Q&A: Do I count corporate employees for EPCRA TRI reporting?

Question

In counting my full-time employees or equivalent hours for EPCRA Toxics Release Inventory reporting, do I need to include corporate HQ and support staff if they do not work onsite?

Answer

EPA addresses this situation in its 2024 Questions and Answers for the Toxics Release Inventory (TRI) Program. The question posed was “When should an individual’s time spent working for a facility be counted for purposes of determining whether or not a facility exceeds the 20,000-hour employee threshold?”

EPA’s reply is as follows: “If an individual is employed by the facility or by the facility’s parent company to work for the facility, then all of the hours worked by the individual at or for the facility should be counted toward the 20,000-hour employee threshold. For example, a headquarters engineer spends most of her time at headquarters, but some of her time is spent at a covered facility. The time the engineer spends at the covered facility and the time the engineer spends working for the covered facility while at headquarters should be included in the facility’s employee threshold determination. If the individual is hired by the facility (or by the facility’s parent company) as a contractor to work at the facility and is based at the facility, then all hours worked by the contractor should be counted. If the individual is not an owner, contractor, nor an employee of the facility, then the individual’s time spent working at the facility should not be counted toward the 20,000-hour employee threshold. For example, the time spent by individuals who are performing intermittent service functions at the facility, such as municipal trash collectors or the electric utility company repairing power lines, should not be counted.”

So yes, you need to include any hours that regional work teams, corporate staff, and contractors work at the facility and any hours they spend working for the facility while at the regional/corporate location.

The EPA provides this screening tool to help you determine total hours per year. To use the tool, click the “Help me determine” option on the page, which guides you through the process of accurately calculating the necessary hours.

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