The US Environmental Protection Agency has revised the
annual reporting threshold for lead and lead compounds under the existing Toxics
Release Inventory (TRI) reporting program. The new rule takes effect with the TRI report due on
June 30, 2002 for the 2001 reporting year.
Previously, the thresholds were 25,000 pounds manufactured or processed,
or 10,000 pounds otherwise used. These
thresholds applied to lead as well as most other chemicals regulated by the TRI
program. The new rule lowers the
threshold for lead only to 100 pounds. The
USEPA is taking this action because lead is defined as a persistent
bioaccumulative toxic (PBT) chemical. PBT
chemicals such as lead are a concern not only because they are toxic, but also
because they remain in the environment for long periods of time, are not readily
destroyed, and accumulate in body tissue. Such
PBT chemicals are known to be especially toxic to children.
Facilities
that do meet the revised criteria will have to submit a Form R for lead just as
for other reportable chemicals. The
data required on the Form R identifies all releases of lead from the facility,
including not just fugitive releases to air or water, but also onsite or offsite
recycling, processing, and disposal.
It
is anticipated that this new requirement will greatly increase the number of
facilities reporting for lead. It
is also anticipated that a high percentage of these facilities will be
first-time reporters under the TRI program.
The new rule means that reporting facilities will
need to calculate their usage of lead or lead compounds carefully to see if they
meet the 100-pound criteria. Manufacturing
facilities that utilize any lead compounds may want to analyze the situation at
this time in order to ensure that accurate tracking or data collection systems
are in place to provide the data required to file the TRI report for 2001 in
June 2002.
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