Updated Security Requirements for CY2012 Toxic Release Inventory Reporting

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.  

Background:

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:

1. The Certifying Official will need to log-in to their Central Data Exchange (CDX) account at https://cdx.epa.gov/CDX/Login.
2. If they haven’t logged in since last summer, they will be prompted to pick and answer three new security questions (the answer can be the same for each).
3. If it has been several months since logging in, the system will ask that the login password be changed.
4. Once the password has been changed, the system will require the Certifying Official to pick and answer five new security questions (this is required to update the Electronic Signature Agreement and will likely be used during the TRI reporting certification process this year). These security questions must each be unique.
5. From the main CDX page, click on the “TRIME-web” link under the “Roles” column. 
6. Instead of loading the TRIME-web application this time, it will take the Certifying Official to the ESA update. A security warning will open in a separate window. The “I accept the risk and want to run this application” box must be checked before clicking the “Run” button.
7. After that window closes, click the green “Sign Electronically” button at the bottom of the page. Click “Accept” on the next window to certify.
8. A new window will open prompting for your CDX password, then an answer to a secret question (from the five created in step 4 above), and then the “Sign” button will have to be clicked. Wait a couple of seconds and it will take them back to the main CDX page.
9. Click on the “TRIME-web” link under the “Roles” column again and the application will open in a separate window.
10. In the TRIME-web application, click on the “Certify” tab at the top. On the following screen, the certifying official will need to provide their title by clicking the “Provide Title” button and entering that information.
11. After updating the title, click the check box next to the facility’s name under the Pending Signature section and then click on the “Sign Agreement” button. On the next page, click the “Sign Agreement” button at the top.
12. A new window will open prompting for the CDX password, then an answer to a secret question (from the five created in step 4 above), and then the “Sign” button will have to be clicked. It will confirm that the signature was completed successfully.  At this point, the ESA has been updated.
13. Click on the “My Facilities” tab at the top and confirm a green check mark in the “ESA Status” column.