In October 2005, Facility X changes ownership and is purchased by Company Y. For the 2005 reporting year, which facility is obligated to submit the Form R or Form A, and whose name and what TRI identification number should be on the form?
The owner or operator of the facility on the annual July 1 reporting deadline (i.e., Company Y) is primarily responsible for reporting the data for the entire previous year’s operations at that facility. Any other owner or operator of the facility before the reporting deadline may also be held liable. The form submitted for a given reporting year must reflect the names used by the facility and its parent company on December 31 of that reporting year, even if the facility changed its name or ownership at any time during the reporting year (Monthly Call Center Report Question, EPA530-R-98-005j; October 1998). In this scenario, because Facility X changed ownership before December 31 of the reporting year, Company Y’s name should appear on the form. The TRI identification number is location-specific; thus, the identification number will stay the same even if the facility changes names, production processes, or NAICS codes.