If a person is simply storing and redistributing a toxic chemical without repackaging it, is this activity considered processing of the toxic chemical for Section 313 purposes?
No. The term process means the preparation of a listed toxic chemical, after its manufacture, for distribution in commerce. Because the toxic chemical is not repackaged but is merely redistributed, the facility is not processing the toxic chemical. Additional guidance on processing threshold determinations is available in the Toxic Release Inventory Reporting Forms and Instructions.