Frequent Questions

Can the articles exemption apply to sheet metals?

Does the article exemption apply to flat rolled sheet metals, if they are used in operations which typically produce scrap but no release?

Assuming the scrap metal pieces are recognizable as the original piece, the article exemption does apply to these metals if the forming process caused 0.5 pounds or less of releases of a listed toxic chemical from all like items or the items retain the thickness of sheet metal in whole or in part. Once an operation is performed on a metal that causes a release which is not recycled and which exceeds 0.5 pounds for the reporting year (for example, from operations such as heating, grinding, or welding), the article exemption no longer applies and releases must be reported when listed chemicals in a sheet metal are processed in quantities greater than the processing threshold.  Additional guidance regarding the article exemption can be found in Directive #1 of the Revised 1998 EPCRA Section 313 Questions and Answers Document.

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