Four commonly overlooked categories in TRI reporting

Toxics Release Inventory (TRI) reporting is a well‑established requirement for many industrial facilities, yet it remains one of the most challenging environmental reporting programs to execute accurately. Even experienced environmental, health, and safety (EHS) teams can unintentionally miss reportable chemicals. In many cases, facilities believe they are fully compliant because they understand the basic rules and have reported consistently in prior years. However, TRI oversights frequently occur because chemicals appear in less obvious ways than during routine operations.

Most missed TRI chemicals tend to fall into four commonly overlooked categories. Understanding where these gaps arise can help facilities improve data accuracy, reduce compliance risk, and avoid last‑minute corrections or enforcement issues.

Newly added or updated TRI chemicals

One of the most common reasons facilities miss TRI chemicals is failure to track changes to the TRI chemical list. EPA updates the list more frequently than many organizations expect, adding new chemicals, expanding existing categories, or lowering reporting thresholds. When facilities rely on past reporting assumptions without reviewing annual updates, they may continue using materials that now contain reportable chemicals without realizing it.

Recent changes provide clear examples. EPA expanded TRI reporting for per‑ and poly‑fluoroalkyl substances (PFAS) for Reporting Years 2024 and 2025, significantly increasing the number of covered compounds and tightening reporting expectations. In addition, EPA added a full diisononyl phthalate (DINP) chemical category in 2023. These changes mean that products such as coatings, sealants, lubricants, plastic components, and flexible materials—items not traditionally viewed as “toxic chemicals”—can suddenly trigger TRI applicability.

Because these substances are often embedded in purchased materials rather than handled as standalone chemicals, facilities may overlook them unless they perform a detailed review of safety data sheets (SDSs) and supplier disclosures each year.

“Otherwise used” chemicals

Another frequently missed category involves chemicals that are “otherwise used.” TRI reporting is not limited to chemicals that are manufactured or processed into products. Many TRI‑listed substances are used in support roles, including cleaning, degreasing, equipment maintenance, laboratory analysis, and utilities.

Facilities often overlook these chemicals because they are not part of the production process and may be purchased in small quantities. However, repeated use across departments, shifts, or maintenance activities can quickly accumulate. Solvents, acids, caustics, adhesives, and specialty cleaners are common examples.

For most TRI chemicals, the reporting threshold for “otherwise used” is 10,000 pounds per year. Without tracking total annual usage, facilities may underestimate how quickly these chemicals add up, especially when multiple products contain the same TRI‑listed substance.

Coincidentally manufactured byproducts

Some TRI chemicals are not intentionally used at all but are created unintentionally as part of normal operations. These coincidentally manufactured byproducts are still considered “manufactured” under TRI rules and must be evaluated against reporting thresholds.

Common examples include ammonia formed during heating, baking, or combustion processes; nitrates generated through biological or chemical wastewater treatment; and metal compounds produced during welding, machining, grinding, or corrosion. Diesel‑powered equipment can also generate reportable byproducts such as naphthalene and polycyclic aromatic compounds.

These chemicals are often overlooked because they are difficult to quantify and may not be captured through standard purchasing records. Facilities may also assume that byproducts managed on‑site or sent to wastewater treatment are exempt, which is not necessarily the case. Engineering estimates, emissions factors, and coordination with operations staff are often needed to properly evaluate these substances.

Impurities or additives in mixtures

Many TRI‑listed chemicals are present not as primary ingredients, but as impurities, stabilizers, or additives within mixtures. Oils, fuels, coatings, inks, lubricants, and plastic resins frequently contain small percentages of reportable chemicals.

If a facility focuses only on the main ingredient of a product, it may miss these hidden components entirely. Yet even low‑percentage constituents can exceed reporting thresholds when large volumes of material are used over the course of a year. This is especially common with metal compounds, solvents, and plasticizers.

Careful review of SDS Section 3 information and follow‑up with suppliers when composition details are unclear are critical steps in identifying these chemicals.

Reducing TRI reporting risk

TRI oversights typically occur not because facilities ignore the rules, but because chemicals appear in unexpected forms. Staying current with EPA updates, tracking cleaners and maintenance chemicals, evaluating process byproducts, and closely reviewing mixtures can prevent the most common reporting errors. With a proactive and systematic approach, facilities can improve TRI accuracy and maintain stronger regulatory compliance year after year.

Let J. J. Keller help you with TRI Reporting.  Call 844-803-0172 or Learn more.