The following post is provided by our guest author, Karen Lutz from TRC Environmental Corporation.
This year, USEPA has made a change in the Toxic Release Inventory (TRI) reporting process, merging their reporting/certification systems. As part of this process, they have added several new steps that previously approved Certifying Officials will need to conduct in order to be able to certify reports for this year.
Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) of 1986 was enacted to facilitate emergency planning, to minimize the effects of potential toxic chemical accidents, and to provide the public with information on releases of toxic chemicals in their communities. Each year by July 1, regulated companies are required to provide information for the prior calendar year on disposal or other releases and other waste management activities related to the list of regulated chemicals.
The information is submitted electronically, via the Toxics Release Inventory – Made Easy web site (TRI-MEweb). The U.S. Environmental Protection Agency (EPA) then maintains this data in a national database called the Toxics Release Inventory, which is available to the public.
The reports are required to be signed by a Certifying Official, typically a senior management official with the authority to certify the report. In signing the document, the Certifying Official states that to the best of their knowledge, all information is complete and accurate and that any knowing or willful misinterpretation is subject to criminal penalty.
What is New:
All existing Certifying Officials are now required to electronically update their Electronic Signature Agreement (ESA) which was previously submitted via hard copy. This update can be done electronically in the system; no additional hardcopy submittals are required. Because the Certifying Official is sometimes not the Preparer of the report, and because there may be some turnaround on USEPA’s part to verify the Certifying Official’s title and signature authority, we recommend that the ESA update process be completed prior to TRI submittal so that a certified report is not delayed past the July 1 deadline.
Follow the steps below to update the ESA electronically: