SECOND MEASUREMENT SM-016
Toxic-release reports are due 1 July, with a statutory fine of up to $71,545 for each day late. A thousand plants filed more than a year late for 2019, and 61 of them appear in any EPCRA 313 case opened since
Factories, refineries, metal and coal mines and power plants in the covered sectors, with ten or more employees and above the chemical thresholds, have to tell the Environmental Protection Agency once a year how much of each listed toxic chemical it released, and the regulation names the day: on or before 1 July. The statute behind it prices a missed deadline at up to $25,000 per chemical per day, which inflation adjustment has carried to $71,545. EPA keeps the postmark of every form in a public database, so the deadline can be checked by anyone. We checked all 473,709 forms filed for the reporting years 2019 to 2024. Sixteen and a half thousand were postmarked after 1 July, and 5,964 of those more than a year after. We then took every facility that was late and looked for it in EPA’s own enforcement case file. For 2019, the oldest year, where five years have passed since the deadline itself: 1,788 facilities late, 1,003 of them by more than a year, and 61 of those thousand appear in any EPCRA 313 case opened since. EPA’s formal actions under this section of the law ran 52, 51 and 41 a year in fiscal 2022 to 2024, then 16 in fiscal 2025 and 14 so far in 2026. The year-late list for 2023 has two Henkel plants at 480 days, a Beam Suntory rum distillery at 478, a Berkshire Hathaway foundry at 466 and a Rust-Oleum plant at 465, and 22 federal facilities, which the statute exempts from penalties altogether.
- 40 CFR 372.30(d): each report “must be submitted on or before July 1 of the next year.” EPCRA section 325(c): a civil penalty of up to $25,000 per violation, each day a separate violation, adjusted to $71,545 today. “Any person (other than a governmental entity).” EPA’s own penalty policy assesses a late form as a single violation per chemical per year, so the per-day figure is the statute’s ceiling, not EPA’s practice.
- EPA’s Envirofacts database carries the original postmark of every form. Reporting years 2019 to 2024: 473,709 forms, 16,522 postmarked after 1 July (3.5%), 5,964 of them more than a year late. Between 354 and 1,788 facilities late each year.
- Reporting year 2019, now past the five-year limit on penalty actions: 1,003 facilities more than a year late; 61 appear in any EPCRA 313 case opened since. 104 of all 1,788 late facilities do. EPA’s cases cover every kind of 313 violation, so 6% is a ceiling on how often late filing alone drew an action.
- EPA’s formal EPCRA 313 actions by fiscal year: 52, 51, 41, then 16 in 2025 and 14 in 2026 to 26 September. Penalties assessed: $3.96M, $3.37M, $2.39M, $1.00M, $2.07M.
- 2023’s year-late filers include Henkel (two plants, 480 days), Beam Suntory’s Cruzan Rum (478), Berkshire Hathaway’s Cannon-Muskegon (466), RPM’s Rust-Oleum (465). Texas Molecular’s Deer Park plant, 54 forms one day late, carries a fiscal 2025 case, about industry codes on earlier forms.
- 22 federal facilities filed late for 2023, Picatinny Arsenal 42 forms among them. The statute’s penalty clause excludes governmental entities.
- Floors, not totals: the database runs to 31 October 2025, late forms keep arriving for years (2019’s median late form came 394 days after the deadline), and on 3 October 2026 EPA had published no form at all for reporting year 2025, three months after that year’s deadline.
Disclosure: Markovian Protocol holds no financial position in any organisation named here, was paid by no one for this work, and showed it to no one before publication except the organisations measured. How we work.
The Toxics Release Inventory (TRI) is the public register of toxic chemical releases created by section 313 of the Emergency Planning and Community Right-to-Know Act of 1986. A covered facility files one form per listed chemical (Form R, or the short Form A) through EPA’s TRI-MEweb system; the regulation sets the deadline at 1 July of the following year. EPA publishes every form through Envirofacts, and the TRI_REPORTING_FORM table carries, for each form, the date EPA records as the original postmark (its data dictionary: “The original postmark date for a submission for this chemical from this facility and this reporting year”). For electronic filings that is the certification timestamp; the two are identical on 75,939 of the 77,295 forms for 2024 and fall on the same day on 76,086. We pulled every form for reporting years 2019 to 2024 on 3 October 2026, kept one row per form, and called a form late if its original postmark fell after 1 July of the year after the reporting year. A facility is late if any of its forms is. For enforcement we took ECHO’s bulk export of EPA’s civil case file (26 September 2026), kept the 5,985 cases whose law section is EPCRA 313, and joined them to facilities by EPA registry ID, which every late facility has. A late facility “has a case” if any 313 case naming it was opened in a fiscal year after the one containing its deadline. EPA’s enforcement policy for the section, issued in 1992, amended through 2001 and updated in 2017, keys lateness to the date the form is certified in TRI-MEweb; on the 2024 forms that date is the same calendar day as the postmark field on 76,086 of 77,295. A report one year or more past 1 July is the policy’s most serious category.
What they said, what we found
| The rule | We found |
|---|---|
| EPA’s Inspector General, September 2020: between 1 July and the mid-October data freeze, “approximately 800–2,000 facilities submitted about 2,500–9,000 TRI reports” a year for 2013 to 2017, about 8% of reports. The project began in 2018 as EPA Enforcement of Toxic Release Inventory (TRI) Late Reporters and was renamed on 25 February 2019 to measure the late reports’ effect on the annual analysis instead.8 | In the Inspector General’s window, 2 July to 15 October, we count 868 to 1,384 forms a year from 341 to 511 facilities for 2019 to 2024; the Inspector General’s larger figures include revisions. The half the Inspector General set aside is the one here: of 1,003 facilities more than a year late for 2019, 61 appear in any EPCRA 313 case opened since, and formal actions fell from 52 a year to 16. |
| 40 CFR 372.30(d): “Each report under this section for activities involving a toxic chemical that occurred during a calendar year at a covered facility must be submitted on or before July 1 of the next year.”1 | 16,522 of 473,709 forms for 2019 to 2024 postmarked after 1 July; 5,964 more than a year after. Per year, 1.1% to 4.8% of forms and 354 to 1,788 facilities. |
| EPA, Reporting Forms and Instructions: “Facilities are legally obligated to file an accurate and complete Form R or Form A for each chemical by July 1 each year. EPA may take enforcement action and assess civil administrative penalties …”2 | For 2019, 61 of 1,003 facilities more than a year late appear in any EPCRA 313 case opened since. Formal 313 actions fell from 52 in fiscal 2022 to 16 in fiscal 2025. |
| 42 U.S.C. 11045(c)(1): “Any person (other than a governmental entity) who violates any requirement of section 11022 or 11023 of this title shall be liable to the United States for a civil penalty in an amount not to exceed $25,000 for each such violation.” 40 CFR 19.4 adjusts that to $71,545.3 | 22 federal facilities late for 2023, 21 for 2019. The exemption is in the statute; the postmarks are in the same database as everyone else’s. |
Six years of postmarks
Older years look worse because late forms keep arriving. A form for 2019 could still turn up in 2025 and did; the median late 2019 form was postmarked 394 days after its deadline. The 2024 row stops at the 31 October 2025 snapshot, 122 days after that year’s deadline, so it will grow.
| Reporting year | Deadline | Forms | Postmarked late | Share | Facilities late | Facilities more than a year late | Median days late | Longest |
|---|---|---|---|---|---|---|---|---|
| 2019 | 1 Jul 2020 | 80,831 | 3,793 | 4.7% | 1,788 | 1,003 | 394 | 1,927 |
| 2020 | 1 Jul 2021 | 78,655 | 3,785 | 4.8% | 1,670 | 880 | 364 | 1,581 |
| 2021 | 1 Jul 2022 | 78,241 | 3,301 | 4.2% | 1,486 | 657 | 269 | 1,216 |
| 2022 | 1 Jul 2023 | 80,040 | 2,748 | 3.4% | 1,180 | 387 | 100 | 852 |
| 2023 | 1 Jul 2024 | 78,647 | 2,010 | 2.6% | 885 | 131 | 31 | 485 |
| 2024 | 1 Jul 2025 | 77,295 | 885 | 1.1% | 354 | 0 | 9 | 122 |
Envirofacts TRI_REPORTING_FORM, pulled 3 October 2026, one row per form (document control number), late by orig_postmark against 1 July of the year after the reporting year. Snapshot runs to 31 October 2025.
Who was more than a year late for 2023
131 facilities filed at least one 2023 form more than a year after 1 July 2024, that is, on 2 July 2025 or later. 108 of them name a parent company in the TRI facility record. The fifteen furthest past the line:
| Facility | Parent company | State | Days late | Late forms | Chemicals (first three) |
|---|---|---|---|---|---|
| Bayou Holdco Inc | Altamont Capital Partners | LA | 485 | 5 | diisocyanates, lead compounds, manganese compounds |
| Henkel US Operations Corp | Henkel of America Inc | NY | 480 | 2 | a musk fragrance compound, glycol ethers |
| Henkel US Operations Corp | Henkel of America Inc | KY | 480 | 2 | a musk fragrance compound, lead compounds |
| Sinton Dairy Foods Co LLC | LALA US Inc | CO | 479 | 2 | nitrate compounds, nitric acid |
| Cruzan Rum Ltd. | Beam Suntory | VI | 478 | 3 | cumene, naphthalene, propylene |
| Cannon-Muskegon | Berkshire Hathaway Inc | MI | 466 | 4 | chromium compounds, cobalt compounds, lead |
| NHS U.S. LLC | Nestlé Health Science US | FL | 466 | 1 | zinc compounds |
| MSSC-US | MSSC US | KY | 465 | 7 | arsenic, chromium, copper |
| Rust-Oleum Corp in MD | RPM International Inc | MD | 465 | 6 | barium compounds, cobalt compounds, copper compounds |
| Hydro Extrusion USA LLC | Hydro Extrusion USA LLC | AZ | 462 | 1 | lead |
| Vanguard Research Industries Inc | Vanguard Holdings | NJ | 457 | 2 | copper, nickel compounds |
| RedGuard LLC | Lange Gen Y LLC | LA | 457 | 2 | lead compounds, zinc compounds |
| Hydro Extrusion USA LLC | Hydro Extrusion USA LLC | OH | 457 | 1 | lead |
| Hycast LLC | none listed | IA | 456 | 5 | chromium, copper, lead compounds |
| Gulf Coast Marine Fabricators Inc | none listed | LA | 456 | 2 | lead compounds, zinc compounds |
None of the fifteen appears in an EPCRA 313 case opened in fiscal 2025 or 2026; Cruzan Rum, Hycast and Rust-Oleum carry older ones. Parent names are the register’s standardized names, lightly normalised. The full list of 885 late facilities for 2023, with parents, registry IDs and any case, is in the exhibits. By parent, the most year-late plants belong to Charter Next Generation (9), RPM International (4), Agri Beef (4), Henkel (3), Quikrete (3), Opta (3), Republic Services (3) and Texas Instruments (3).
Texas Molecular’s Deer Park, Texas plant filed 54 of its 2023 forms one day late and is named in EPA case 06-2025-0501, opened in fiscal 2025. ECHO’s summary of that case says it concerned an incorrect primary industry code on the plant’s forms for 2019 to 2021, not the late filings. Its 54 forms are counted as late here all the same.
Federal facilities file too, and 22 of them were late for 2023: Picatinny Arsenal with 42 forms, Hill Air Force Base’s test range 387 days late, Portsmouth Naval Shipyard 324 days, the Marion federal prison 338 days. Section 325(c) of the Act applies to “any person (other than a governmental entity),” so none of them can be fined.
What EPA did about it
EPA’s civil enforcement case file is public through ECHO. We kept every case that cites EPCRA 313 among its law sections and counted them by the fiscal year opened, with the federal penalties assessed:
| Fiscal year | Formal EPCRA 313 actions | Federal penalties assessed |
|---|---|---|
| 2019 | 46 | $2,283,301 |
| 2020 | 23 | $1,857,770 |
| 2021 | 35 | $3,693,444 |
| 2022 | 52 | $3,958,173 |
| 2023 | 51 | $3,366,926 |
| 2024 | 41 | $2,389,157 |
| 2025 | 16 | $1,003,703 |
| 2026 (to 26 Sep) | 14 | $2,072,843 |
ECHO case download of 26 September 2026: 5,985 EPCRA 313 cases all-time; of the 174 opened since fiscal 2022, all but one are administrative. The 2026 penalty total is one $995,000 settlement with Brenntag Great Lakes plus twelve smaller penalties and one case with none. Informal actions under EPCRA as a whole, 672 of 729 of them notices of noncompliance, ran six to thirteen a year in fiscal 2021 to 2026.
Then the join. For each reporting year, the late facilities, the ones more than a year late, and how many of each turn up in any 313 case opened in a later fiscal year:
| Reporting year | Facilities late | With a 313 case since | More than a year late | With a 313 case since |
|---|---|---|---|---|
| 2019 | 1,788 | 104 (5.8%) | 1,003 | 61 (6.1%) |
| 2020 | 1,670 | 77 | 880 | 42 |
| 2021 | 1,486 | 56 | 657 | 24 |
| 2022 | 1,180 | 36 | 387 | 13 |
| 2023 | 885 | 13 | 131 | 0 |
| 2024 | 354 | 2 | 0 | – |
“Since” means a case opened in any fiscal year after the one containing the deadline. A case counts whatever it was about, so these are ceilings on enforcement of lateness itself. The limitation period for a civil penalty is five years from accrual (28 U.S.C. 2462), so for the 2019 deadline the five years have passed; a day of continuing lateness accrues its own claim, so later filings can still be reached.
The thresholds that matter
A late form is one row here, whether it is a day late or two years, and whether it reports fifty pounds or a million. Five lines in EPA’s own practice say which of them count. Mid-October: EPA freezes the year’s dataset then and, the Inspector General found, chases prior-year filers who haven’t filed by that date, so 1 July is the legal line and mid-October the operational one. One year: EPA’s penalty policy puts a report a year or more late in its most serious category. Two prior cases: the policy reserves the per-day statutory penalty for a company that has already resolved two earlier filing complaints. Pounds: the Inspector General weighted late forms by the releases on them. Five years: the limit for a civil penalty claim.
| Reporting year | Late forms, 2 Jul to 15 Oct | After 15 Oct | More than a year | Pounds on late forms | Share of all pounds | Pounds on year-late forms | Late facilities with 2+ prior 313 cases | of which more than a year late |
|---|---|---|---|---|---|---|---|---|
| 2019 | 1,116 | 2,677 | 1,947 | 40.5 M | 1.18% | 19.3 M | 74 | 37 |
| 2020 | 1,302 | 2,483 | 1,791 | 40.5 M | 1.30% | 18.7 M | 70 | 34 |
| 2021 | 1,366 | 1,935 | 1,203 | 27.4 M | 0.84% | 7.5 M | 62 | 25 |
| 2022 | 1,384 | 1,364 | 712 | 81.8 M | 2.43% | 64.2 M | 53 | 21 |
| 2023 | 1,266 | 744 | 311 | 32.1 M | 0.94% | 4.0 M | 51 | 8 |
| 2024 | 868 | 17 | 0 | 19.0 M | 0.58% | 0 | 19 | 0 |
Pounds are the “total releases” figure on each form in EPA’s Basic Data Files, dioxin grams converted; each year reports 3.1 to 3.4 billion pounds in all. “Prior cases” are EPCRA 313 cases on the facility’s registry ID opened in or before the deadline’s fiscal year, which is wider than the policy’s “resolved by complaint”. Scripts pounds.py; results pounds_results.json, prior_cases_threshold.json.
By weight the late filers are small: forms postmarked after 1 July carry between 0.6% and 2.4% of the pounds reported each year, and the year-late ones a fifth of a percent in most years, which is the same order the Inspector General found for 2013 to 2017. The exception is 2022, when a single Dark Horse Treating Facility form reporting 57.7 million pounds arrived more than a year late. The repeat-offender line is where the names change: the year-late filers with two or more cases already on file include Lanxess’s Central plant (32 cases), Cleveland-Cliffs Steel (27), Phillips 66 Ponca City (30), INEOS Battleground (24) and Shell Norco (8), and for 2023 Cruzan Rum (6) and Texas Instruments (4). Those are the facilities EPA’s own policy says the per-day penalty is for, and none of them appears in a 313 case opened after its late year.
How this ends
It ends one of two ways, and the recheck measures both. The forms for 2025 were due on 1 July 2026; when EPA loads them, the recheck counts the late ones and the clock starts on each. The enforcement side ends when a year-late filer appears in a 313 case or the five years run out; the recheck re-joins the case file to the late lists after each ECHO refresh and moves the 61 up or leaves it. There is a third clock on EPA itself: the 2023 preliminary data came in July 2024 and the 2024 set reached TRI Explorer on 24 September 2025, and on 4 October 2026 Envirofacts held no 2025 form and the bulk files were dated 5 November 2025.
The evidence
Every quote below was copied from the source and checked against a saved copy, fetched 3 October 2026. The regulation, the statute, the penalty table, the enforcement policy, the data dictionary entry and the scripts are published next to this page (SHA256SUMS).
Exhibit 1 · The deadline
“Each report under this section for activities involving a toxic chemical that occurred during a calendar year at a covered facility must be submitted on or before July 1 of the next year.”
40 CFR 372.30(d), eCFR as of 1 October 2026 · saved copy ecfr_372_30.xml
Exhibit 2 · The penalty, and who is exempt
“Any person (other than a governmental entity) who violates any requirement of section 11022 or 11023 of this title shall be liable to the United States for a civil penalty in an amount not to exceed $25,000 for each such violation.”
40 CFR 19.4, civil monetary penalty inflation adjustments: 42 U.S.C. 11045(c)(1) EPCRA statutory $25,000 current $71,545
42 U.S.C. 11045(c)(1) via law.cornell.edu · 40 CFR 19.4 via eCFR · saved copies 42usc11045.html, ecfr_19_4.xml
Exhibit 3 · EPA’s own words on the deadline
“Facilities are legally obligated to file an accurate and complete Form R or Form A for each chemical by July 1 each year. EPA may take enforcement action and assess civil administrative penalties …”
EPA, Toxic Chemical Release Inventory Reporting Forms and Instructions, reporting year 2025, EPA-740-B-25-003, cover dated January 2026, revised 24 March 2026, p. 4 (PDF p. 12) · saved copy ry_2025_rfi_final_3.24.26.pdf
Exhibit 4 · The certification date is the date that counts
“The date used to determine the circumstance level for failure to report in a timely manner is the date the non-trade secret Form R or Form A is certified in TRI-MEweb. All violations are ‘one day’ violations unless otherwise noted.” (2017 replacement page) … “Category I: Form R reports that are submitted one year or more after the July 1 due date.”
Envirofacts, reporting year 2024: orig_postmark equals certif_date_signed on 75,939 of 77,295 forms; same calendar day on 76,086
EPA, Enforcement Response Policy for Section 313 of EPCRA and Section 6607 of the Pollution Prevention Act, 1992, amended 1996, 1997 and 2001, updated 24 February 2017 · saved copy epcra313_erp_amendments2017.pdf (scanned; OCR text alongside) · agreement check postmark_vs_certification_2024.json
Exhibit 5 · The data
Envirofacts TRI_REPORTING_FORM, column ORIG_POSTMARK: "The original postmark date for a submission for this chemical from this facility and this reporting year." Reporting year 2024: 77,295 forms; orig_postmark equals certif_date_signed on 75,933 Reporting year 2025 on 2026-10-04: 0 rows (saved response); TRI Basic Data Files page: "reporting forms processed as of: November 5, 2025" ECHO case_downloads.zip, 2026-09-26: CASE_LAW_SECTIONS EPCRA 313 = 5,985 cases; CASE_FACILITIES joined on REGISTRY_ID
data dictionary ef_column_orig_postmark.html · results tri_results.json, eventual_enforcement.json, late_facilities_2023.json, epcra313_cases.json · bulk files page tri_basic_data_files_page.html · 2025 count envirofacts_tri_reporting_form_2025_count_2026-10-04.json
Exhibit 6 · What enforcement looks like when it happens
“Loparex LLC – A CAFO was filed on August 21, 2024 … The CAFO resolves alleged violations of Sections 313 of EPCRA for failing to timely file its Form R. The CAFO requires the company to pay a civil penalty of $33,710.”
EPA Region 4 news release, 30 September 2024 · saved copy epa_r4_2024_release.html
Our questions
Prepared for the TRI Program (tri.help@epa.gov, the address on the reporting instructions) and EPA’s Office of Enforcement and Compliance Assurance. Sent 4 October 2026 to the TRI Program address. Answers will be printed here as written.
- Is the Envirofacts
ORIG_POSTMARKthe date EPA uses to decide whether a form was filed by 1 July? If a different date is used, which? - Of the 131 facilities whose 2023 forms arrived more than a year late, how many received any enforcement response, formal or informal, as of today?
- Formal EPCRA 313 actions fell from 41 in fiscal 2024 to 16 in fiscal 2025. Was the section’s enforcement policy or staffing changed, and if so, is the change public?
- When will the reporting year 2025 forms, due 1 July 2026, appear in Envirofacts and the basic data files?
Their reply, scored
Disclosure timeline
| 3 Oct | Measured; independent review pass, 26 corrections applied before publication. |
| 4 Oct | Published. The four questions sent to EPA’s TRI Program; posted on X. |
Waiting since 4 Oct.
What we can’t be sure of
- A late form is often a facility’s first filing for a chemical it had not realised it had to report. EPA’s policy treats that as a failure to report on time all the same (“Every Form R report submitted after July 1 for a chemical not previously submitted is not a revision, but a failure to report in a timely manner”), and so do we, but it means the year-late list mixes forgotten filings with discovered ones.
- EPA may have granted a facility relief we cannot see, or chosen not to act for reasons that live only in regional files. The case file records actions, not decisions not to act.
- Cases are joined on EPA registry ID. A facility whose TRI record and enforcement record carry different registry IDs would show as having no case. Every late facility has an ID. 46 of the 5,985 cases have no facility row with a registry ID, all opened before fiscal 2021, so none affects the join.
- A 313 case naming a late facility may be about data quality or an unreported chemical rather than lateness. The 61 and the 104 are therefore ceilings on enforcement of the deadline itself; the floor could be lower.
- One snapshot, 31 October 2025 for the forms and 26 September 2026 for the cases. The recheck re-pulls both after each EPA refresh.
Run it yourself
Python 3 standard library and curl. About 640 MB of downloads (six years of forms from Envirofacts, the facility table, and ECHO’s 81 MB case archive); the pulls take about 25 minutes, the analysis under two.
for y in 2019 2020 2021 2022 2023 2024; do ./fetch_tri.sh $y $(curl -s "https://data.epa.gov/efservice/TRI_REPORTING_FORM/REPORTING_YEAR/$y/COUNT/JSON" | python3 -c 'import json,sys;print(json.load(sys.stdin)[0]["TOTALQUERYRESULTS"])'); done
./fetch_facilities.sh # TRI_FACILITY, 64,990 rows
for y in 2019 2020 2021 2022 2023 2024; do curl -s "https://data.epa.gov/efservice/downloads/tri/mv_tri_basic_download/${y}_US/csv" -o basic/${y}_US.csv; done
curl -sO https://echo.epa.gov/files/echodownloads/case_downloads.zip && unzip -q case_downloads.zip -d echo
python3 analyze_tri.py 2019 2020 2021 2022 2023 2024 # late forms and facilities per year
python3 cases.py # EPCRA 313 cases, penalties by fiscal year
python3 eventual.py 2019 2020 2021 2022 2023 2024 # join late facilities to the case file
python3 pounds.py 2019 2020 2021 2022 2023 2024 # weight late forms by the releases they report
What you can do with this
- If you run a state or tribal TRI program, the facilities in your state that filed more than a year late with no federal action are in late_facilities_2023.json, with registry IDs; the state receives the same forms and has its own authority under section 326.
- If you file TRI forms, the postmark is public and the one-year line is the one EPA’s own policy treats as most serious; a form filed on 2 July is visible to anyone with this script.
References
- 40 CFR 372.30(d), Reporting requirements and schedule for reporting. ecfr.gov.
- U.S. EPA. Toxic Chemical Release Inventory Reporting Forms and Instructions, Reporting Year 2025, EPA-740-B-25-003, January 2026, revised 24 March 2026, p. 4. epa.gov.
- 42 U.S.C. 11045(c), Civil and administrative penalties for reporting requirements. law.cornell.edu; 40 CFR 19.4, Statutory civil monetary penalties, as adjusted for inflation. ecfr.gov.
- U.S. EPA. Enforcement Response Policy for Section 313 of EPCRA and Section 6607 of the Pollution Prevention Act, 1992, amended 2017. epa.gov.
- U.S. EPA. Envirofacts, TRI_REPORTING_FORM and TRI_FACILITY tables. data.epa.gov/efservice.
- U.S. EPA. ECHO, Enforcement case data downloads. echo.epa.gov.
- 28 U.S.C. 2462, Time for commencing proceedings. law.cornell.edu.
- U.S. EPA Office of Inspector General. Data Used for Annual Toxics Release Inventory National Analysis Are 99 Percent Complete, but EPA Could Improve Certain Data Controls, Report 20-P-0337, 30 September 2020. epaoig.gov; revised project notification memo of 25 February 2019, No. OA&E-FY18-0002. Saved copies in the exhibits.
Cite as
@misc{markovian-sm016,
author = {{Markovian Protocol}},
title = {The 1 July deadline for Toxics Release Inventory forms, 2019 to 2024, and EPA's enforcement of it},
number = {SM-016},
doi = {10.5281/zenodo.23130553},
year = {2026},
month = oct,
url = {https://markovianprotocol.com/measurements/sm-016.html}
}