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April 23, 2019

EHS Compliance Reporting and Change Management Costs - TRI Reporting

TRI Reporting Blog HeaderBack in November, we posted an article called EHS SOFTWARE AND SAAS - TWO SITUATIONS TO CONSIDER. In that article, we talked about topics to consider as you look to purchase software or replace aging software to enable your EHS compliance and risk reduction programs.  One additional topic to consider is the cost of change management. This article touches on one example of the pace of change of regulatory reporting and how the IT strategy your organization takes (On Premise or Cloud) will impact your internal change management costs. 


In 2017, there were 21,456 facilities in the U.S. that were required to submit Toxics Release Inventory (TRI) Reports. Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) created the TRI Program and the facilities that report under that program generated and managed a combined 30.5 billion pounds of production-related waste.


If your facility is in a regulated industry sector, employs more than ten full-time employees, and manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above threshold levels in a given year you are responsible for submitting a TRI Form R.  A Form R is submitted for each TRI-listed chemical above the reporting threshold at each location.


It also means you must submit each reporting form using TRI-MEweb.  TRI-MEweb is the EPA's online TRI reporting application used to provide national and local analysis of chemical releases. The information provided in TRI reports is required to enable decision-making by communities, government agencies, companies, and others. EPA has records on TRI reports from 1987 to 2017, and 2018 reporting is due by July 1, 2019.


Each year EPA adjusts their requirements for submission. The changes can be small or large depending on the year and the needs of the program. They can be both technical changes in the reporting like adjusting the XML schema, or functional changes in lists, thresholds, or any number of highly detailed changes in the information collected or calculations performed in the parts and sections of the TRI report generation. The best example to understand TRI reporting is your annual tax return each year there are small or large changes in your tax reporting submissions. TRI is the same.


As a software provider, Enviance software as a service is delivered to our customers on a desktop computer, tablet, or mobile device via a web browser. Our customers use our air compliance software to collect both measured (e.g., Continuous Emissions Monitoring devices) and modeled (e,g. AP 42, Fire, and Tanks Emissions Factors) emissions. They use waste management software to track waste containers and shipments for both on-site and offsite disposal. They use water compliance software to report water discharges to both publicly owned treatment works (POTW) or directly into waters of the United States. Daily use of our software makes the TRI reporting a significantly less burdensome process for organizations to submit. Chemicals that exceed activity threshold are automatically pulled in Enviance’s TRI Reporter. The Enviance TRI reporting tool has been in use for 18 years and updated each year as EPA changes their requirements. 


For the reporting year 2018 (reporting forms due by July 1, 2019), EPA made various enhancements to TRI-MEweb to improve the user experience and also update the software to reflect the Information Collection Request (ICR) renewal finalized in October 2018. The documents below describe the RY 2018 changes. Each year EPA makes reporting changes, and our software needs to be adjusted to enable this reporting. 


The Enviance TRI Reporter mimics the Form R so it's easy and intuitive to review, edit and populate your data. It allows you to track your reviewing progress and once done, with two clicks you can export all Form R’s in XML format and upload them to TRI-ME Web. It’s that easy. Changes to the Form R can be both well communicated by the EPA and at other times changes can be relatively last minute. Either way when the changes are provided to the reporting community the report submission date does not change.


They (EPA) also finalized a rule effective for 2019 TRI reporting (forms due July 1, 2020) adding NPEs Chemical Category to the TRI list. Our reporting software is ready now to enable your TRI chemical tracking in advance, you can get ahead and start tracking it now and do analysis before new RY is due. For example, if you have a pollution prevention goal in place you can easily monitor it throughout the year; you don’t have to wait until annual reporting. We can create dashboards and visualizations with your TRI data so you can plan improvements and reductions proactively. 


As you consider software tools to improve the productivity and accuracy of your reporting, cloud software has a major advantage over software designed in an on-premise delivery era. As regulatory agencies require TRI reporting, NPDES, Emissions Inventories, Biannual Waste Reporting, Electronic Manifesting and more each one of these programs has ongoing regulatory and technology changes that must be addressed quickly and be tested based on unique customers configurations and compliance situations.


IT and EHS departments want software to manage their EHS programs, but they are not in the business of managing QA & and testing new versions to address rapid changes in regulatory reporting. Our job as the software provider is to drive the accuracy and productivity of compliance reporting. As cloud providers and having access to the EPA test environments, our ability to get ahead and quickly change the software and test a wide range of situations is unmatched by any provider not in a multi-tenant SaaS environment. Again, the goal is to make compliance reporting on time and accurate but keep compliance costs low. 


If you have software deployed on your servers, when the EPA or other government agencies make changes to their paper or electronic reporting standards your software supplier needs to update their software just like us. The difference is the supplier needs to send you the updates to install test and verify against your specific deployment. After you test your specific configurations you can provide feedback that may require changes again by the provider. That means your IT or EHS staff need to be ready and available to make those updates and test for accuracy. This process creates a cost for your business.


With the Enviance EHS Platform, we take care of upgrades and can test our changes quickly. If the agencies change reporting requirements at the last minute, we can change quickly. Our customer success managers and software team are committed to providing you with the regulatory changes to ensure accuracy with your TRI Reporting and many other electronic reporting formats. 


If you want to learn more about how our Software as a Services can help you improve your performance click on any of the links on the right-hand side of this post.


Link to EPA Toxic Release Inventory Reporting Forms and Instructions

Link to changes in TRI-MEweb Reporting Tool for 2018


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