Frequent Questions

How could a facility with multiple establishments with separate activity thresholds report their releases?

A covered facility with three establishments exceeds an activity threshold for a listed toxic chemical. The facility has the option to file one form to cover the activities at the entire facility or they may file forms for each of the establishments as long as the threshold determinations and release and other waste management calculations are based on all of the activities at the entire facility. The facility chooses to file separate Form R reports for each establishment. All three of the establishments conduct a threshold activity with the listed toxic chemical. However, one establishment does not release or perform any waste management activities with the listed toxic chemical. Must this establishment also file a Form R or can the facility submit only two Form R reports?

If individual establishments or groups of establishments report separately for one listed toxic chemical, they must report separately all covered activities, releases, and other quantities of the toxic chemical managed as waste. Therefore, if each establishment conducts a threshold activity with the toxic chemical, each establishment is also required to report separately for the toxic chemical even if the establishment had no releases or other waste management activities with the toxic chemical. 

To create one or more establishments for a particular facility within TRI-MEweb, click on “Facility Management” and go to the “Manage Facilities” page. Under the “Multi-Establishment” column, click on the “Create Establishments” link for the facility for which you want to create additional establishments for use in reporting by part. To add an establishment, create a unique name for each establishment and click the “Create” button. A unique name should help distinguish this part or establishment from other establishments (e.g., incinerator unit, storage unit). Once you have created one or more additional parts, the preparer should edit the NAICs code(s) and Dun & Bradstreet Number(s) for each establishment unit. 

Additional information on multi-establishment facility determinations can be found in the Reporting Forms and Instructions and in guidance documents and Q&As on GuideME.


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