Understanding TRI Reporting and How RCAP Supports Accurate Emissions Data

What is TRI Reporting?

The Toxics Release Inventory (TRI) is a program mandated by the EPA that requires facilities who meet the reporting thresholds to submit information annually on July 1st about the release and management of chemicals. Both methylene diphenyl diisocyanate (MDI) and toluene diisocyanate (TDI) are covered by the TRI program, and facilities that manufacture or use either chemical may be required to report their releases to EPA. 

TRI was created to be a resource for the public on releases and other waste management of listed chemicals in their communities. In addition to this, TRI information can and has been used in the following ways:

• Federal, state and local governments use TRI data to develop environmental policies and regulations,¹ 
• Non-governmental groups use TRI data to evaluate local environmental conditions and design improvement goals,²  
• Academic institutions use TRI data to investigate research questions,³ 
• Media/journalists use TRI data to report on trends in toxic chemical releases.⁴ 

The Importance of Accurate Reporting 

Industry is encouraged to take a science-based approach to environmental, health and safety (EH&S) reporting. This includes engaging with stakeholders, participating in open, constructive dialogue, and promoting transparency and data integrity in governmental decision-making processes. 
It’s important to provide reliable information on actual emissions given the important uses of TRI data. In the past, publications have correlated TRI data to adverse health effects, though these may be weak correlations based on inaccurately estimated releases.^5,6 For these reasons, it is vitally important for those calculating and reporting air emissions to take steps to report accurately and to understand the potential implications of inaccurate reporting.

How CPI’s RCAP Tool Can Help

The American Chemistry Council’s Center for the Polyurethanes Industry (CPI) offers a free Regulatory Compliance Assistance Program (RCAP) to assist reporting of accurate TDI and MDI emissions. 

Key Features of the RCAP Tool

1.MDI & TDI Emissions Estimator Tools:

• Available for polymeric MDI (PMDI), MDI, and mixed isomer TDI as well as two isomers (2,4-TDI and 2,6-TDI)
• Offers a method to estimate the emissions from typical process activities including storage tank and fugitive emissions with enclosed process and/or open process

2. User-Friendly Interface:

• The tools are available as lockable spreadsheets compatible with Microsoft Excel, allowing users to import data and generate reports easily

3. Guidance and Support:

• CPI provides general guidance about the reporting process and individual assistance to RCAP tool users, including a how-to webinar. However, each facility must independently determine its reporting obligations

For more detailed information and access to the tools, visit the RCAP tool available on CPI’s website. 

_{¹ U.S. Environmental Protection Agency. "TRI for Government." Toxics Release Inventory (TRI) Program, https://www.epa.gov/toxics-release-inventory-tri-program/tri-government.}

_{² Neltner, T., McCormick, L., & McIntosh, A. (2018, July 31). Lead service line inventories – Indiana as a good model of a voluntary survey. EDF Health. https://blogs.edf.org/health/2018/07/31/lsl-inventories-indiana-model-voluntary-survey/.}  

_{³Gaona, S. (2020, February 25). How TRI data are used by academics and other researchers. Commission for Environmental Cooperation. https://www.cec.org/wp-content/uploads/2020/05/session-13-how-tri-data-are-used-by-academics-and-others_s-gaona_eng.pdf.}

_{⁴Davis, J. A. (2023, April 5). Latest TRI data can charge up local stories, including on PFAS. Society of Environmental Journalists. https://www.sej.org/publications/reporters-toolbox/latest-tri-data-can-charge-local-stories-including-pfas.}

_{⁵Jordan Zeldin et al. Exposure to isocyanates predicts atopic dermatitis prevalence and disrupts therapeutic pathways in commensal bacteria. Sci. Adv.9, eade8898(2023).DOI:10.1126/sciadv.ade8898}

_{⁶Energy Efficiency for All, Chemical and Environmental Justice Impacts in the Life Cycle of Building Insulation. Sept 2022.}