Paint containing listed toxic chemicals is applied to a product and becomes part of an article. Does the processing threshold apply? What about the volatile toxic chemicals from the painting operation - are they otherwise used?
Yes. This is a case in which different listed toxic chemicals in the same mixture may have different uses and therefore, different thresholds. The listed toxic chemicals that are incorporated as part of the coating are processed, whereas the volatile solvents in the paint are otherwise used because their function is such that they do not become incorporated into the article. Additional information on determining processing thresholds is available in the Toxic Release Inventory Reporting Forms and Instructions and the Revised 1998 EPCRA Section 313 Questions and Answers Document.