022
In this figure, the value for “Disposal or Other Releases” in the waste managed pie chart (3.30 billion lb) is greater than the value for “Total Disposal or Other Releases” (3.28 billion lb). There are several reasons why these quantities differ slightly, including:
- Double counting: Total disposal or other releases (the 3.28 billion pound value in the figure) removes "double counting" that occurs when a facility reports transfers of TRI chemicals in waste to another TRI-reporting facility. For example, when Facility A transfers a chemical off site for disposal to Facility B, Facility A reports the chemical as transferred off site for disposal while Facility B reports the same chemical as disposed of on site. In processing the data, the TRI Program recognizes that this is the same quantity of the chemical and includes it only once in the total disposal or other releases metric. The waste managed metric in TRI, however, considers all instances where the TRI chemical in waste is managed (first as a quantity sent off site for disposal and next as a quantity disposed of on site), and includes both the off-site transfer and the on-site disposal. Typically, double counting accounts for most of the difference between the two release quantities shown in the TRI Quick Facts figure.
- Non-production related waste managed: Non-production-related waste refers to TRI chemical waste that results from one-time events, remedial actions, catastrophic events, or other events rather than standard production activities. Facilities typically report managing these waste quantities as on-site releases or transfers off site which are included in a facility’s total disposal or other releases but not in the overall total for waste managed.
For more information on TRI, the chemicals and industry sectors it covers, the reporting requirements, and to access TRI data, visit the TRI website.
This page was published in March 2024 and uses the 2022 TRI National Analysis dataset made public in TRI Explorer in October 2023.