# Discussion Forum: Electronic Reporting of Toxics Release Inventory (TRI) Data

http://blog.epa.gov/trielectronic



### Discussion Forum Contents

The Discussion Forum is Open [posted by EPA]

................................ .............................. 2 13 Responses to The Discussion Forum is Open

................................ .................... 2
Use of TRI

- MEweb by Reporting Facilities [posted by EPA]

................................ .......... 5 8 Responses to Use of TRI

- MEweb by Reporting Facilities

................................ ..... 5 Expected Benefits of using TRI

- MEweb [posted by EPA]

................................ .............. 8 3 Responses to Expected Benefits of using TRI

- MEweb

................................ ......... 8 Potential Impacts Associated with a Requirement to use TRI

- MEweb [Posted by EPA]

................................ ................................ ................................ ................................ ......................... 9 2 Responses to Potential Impacts Associated with a Requirement to use TRI

- MEweb

................................ ................................ ................................ ................................ . 9 Facility Experiences with EPA’s Electronic Reporting Process [Posted by EPA]

. 10 11 Responses to Facility Experiences with EPA’s Electronic Reporting Process

... 10
General Comments [Posted by EPA]

................................ ................................ .................. 15 12 Responses to General Comments

................................ ................................ ..... 15

The Discussion Forum Is Now Closed [Posted by EPA]

................................ ............... 18 About Electronic Reporting [Posted by EPA]

................................ ................................ .. 19 1 Response to About Electronic Reporting

................................ ............................. 19 Comment Policy [ Posted by EPA]

................................ ................................ ....................... 20 6 Responses to Comment Policy

................................ ................................ ........... 21 Frequent Questions [Posted by EPA]

................................ ................................ ................ 23

1 Response to Frequent Questions

................................ ................................ ........ 24
Useful Resources [Posted by EPA]

................................ ................................ .................... 24

## The Discussion Forum is Open [posted by EPA]

EPA’s Toxics Release Inventory (TRI) Program plans to issue a proposed rule to require the electronic reporting of TRI data. Under this proposed rule, facilities would be required to use the TRI Made Easy Web ( TRI

- MEweb ) application to report TRI data to EPA. EPA invites you to comment on its plans to issue a TRI electronic reporting rule. EPA will not respond directly to any comments received in this forum.

This online discussion forum will remain open and available fo r comment until 5:00 p.m. on July 1, 2011

. Once the discussion forum closes, EPA will place the entire discussion forum, with comments included and attached to their associated post, into the docket identified as

EPA

- HQ

- TRI

- 2011

- 0174, which is accessible via regulations.gov.

Please review the Comment Policy and Frequently Asked Questions pages and then consider the topics posted below.



### 13 Responses to The Discussion Forum is Open

1. Rod Millhof

, May 26, 2011 I have no issue myself, since we have been reporting electronically for years now, but is it fair to mandate that all the small mom and pop businesses around the country have to have computers and internet access to perform this reporting? Just food for th ought.

2. Judy Schnaath , May 26, 2011 I too have no issue since I too have been using it since it was made available. I too agree with Rod Millhof that the small mom and pop businesses should not be made to use Tri

- MEweb. Maybe you make it mandatory for busin ess with over a certain amount of employees.

3. BZ , May 26, 2011

TRI

- ME works fine except if the company official who is authorized to sign the electronic reports is unable to electronically sign (sick, no longer employed, etc.) the requirements for getting a new person authorized are too difficult and can not be done quickly. If this occurs the last week in June the electronic submital may not be possible under the current system.

4. James Smith , May 26, 2011

Comment #1

– using an online forum to solicit input about the required use of electronic reporting automatically biases the results. Only computer users and those familiar with the system will know that the forum is available and have ready access to it. Those typically smaller
entities that do not have dai ly access or use of computers, who are the most likely to be3

opposed, are much less likely to respond to the forum.

Comment #2

– Use of TRI

- ME is relatively simple and the process is helpful once you are
familiar with it. Comment #3

– Use of the CDX is not so simple and could use some improvements in moving through the system with improved ability to move forward and backward in the process. Overall a good program. Comment #4

– It should be disclosed on the CDX program that it is used as a screening tool by the enforcement group at US EPA. I know this is done as companies have been fined for failing to report under one program that had been cross

- referenced from reporitng of another program in CDX.

5. Sheri Peterson , May 27 , 2011 I support every word in the pos ting already made below.

BZ says:

May 26, 2011 at 10:35 pm

TRI

- ME works fine except if the company official who is authorized to sign the electronic reports is unable to electronically sign (sick, no longer employed, etc.) the requirements for getting a ne w person authorized are too difficult and can not be done quickly. If this occurs the last week in June the electronic submital may not be possible under the current system.

6. Al Bressler , May 27, 2011

TRI

- ME and TRI

- MEweb have worked well for me over the past nine years. Unfortunately it is diffiicult for the certifying official to to use. Most of our General Managers have been ―computer challenged‖. Even the one or two who are ―computer

- literate‖ must start early in order to get their certifications

– I usually start the process early in May. Every year over the past 4 years, we have had a new General Manager. One general manager could not get the process completed until AUGUST

– he had a very hard time with TRI

- MEweb. I hope that I never get a new general manager in June

– the report will not be certified on time.

7. Douglas , June 21, 2011 I recommend having a backup for the certifying official and for the technical contact.

8. Roger Harmon , May 27, 2011
Tri Me is a good tool. Works fine for me. No issues and have been using for several years.

9. Dave Like , June 2, 2011 The certifying official process is not user friendly. In our industry certifying officials move around in the organization. While the ESA process sounds simple, it takes time, and requires a4

mill manager to go on line. In order to get the ESA and the certi fication they will need to have done it several times, or the technical contact (me) has to go to the site and help them. When there are multiple sites this is difficult. In smaller organizations that do not have a technical contact person the mill manager becomes the certifying official, contact, and when you put those together, it creates a very time consuming process.

10. Eric Steffensen , June 10, 2011 Let me start with: I do prefer electronic submittals. It seems that every year I prepare a TRI, the system has changed just slightly enough that I end up in a quandry and have to call the help desk for something. Once I’ve finally completed the 1st TRI the next one is much smoother. The amount of effort to get the Certifying Official set up is usually a challan ge because most year’s it’s a new person. The Certifying Official is usually unfamiliar with the system, so it also involves a significant amount of time holding that individuals hand through the process. I encourage EPA to leave the hardcopy option availa ble to those facilities who need this last minute option due to last minute IT problems or Certifying Official changes. This will continue to help us ensure compliance with the submittal deadline.

11. Rupert , June 15, 2011
I have reported electronically for years, but the last modifications made in the CDX apparently has wiped out all my previous years information or has made it inaccessible to me. This requires that I go back and begin input from scratch. I have chosen to g o back to paper reporting. I do not want this option to go away.

12. Mike Albers

. June 21, 2011 The web application is easy to use. If electronic filing is required for facilities, then I would hope that all states would be required to accept TRI reports throu gh the TRI

- ME web as well.

13. Miles Koppersmith , June 21, 2011
I have used the TRI

- ME and TRI

- MEweb for our TRI reporting in the past, but have learned that because we only have one Form R to prepare each year and sometimes an occasional Form
A it is much sim pler and easier to just fill in the form or forms and mail them.

The reason for this is likely because since we only use the TRI software once each year for one or two forms, we have to go through a steep and time consuming learning curve every year.

Facil ities that only have one or a few forms to prepare each year would likely be much better served by being allowed to continue using the electronically fillable forms currently provided by the EPA which can be completed using a computer and then printed, sig ned, and mailed.5 

## Use of TRI

- MEweb by Reporting Facilities [posted by EPA]
For Reporting Year (RY) 2009, approximately 94% of TRI facilities used the Toxics Release Inventory Made Easy Web (TRI

- MEweb ) application to report TRI data. EPA believes that each regulated facility can, or could potentially, gain access to the application since it is available at no charge over the Internet. Informal feedback from facilities that are currently using TRI

- MEweb to submit TRI data has generally been positive. E PA is not aware of any problems inherent in the TRI

MEweb application that would prevent a facility from using it to submit TRI data. If facilities have experienced any major problems in using TRI

- MEweb, EPA would be interested in hearing about them.



### 8 Responses to Use of TRI

- MEweb by Reporting Facilities

1. Rich Kupiec , May 26, 2011 I don’t think EPA has the authority from Congress to require or even allow electronic reporting of TRI. The language in EPCRA talks about forms. When Congress passed EPCRA in 1 986, a form absolutely meant a piece of paper.

I would suggest EPA go back to Congress and get the language of EPCRA revised to require electronic reporting. Why prolong this with comment periods, revised deadlines, and the lawsuits that occur during the r ulemaking process?

There are businesses without Internet access. Sometimes computer systems break down. I think EPA needs to permit regulated entities to submit a limited number of hardcopies of Form R’s and/or Form A’s. Sometimes paper is the appropriate technology.

2. Andrew , June 1, 2011 I believe Rich correct in what he says about the EPA’a authority here.

3. TRI Data User , June 1, 2011 I think it is important to note that statutorily, there is no reference to a form being a paper form. When considering the added benefits to both the regulated community and the EPA that electronic filing offers (e.g., faster filing time, increased data qu ality, quicker turn around of data, etc), there really should be no point of contention here.

Ultimately, EPCRA does not mandate a paper form be required as an option for TRI filers. Assuming Congress intended ―form‖ to be a paper form is irrelevant as the true intention of EPCRA is that of an information disclosure program. To give the public access to information they might not otherwise have. There is no regulatory apparatus under EPCRA 313 requiring facilities to implement pollution reduction measures o r even require them to monitor releases.6

The main intention was of the program was to provide data access. The elimination of paper based forms means quicker access to higher quality data, which was very much the intention of Congress during the creation o f the Act.

EPA’s transition to an electronic

- based reporting requirement is already in process, as paper

based filers need to access the internet to utilize the new fillable files. Which EPA put out to
reduce error and decrease costs associated with consol idating paper

- based form data.

Rich, your comment that this rulemaking will get tied up in law suits

– would they be from the 6% of paper

- filers without internet access? Ultimately, this program is about the community’s right

- to

- know, this rulemaking facilit ates that concept. I completely support it.

4. Rich Kupiec , June 6, 2011 I think eliminating paper

- filers is a good idea . . . a no brainer. I was just trying to say in my earlier post that there is not clear authority from Congress to require electronic repo rting of TRI data, and that there is a potential for a lawsuit in the rule making process. I think having Congress revise the language of EPCRA is a more elegant solution than the rulemaking process.

They talk about publishing a form is the statute. To a c ongressman or senator in 1986, how could this form be anything but a paper copy? Do remember how work use to get done before the Internet, mobile phones, PC’s, and fax machines? The TRI reports I prepared in 1988 were done on a typewriter.

I don’t think yo u can pick and choose the intentions of Congress. Congress certainly intended that the public have access to TRI data. They also intended that EPA enter the data from the paper copies into an electronic database.

I don’t think any of the paper filers will file a lawsuit. I think it would be filed by a trade group representing a portion of the other 94 percent. I don’t know what their motivation might be to obstruct this rule, but it only takes one lawsuit to delay it.

5. TRI Data User , June 7, 2011 I agree with you, it would be more elegant solution to revise the statutory language. However, in this current political climate the easier solution may be through a rulemaking.

Despite the word paper not being mentioned, even if it was Congress’ intention that TR I forms be filed on paper

– programs need to change and develop alongside current technologies. Congress mandated that EPA publish a form (a document with blank fields for the insertion of7

details) and the regulated community provide relevant data. As our te chnologies and capabilities progress, our everyday vernacular does so too

– reading the statute in present day context, electronic reporting is not prohibited.

Congress did not detail the methodology for implementing EPCRA 313 for the specific reason
that th e Agency is more capable and should have the ability to prescribe the form publication
and submission methods.

I hope lawsuits are not a consequence of this rulemaking. But if they did arise, I would imagine it would be from the regulatory language establi shed by the Cross Media Electronic Reporting
Rule. In order for TRI

- MEdesktop/web to become reporting options, EPA had to abide by the requirements outlined in 40 CFR Part 3 (publish a notice in the FR). 40 CFR Part 3.2(c) maybe the only place that states that even if programs utilize this option, it does not require the submission of electronic documents in lieu of paper. But EPCRA328 does say the Administrator can prescribe such regulations as necessary to carry out the chapter

— so I am
curious to see how this all works out.

6. Corporate Representative , June 8, 2011 We have several facilities that report and have regular problems with the process. The TRI

- ME program is not a problem. The CDX registration and getting the certifying official approved is a major problem. Every time we have and organizational change, we have to get a new person approved to electronically sign the report. When you are reporting one chemical and have to go through this cumbersome process every year, it is MUCH MUCH easier to use the paper form. Also, we have been trying for 5 years to get one of our certifying officials listed as ―approved‖ and the HelpDesk can not fix the problem/error message/warning notice.

7. Bill , June 10, 2011 I find it hard to believe there are any companies out t here that don’t have a computer and
internet access. For those that haven’t used the TRI

- ME web site you will find it much easier and quicker then filling out paper forms, especially in future years as it populates the current years form with the informati on from the previous year and you only have to make the changes to reflect what has changed at your facility. It saves time for all of us environmental types to do what we really should be doing, helping to preserve the environment for future generations.

8. OMB Watch , June 1, 2011 The EPA has the authority to require electronic reporting of TRI data under the Government Paperwork Elimination Act (GPEA) and the EPA’s Cross

- Media Electronic Reporting Regulation (CROMERR). The GPEA requires Federal agencies to provide for the ―option of electronic maintenance, submission, or disclosure of information, when practicable as a8

substitute for paper.‖ The CROMERR provides the legal framework for electronic reporting for
al l EPA en vironmental regulations.



## Expected Benefits of using TRI

- MEweb [posted by EPA]

TRI

- MEweb includes a number of data entry and validation features that help facilities prepare and submit accurate TRI data more easily and efficiently. In addition, facilities that have previously used TRI

- MEweb can compare their most recent year’s data to the prior year’s data, which may help them identify potential data errors. In addition, the submission of electronic TRI reports using TRI

- MEweb helps EPA process and make t he data available to the public soon after the July 1 st reporting deadline, since the data have already undergone a number of data quality checks in TRI

- MEweb and EPA does not have to enter the data manually into the
TRI database. EPA would be interested in hearing about facilities’ experiences in using TRI

MEweb

– particularly any benefits they have experienced by using TRI

- MEweb.



### 3 Responses to Expected Benefits of using TRI

- MEweb

1. Dave Like , June 2, 2011 The benefits of using Tri

- MEweb are to the benefit of the EPA staff and to environmental activists. Overall, filling the Form R out in pen and online takes about the same amount of time for me. There may be a problem reading my hand writing though.

2. Jessica , July 1, 2011 I agree that the benefits maybe for EPA, but I definitely benefited from TRI

- Meweb. Being a
user of TRI

- Meweb and having the opportunity to fill out the Form R/A via TRIME being pushed to my desktop, I honestly like the web base application. In a given reporting year, I may report over 20 chemicals with EPA along with two different state agencies reviewing my reports. Before TRI

- MEweb, I was literally doing an arts and crafts project when it came to submitting the cover letters and files. Now , I only have to submit to EPA and the two state agencies are part of the State Data Exchange. Therefore, my local state agencies will receive the data shorrtly after my report is submitted and I do not have to go through the art project when submitting my reports. TRI

- MEweb has definitely saved me time with the submittal process.

3. OMB Watch

, July 1, 2011 We strongly support EPA’s plans to require TRI facilities to submit TRI data electronically using TRI

- MEweb. Electro nic reporting improves the accuracy of data and eases public access to the information, leading to environmental and public health gains. Electronic reporting9

would also be easier for facilities, though we would encourage the agency to make improvements to the TRI

- MEweb based on the complaints of users that it is not intuitive and there are difficulties getting new validating officials approved. Additionally, electronic reporting system will reduce the processing burden on EPA and allow the agency to more

q uickly release the TRI data. Electronic reporting has been shown to substantially reduce administrative costs and burdens. EPA already moved to electronic reporting for new chemical notices under the Toxic Substances Control Act (TSCA) on April 6, 2011. Th e more rapid processing of data could lead to faster identification and analysis of the potential
environmental and health risks associated with toxic chemicals.



## Potential Impacts Associated with a Requirement to use TRI

MEweb [Posted by EPA]

EPA believes that if a facility has used TRI

- MEweb in the past to report any portion of its TRI
data

– including original submissions, revisions, or withdrawals

– then the facility would likely continue its use of electronic reporting rather than use paper TRI reporting forms. Thus, EPA expects that only those facilities that have not yet begun using TRI

- MEweb ( i.e. , ~6% of facilities) would be affected by a requirement to use TRI

- MEweb (except for trade secret information)

. EPA would be interested in hearing f acilities’ views on the potential impacts they might experience

– if any

– if EPA were to require all facilities to utilize electronic reporting
and TRI

- MEweb (except for trade secret information)

.


### 2 Responses to Potential Impacts Associated with a Requir ement to use TRI

- MEweb

1. George Tyrian , June 28, 2011 The point that seems to be missed on requiring TRI

- MEweb is the requirement to complete and submit an electronic signature agreement to certify the report. This has to be done whenever there is a change in the certifying official, which of course cannot be tracked by CDX (i.e., CDX notes that there is a certifying official on record, not that the certifying official no longer works for the company, and that the company does not allow the official to certify reports any longer). I have several facilities goi ng through reorganization in June, therefore, it seems doubtful that the new ESA will be approved in time. For this reason, we are submitting paper TRI reports while the reorganization is completed. This maintains the facility compliance and allows us to w ait on CDX to process the ESA without the threat of penalties that can be occurred due to certifying the report after July 1 caused by the June reorganization10

and changing of certifying officials. Once the ESA is approved and there is no change in

manageme nt, I agree the process runs smoothly. I do not agree with deleting the option to submit paper reports, however, if only to cover these type of incidents.

2. Rav , June 29, 2011 We just had a case in which the certifying official became ill. He was having medical issues while trying to re

- establish/change his password so that he could certify the forms and leave work to tend to his medical problems (having already been in a hospit al for most of the week). It may have been better this year if we would have sent our Form A in paper format even if a processing fee had been required. Also it needs contemplating; the possibility of some type of cyber attack taking place that
renders eit her the TRI

- ME web site or the reporting facilities systems impractical for reporting
online.

One other point is that it is handy to print off a paper form before stating preparation of reports so that all data fields can be reviewed so as to make sure all reporting data is readily available when the attempting a submission electronically.



## Facility Experiences with EPA’s Electronic Reporting Process [Posted by EPA]

EPA expects that the use of TRI

- MEweb to prepare and submit TRI data will ultimately reduce the burden associated with reporting TRI data. At the same time, EPA acknowledges that there are currently requirements regarding facility registration with EPA’s Central Data Exchange (CDX), the designation of a facility’s TRI form Preparer and Certifyi ng Official in TRI

- MEweb

, and the submission of Electronic Signature Agreements (ESAs) that a facility must address before utilizing electronic reporting. To assist reporting facilities, particularly those that are less familiar with electronic reporting , EPA provides step

- by

- step guides and online tutorials regarding the TRI electronic reporting process on the TRI website

. EPA does not expect that the initial electronic reporting registration requirements and ESA process will pose a significant burden on TRI reporting facilities. The Agency would be interested in feedback on facilities’ experiences with the CDX registration process, the ESA process, or other aspects of the TRI

- MEweb electronic reporting process.



### 11 Responses to Facility Experiences with EPA’s Electronic Reporting Process11

1. Michael Broder , May 26, 2011 Electronic submittal has saved time and effort. We operate electrical generation facilities in three states. Two of the states participate in the TRI Data Exchange. The state where most of our plants are located, still requires signed hard copies of Form R s for each chemical. This is quite burdensome. Please encourage or require all states to participate in this data exchange

program.

2. Tom Spalding , May 26, 2011 Sometimes it is not clear that we have actually ―delivered the goods‖ so to speak. I may think I am finished, I can print various documents but I cannot be sure my clicks have honored the correct place in your database.

3. Shelley , May 26, 2011 I believe that I had an issue with using Mozilla Firefox for registration and using TRIMe, Don’t
remember if they get that fixed or not.

If there is going to be a mandate that the software be used, then the EPA will need to make sure that it ―can‖ be used on ―all‖ browser platforms not just Explorer, Even you Apple People.

The registration process was at best con fusing and I think made more difficult than it needed to be. I did not see why they needed to make it an entire separate process.

It seems every year when I go to file

– I have to come up with a new really super Human impenetrable Super hero password that even I can not remember (Even if I wrote it down, somehow I can’t use it again) I believe that it has to be 99 characters with a combination of letters, Numbers and one character that your key board can not make, followed by the name of your elementary sch ool teachers name!.... Really, I could not think of a scenario where some one would want to hack into my EPA account and fill out my TRI reporting for me. Should I ever leave this company or this earth, no one will ever be able to access the TRI account I me an

no one. <

— Humor people, Hope it's ok to still have some.

The truth, I know from experience that I get all stressed out in the beginning with the hassles of trying to get into the program then once I am in... It really is pretty easy. It it not designed th at well

– You have no idea if you are done, not done, could be done before Lunch or before quitting time. Then once you submit

– you wonder if it went ( I do not think that they use "Submit or "Send" I think they used some really sophisticated word like pr ess here if you would like to activate the "unseen intergalactic messaging to the EPATRIMeCDX ESA" ... Its kind of
weird

– it is not layed out like other programs where you hit an OK button, don't know how to12

explain it except it is not like a windows progra m. It's much more unclear what you are supposed to do after entering something. Really an "OK" button is good

– we all know what
that means and does.

Ok, It really is a Good program and I am all for making it mandatory, Don't mind my humor about the progra m, You will see it is easy and you will also see I am correct about somethings, But nothing to stress about.... Smile and remember you read it here first.

Making Waste Management and reporting Fun!

Oh, I just receive this message when pressing the "Post Comm ent" button Error: please enter a valid email address.

4. Mr. Wilson , May 27, 2011 Having used & submitted both paper and electronic versions of the Form R report, I much prefer the ―e‖ version. The help provided on the TRI Me software is terrific. It’s much quicker to complete each report on line and the registration process is simple enough. I can’t believe many companies that process enough of a 313 chemical to report on Form R don’t have internet access so make it mandatory.

5. Mina Oler , May 27, 2011 Electronic reporting is so easy!!! Don’t have to print all the papers involved and worry about getting them mailed.

6. Tim Sheehan , May 27, 2011 I work for a very small company that is required to file these reports. In small companies, people wear multiple hats. We do our best to be accurate and to stay current, but we’re not experts in all of the jobs that have to be done for regulatory reasons. We can’t always afford to hire high priced experts to do these things for us either. We want to comply with all o f the laws and regulations that pertain to our businesses, and we try very hard to do so, but that is a difficult task for small businesses. To say the least. Staying current with all of the regulatory changes coming from multiple agencies is very time con suming. Like other government agency designed user interfaces that I have used, I find the Tri

- Me software difficult to navigate and use. I’m sure that it’s less expensive overall for the agencies to handle less paper, but frankly, the reporting process wa s easier to follow and complete when it was an all paper process. I’m all for saving taxpayer money. I just wish the software was more intuitive. How to make it more user friendly? I don’t know. I’m not a software writer. But I’m sure there are plenty of e xperts who could assist the EPA in that regard.13 7. John E. Horn , May 23, 1011 TRI is great in theory. Even the software navigation can be figured out after a few tries. One year the CDX went down during the last month of reporting but no extensions were give n. The reliability of the CDX is the weak link in the process followed by the help desk. I have, on occasion reported problems or asked questions only to be funneled to an answering machine which did not trigger a response at all in one case and a response days later in others. It appears that one is on their own with the CDX. Any improvement in reliability would be appreciated and a better help response is needed. I would like to see all states required to take the TRI electronically, I have one state that still wants floppy disks !!

8. Corporate Representative , June 8, 2011 We have multiple facilities that report for TRI each year. For the larger facilities the electronic reporting is a great tool. For the small facilities, many that report one chemical, the TRI

- ME part is okay, but the CDX registration is VERY cumbersome, time consuming, and frustrating. Our small facilities frequently change plant managers, and we have to go through that whole process of getting a new certifiying official approved. It’s muc h easier to send in a paper TRI report than to go through the CDX approval process every year. Also, we have one plant manager that we have been trying for 5 YEARS to get properly designated as ―approved‖ for certifying, but the HelpDesk can not fix the pr oblem.

Bottom line

— If there were an easier method of certifying the report, TRI

- ME would be a good
tool.

We have three new plant managers this year for facilities that report ONE chemical. We can print off the TRI paper form (which we fill out anyway, ju st to be sure we have all the necessary information), and have the plant manager sign two copies and mail them off all in less than 30 minutes. Or, we can print off the CDX form and have them sign it, mail it in, and wait to get confirmation that they have been approved. Then we can link them to the facility, and get them set up as the certifying official. Then we can go on line, and fill in the TRI information electronically. Then we can notify the plant manager, and warn them not to delete the email sayin g that the form is ready to certify (and to check their spam folder in case they can’t find the email.) Then they can sign off on the form, and we can go BACK into the system to print of copy the final certified version of the form. All of this takes about three weeks, and countless hours of ―babysitting‖ to be sure everything is done on time.

9. Steve Woock for Weyerhaeuser Company

, June 13, 2011 We believe EPA should maintain availability of additional reporting paths, and at least the editable pdf electroni cally submittable (e

- pdf) form version which the Agency added this year14

as an option. While many of our facilities have mastered the TRI

- MEweb reporting tool, as others have stated here the CDX registration system can be problematic and that means non

flex ibility, added costs, and significant unproductive time. That system requires that both the preparer and the certifier establish accounts with CDX, and the certifying official has to submit an electronic signature agreement some two weeks in advance of the reporting deadline in order to be able to make a timely certification. Others on this blog have provided greater detail of the steps. However, with the e

- pdf, a complete report can be prepared and submitted in a
short amount of time. This is a critical fe ature for reporting flexibility, for example, when personnel change at facilities during or just prior to the reporting window. Such flexibility in reporting methods is important since to our knowledge EPA does not have provisions for TRI reporting extensi ons.

10. Lori , June 21, 2011
The TRI Me reporting tool was just ok to use. Not as user friendly as it could be. I had issues with using Google Chrome as my browser. I would choose the code for Part C in Section 6.2 and would then proceed to save it. I would go back to it later and there would b e no data there. Very frustrating. I had to redo that section several times. Overall, there could be improvements made to the tool but I got through it.

11. Diane , June 22, 2011 Electronic reporting is burdensome for certifying officials who have to go into th e CDX website and fiddle around. If the TRI reports need to be signed at a coporate officer level, there should be a paper option. In my opinion, TRI reports should be submitted by the preparer, without an additional step for certification.

The CDX system is not user

- friendly, and the user should at least be able to change their email address without calling the help desk.15 

## General Comments [Posted by EPA]
EPA plans to publish a proposed rule in late calendar year 2011 which would require TRI
facilities to submit TRI data electronically to EPA using TRI

- MEweb

. The final electronic reporting rule could potentially be effective beginning with RY 2012 (reports due July 1, 2013).



### 12 Responses to General Comments

1. Tom Spalding , May 26, 2011
I am interested in further data simplification through the web.

2. Ronald L. Bedard , May 26, 2011 In any transition technology, such as using the TRI

- MeWeb on

- line system for TRI reporting, there will always be some few members of the regulated community who will be reluctant to embrace this new technology. In many cases this reluctance is legitimate, in others it is not, fueled by emotional, political, lack of knowledge, etc.

The TRI

- MeWeb designers have made every attempt to make the system accessible, usable, accurate and convenient, although they have not succeeded in every attempt to make it intuitive. The system does take some instruction and practice. But for those who are unwilling to or constitutionally unable to absorb the instruction, consultants are readily available for reasonable cost to assume the reporting burden for specific sources.

It has been my personal experience that on

- line reporting is ultimately easier, less error

- prone, faster and more convenient than paper reporting. I am sure it is also less expensive for Government processing. (This may be the very reason it is opposed by consultants.) I am in favor of all Government reporting, Fed eral, State and Local, by web

- based programs, for these

same reasons.

My only suggestion is that software development companies use software principles common to the most widely used software principles in commerce, for example, in text entering and
editin g, screen progressions, line editing, logic sequences, etc. Many software programs, especially those designed by State programmers, are designed with a lack of intuitive logic in screen progressions for entering data, and this places an extraordinary burde n on reference to the operating manual, which most often is unavailable.

3. Jeff Axthelm , May 27, 2011 The system is not bad, but is anything less than intuitive. The CDX website is a navigational nightmare. Facilities should embrace the technology, it does r educe the amount of time needed to fill out the forms, year to year.16

4. Bill Lester , May 27, 2011
I have used the TRI

- MEweb since it became available. To me it is simple and easy to use. I would like to see all 50 states accept the TRI

- ME submission vs paper or state programs.

5. Charles T. Evans

, May 27, 2011 I agree with Jeff Axthelm from above ―The system is not bad, but is anything less than
intuitive.‖ Also, when I have a question, it would be helpful to get a live person on the phone instead of leaving a message.

6. Georganna Lagen , May 27, 2011
I used TRI

- MEweb as a newby to environmental reporting for the 2009 reporting year and found it to be easy and convenient to use. I am sure it is more efficient for regulators and I am all for a good system that saves time and government money. I am also confident that the system will improve over time. One suggestion: Some facilities have commercial or home

grown report writers that take advantage of inventory and other data to produce their reports. A way of inputtin g a flat file or some other convenient data entry format would be a nice feature. My facility does not report a large number of chemicals, so this is not something I would use personally, but I can see an advantage for others.

7. Rex Butler , May 31, 2011

I t hink TRI

- MEweb is an excellent means of reporting and provides a simplified process for getting information to the EPA. It helps to significantly reduce paperwork and provides a far more efficient method of recordkeeping. I agree with others who’ve outline d the shortcomings of the software interfacing. There definitely needs to be a more intuitive and user

- friendly format that will better suit the average stakeholder who might not be as comfortable with the
current format. I’d also like to see more obvious queues for special circumstances like the reporting of dioxins. Specifically, a field indicating ounces as opposed to pounds. Finally, more tweaking of the error checking tool would be good since there are times when error notifications are generated unnec essarily...or perhaps a method for disabling the error warning once you’ve verified that it is unwarranted.

If the percentage of users is so high at this point, it appears that the EPA is already justified in instituting a requirement for this reporting form at so that work can be done to continuously improve it.

8. Mark Vander Weerd , June 1, 2011 The ability to file a paper copy of the TRI Report is a Necessity!17

Each year that I have used the web site I have been unable to complete the process successfully at work. These failures (5 for 5) have happened at work on three different computers and computer networks, and at two different companies. Yes, I did find the TRI

- MEweb easy to use, the security fixes easy to apply, and the help

- desk personal helpful and knowledgeable, but in the end the program would appear to freeze and time out (because of java script errors??). This last go around, I invested over six hours of my time trying to enter the data and failing, when I could have just signed the forms. I am sure it is more efficient for regulators and that it saves the government time and money, but it was a massive waste of our tech support resources and my time. I would much prefer that EPA take 10 minutes of its time to copy our data into its data base. I was only successful in entering the data this year, by using a consultant’s computer. How many people can’t get your web page to run? My experience would
indicat e that number to be 83%.

Everyone should have alternate method of filing the TRI report, as long as the TRI

- MEweb will not run on ever companies computers (our are Dell’s w/MS). And I think the best alternative is mailing EPA a paper copy.

9. Ralph Horton

, July 1, 2011 I would not be surprised to find your 83% is too low! I spent the better part of three days (8 hr + days) trying to submit my TRI. I too received several time out errors and had to log in again. Also, I got an error message over and over sayin g someone else was trying to enter data on the same form I was using (not true

– at least on my end), and many other errors that I don’t want to take the time to type in. Unfortunately, my experience with the help desk was opposite of

yours

– Basically I w as told the problems were due to heavy traffic and I shouldn’t have waited ―until the last minute‖ to submit my TRI

10. Maria Gomez , June 2, 2011
I am a consultant that uses TRI

- MEweb for filing TRI reports for multiple facilities. It is an amazing time saver . I have never run into issues, except one year my certification was stuck in pending, but eventually the help desk fixed the issue.

It is an amazing time saver to have all the data pre

- loaded in your Form R! As someone used to who review many paper copies of Form Rs prior to their submission, I understand the need for EPA to go electronic. The multitude of errors that come in on paper forms can’t happen in the
electronic form

– not to mention hand writing is impossible. It takes a large amount of time and
ef fort to look over paper forms, send them back for corrections, have those edits made. EPA has to do that with paper forms but on top of that will need to enter the data in by hand. EPA’s manual data entry creates the possibility of user error that could ef fect my company’s data.18

I believe the remainder of companies using paper forms will be pleasently surprised with TRI

MEweb.

11. Diana B. ., June 13, 2011
I like the TRI

- MEweb. I don’t particularly care for CDX. That’s a bear to get through. My company has curre ntly set up 2 certifying officials, just in case we have problems...which we did one year.

12. Adam Swercheck , June 30, 2011 EPA should not make TRI electronic reporting mandatory. The option to submit the report electronically or manually (via hard copy) should continue to exist so companies can utilize their discretion based on respective company policies, practices, and resources.

Technical issues with TRI

- MEweb, which are always possible, could potentially undermine the timeliness of reporting or jeopardize a company’s compliance obligation. Without the option to submit manually, the ability to meet the reporting deadline could be severely impacted.

It has been noted that, in reporting year 2009, 94% of the submissions were made electronically. Based on this f act, it seems unnecessary for EPA to consider mandating a voluntary application that already yields such a high usability rate amongst submitters.



## The Discussion Forum Is Now Closed [Posted by EPA]

The Discussion Forum collected comments up through July 1, 2011. Thank you very much for your participation.19 

## About Electronic Reporting [Posted by EPA] EPA’s Toxics Release Inventory (TRI) Program plans to issue a proposed rule to require the electronic reporting of TRI data. Under this proposed rule, facilities would be required to use the TRI Made Easy Web ( TRI

- MEweb ) application to report TRI data to EPA. EPA invites you to comment on its plans to issue a TRI electronic reporting rule. This online discussion forum will remain open and available for comment until 5:00 p.m. on July 1, 2011. Comments received will be posted to the docket identified as EPA

- HQ

- TRI

- 2011

- 0174. EPA is providing this discussion forum prior to publishing the proposed rule so that it can
receive and consider information and fe edback from TRI reporting facilities; State, local, and tribal officials; various TRI data users and stakeholders (industry, academia, nongovernmental organizations, community groups, etc.); as well as the general public. The feedback received
from this o nline forum will help EPA develop a proposed rule that considers various perspectives, while also fostering efficient TRI reporting and data dissemination processes.

Comments received before 5:00 p.m., July 1, 2011, will be included in the public docket, and EPA will provide a link to the docket once it is posted. EPA currently plans to publish a proposed rule in late calendar year 2011. Please consult the comment policy prior to posting a

comment.



### 1 Response to About Electronic Reporting

1. Tom Hankins , May 27, 2011 The web based reporting is an excellent tool for reporting and with corporate IT policies for only corporation approved software on PCs this avoids a lot of hassle for the reporting sites.
Is there a method or section in the TRI

- MEweb reporting system for a person at a corporate office to be able to collect all the data from the corporation’s sites? Most businesses would like to track their individual sites, corporation divisions, and the corporation as a whole for trends
in releases a nd to use the data to set goals for release reductions. The CDX needs to have a section to support not only supplying information to the public but also to the reporting facilities and their business organizations. This system would reduce the
need for the corporations to have the IT support to maintain software databases and structure

to re

- manage the data that is being maintained for outsider access already. It would just be a matter of access security to the CDX and a hierarchy structure for the business organization.20 

## Comment Policy [ Posted by EPA]
We encourage you to share your thoughts as they relate to the topic being discussed. We
review and post comments according to the policy below. The views expressed in comments reflect those of the author and do not necessarily reflect the official views of the U.S. Environmental Protection Agency or the Federal government. We want to publish your comments, but we expect comments generally to be courteous. To that end, we have established the following policy.

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– 5:00 p.m. Monday through Friday except for on Federal holidays.21

We intend to review and post comments submitted at other times as soon as possible on the next business day.

This site will be ope n for comments until 5:00 p.m. on July 1, 2011. EPA will not respond directly to any comments received in this forum. However, EPA will place the entire discussion forum, with comments included and attached to their associated post, into the docket, whic h is accessible via regulations.gov. We will post a link to the docket once the discussion forum is
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Comments may also be submitted by mail and must arrive prior to the closing of this discussion forum at 5:00 p.m. on July 1, 201 1. Please mail written comments to David Turk, Toxics Release Inventory Program Division, Mailcode 2844T, OEI, Environmental Protection Agency, Ariel Rios Building, 1200 Pennsylvania Ave., NW, Washington, DC 20460. All comments received by mail that adhe re to the requirements described on this page will be transcribed and posted as soon as possible.

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. Thank you for taking the time to read this comment policy. We encourage your participation in this discussion and look forward to an active exchange of ideas.



### 6 Responses to Comment Policy

1. Charles Wurm , May 26, 2011 I think this is a good idea. It will save time and money and make it easier to review chemical storage activities; track increases, decreases, etc. Please require the states to accept this type of reporting. Thanks , cw

2. Charles Wurm

, May 27, 2011 http://blog.epa.gov22 3. John Bilski , May 27, 2011 Pennsylvania made a similar mistake. They sent out new rules for land application of materials by email. All of the amish and many of the menonite farmers were left in the dark since they do not use computers. I am not sure how their businesses would/could comply with an electronic reporting requirement.

4. Robin Wood , May 31, 2011 In general, I am not opposed to ―requiring‖ electronic reporting. Howev er, in some cases, there are computer malfunctions, power outages, and/or if a facilitiy is a first time submitter electronically, it requires more time to get responsible official passwords approved, etc., all that could result in the report being late.

T here should be provisions for submitting paper copies in the event one of the above has or is happening, without penalty.

5. Robin Wood , May 31, 2011 Although it is difficult to think of some companies without having computers and/or internet access, I think this should be thoroughly investigated prior to making this requirement.

6. Dorothea E. Graddy , June 30, 2011 I currently use the TRI Me Web for my reporting requirements and it works well for my facility. I think it is a good idea to have electronic reporting available. However, I agree with the comment made on May 31, 2011 at 2:42pm that there should be provisio ns for submitting paper copies in the event there are computer malfuntions without penalty.23 

## Frequent Questions [Posted by EPA]

How may I participate in the conversation? The discussion forum is open to the public for commenting. Comments are moderated according to our comment policy

. The views expressed in comments do not necessarily reflect the official views of the U.S. Environmental Protection Agency or the Federal government. Comments may be posted online or submitted by mail. If sent by mail, comments must arrive prior to the closing of this discussion at 5:00 p.m. on July 1, 2011. Please send written comments to David Turk, Toxics Release Inventory Program Division, Mailcode 2844T, OEI

, Environmental Protection Agency, Ariel Rios Building, 1200 Pennsylvania Ave., NW, Washington, DC 20460. All comments received by mail that adhere to our comment policy will be transcribed and posted as soon as possible.

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.24

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### 1 Response to Frequent Questions

1. Allen Kinsler , May 26, 2011 Making reporting consistent is always a good idea. It allows programs to automatically prepare data for the rports.

The only comment is that all states must be required to use it

– without ―special‖ exceptions.



## Useful Resources [Posted by EPA]

Toxics Release Inventory (TRI) Program

TRI

- MEweb Resources (including tutorials on how to use TRI

- MEweb )

CDX Login Page
The TRI Customer Service Page