TRI Form A vs. Form R: The Alternate Threshold Reporting System
Most TRI reports are submitted on Form R — the standard reporting form that requires detailed information on releases, waste management, and production ratios. But facilities that meet certain criteria can instead submit Form A, a simplified alternate threshold form that provides much less detail. Understanding the difference between Form R and Form A submissions is important for interpreting TRI data at the facility level.
When Form A Is Allowed
A facility can submit Form A for a specific chemical if: (1) it manufactures, processes, or otherwise uses the chemical in amounts above reporting thresholds, (2) its total annual releases to all environmental media are 500 lbs or less, and (3) its total annual waste managed (releases plus transfers) is 1 million lbs or less. Form A was introduced to reduce the reporting burden for facilities with low-level releases, since those facilities are presumably lower priority for environmental concern.
What Form A Lacks
Form A provides much less information than Form R. It confirms that a facility manages the chemical in reportable quantities, but it doesn\'t break down releases by media (air vs. water vs. land), doesn\'t report off-site transfers to specific facilities, doesn\'t provide production ratio information, and doesn\'t detail waste management activities (recycling, treatment, energy recovery). This means facilities reporting on Form A appear in TRI with minimal detail compared to Form R filers.
Implications for Data Analysis
When browsing TRI data on EmissionsLookup, facilities that submitted Form A for a chemical will show minimal release quantities — potentially 0 or very small amounts reported to specific media — even though they are confirmed to handle the chemical. Analysts comparing total releases across facilities should be aware that Form A filers are systematically underrepresented in release totals, not because they release nothing, but because detailed release data isn\'t reported. Browse facilities with TRI data at the top emitters page and individual chemicals of concern.
PFAS and Form A
For PFAS chemicals added to TRI, EPA set the reporting threshold at 100 lbs — lower than the standard 25,000/10,000 lb thresholds. But the Form A alternate threshold is based on releases (500 lbs or less), which can still be significant for PFAS given their persistence. The interaction between the lower PFAS reporting threshold and Form A eligibility is an active area of EPA regulatory attention. Browse PFAS-reporting facilities at the PFAS facilities index.