Reviewing TRI Requirements for Consumer & Industrial Goods Client
The client, a leading supplier of carbon, stainless, galvanized and aluminum stamped and fabricated parts and assemblies, reached out to Antea Group requesting support for their Toxic Release Inventory (TRI) requirements for RY2019 and RY2020 for their facility. The challenge was to first research the inventory for the facility for RY2019 and RY2020 to determine if the facility met reporting requirements for the time frame. If research determined that reporting was required, Antea Group would complete the reporting for that reporting year. The client did not complete a TRI report for RY2019 which was due to the regulatory agency by July 1, 2020. Since the client was overdue for their potential RY2019 report, this evaluation was to be completed ASAP to mitigate potential risk for the client. The RY2020 evaluation would be conducted after completion of the RY2019. The objective of the project was to complete the TRI reports prior to the regulatory reporting deadline of July 1, 2021, for RY2020.
Antea Group started by reviewing applicable facility employee working hours and inventory and comparing findings to the EPA reporting thresholds. If employee working hours and inventory for the reporting year were above the threshold, a TRI report would be completed by experienced junior level Antea Group staff and reviewed by Subject Matter Experts prior to submittal and prior to the reporting deadline of July 1, 2021. If the facility was below the reporting threshold for either the employee working hours or for the inventory, Antea Group would provide documentation of the evaluation and submit to the client for their records.
After reviewing the facility employee working hours for RY2019, it was determined that the facility was below the employee working hours threshold and, therefore, a review of inventory was not needed. Evaluation of employee working hours was documented and provided to the client for RY2019.
After reviewing the facility employee working hours for RY2020, it was determined that further evaluation of inventory was required. Inventory evaluation did not yield any reporting requirements therefore a TRI report was not needed. Evaluation of employee working hours and inventory was documented and provided to the client for RY2020.