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APPENDIX B

REPORTING FORM R AND FORM A CHANGES AND ASSOCIATED 

INSTRUCTION REVISIONS
61

Appendix B: Reporting Form R and Form A Changes and Associated Instruction Revisions

New revisions to the Form R and Form A instructions follow. These revisions are aimed at 

improving the user experience by clarifying the intent of questions and reducing confusion. An 

overview of changes made in this version of the Form R and Form A is provided in Table B-1 

below. Revisions to the instructions are identified in the subsequent pages using underlined text

for new text and strikeout for deleted text. Sections of the instructions that remain unchanged are 

not referenced. To review the existing instructions, Toxic Chemical Release Inventory Reporting 

Forms and Instructions – Revised 2012 Version, visit http://www.epa.gov/tri/report/index.htm.

Revisions to Form R and Form A

Table B-1: Overview of Form R and Form A Revisions

Please refer to specific sections in the following text for details

Form Revision Rationale Form

1 Add an optional extension to all phone 

numbers to allow facility 

representatives to provide the extension 

needed for a direct connection. (Part I: 

Section 4)

The phone number provided is often the main company line. Many 

companies have extensions for direct connection with employees. 

Addition of the optional phone extension would expedite calls to 

facilities and help ensure the EPA can reach facilities when needed. 

R/A

2 Add an optional field for the reach 

code corresponding with the receiving 

water body for each surface water 

discharge. (Part II: Section 5.3)

40 CFR §372.85(b)(7) requires facilities to include on their form Rs 

“the name(s) of receiving stream(s) or water body to which the 

chemical is released.” Water body name is not a unique identifier, 

however, and a single water body can cover a large and disparate 

geographic area. Therefore, in order to model the potential impact of 

chemical discharges on downstream and intermediate receiving water 

bodies, EPA and other regulatory agencies, researchers, and analysts 

use the 14-digit codes, called reach codes, assigned in the USGS’s 

National Hydrography Dataset (NHD). These reach codes identify a 

continuous piece of surface water with similar hydrologic 

characteristics. Once linked to the NHD by their reach code, the 

upstream/downstream relationships of water-related entities such as 

drinking water supplies, fish habitat areas, or wild and scenic rivers 

can be analyzed using software tools ranging from spreadsheets to 

Geographic Information Systems (GIS) and the potential cumulative 

environmental impacts of TRI chemical can be assessed.

While optional, this field would populate automatically when a user 

selects their receiving water body on the map provided in the TRIMEweb interface for this section. EPA is also looking into whether 

TRI-MEweb could pre-populate this field in cases where the reach 

code is included on facilities’ discharge permits.

R

3 Move the header “5.5 Disposal to land 

on-site” to precede Sections 5.4 and 5.5 

on Form R so that it covers both 5.4 

and 5.5. Re-word 5.4.1 and 5.4.2 to fit 

under the new header as follows: 

This change would clarify that releases to underground injection wells 

are considered releases to land.

R
62

Section 5.4-5.5: Disposal to land onsite, Section 5.4.1: Class 1 

Underground Injection Wells, Section 

5.4.2 Class II-V Underground Injection 

Wells. (Part II: Section 5.4-5.5)

4 Provide the heading, “Productionrelated waste managed” for Sections 

8.1-8.7 and re-label Section 8.8 “Nonproduction-related waste managed,” 

with a footnote indicating that this 

Section “includes quantities released to 

the environment or transferred off-site 

as a result of remedial actions, 

catastrophic events, or other one-time 

events not associated with production 

processes” (Part II: Section 8.1-8.8).

Form R does not currently indicate that quantities reported in Sections 

8.1 through 8.7 are exclusive of the amounts reported in Section 8.8. 

Adding the labels “Production-related” and “Non-production-related” 

waste managed would mirror the terminology used to describe these 

data elements in TRI tools and the TRI National Analysis and clearly 

delineate which releases and transfers to report in which Sections. 

R

5 Add checkboxes to indicate whether 

the facility has provided a “Production 

Ratio” or an “Activity Ratio” (Part II: 

Section 8.9).

Section 6607(b)(5) of the PPA requires facilities to submit a ratio of 

production in the reporting year to production in the previous year. 

Where some variable other than production is the primary influence on 

waster characteristics or volumes, facilities may base this ratio on the 

primary influencing variable. The existing form does not specify 

which type of ratio was used and thus limits the utility of this metric. 

Additionally, “production or activity ratio” is a more precise 

description of this Section than “production ratio or activity index” 

since the metric reported is a ratio regardless of whether production or 

some other activity variable is used.

R

6 Add a new column where the facility 

can provide an optional percentage 

range indicating the estimated annual 

reduction in chemical waste generation 

associated with a given source 

reduction activity (Part II: Section 

8.10).

This change would make it easier to report and assess the effectiveness 

of different types of source reduction activities and thus promote the 

adoption and recognition of successful pollution prevention practices. 

To simplify reporting, facilities would report their estimates using one 

of six percentage ranges (just as treatment efficiencies are reported in 

ranges in Section 7). While optional, completion of this Section would 

be a simple way for a facility to highlight positive steps it has taken to 

reduce releases of toxic chemicals to the environment.

R

7 Provide optional barrier codes that 

facilities can use to indicate why they 

could not implement any source 

reduction activities during the reporting 

year (Part II: Section 8.11).

Facilities are required to pick a code if they perform a new source 

reduction activity. However, there is currently no way for a facility to 

indicate why they didn’t implement a source reduction activity. While 

these codes would be optional, it would allow EPA to assist facilities 

in overcoming barriers to implementing source reduction activities.

R

8 Allow facility to categorize optional 

free-text information entered in 

Sections 8.11 and 9.1 by selecting from 

a list of topics provided in TRI-MEweb 

(Part II: Section 8.11 and Section 9.1).

Letting facilities flag their free-text entries as relevant to certain 

commonly-used topics would improve TRI tools that display free-text 

information, data quality efforts, and overall analytical utility of the 

dataset.

R
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Revision to TRI-MEweb

Additionally, the EPA proposes modifying TRI-MEweb to collect, as optional, information that 

some facilities have historically provided, unsolicited, to EPA on matters related to TRI 

(collectively called miscellaneous TRI documents). Examples of these miscellaneous TRI 

documents include updates to contact and location information for the facility and reasons for nonreporting. Some of this information is useful to the Agency and could be useful to the public. 

Currently, the EPA receives this unsolicited information on paper. 

This proposed modification would allow for an online means for the EPA to receive miscellaneous 

documents, reducing the cost of processing their submission aligning how EPA processes such 

documents with the recent requirement to submit TRI reporting forms electronically. In other 

words, with this change, facilities could use TRI-MEweb to provide details on specific categories 

of information that they have been providing on a voluntary basis to the EPA throughout the 

existence of the program (e.g., supplemental information on updates to the facility’s name, status, 

location, and/or parent company; supplemental information on updates on whom to contact for 

technical and/or public matters; and reasons for not reporting (indicating the facility did not meet 

thresholds or did not report for any other appropriate reason)). Receipt and processing of this 

information would not affect any reporting forms certified and submitted to the agency, but rather 

would allow facilities to provide an electronic means to submit contextual information concerning 

their facilities that can enhance the context of TRI data for the EPA as well as for the public.

Specific Form Revisions and Associated Instruction Revisions 

PART II CHEMICAL-SPECIFIC INFORMATION 

Section 5. Quantity of the Toxic Chemical Entering Each Environmental Medium Onsite 

5.3 Discharges to Receiving Streams or Water Bodies 

Form Revisions: Added column for “Reach code (optional)” next to “Stream or Water Body 

Name” 

Instruction Revisions: See underlined and strikeout text which follows.

In Section 5.3 you are to enter all the names of the streams or water bodies to which your facility 

directly discharges the EPCRA Section 313 chemical on which you are reporting. In addition, you 

may also enter the 14-digit reach code assigned to each receiving water body by the USGS’s 

National Hydrography Dataset (NHD). TRI-MEweb will automatically populate the appropriate

code field when you select your receiving waterbody on the map provided in the user interface for 

this section. You may also be able to find the correct reach code by consulting readily available 

sources, such as your discharge permit. Note that reach data are not available for Alaska, Guam, 

American Samoa and the Northern Mariana Islands, so facilities located in these areas should 

leave this field blank.

EPA maps all reported discharges to reaches for purposes of its Risk Screening Environmental 

Indicators (RSEI) model, Discharge Monitoring Reports (DMR) Pollutant Loading Tool, and for 
64

other analyses. Identifying your stream or water body by entering a reach code in this section 

ensures that EPA will map your discharges to the correct reach. 

Section 8. Source Reduction and Waste Management

Form and Instruction Revisions: Title changed from “Disposal or Other Releases, Source 

Reduction, and Recycling Activities” to “Source Reduction and Waste Management.” Provided 

heading, “Production-related waste managed” for Sections 8.1-8.7. Section 8.8 re-labeled “Nonproduction-related waste managed,” with a footnote indicating that this Section “includes 

quantities released to the environment or transferred off-site as a result of remedial actions, 

catastrophic events, or other one-time events not associated with production processes.”

8.9 Production Ratio or Activity Ratio 

Form Revisions: Question changed to “Production Ratio or Activity Ratio (select one and enter 

value to right).” Checkboxes added next to “Production Ratio” and “Activity Ratio.” 

. 

Instruction Revisions: See underlined and strikeout text which follows.

For Section 8.9, you must provide either a production or activity ratio or an activity index and 

indicate which type of ratio you reported using the checkboxes provided. The production or 

activity ratio or activity index allows year-to-year changes in release and other waste management 

quantities to be viewed within the context of production. 

Production Ratio vs. Activity Ratio Index

A production ratio is a ratio of reporting year production to prior year production. Calculate a 

production ratio for the chemical when production levels most directly affect the quantity of the 

chemical managed as waste. 

An activity index ratio is also a ratio of current year to prior year values, but it is used when a 

variable other than production is the primary influence on the quantity of the reported EPCRA

Section 313 chemical managed as waste. An activity Index ratio may be applicable when the 

EPCRA Section 313 chemical is “otherwise used” (e.g., non-incorporative activities such as 

extraction solvents, or metal degreasers). 

What Variable is Used to Calculate This Ratio?

The production or activity ratio or activity index must be based on the variable(s) that most 

directly affect(s) the quantity of the EPCRA Section 313 chemical generated as waste (i.e., 

recycled, used for energy recovery, treated, disposed or otherwise released). If an EPCRA Section 

313 chemical is used in the production of refrigerators, for example, the production ratio would be 

based on the number of refrigerators produced (see Example 22). 

In most cases, the production or activity ratio or activity index must be based on a variable other 

than the quantity of the EPCRA Section 313 chemical manufactured, processed, or otherwise used. 

This is because indices based on chemical or material usage may reflect the effect of source 
65

reduction activities (e.g., process improvements) rather than changes in business activity. If the 

reported EPCRA Section 313 chemical is itself the end product, however, the quantities of the 

EPCRA Section 313 chemical(s) produced in the current and prior years do provide a good basis 

for the production ratio. In any case, the variable used to calculate production ratio should 

generally be a measure of output, not a measure of input or throughput. Example 25 gives 

examples of production ratio or activity index variables reported by industry.

Reporting Tips:

 TRI-MEweb includes a production or activity ratio/activity index wizard to help you calculate 

your ratio automatically.

 The ratio or index must be reported to the nearest tenths or hundredths place (i.e., one or two 

digits to the right of the decimal point) for all EPCRA 313 chemicals, including PBT 

chemicals. A zero is not an acceptable response unless the calculated value is less than 1/200th, 

which can then be rounded to zero. 

 If the manufacture, processing, or other use of the reported EPCRA Section 313 chemical 

began during the current reporting year, select NA as the production or activity ratio or activity 

index. Otherwise, you must enter a value even if your facility did not exceed a reporting 

threshold for the chemical in the previous reporting year.

 The ratio or index is not to be reported as a percent change between years (i.e., for a 10 percent 

increase, you would report the ratio 1.10, not 10% or 10). 

 Some facilities may use the same EPCRA Section 313 chemical in more than one production 

process. In this case, a production or activity ratio or activity index can be estimated by 

weighting the production or activity ratio for each process based on the respective contribution 

of each process to the quantity of the reported EPCRA Section 313 chemical recycled, used for 

energy recovery, treated, or disposed of (see Example 25). 

 It is important to realize that if your facility reports on more than one EPCRA Section 313 

chemical, the production or activity ratio or activity index may vary for different chemicals.

 Details regarding the method used to calculate the Production or Activity Ratio/Activity Index

can be included in Section 9.1, “Additional Information.” This information will provide 

context for the production or activity ratio and may help TRI data users better understand 

changes in releases or other waste management quantities. In Example 22, the facility could 

report, “Used the number of refrigerators painted as the production variable, because our 

facility otherwise uses toluene to paint refrigerators” in order to provide more information in 

Section 9.1. 
66

8.10 Did your facility engage in any newly implemented source reduction activities for this 

chemical during the reporting year? 

Form Revisions: Added new column (d), “Estimated Annual Reduction (Enter code(s)) 

(optional)”.

Instruction Revisions: See underlined and strikeout text which follows.

If Your Facility Implemented Source Reduction Activities. If your facility implemented a new 

source reduction activity for the reported EPCRA Section 313 chemical during the reporting year, 

report the activity or activities that were implemented by selecting the most relevant activity 

code(s) from the drop down list in TRI-MEweb (see W-codes listed below). 

 

For each “Source Reduction Activity” reported, you must also enter one or more code(s) that 

correspond to the internal and external method(s) or information sources you used to identify the 

possibility for implementing a source reduction activity at your facility. If more than three 

methods were used to identify the source reduction activity, enter only the three codes that 

contributed most to the decision to implement the activity.

For each “Source Reduction Activity” reported, you may also provide an estimate of the resulting 

reduction in the annual amount of the chemical to be managed as waste (i.e., released, recycled, 

treated, or used for energy recovery). The estimated annual reduction can be calculated as follows:

(B - A) × 100%

 B

where:

A = estimated amount of the EPCRA Section 313 chemical to be managed as waste in the year 

after the source reduction activity has been implemented and

B = estimated amount of the EPCRA Section 313 chemical that would have been managed as 

waste had the source reduction activity not been implemented.

If you choose to complete this field, the reductions associated with your pollution prevention 

efforts will be featured on EPA’s website through the Pollution Prevention Search Tool at 

www.epa.gov/tri/p2. The estimated annual reduction should be reported using the range codes 

listed below.

Reporting Tips:

 This estimate is based on the facility’s best readily available information at the time the 

activity is reported and will not necessarily reflect the actual reduction once 

implementation of the activity is completed.

 The estimated annual reduction only accounts for the impact of the particular source 

reduction activity. For example, if production is expected to double, but chemical 

quantities are expected to remain constant (when they also would have doubled if not for 

the source reduction activity), then the estimated annual reduction for the activity is 50%.

Estimated Annual Reduction Range Codes:
67

R1 = 100% (elimination of the chemical)

R2 = greater than or equal to 50%, but less than 100%

R3 = greater than or equal to 25%, but less than 50%

R4 = greater than or equal 15%, but less than to 25%

R5 = greater than or equal 5%, but less than to 15%

R6 = greater than 0%, but less than 5%

8.11 If you wish to submit additional optional information on source reduction, recycling, or 

pollution control activities, provide it here. 

Form Revisions: None.

Instruction Revisions: See underlined and strikeout text which follows.

When completing this section in TRI-MEweb, you may indicate that you have submitted 

information pertaining to one or more of the following topics by checking a box next to the topic 

to which your information pertains: 

 Source Reduction

 Recycling

 Energy Recovery

 Waste Treatment

 General Environmental Management

 Methods for Identifying P2 Opportunities

 Ways P2 Was Incorporated in Original Process Design

If you do so, each topic you have selected will be included in your Section 8.11 entry, followed by 

the information you have provided about that topic. Using these checkboxes will facilitate 

searches for information about P2 and other environmentally-friendly practices by users of the TRI 

database.

Barriers to Implementing Pollution Prevention Activities

You may also provide details on any barriers your facility faces in implementing additional source 

reduction, recycling or pollution control activities. If you choose to provide this information, EPA 

encourages you to select one or more of the following barrier categories from the checklist 

provided in TRI-MEweb and describe specifically how one of these barrier categories applies to 

your facility: 

1. Insufficient capital to install new source reduction equipment or implement new source 

reduction activities/initiatives.

2. Require technical information on pollution prevention techniques applicable to specific 

production processes.

3. Concern that product quality may decline as a result of source reduction.

4. Source reduction activities were implemented but were unsuccessful.

5. Specific regulatory/permit burdens. 

6. Pollution prevention previously implemented- additional reduction does not appear 

technically or economically feasible.
68

7. No known substitutes or alternative technologies.

8. Other barriers.

Each category you select in TRI-MEweb will be included in your Section 8.11 entry, followed by 

the additional details you provided on that topic (if any).

9.1 Miscellaneous, Optional, and Additional Information for Your Form R Report. 

Form Revisions: None.

Instruction Revisions: See underlined and strikeout text which follows.

Your facility may provide additional information pertaining to any portion of your Form R 

submission in the box provided in the free text box provided in TRI-MEweb or on the hard copy 

form (trade secret submissions only). Your submissions to Section 9.1 regarding miscellaneous, 

additional, optional information may provide the Agency and/or the public with useful data that 

helps explain why your facility submitted data in one or more data elements that might appear 

unusual or inconsistent with previous TRI Form R submissions or with other data supplied by your 

facility during this reporting year. Such additional data may help EPA reduce the need for 

additional data quality control as well as additional TRI-related enforcement and compliance 

efforts. Do not submit information you consider to be CBI or otherwise protected on your 

Form R.

When completing this section in TRI-MEweb, you may indicate that you have submitted 

information pertaining to one or more of the following topics by checking a box next to the topic 

to which your information pertains:

 Changes in Production Levels

 Calculation Methods, e.g., Emission Factors

 One-time or Intermittent Events Impacting Reported Quantities

 Issues or Difficulties Encountered in Submitting Form



 Additional Contact Info

 Other Regulatory Requirements Related to This Chemical

 No TRI Reports Expected for This TRIFID Next Year

 No TRI Report Expected for This Chemical Next Year

If you do so, each topic you have selected will be included in your Section 8.11 entry, followed by 

the information you have provided about that topic (if any). Using these checkboxes will ensure 

that EPA and other TRI data users understand the factors that have contributed to any apparent 

data quality issues. Note that if you select one of the last two topics above, it is helpful to include 

the reason you will not be submitting a report next year (e.g., facility closure, move, temporary 

shutdown, etc.).

APPENDIX C

INFORMATION SOURCES CONTAINING DATA SUBSETS, BUT NOT 

COMPREHENSIVELY COMPARABLE ALTERNATIVES TO TRI DATA 
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Appendix C: Information Sources Containing Data Subsets, but not Comprehensively Comparable Alternatives to TRI Data

In this appendix, data elements available from several information sources are compared to those reported to TRI. The analysis is broken 

down by the specific types of data collected under TRI. While some sources may appear to be substitutes for TRI, they do not adequately 

address the entire scope of TRI, even in combination. For example, a given source may:

 Not include all toxic chemicals covered by TRI,

 Be compiled less frequently than TRI, and/or

 Not be as easily accessible (if at all) to the general public.

Table C-1: Relevant Information Sources

(TRI Included for Comparison)

Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

TRI DATA

EPCRA §313 requires facilities to submit 

reports on releases (including disposal) of 

particular toxic chemicals exceeding a given 

threshold. The reports provide information 

on the quantity of chemical released into the 

environment and to which medium (air, 

land, water) the disposal took place, as well 

as information about waste management and 

the amount of chemicals stored on-site.

TRI contains 

information on 

releases, transfers, 

and pollution 

prevention activities 

for 593 individually 

listed chemicals and 

30 chemical 

categories—totaling 

to 682 toxic 

chemicals. 

NAICS codes 

corresponding to SIC 

codes 20-39, 10; 12; 

4911, 4931, 4939; 4953; 

5169; 5171; and 7389.

A facility need only 

report if it has 10 or more 

Full Time Equivalents

(FTEs).

Annual. EPA compiles the TRI data and 

makes them available through 

several data access tools, including 

the TRI Explorer and Envirofacts. 

Other organizations also make the 

data available to the public through 

their own data access tools.
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

AIR EMISSIONS (SECTIONS 5.1 AND 5.2)

National Emissions Inventory (NEI)

NEI provides estimates of anthropogenic

pollutant emissions from stationary sources, 

as well as area sources and mobile sources. 

These estimates, submitted to EPA by 

delegated authorities (state or county), 

electric utilities, and/or generated by EPA 

from various sources, differ in estimation 

methodology used.

8 CAPs and 187 

HAPs.

No NAICS limitations. Triennial. CSV files can be downloaded from 

EPA’s Web site.

Air Facility System (AFS)

AFS contains compliance and permit data for 

stationary sources of air pollution regulated 

by U.S. EPA, and state and local air 

pollution agencies.

N/A No NAICS limitations. Annual. Can be accessed on a facility-byfacility basis through EPA data 

access tools, including Envirofacts 

or the Enforcement and 

Compliance History Online 

(ECHO).

State Air Emissions Inventories

Several states and regional agencies 

maintain their own air emissions inventories. 

However, the amount of data as well as the 

types of data elements collected vary widely 

from state to state.

Varies widely (e.g., 

the California Air 

Resources Board 

maintains its own 

list of about 400 

toxic air pollutants).

Varies. Varies. Most of these data are submitted to 

NEI. Some data are available on 

the Web on a state-by-state basis.

Title V Part 70 Operating Permits

Under the 1990 Clean Air Act Amendments, 

facilities designated as "major sources" and 

facilities otherwise subject to §112 and Title 

V must apply for a Title V Part 70 Operating 

Permit. As part of the application for a Title 

V permit, some facilities may have to report 

emissions of air toxics.

187 HAPs. No NAICS limitations. At the time of 

permit 

application, 

renewal, and 

modification—

permits are 

typically renewed 

every 5 years.

No central repository for the 

information.
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

DIRECT DISCHARGES TO WATER (SECTION 5.3)

Integrated Compliance Information System–National Pollutant Discharge Elimination System (ICIS-NPDES)

ICIS-NPDES is a national information 

management system that tracks 

implementation of the National Pollutant 

Discharge Elimination System (NPDES) 

program, authorized by the Clean Water Act. 

ICIS-NPDES tracks permit issuance, permit 

limits, self-monitoring data, compliance data 

and other data pertaining to facilities 

regulated under NPDES. 

Monitoring data for 

major dischargers 

includes only 

chemicals for which 

a monitoring 

requirement has 

been set in the 

permit—a facility's 

record may not 

include all 

pollutants actually 

discharged.

No NAICS limitations. Major permittees 

must submit 

Discharge 

Monitoring 

Reports (DMRs) 

monthly or 

quarterly; nonmajor permittees 

must submit at 

least annually.

Can be accessed on a facility-byfacility basis through EPA data 

access tools, including Envirofacts, 

and ECHO.
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

UNDERGROUND INJECTION AND LAND DISPOSAL ON-SITE (SECTIONS 5.4 AND 5.5)

RCRA Biennial Reports

Section 3002(a)(6) of the Resource 

Conservation and Recovery Act (RCRA)

requires EPA to develop a program for 

hazardous waste generators to report the

nature, quantities, and disposition of 

hazardous waste generated at least once 

every two years. In addition, section 

3004(a)(2) of RCRA requires treatment, 

storage and disposal facilities (TSDFs) to 

submit a report on the wastes that they 

receive from off-site. The biennial 

Hazardous Waste Report (also known as the

“Biennial Report”) was implemented in 

1985 to comply with these requirements.

The Biennial Report form (8700-13A/B) 

must be submitted to the authorized state 

agency or the EPA Regional Office by 

March 1st of every even-numbered year.

The form includes information such as the 

facility's RCRA ID number, the name

and address of the facility, the quantity of 

hazardous waste sent to each TSDF in

the United States and the manner in which 

the waste was treated during the previous 

year.

Biennial Reports 

contain data on 

hazardous wastes as 

defined by RCRA 

and reported by 

waste codes – not 

all of which map 

directly to a single, 

unique chemical.

No NAICS limitations; 

however, certain waste 

categories are excluded 

(e.g., mining and 

agriculture).

Biennial. Can be accessed on a facility-byfacility basis through EPA data 

access tools, including Envirofacts. 

Text files can be downloaded from 

EPA’s Web site.

DISCHARGES TO A POTW (SECTION 6.1)

RCRA Biennial Reports (BR)

Biennial Reports require some reporting of 

discharges to POTWs. See above for more 

details.

See above. See above. See above. See above.

ICIS-NPDES
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

ICIS-NPDES allows for reporting of indirect 

discharges to water. See above for more 

details.

See above. See above. See above. See above.

TRANSFERS TO OTHER OFF-SITE LOCATIONS (SECTION 6.2)

RCRA Biennial Reports (BR)

Biennial Reports contain hazardous waste 

data from large quantity generators and 

TSDFs. Biennial Reports also require 

reporting of off-site transfers on Form GM. 

Information includes the RCRA ID of the 

facility to which the waste was shipped, the 

processes used to treat, recycle, or dispose of 

the waste at the off-site facility, the off-site 

availability code, and the total quantity of 

waste shipped during the report year. The 

reports also provide data on the volume of 

hazardous waste shipped off-site for land 

disposal, a release end-point of relevance to 

TRI. See above for more details.

See above. See above. See above. See above.

CHEMICAL STORAGE AND INVENTORY DATA (SECTION 4.1)

EPCRA §312 Tier I and II Reports

EPCRA §312 requires that states establish 

plans for local chemical emergency 

preparedness and that inventory information 

on hazardous chemicals be reported by 

facilities to state and local authorities.

Hazardous or 

extremely 

hazardous 

substances 

(essentially any 

substance that poses 

a health or physical 

hazard).

No NAICS exemptions 

for facilities that are 

covered under the 

reporting threshold 

requirements, but 

facilities not included 

under OSHA’s Hazard 

Communication Standard 

(e.g., mines) do not have 

to file.

Annual. On a facility-by-facility basis, by 

forwarding a written request.

Risk Management Plan (RMP)
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

Under the authority of section 112(r) of the 

Clean Air Act, the Chemical Accident 

Prevention Provisions require facilities that 

produce, handle, process, distribute, or store 

certain chemicals to prepare a Risk 

Management Plan (RMP) and submit the 

RMP to EPA. These plans include 

information about chemical amounts stored 

and processed at RMP facilities.

Certain flammable 

and toxic 

substances.

No NAICS limitations. At least every 

five years, or 

within six months 

of an incident.

Restricted access: RMP 

information may be accessed via 

the Federal Reading Rooms.

Chemical Data Reporting (CDR)

Under TSCA Section 8(a), chemical 

manufacturers (including importers) are 

required to report manufacturing-related 

information to EPA for sites that 

manufactured (including imported) 25,000 

pounds or more of a reportable chemical 

substance any one calendar year between 

submission periods. Industrial processing 

and use information and commercial and 

consumer use information must also be 

reported for these sites.

CDR reporting 

typically covers 

about 7,000 to 8,000 

chemicals in each 

reporting cycle.

Limited to manufacturers, 

including importers, of 

subject chemicals. 

Certain manufacturers are 

exempt, including small 

manufacturers (sales 

<$40 million), those 

manufacturing a chemical 

for research and 

development, those 

manufacturing chemicals 

as impurities, and those 

submitting information 

under another TSCA 

Section 8a rule.

Every four years. Data claimed as Confidential 

Business Information (CBI) are not 

available to the public. Non-CBI 

data downloads are available from 

EPA’s CDR website.

POLLUTION PREVENTION DATA (SECTIONS 8.1-8.7; 8.10)

RCRA Biennial Reports (BR)

Biennial Reports contain pollution 

prevention information on hazardous waste 

from large quantity generators and TSDFs. 

Data are collected primarily by states, and 

are collated by EPA. See above for more 

details.

See above. See above. See above. See above.
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

State Environmental Agency Databases

At least fourteen states1implement 

mandatory pollution prevention programs. 

Pollution prevention data collected under 

these programs varies by state, and may 

include both data similar to that collected by 

TRI (e.g., quantities of waste managed, 

source reduction activities, etc.) and details 

not found in TRI (e.g., pollution prevention 

plans, costs associated with waste 

management, etc.).

Varies. Varies. May include TRI 

filers, facilities that use 

toxic chemicals, and 

generators of hazardous 

waste.

Varies. There is no central source for state 

collected pollution prevention data. 

Accessibility varies by state.

EMERGENCY RELEASE DATA (SECTION 8.8)

National Response Center (NRC)

NRC collects real-time information about 

virtually all oil and chemical spills 

throughout the United States to identify 

spills for which to coordinate emergency 

response.

Oils and chemicals. No source exemptions. Real-time. Historical information about spills 

can be retrieved through the NRC 

online query system: 

www.nrc.uscg.mil/foia.html.

Risk Management Plan (RMP)

RMP contains a five-year accident history

for each facility with details on releases of

regulated substances from covered processes 

with 1) on-site deaths, injuries, or significant 

property damage; or 2) known off-site 

deaths, injuries, property damage,

environmental damage, evacuations, or 

sheltering in place. See above for more 

details.

See above. See above. See above. See above.

 

1 Arizona, California, Georgia, Maine, Massachusetts, Minnesota, Mississippi, New Jersey, New York, Oregon, Tennessee, Texas, Vermont, and Washington. 
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Description Chemical 

Coverage

Industry/Facility 

Coverage

Reporting 

Frequency Public Access

STATE RIGHT-TO-KNOW PROGRAMS

Several states require expanded state TRI 

reporting to include industries or facilities 

not covered by TRI or to report information 

beyond that required by the federal TRI 

Program (e.g., Arizona, Massachusetts, and 

Wisconsin).

Varies. Often 

identical to TRI.

Varies. May include more 

industries than TRI.

Annual. There is no central source for state 

collected data. Accessibility varies 

by state.
6/11/14

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Appendix C References:

Abt Associates, “Comparison of Toxics Release Inventory and the Permit Compliance System,” 

(2005).

Abt Associates, “Comparison of Toxics Release Inventory and the National Emissions 

Inventory,” (2005): 6.

Arizona Department of Environmental Quality. 2014. Waste Programs Division: Pollution 

Prevention (P2) Program. www.azdeq.gov/environ/waste/p2/index.html

California Department of Toxic Substances Control. 2010. Pollution Prevention. 

www.dtsc.ca.gov/pollutionprevention/.

Georgia Department of Natural Resources. 2013. EPD Forms: Land Protection Branch: Hazardous 

Waste Managementwww.gaepd.org/Documents/epdforms_hwb.html

Great Lakes Information Network, 1996. "Regional Air Pollutant Inventory Development

System," Information from Great Lakes Information Network Web site: 

www.glc.org/projects/air/rapids/rapids.html www.glc.org.

ICF Incorporated, 1993. Data Gaps and Redundancies in Pollution Prevention Reporting; A

Compendium of Memoranda. Prepared for U.S. EPA, Office of Prevention, Pesticides, and 

Toxics, Pollution Prevention Division.

Maine Department of Environmental Protection. 2013. Toxics Use Reduction Program (TUR). 

www.maine.gov/dep/sustainability/tur/index.html.

Massachusetts Executive Office of Energy and Environmental Affairs. 2014. Toxics Use 

Reduction Act. www.mass.gov/eea/agencies/massdep/toxics/tur/. 

Minnesota Pollution Control Agency. 2012. Minnesota Guide to Pollution Prevention Planning. 

www.pca.state.mn.us/index.php/topics/preventing-waste-and-pollution/assistance-andresources/minnesota-guide-to-pollution-prevention-planning.html. 

Mississippi Department of Environmental Quality. 2007. Pollution Prevention. 

www.deq.state.ms.us/mdeq.nsf/page/ERC_pollution_prevention?OpenDocument.

New Jersey Department of Environmental Protection. 2014. Office of Pollution Prevention

and Community Right To Know. www.nj.gov/dep/opppc/. 

New York Deparmetn of Environmental Conservation. 2013. Hazardous Waste Reduction Plans. 

www.dec.ny.gov/chemical/8771.html.

Oregon Department of Environmental Quality. 2006. Toxics Use and Hazardous Waste Reduction. 

www.deq.state.or.us/lq/hw/tuhwr.htm.
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78

Seitz, John S., Director OAQPS, 1995. Memorandum: "Title V Permitting for Non-major Sources 

in Recent §112 Maximum Achievable Control Technology (MACT) Standards," May 16, 1995.

Tennessee Department of Environment and Conservation. 1999. Writing a Waste Reduction Plan. 

www.tn.gov/environment/solid-waste/docs/wrplan.pdf.

Texas Commission on Environmental Quality. 2013. About Pollution Prevention (P2) Planning. 

www.tceq.texas.gov/p2/wrpa/p2planning.html.

U.S. EPA, 1991. 1991 Hazardous Waste Report: Instructions and Forms. EPA Form 8700-

13A/B (5-80) revised 8-91. 

U.S. EPA, 1994. "National Analysis: The Biennial RCRA Hazardous Waste Report (Based on 

1991 Data)." September 1994.

U.S. EPA, 1995. "User's Guide to Federal Accidental Release Databases," Office of Solid 

Waste and Emergency Response, September 1995. 

http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=100035EX.TXT. 

U.S. EPA, 2006. "Phase III: Data Proxies for the Toxics Release Inventory (TRI)," January 

2006.

U.S. EPA, 2009. "General Risk Management Program Guidance: Chapter 9: Risk Management 

Plan,” March 2009. www.epa.gov/osweroe1/docs/chem/Chap-09-final.pdf. 

U.S. EPA, 2012. Air Facility System 

www.epa.gov/compliance/data/systems/air/afssystem.html.

U.S. EPA, 2013a. “2011 National Emissions Inventory, version 1 Technical Support Document 

November 2013 – DRAFT” www.epa.gov/ttn/chief/net/2011nei/2011_neiv1_tsd_draft.pdf. 

U.S. EPA, 2013b. “National Biennial RCRA Hazardous Waste Report: Documents and Data" 

www.epa.gov/osw/inforesources/data/biennialreport/.

Vermont Department of Environmental Conservation. 2003. Pollution Prevention Planning. 

www.anr.state.vt.us/DEC/ead/ppap/index.htm.

Washington Department of Ecology. Pollution Prevention and Planning in Washington State. 

www.ecy.wa.gov/programs/hwtr/p2/index.html.

Wisconsin Emergency Management. “An Information Guide: Emergency Planning and 

Community Right-to-Know Act Wisconsin Statute 323.60,” 

http://emergencymanagement.wi.gov/EPCRA/docs/EPCRA%20BookletWHOPRS.pdf. 
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APPENDIX D

TRI CONSULTATION MEETINGS 
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80

Appendix D: TRI Consultation Meetings

February 7, 2011 and February 28, 2011

Tribal consultation calls with Tribal Leaders or Designates regarding the “Toxics Release 

Inventory (TRI) Reporting for Facilities Located in Indian Country and Clarification of 

Additional Opportunities Available to Tribal Governments under the TRI Program” rule

February 7, 2011

Attendees Included:

Craig Tepper, Seminole Tribe

Sarah Hill, Cherokee Nation

Matthew Thompson, St. Regis Mohawk Tribe

Dwight Peavey, EPA Region 1

Nora Lopez, EPA Region 2

Bill Reilly, EPA Region 3

Ezequiel Velez, EPA Region 4

Willie Harris, EPA Region 5

Mort Wakeland, Randy Gee, EPA Region 6

Gabriela Carvalho, EPA Region 10

Robin Gonzalez – Acting Director, EPA Office of Information Analysis and Access 

Nancy Wentworth – Acting Deputy Director, EPA Office of Information Analysis and Access

Rebecca Moser – Director, TRI Program Division

Beth Jackson – Tribal Program Coordinator, Office of Environmental Information

Louise Camalier – Office of Information Analysis and Access

Larry Reisman – TRI Program Division

Sarah Swenson – TRI Program Division

Caitlin Briere – Office of Information Analysis and Access

February 28, 2011

Attendees Included:

Vicki Kujawa, Iowa Tribe of Oklahoma

Denise Jensen, Winnebego Tribe of Nebraska

Melonee Montano, Redcliff Tribe (Wisconsin)

Nora Lopez, EPA Region 2

Ezequiel Velez, EPA Region 4

Thelma Codina, Willie Harris, EPA Region 5

Randy Gee, EPA Region 6

Barbara Conklin, EPA Region 8

Gabriela Carvalho, EPA Region 10

Kevin Donovan, TRI Program Division

Larry Reisman, TRI Program Division

Nancy Wentworth, Acting Deputy, Office of Information Analysis and Access

Mike Petruska, Director, Environmental Analysis Division

Louise Camalier, Office of Information Analysis and Access
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Guy Tomassoni, Environmental Analysis Division

Nicky Paquette, Environmental Analysis Division

Beth Jackson, Tribal Program Coordinator, Office of Environmental Information

Robin Gonzalez, Acting Director, Office of Information Analysis 

TRI National Training Conference

April 2012

Attendees Included:

3M Company

Alaska Department of Environmental Conservation

Ark. Dept. of Environmental Quality

Birmingham City Council

BP

Calvert Inc. 

Center for Environmental Health

Cherokee Services Group, LLC (CSG)

Clean Air Coalition of WNY

Colorado Department of Public Health and Environment

Commission for Environmental Cooperation

Committee on Environment and Public Works

Confederation Salish & Kootenai Tribes

Consolidated Edison of New York

Cornell University

Covanta Energy

CT Department of Energy and Environmental Protection

DM Petroleum Operations Company

Duke Energy

Environmental Council of the States

ExxonMobil

Freeport-McMoRan Copper & Gold

Georgia-Pacific LLC

Harvard Business School

Harvard Law School

Holcim (US)

HRI

Huxley College of the Environment

Idaho Bureau of Homeland Security

Indiana Dept of Environmental Management

Institute for Tribal Environmental Professionals

Iowa Department of Natural Resources

Johnson & Johnson

JR Simplot Company

Kansas Department of Health & Environment

Kentucky Department for Environmental Protection
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Koch Industries

K-State Pollution Prevention Institute

Lubin School of Business

Maine Emergency Management Agency

Maryland Department of the Environment

MI Dept of Environmental Quality

Michelin North America, Inc.

Minnesota Pollution Control Agency

Mississippi Department Of Environmental Quality

Montana Department of Environmental Quality

Morgan State University

MS Dept. of Environmental Quality

NAPCA

National Library of Medicine

National Lime Association

National Mining Association

National Pollution Prevention Roundtable

Nebraska Department of Environmental Quality

New Mexico Environment Department

NIHHS

NJ Department of Environmental Protection

Northeastern University

NYC Environmental Justice Alliance (NYC-EJA)

NYS Pollution Prevention Institute

Ohio Environmental Protection Agency

Oklahoma Department of Environmental Quality

OMB Watch

Oregon Office of State Fire Marshal

Oxbow

Penobscot Nation

Pfizer, Inc.

Potomac-Hudson Engineering, Inc.

Rochester Institute of Technology

SEMARNAT, Ministery of Environmental Natural Resources in Mexico City

Seneca Nation of Indians

Senior Service America, Inc.

Sierra Club

Small Business Administration

Staples

State of Hawaii, Department of Health

State of Utah

Stewardship Action Council

TCEQ

Tennessee State University

TG Missouri Corporation

The Vinyl Institute
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Thompson Publishing Group

Towson University

U.S. Department of the Army

U.S. Virgin Islands

UMASS Lowell, Department of Community Health and Sustainability

University of Colorado Denver

University of Minnesota

University of Utah

University of Wisconsin Extension

University of Wyoming

US Air Force

Virginia Department of Environmental Quality

Washington Department of Ecology

Washington State Department of Ecology

Waste Management

WE ACT for Environmental Justice

West Liberty Foods

Western Washington University

Wisconsin DNR

WV Department of Environmental Protection

Yukon River Inter-Tribal Watershed Council

Yurok Tribe Environmental Program

Zero Waste Network - Center For Environmental Excellence-University of Texas at Arlington

January 22, 2013

Stakeholder Briefing on 2011 TRI National Analysis

Attendees Included:

OMB Watch

National Mining Association

SBA

Earthworks

ECOS

Society of Glass and Ceramic Decorated Products
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July 29, 2013

Discussion Meeting regarding Adding Oil and Gas Extraction Industry to TRI

EPA hosted a listen session during which Petitioners discussed their Petition to Add the Oil and 

Gas Extraction Industry, Standard Industrial Classification Code 13, to the List of Facilities 

Required to Report under the Toxics Release Inventory.

Attendees Included:

EPA

Steve Knizner, Director, TRI Program Division (knizner.steve@epa.gov)

Ingrid Rosencrantz, Branch Chief, TRI Regulatory Development Branch 

(rosencrantz.ingrid@epa.gov)

Gilbert Mears, Staff, TRI (mears.gilbert@epa.gov)

Cory Wagner, Staff, TRI (wagner.cory@epa.gov)

Chris Kaczmarek, Attorney, Office of General Counsel (kaczmarek.chris@epa.gov)

Ben Wakefield, Attorney, Office of General Counsel (wakefield.benjamin@epa.gov)

Non-EPA

Eric Schaeffer, Executive Director, Environmental Integrity Project

(eschaeffer@environmentalintegrity.org)

Adam Kron, Attorney, Environmental Integrity Project (akron@environmentalintegrity.org)

Sofia Plagakis, Policy Analyst, Center for Effective Government (formerly OMB Watch)

(splagakis@foreffectivegov.org)

Sean Moulton, Director of Open Government Policy Program , Center for Effective Government

(smoulton@foreffectivegov.org)

Diana Dascalu-Joffe, Senior General Counsel, Chesapeake Climate Action Network

(diana@chesapeakeclimate.org)

Aaron Mintzes, Policy Advocate, Earthworks (amintzes@earthworksaction.org)

Matthew McFeeley, Attorney, Natural Resources Defense Council (mmcfeeley@nrdc.org)

Craig Segall, Sierra Club, Attorney (Craig.Segall@sierraclub.org) 

Ryan Hamilton, Intern, Environmental Integrity Project

Ariel Solaski, Intern, Environmental Integrity Project

Caitlin Stantion, Intern, Environmental Integrity Project 
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APPENDIX E

FACILITIES REQUIRED TO REPORT TO TRI (NAICS)
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Table E-1

Facilities Required to Report to TRI (NAICS)

(Corresponding to SIC codes 20 through 39)

Subsector 

or Industry 

Code

Industry

Code

Exceptions and/or Limitations

311 Except 311119 - Exception is limited to facilities primarily engaged in Custom Grain Grinding for Animal Feed 

(previously classified under SIC 0723, Crop Preparation Services for Market, Except Cotton Ginning);

Except 311340 - Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, popcorn and other 

confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut, 

and Confectionery Stores);

Except 311352 - Exception is limited to facilities primarily engaged in the retail sale of candy, nuts, popcorn and other 

confections not for immediate consumption made on the premises (previously classified under SIC 5441, Candy, Nut, 

and Confectionery Stores);

Except 311611 - Exception is limited to facilities primarily engaged in Custom Slaughtering for individuals 

(previously classified under SIC 0751, Livestock Services, Except Veterinary, Slaughtering, custom: for individuals);

Except 311612 - Exception is limited to facilities primarily engaged in the cutting up and resale of purchased fresh 

carcasses for the trade (including boxed beef), and in the wholesale distribution of fresh, cured, and processed (but not 

canned) meats and lard (previously classified under SIC 5147, Meats and Meat Products); 

Except 311811 - Retail Bakeries (previously classified under SIC 5461, Retail Bakeries); 

312 Except 312112 - Exception is limited to facilities primarily engaged in bottling mineral or spring water (previously 

classified under SIC 5149, Groceries and Related Products, NEC) 

Except 312230 - Exception is limited to facilities primarily engaged in providing Tobacco Sheeting Services 

(previously classified under SIC 7389, Business Services, NEC);

313 Except 313310 - Exception is limited to facilities primarily engaged in converting broadwoven piece goods and 

broadwoven textiles, (previously classified under SIC 5131, Piece Goods Notions, and Other Dry Goods, broadwoven 

and non-broadwoven piece good converters);, and facilities primarily engaged in converting narrow woven Textiles 

and narrow woven piece goods, (previously classified under SIC 5131, Piece Good Notions, and Other Dry Goods, 

converters, except broadwoven fabric); and facilities primarily engaged in sponging fabric for tailors and dressmakers 

(previously classified under SIC 7389, Business Services, NEC (Sponging fabric for tailors and dressmakers));

314 Except 314120 - Exception is limited to facilities primarily engaged in making Custom drapery and in making Custom 

slipcovers for retail sale (previously classified under SIC 5714, Drapery, Curtain, and Upholstery Stores);

Except 314999 - Exception is limited to facilities primarily engaged in Binding carpets and rugs for the trade, Carpet 

cutting and binding, and Embroidering on textile products (except apparel) for the trade (previously classified under 

SIC 7389, Business Services Not Elsewhere Classified, Embroidering of advertising on shirts and Rug binding for the 

trade);

315 Except 315220 - Exception is limited to custom tailors primarily engaged in making and selling men's and boys' suits, 

men’s and boys’ dress shirts, and bridal dresses or gowns or women’s, misses’ and girls’dresses, cut and sewn from 

purchased fabric (previously classified under SIC 5699, Miscellaneous Apparel and Accessory Stores (custom tailors)) 

and to custom tailors primarily engaged in making and selling bridal dresses or gowns, or women's, misses' and girls' 

dresses cut and sewn from purchased fabric (except apparel contractors)(custom dressmakers) (previously classified 

under SIC Code 5699, Miscellaneous Apparel and Accessory Stores);

316

321

322

323 Except 323111 - Exception is limited to facilities primarily engaged in reproducing text, drawings, plans, maps, or 

other copy, by blueprinting, photocopying, mimeographing, or other methods of duplication other than printing or 

microfilming (i.e., instant printing) (previously classified under SIC 7334, Photocopying and Duplicating Services, 

(instant printing));

324

325 Except 325998 - Exception is limited to facilities primarily engaged in Aerosol can filling on a job order or contract 

basis (previously classified under SIC 7389, Business Services, NEC (aerosol packaging)); 

326 Except 326212 - Tire Retreading, (previously classified under SIC 7534, Tire Retreading and Repair Shops 

(rebuilding)); 

327 Except 327110 - Exception is limited to facilities primarily engaged in manufacturing and selling pottery on site 

(previously classified under SIC 5719, Miscellaneous Homefurnishing Stores)
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331

332

333

334 Except 334614 – Exception is limited to facilities primarily engaged in Software Reproducing (previously classified 

under SIC 7372, Prepackaged Software, (reproduction of software)) and to facilities primarily engaged in mass 

reproducing pre-recorded Video cassettes, and mass reproducing Video tape or disk (previously classified under SIC 

7819, Services Allied to Motion Picture Production (reproduction of Video));

335 Except 335312 - Exception is limited to facilities primarily engaged in armature rewinding on a factory basis 

(previously classified under SIC 7694 (Armature Rewinding Shops (remanufacturing));

336

337 Except 337110 - Exception is limited to facilities primarily engaged in the retail sale of household furniture and that 

manufacture custom wood kitchen cabinets and counter tops (previously classified under SIC 5712, Furniture Stores 

(custom wood cabinets));

Except 337121 - Exception is limited to facilities primarily engaged in the retail sale of household furniture and that 

manufacture custom made upholstered household furniture (previously classified under SIC 5712, Furniture Stores 

(upholstered, custom made furniture));

Except 337122 - Exception is limited to facilities primarily engaged in the retail sale of household furniture and that 

manufacture nonupholstered, household type, custom wood furniture (previously classified under SIC 5712, Furniture 

Stores (custom made wood nonupholstered household furniture except cabinets));

339 Except 339113 - Exception is limited to facilities primarily engaged in manufacturing orthopedic devices to 

prescription in a retail environment (previously classified under SIC 5999, Miscellaneous Retail Stores, NEC)

Except 339115 - Exception is limited to lens grinding facilities that are primarily engaged in the retail sale of 

eyeglasses and contact lenses to prescription for individuals (previously classified under SIC 5995, Optical Goods 

Stores (optical laboratories grinding of lenses to prescription));

Except 339116 - Dental Laboratories (previously classified under SIC 8072, Dental Laboratories);

111998 Limited to facilities primarily engaged in reducing maple sap to maple syrup (previously classified under SIC 2099, 

Food Preparations, NEC, Reducing Maple Sap to Maple Syrup);

113310 

211112 Limited to facilities that recover sulfur from natural gas (previously classified under SIC 2819, Industrial Inorganic 

chemicals, NEC (recovering sulfur from natural gas));

212324 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating kaolin and clay 

(previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, 

separating, etc. of minerals in SIC 1455)); 

212325 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating clay and 

ceramic and refractory minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise 

Treated (grinding, washing, separating, etc. of minerals in SIC 1459));

212393 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating chemical or 

fertilizer mineral raw materials (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise 

Treated (grinding, washing, separating, etc. of minerals in SIC 1479));

212399 Limited to facilities operating without a mine or quarry and that are primarily engaged in beneficiating nonmetallic 

minerals (previously classified under SIC 3295, Minerals and Earths, Ground or Otherwise Treated (grinding, washing, 

separating, etc. of minerals in SIC 1499));

488390 Limited to facilities that are primarily engaged in providing routine repair and maintenance of ships and boats from 

floating drydocks (previously classified under SIC 3731, Shipbuilding and Repairing (floating drydocks not associated 

with a shipyard));

511110

511120

511130

511140 Except facilities that are primarily engaged in furnishing services for direct mail advertising including Address list 

compilers, Address list publishers, Address list publishers and printing combined, Address list publishing , Business 

directory publishers, Catalog of collections publishers, Catalog of collections publishers and printing combined, 

Mailing list compilers, Directory compilers, and Mailing list compiling services (previously classified under SIC 7331, 

Direct Mail Advertising Services (mailing list compilers));

511191

511199

512220
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512230 Except facilities primarily engaged in Music copyright authorizing use, Music copyright buying and licensing, and 

Music publishers working on their own account (previously classified under SIC 8999, Services, NEC (music 

publishing));

519130 Limited to facilities primarily engaged in Internet newspaper publishing (previously classified under SIC 2711, 

Newspapers: Publishing, or Publishing and Printing), Internet periodical publishing (previously classified under SIC 

2721, Periodicals: Publishing, or Publishing and Printing), Internet book publishing (previously classified under SIC 

2731, Books: Publishing, or Publishing and Printing), Miscellaneous Internet publishing (previously classified under 

SIC 2741, Miscellaneous Publishing), Internet greeting card publishers (previously classified under SIC 2771, Greeting 

Cards); Except for facilities primarily engaged in web search portals.

541712 Limited to facilities that are primarily engaged in Guided missile and space vehicle engine research and development 

(previously classified under SIC 3764, Guided Missile and Space Vehicle Propulsion Units and Propulsion Unit Parts), 

and in Guided missile and space vehicle parts (except engines) research and development (previously classified under 

SIC 3769, Guided Missile and Space Vehicle Parts and Auxiliary Equipment, Not Elsewhere Classified); 

811490 Limited to facilities that are primarily engaged in repairing and servicing pleasure and sail boats without retailing new 

boats (previously classified under SIC 3732, Boat Building and Repairing (pleasure boat building));

Table E-2

Facilities Required to Report to TRI (NAICS)

(Corresponding to SIC codes other than SIC codes 20 through 39)

Subsector 

or Industry 

Code

Exceptions and/or Limitations

212111

212112

212113

212221

212222

212231

212234

212299 

221111 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221112 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221113 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221118 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221121 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221122 Limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce.

221330 Limited to facilities engaged in providing combinations of electric, gas, and other services, not elsewhere classified 

(N.E.C.)(previously classified under SIC 4939, Combination Utility Services Not Elsewhere Classified. ) 

424690

424710

425110 Limited to facilities previously classified in SIC 5169, Chemicals and Allied Products, Not Elsewhere Classified.

425120 Limited to facilities previously classified in SIC 5169, Chemicals and Allied Products, Not Elsewhere Classified.

562112 Limited to facilities primarily engaged in solvent recovery services on a contract or fee basis (previously classified under 

SIC 7389, Business Services, NEC);

562211 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq.

562212 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq.

562213 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq.

562219 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq.

562920 Limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. 6921 et seq.