EHS Support Blog EPCRA Section 313 Toxic Release Inventory (TRI) Reporting Obligations: Readily Available Data and Reasonable Estimates

By: Bob PickertWe recently provided a client alert for the United States Environmental Protection Agency's (EPA) March 26, 2020 policy memo COVID-19 Implications for EPA's Enforcement and Compliance Assurance Program. The bottom line is that facilities are expected to make every reasonable effort to comply. If compliance is not possible, regulated facilities are advised to document that non-compliance was not intentional, and therefore not a criminal violation. For submittal of TRI forms (Form R or Form A), there ...