For EPCRA §313 TRI reporting, if a covered facility determines that it erroneously submitted a Form A in a given reporting year, can the facility change the Form A to a Form R by submitting a revision?
A TRI-covered facility that submitted a Form A for a given reporting year but later determines that it should have submitted a Form R must withdraw its Form A and submit a Form R for that reporting year as soon as possible. In this case, the withdrawal of the Form A and subsequent submission of a Form R will result in the loss of the original submission date of the Form A. If the Form R is submitted after the deadline for the applicable reporting year then the Form R is considered a late submission.
Additionally, the facility may wish to consult the Environmental Protection Agency’s (EPA) Audit Policy, a policy offering incentives to promote self-disclosure and expeditious correction of violations, to see whether it is applicable to the facility’s situation. Information on the Audit Policy and EPA Audit Policy Contacts is accessible at www.epa.gov/compliance/epas-audit-policy. The TRI Regional Coordinator for your facility should also be able to assist you should you have any questions on TRI reporting or the Audit Policy.