Frequent Questions

TRI applicability for auxiliary facilities

An auxiliary facility is one that supports another covered establishment's activities (e.g., research and development laboratories, warehouses, and storage facilities).  How has the switch from the Standard Industrial Classification (SIC) system to the North American Industry Classification System (NAICS) for TRI reporting affected auxiliary facilities?

The SIC system assigns SIC codes to auxiliary facilities according to the primary activity of the establishment that they serve.  NAICS does not recognize the concept of auxiliary facilities and assigns NAICS codes to all establishments based on their own activities.  For the purpose of establishing consistency with the NAICS classification methodology, EPA changed its interpretation of the applicability of TRI reporting requirements to auxiliary facilities.  As a result, some auxiliary establishments will no longer be subject to TRI reporting.  For the years in which SIC codes and auxiliary facilities were relevant (Reporting Years 1991-2005), TRI-MEweb will automatically guide users to select a SIC code in lieu of a NAICS code.  TRI-MEweb contains a list of SIC and NAICS codes for users to search and select.

For example, Company X owns and operates a rice milling facility with NAICS code 311212.  Company X also owns a warehouse where the finished product from the rice milling facility is stored before it is distributed to customers.  Under the SIC system, the warehouse would adopt the same SIC code as the rice milling facility (2044) and would be subject to TRI reporting if it met the other applicability criteria.  However, under the NAICS system, the warehouse would not adopt the code of the rice milling facility and would be assigned a NAICS code based on its own economic activity.  As a result, the warehouse might not be subject to the TRI reporting requirements.

 

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