What is Recycling for TRI P2 Reporting?

Chem Industry News


Here is a pop quiz on being green: name everything that can go in the recycling bin at home! Which types of plastics? And is used aluminum foil okay to throw in there? This is a question that is tough for the typical home cook, even though in some places, the law says we must participate in recycling programs.

The rules for chemical industry recycling are much more complex and the regulations are much tighter. These facilities have great potential to keep hazardous materials out of the environment, and we’re not talking about plastics code 1 or 2, that’s little league. We’re looking at chromium sludge and Freon 113 and other toxic materials that can be recycled in bulk by their respective facilities for the betterment of human kind.

Companies that fall under the jurisdiction of the Toxic Inventory Release (TRI) reports have an opportunity to humbly brag about their recycling and source reduction accomplishments in the P2 section of the report. This is a chance for public reputation building and for sharing best practices with the rest of the industrial field.

The EPA oversees the TRI reports and they have a handy tool to search for other P2 reports from other companies. With TRI.NET, anyone can search the TRI reports by location and more. This is one way that safety professionals can find out what solutions are already out there so they don’t have to reinvent the wheel. One of the driving goals of this program is to break down barriers to access all the existing excellent pollution solutions.


The EPA tells us that they’re trying to make the TRI reporting process as painless as possible. In addition to the TRI.NET, the EPA website offers resources to help facilities really pinpoint what activities really count as recycling.

This qualification depends on the function and direction of the chemical in the industry process. It’s important to get down to specifics so that the proper amount of “recycled” material is reported in the right calendar year. It’s a juggling act of calendars and chemical reactions. The people in each company who write the reports have their work cut out for them!

The EPA offers guidance documents on TRI recycling and reporting complete with several “what if” scenarios. For example, what if a wastewater facility takes the chromium out of sludge, recovers the chromium and sells it for reuse? The EPA says that if all of these processes occur within the calendar year, then the reclaimed chromium that was sold is the amount to report as recycled.


That is pretty straightforward, so here’s another scenario. What if the sludge was treated at the wastewater facility and the metal-bearing sludge was kept into the next calendar year before treating and reselling it? In this case, the EPA’s guidance documents tell us that the material should not be reported as recycled until the metal is recovered into a usable product. It doesn’t have to be reused or sold, only “recovered into a usable product,” before it can don the moniker recycled.

Here’s one more question. What if there was a software solution that could track chemical inventory in real-time and enable turnkey regulatory reporting? The answer to this question comes to us from ChemSW. Please visit our site to find out more about our inventory management software, CISPro™, and how it can help you with TRI reporting today!

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