TRI reporting: New chemicals on the list

July 1 CalendarIt’s almost July 1, which means Toxics Release Inventory (TRI) reports are on the top of EHS professionals “to-do” list.

In a recent article for, Tim Fagan gave an overview of EPA’s changes to the list of chemicals and chemical categories subject to inclusion in TRI reports.

  • o-Nitrotoluene (CAS# 88-72-2).  Facilities are required to include o-Nitrotoluene in TRI reports for the 2014 RY if the applicable thresholds are exceeded.  The EPA added o-Nitrotoluene to the TRI list because it was recently classified as “reasonably anticipated to be a human carcinogen” by the National Toxicology Program.
  • Nonylphenol category.  Facilities are not required to include chemicals in the nonylphenol category for the 2014 RY, but should begin tracking these chemicals.  Reporting nonylphenol category chemicals will begin with the 2015 RY TRI reports due July 1, 2016.  The EPA added the nonylphenol category, which includes the following, to the TRI list because these substances are highly toxic to aquatic organisms:
    • 4-Nonylphenol (CAS#  104-40-5)
    • Isononylphenol (CAS# 11066-49-2)
    • Nonylphenol (CAS# 25154-52-3)
    • 4-Isononylphenol (CAS# 26543-97-5)
    • 4-Nonylphenol, branched (CAS# 84852-15-3)
    • Nonylphenol, branched (CAS# 90481-04-2)

We hope this helps you prepare TRI reports by the July 1 deadline.

tim faganTimothy P. Fagan is a Legal Editor for BLR’s environmental publications, focusing primarily on air quality related topics. Before joining BLR, he spent 5 years in environmental consulting and was responsible for air quality permitting and compliance for a broad range of industries in both the private and public sector. He received a Bachelor of Science degree in chemical engineering from Villanova University and a Master’s degree in environmental engineering from the Pennsylvania State University. He is a member of the Air and Waste Management Association.

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