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 for 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 thought.

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 business 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 daily access or use of computers, who are the most likely to be 
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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 posting 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 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.

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 a 
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mill manager to go on line. In order to get the ESA and the certification 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 challange 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 available 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 go 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 through 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 simpler 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.

Facilities 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, signed, and mailed.
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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. EPA is not aware of any problems inherent in theTRIMEweb 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 1986, 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 rulemaking 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 quality, 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 or even require them to monitor releases. 
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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 of the Act.

EPA’s transition to an electronic-based reporting requirement is already in process, as paperbased filers need to access the internet to utilize the new fillable files. Which EPA put out to 

reduce error and decrease costs associated with consolidating 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 facilitates 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 reporting 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 congressman 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 you 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 TRI 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 of 
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details) and the regulated community provide relevant data. As our technologies 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 the 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 established 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 there 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 information 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 a 
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substitute for paper.‖ The CROMERR provides the legal framework for electronic reporting for 

all EPA environmental 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 the data available to the public 

soon after the July 1st 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 TRIMEweb – 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. Electronic reporting improves the accuracy of data and eases public access 

to the information, leading to environmental and public health gains. Electronic reporting 
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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 

quickly 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. The 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 TRIMEweb [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 facilities’ 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 Requirement 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 going 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 wait 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 reorganization 
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and changing of certifying officials. Once the ESA is approved and there is no change in 

management, 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 hospital 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 either 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 Certifying 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 

Process
11

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 Rs 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 confusing 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 school 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 mean 

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 that 

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 press 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 to 
12

explain it except it is not like a windows program. 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 program, 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 Comment" 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 of 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 consuming.

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 was 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 experts who could assist the EPA in that regard.
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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 given. 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 much 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 problem.

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, just 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 

saying 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 electronically submittable (e-pdf) form version which the Agency added this year 
14

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 nonflexibility, 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 feature 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 extensions.

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 be 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 the 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, Federal, 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 

editing, 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 burden 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 reduce the amount of time needed 

to fill out the forms, year to year.
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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 homegrown report writers that take advantage of inventory and other data to produce their reports. 

A way of inputting 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 think 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 outlined 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 unnecessarily...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 format 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!
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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 

indicate 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 saying 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 was 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 

effort 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 effect my company’s data.
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I believe the remainder of companies using paper forms will be pleasently surprised with TRIMEweb.

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 currently 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 fact, 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.
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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 feedback 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 online 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 and 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.
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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.

We reserve the discretion not to post any comments that:

 contain obscene, indecent, or profane language;

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 are far off-topic;

 make unsupported accusations; or

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to the topic or another comment are acceptable.)

We do not edit comments to remove objectionable content, so please ensure that your 

comments contain none of the above. We will not post comments containing objectionable 

content. Additionally, we will not post comments from EPA employees acting in their official 

capacity. Any such comments should be submitted through internal channels. This forum is 

intended solely to provide a discussion forum for external stakeholders. Subject to EPA 

discretion, identical comments may not be posted to the discussion forum.

Do not submit copyrighted or other proprietary material in any form unless you clearly 

indicate that you have permission to do so. By posting your comments or other work, you 

grant EPA and anyone viewing the EPA Web site irrevocable permission to copy, distribute, 

make derivatives, display or perform the commenter’s work publicly and free-of-charge.

If you are a reporter, please send questions to the EPA Newsroom through normal channels 

rather than by submitting questions here as comments. It is our policy not to post reporter 

questions.

We recognize that the Internet is a 24/7 medium and your comments are welcome at any time. 

However, given the need to manage Federal resources, we intend to review and post 

comments from 8:30 a.m. – 5:00 p.m. Monday through Friday except for on Federal holidays.
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We intend to review and post comments submitted at other times as soon as possible on the 

next business day.

This site will be open 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, which is 

accessible via regulations.gov. We will post a link to the docket once the discussion forum is 

closed to further comment.

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, 2011. 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 adhere to the requirements described on this page will be 

transcribed and posted as soon as possible.

In some cases we ask you to provide your name, organization, and e-mail address, although 

providing this information is optional. We request your name and organization to make it 

easier to carry on a conversation. For this reason, we publish your name along with your 

comment. We ask for your e-mail address so that we can contact you if necessary. It is our 

policy not to publish your e-mail address.

To protect your privacy, please do not include information (e.g., an e-mail address or phone 

number) in the text of your comment that identifies you. Please read the privacy discussion in 

Frequent Questions. You can find additional guidance as to how EPA regards privacy issues 

within the privacy policy provided on EPA’s main Web site.

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.gov
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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. However, 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.

There 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 provisions for submitting 

paper copies in the event there are computer malfuntions without penalty.
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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.

In what order do the posts appear?

Posts are added in reverse chronological order, with the newest post at the top of the home 

page. To find any older posts that do not appear on the main page, you can use the ―previous 

post‖ function at the bottom of the page.

Why do you ask for my name, organization, and e-mail address when I leave a

comment? How do you protect my privacy?

Providing your name, organization, or e-mail address is optional. We ask for your name and 

organization to make it is easier to carry on a conversation and to provide context for your 

comment, so we will publish this information along with your comment. If you choose to 

include your organization, please use the format ―Name (Organization)‖ [e.g., "John Smith 

(EPA)"].

We ask for your e-mail address so that we may contact you if necessary. We will not publish 

your e-mail address. To protect yourself, please do not include information that identifies your 

contact information in the body of your comment, such as e-mail addresses or phone numbers. 

We do not edit comments, so we will not be able to publish comments containing such 

information.

Beyond the issues above, we treat privacy issues associated with this discussion forum under 

our privacy policy provided on EPA’s main website.
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What is a permalink?

A permalink is a link to a post’s unique Web page. This is the link best used if you want to 

bookmark a specific entry.

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A trackback is a link to a post’s unique Web page which automatically notifies us that you have 

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How can I find out more?

If you want to leave a comment on a post, the ―Comments‖ link at the end of the post’s text will 

take you to the appropriate comments box. Reporters, please send your questions 

using contacts provided in EPA’s newsroom. Read more about EPA’s mission, who we are,

what we do, and more

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