Another calendar year is drawing to a close; where does the time go? As I plan my own holiday celebrations and commitments, environmental professionals like me have another type of planning to keep in mind. With the start of each new year, we face regulatory submission deadlines reporting data from the past year including Submission of the EPA Community Right to Know (CRTK) Survey -- a Federal act with each state managing their own program due March 1 st and EPA Toxics Release Inventory (TRI) due July 1 st.
Just like Christmas shopping, the compilation and reporting process is less stressful and yields better results if I begin early and develop a strategy with deadlines in mind. As such, here is my personal January 1 st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle.
1) Start requesting and gathering all the information needed for these submittals.
- 2010 purchasing records of the chemicals you are reporting
- 2010 production logs where these chemicals are used
- 2010 waste information
- 2010 recycling information for any reported chemicals that were recycled
- 2010 air emission inventory
2) Develop and write down a comprehensive set of due dates so that you have time to review information as it comes in. If the requested data is late, have a plan to follow up or find another source because the deadline is not going to change!
3) Review the rules early to avoid unpleasant surprises. For example, The Environmental Protection Agency (EPA) finalized a rule effective November 10, 2010 which added 16 chemicals to the list of TRI reportable chemicals. To ensure that you are reporting what you need to report, check the TRI database on the EPA website: http://www.epa.gov/tri/trichemicals/index.htm.
4) Allow time for anomalies and additional fact-finding. As Charles Peruffo described in a recent EHSWire blog about filing the NJ PPA, reported amounts from different sources may not match. If you find that is the case, its your job to figure out why and that always adds more time to the already challenging process.
Emilcotts clients depend on our environmental knowledge and organizational capabilities to gather the required information on time and give them fair warning if there is trouble ahead. My best advice for successful reporting-dont wait until the last minute. Much like shopping for Christmas on Dec 24th, waiting until February to gather the information for the CRTK or starting in June for the TRI will be stressful and could result in costly errors. So, what am I doing today? Like Santa, Im checking my own list twice!
Have you been meeting the CRTK and TRI deadline? If yes, can you offer additional advice or do you have particular steps that you take to get the submission process rolling?