With the New Year creeping around the corner, we're starting to hear from a lot of old & new clients about certain annual requirements. Whether it's annual certifications as part of an NPDES Stormwater Permit or maybe some type of environmental training like SPCC Training, many folks are being proactive and trying to nip their responsibilities in the bud sooner rather than later.
One annual requirement that many people start considering this time of year is the need for TRI Reporting. For those who aren't familiar with the subject, I encourage you to check out What is TRI Reporting? to learn more.
On a side note, I will add that plenty of folks confused both Community Right-to-Know Reporting and TRI Reporting. If you're one of those people, check out our article Is Tier II Reporting the same as TRI Reporting?
For those who are familiar with the subject, let's address one of the more common questions we get, which is what's the difference between Form A Reporting & Form R Reporting when it comes to TRI Reporting.
One of the biggest issues with environmental regulations is the often-confusing names. This is especially true with TRI Reporting. For instance, over the years we've heard TRI Reporting referred to as:
I've heard others too, but they're too incorrect to count. But, these listed above are all technically correct ways to describe the activity. Here's how it all works.
Clear as mud, right? You're probably wondering what's the difference between the two forms at this point.
Think of it like doing your taxes. If you're a contractor, you're using a 1099-MISC form. If you're employed, you'll be using a W-2. At the end of the day you're still using these forms to pay your taxes, there are just different reasons why you would use each form.
At this point, I'm already assuming you know that you need to conduct TRI Reporting. If you're unsure, check out Why do I need to do TRI Reporting? to learn more on the subject.
Here are the main differences between both Form A & Form R.
Without a doubt, this is the more complex form to complete when it comes to TRI Reporting.
Form A is more simplistic and is often referred to as a "certification statement". You only have to answer a few questions, allowing this form to be completed in a fraction of the time compared to Form R.
Form A can be used in place of Form R if all of the following criteria are met:
Like we tell every one of our clients & customers, education and getting things done ahead of time is the best way to stay ahead of this environmental regulation. If you want to avoid a multi-million dollar fine, mountains of paperwork, as well as legal & consultant fees, then stay ahead of reporting by educating yourself and getting things done early!
If you're trying to educate yourself, your best bet is to do one of three things: Ask an industry expert who completely understands TRI Reporting and the regulations surrounding it, contact a competent environmental consultant who understands TRI Reporting (such as us here at RMA!) and the regulations surrounding it, or make an anonymous call to the USEPA and find out more.
If you're hesitant to reach out to experts just yet, I urge you to take anything you hear from colleagues and/or competitors, as well as trade associations with a grain of salt. Why? From our experience, trade groups and colleagues or competitors are often just as in the dark as you are. We've spoken to enough "environmental experts" within various organizations who aren't well-educated on the subject.
With fines for non-compliance ranging from the tens of thousands to tens of millions, no organization out there can afford to be wrong about TRI Reporting.