Frequent Questions

Rounding of PBT releases for article exemption applicability

EPCRA Section 313 chemicals contained in articles that are processed or otherwise used at a covered facility are exempt from threshold determinations and release and other waste management calculations.  One criterion that must be met for a chemical to be exempt as part of the article is that the item does not release a toxic chemical under normal conditions of processing or use.  If a facility processes articles containing lead, a persistent, bioaccumulative, and toxic (PBT) chemical, and the processing of all like items results in a total release of 0.4 pounds during the reporting year, can the facility round this release to 0?

There is no need to round the 0.4 pound release quantity to zero.  If the processing or otherwise use of all like items results in a total release of 0.5 pound or less of the chemical, the items retain their article status.  This means that for purposes of filling out a Form R release report, the facility has the option to: 1) not count the quantities of toxic chemical contained in the like articles towards threshold determinations; and 2) not count the 0.5 pound or less total release quantity (in this example the 0.4 pound quantity) of the toxic chemical that occurred from the processing or otherwise use of all like articles towards the quantities released or otherwise managed as waste.  This applies to PBT toxic chemical (e.g. lead) and all other chemicals included on the TRI list of toxic chemicals.  

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