The EPA finalized its rule adding 12 chemicals to the list of chemicals subject to Toxics Release Inventory (TRI) reporting, which provides important information about how these chemicals are being managed by facilities in a given community.

“Available data show these chemicals have moderately high to high human health toxicity and/or are highly toxic to aquatic organisms,” states the EPA TRI Program website. The EPA has classified one of the chemicals as a persistent, bioaccumulate, and toxic (PBT) chemical and designated it as a chemical of special concern with a 100-pound reporting threshold: 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran (HHCB).

The chemicals now subject to TRI reporting requirements are:

  • Dibutyltin dichloride; 683-18-1;
  • 1,3-Dichloro-2-propanol; 96-23-1;
  • Formamide; 75-12-7;
  • 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran; 1222-05-5;
  • N-Hydroxyethylethylenediamine; 111-41-1;
  • Nitrilotriacetic acid trisodium salt; 5064-31-3;
  • p-(1,1,3,3-Tetramethylbutyl)phenol; 140-66-9;
  • 1,2,3-Trichlorobenzene; 87-61-6;
  • Triglycidyl isocyanurate; 2451-62-9;
  • Tris(2-chloroethyl) phosphate; 115-96-8;
  • Tris(1,3-dichloro-2-propyl) phosphate; 13674-87-8; and
  • Tris(dimethylphenol) phosphate; 25155-23-1.

“TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment,” states the Agency website. “U.S. facilities in different industry sectors must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery and treatment. (A ‘release’ of a chemical means that it is emitted to the air or water or placed in some type of land disposal.)”

Identifying the 12 chemicals

The history of this rule began in May 2014 when the EPA received a petition from the Toxics Use Reduction Institute (TURI) requesting that the EPA add 25 chemicals to the TRI list of chemicals under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA).

The Agency evaluated the 25 chemicals to determine if they met the TRI listing criteria of EPCRA §313(d)(2). In response to the petition, the EPA added 12 of the 25 chemicals to the TRI chemical list in a final rule published on November 30, 2022. In separate, unrelated actions, 3 of the 25 chemicals (1-bromopropane; nonylphenol; and 1,2,5,6,9,10-hexabromocyclododecane) were previously added to the TRI chemical list.

Of the remaining 10 chemicals, the Agency determined that the available data for 9 chemicals was not sufficient for it to find that the chemicals meet the EPCRA §313 listing criteria for human health or ecological effects. Regarding the final chemical, the EPA did not add octabromodiphenyl ether, as the EPA’s production volume screen indicated that no TRI reporting forms would be filed for this chemical.

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599. 

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