Are the thresholds for manufacture and process considered separately? That is, if a covered facility manufactures 24,000 pounds of toxic chemical A (a non-PBT chemical) and processes 24,000 pounds of toxic chemical A, does the facility need to report for toxic chemical A?
No. The facility does not have to report because it has not independently exceeded either threshold. Thresholds are considered separately for manufacture, process, and otherwise use of the same toxic chemical. Assuming that no individual threshold is met for chemical A (i.e., manufacturing, processing, or otherwise use), the facility does not trigger reporting for chemical A. Additional guidance on activity threshold determinations can be found in the Toxic Release Inventory Reporting Forms and Instructions and the Revised 1998 EPCRA Section 313 Questions and Answers Document.