Please clarify the Agency's half pound policy for the article exemption.
The Agency has adopted a "round to the nearest pound policy." If the amount of a listed toxic chemical in releases from processing or otherwise using all like items is equal to or less than a half pound, this amount can be rounded to zero. Thus, the exemption would be maintained. The half pound limit does not apply to each individual article, but applies to the sum of all amounts released during processing or otherwise use of all like items over the entire reporting year. If the listed toxic chemical that is released exceeds a half pound and is completely recycled/reused, on-site or off-site, then the item may still maintain its status as an article. Additional guidance on the articles exemption can be found within Directive #1 of the Revised 1998 EPCRA Section 313 Questions and Answers Document and the Toxic Release Inventory Reporting Forms and Instructions.