When is it due?
1 July each year, for the preceding calendar year.
KODAEnvironmental
Form R · due 1 July
TRI is the filing that most rewards good records and most punishes bad ones. Every number on a Form R has to hold up under scrutiny, and the work that makes it hold up happens when the data is captured, not when the form is filled in.
What actually matters
Where this one
goes wrong
01
The waste management section is where we add most
Section 8 asks what happened to the chemical after it left the process — recycled, recovered, treated, disposed. That is the part KODA already tracks, and the part most often estimated loosely.
02
Every figure needs a basis, not just a value
A Form R number without a written basis will not hold up two years later, once the person who produced it has moved on. We write the basis down as part of the work.
03
It is a public document
TRI data is published and is read by neighbours, journalists, customers and investors. Accuracy matters here for reasons beyond compliance, and a figure that moves sharply without explanation invites a question.
04
Year-on-year movement is the story
The number people react to is rarely the absolute figure — it is the change. Knowing why a stream moved before the data is public is worth more than finding out afterwards.
What we need from you
To start
- Throughput for listed chemicals across the reporting year
- Release and transfer data, by route
- Waste management quantities, by method
- Production index or activity data for the year-on-year comparison
- Process knowledge for the estimation basis behind each figure
What you get back
To file
- Completed Form R submissions ready for certification
- The calculation basis behind every reported figure, written down
- A file that answers the question of where a number came from
- The year-on-year comparison, with the reasons for movement
Deadline
1 July, for the preceding calendar year
KODA prepares the submission. Your authorized official certifies and files it — that is how the requirement is written, and anyone telling you otherwise is describing it loosely.
Questions
Asked most often
Do we have to file one?
It depends on your activity, your employee count and how much of a listed chemical you manufacture, process or otherwise use. Some chemicals carry far lower thresholds than the general ones. It is worth settling the question deliberately rather than carrying an assumption.
Can you sign it?
No. A senior management official of the facility certifies a Form R. We prepare it and the supporting basis; your official certifies and submits.
Also handled
Other filings
EPCRA · due 1 March
Tier II chemical inventory reporting
The annual chemical inventory report. Prepared from your data, ready for you to certify.
State & federal waste reportsAnnual waste summaries and biennial reports
Annual and biennial waste reports, assembled from manifest data rather than rebuilt.
Phase I & Phase IIPhase I and Phase II environmental site assessments
Assessments for transactions, closures and financing — written to be relied on.
Start before the deadline,
not on it
Tell us which filings you carry and we will tell you what we would need and when we would need it.