Dairy companies that process, manufacture or use certain toxic chemicals above threshold amounts are required to submit "Form R" reports to the U.S. Environmental Protection Agency (EPA) every year by July 1. Companies must submit a Toxic Release Inventory (TRI) report for each chemical on the EPA's list of over 600 chemicals, including several cleaning and maintenance chemicals routinely used in dairy operations.

Significant penalties exist for late reporting and failure to report, so IDFA member companies are encouraged to make sure that all operations are in compliance. TRI reporting is part of Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). EPA compiles the submitted TRI reports into a database that is open for public access.

TRI reporting requirements are in addition to a company's obligation to report the storage and inventory of hazardous and toxic chemicals on inventory forms, due each year by March 1. The dairy processing industry is subject to TRI reporting most often because of its use of cleaning solutions that contain acids, such as nitric and peracetic acids, as well as its use of ammonia as a refrigerant.

Members with questions may contact Clay Detlefsen, IDFA vice president, at cdetlefsen@idfa.org or (202) 220-3554.