Toxic Chemical Release Inventory Reporting Forms and Instructions

Appendix C. Facility Data Profiles and Common Errors in Completing
Form R Reports and Form A Certifications
EPA wishes to ensure that facilities submit all required TRI chemical submissions in a timely manner so that the information may
be included in its national database, annual public data release, and other information products. Moreover, EPA seeks to ensure that
all submitted data is complete and accurate. This appendix provides an overview of Facility Data Profiles (FDPs), an important
communication tool that EPA uses to ensure consistent, complete, and accurate submissions from reporting facilities. This appendix
also provides specific guidance to avoid common errors in completing Form Rs and Form A Certification Statements, including errors
in threshold determination, misapplication of exemptions, and overlooking activities involving a reportable chemical, any of which
may result in mistaken non-reporting of a chemical.
A. Facility Data Profile (FDP)
Facility Data Profiles (FDPs) are made available by TRI Data
Processing Center to a reporting facility in response to any
submission the TRI Data Processing Center receives. You may
review your FDP on the internet at http://www.triefdp.org. A
submission can include an original or revised Form R or Form
A, or corrections included in a response to a previous FDP.
The FDP serves two primary purposes. First, EPA wants to
give the reporting facility the opportunity to confirm that the
TRI Data Processing Center has entered its data correctly into
EPA’s national computer system – i.e. the TRI Data Processing
Center “echoes back” the information that it has received.
Second, if the TRI Data Processing Center identifies potential
errors in the forms a facility has submitted, the FDP indicates
what these errors are and requests that the facility provide EPA
with corrections. If the data presented on a facility’s FDP do
not match those on the form(s) it submitted, or if the TRI Data
Processing Center has identified errors in a facility’s
submissions, or if a facility discovers errors in its submitted
data, the facility may use the FDP to make the needed
corrections. The FDP does not serve as a means to withdraw
a Form R and/or Form A. Withdrawal requests should be
mailed to the TRI Data Processing Center. For additional
information regarding withdrawal procedures see Section A.5
of this document or go to . Facilities that
send corrections to their FDPs are encouraged to submit a
revision using CDX. Hard copy FDPs should be signed and
mailed to the address listed in Section A.7.c of this document.
An FDP is comprised of the following sections:
” Cover Letter. This page provides the type of
information included in the report; classification of
possible errors noted; and instructions for contacting
help resources.
” Instruction and Signature page. This page provides
instructions on how to review and respond to the FDP.
The bottom half of the page provides a certification
statement to be signed by a facility owner/operator or
senior management official.
” Summary of Non-Technical Data Changes
(NDCs), Notices of Technical Errors (NOTEs)
and Notices of Significant Errors (NOSEs). FDPs
identify three different types of errors: NDCs,
NOTEs and NOSEs. NDCs and NOTEs are
identified at the end of each chemical report. If you
have no NDCs or NOTEs, this page will indicate so.
There is one page that lists all significant errors
(NOSEs) for your facility’s submissions, organized
by chemical submission. The FDP serves as a Notice
of Significant Error. If you have no significant
errors, this page will indicate so.
” Facility Information. This section displays all
facility specific data, including TRI Facility
Identification, facility name, facility address, facility
mailing address, relevant permits (e.g., RCRA,
NPDES, and UIC), Standard Industrial Classification
code (SIC), and other facility data. Errors related to
facility information will be provided in this section.
” Facility Information (Establishment). If an
establishment reports separately from other
establishments at the facility, this section provides
subordinate facility data. Errors related to this
information will be provided in this section.
” Chemical Report Summary. This section lists all
chemicals reported by the facility for each reporting
year covered by the FDP. For example, if the FDP is
responding to five original chemical submissions for
Reporting Year 1999 and revisions to one chemical
for Reporting Year 1998, a list of all chemicals for
both years will appear.
” Chemical Reports. All recently processed Form R
or Form A submission data (i.e., chemical specific
data) are displayed here under the appropriate facility
or subordinate facility names. The FDP displays
facsimiles for chemical reports for submissions
received during the current calendar year, revisions
or responses to FDPs only. For example, if a facility
originally reported five chemicals for Reporting Year
Toxics Release Inventory Reporting Forms and Instructions C–1