May a representative from a consulting firm that prepares a Form R or Form A for a covered facility sign the certification in lieu of the covered facility's owner/operator?
No. A representative from a consulting firm preparing a Form R or a Form A for a covered facility cannot sign the certification in Part I, Section 3 of either the Form R or the Form A. The certification must be signed by the owner/operator, or a senior management official employed by the facility subject to EPCRA Section 313 toxic chemical release inventory reporting. Senior management official means an official with management responsibility for the person or persons completing the report, or with management responsibility for the manager of environmental programs for the facility or establishments, or with management responsibility for the corporation owning or operating the facility or establishments responsible for certifying similar reports under the other environmental regulatory requirements (40 CFR Section 372.3). Additional guidance can be found on the TRI GuideME Web site.