What is the difference between process and otherwise use for the purposes of EPCRA Section 313 threshold determinations?
Process implies incorporation; the function or intent of the toxic chemical is dependent upon becoming a part of a product. Otherwise use implies non-incorporation; the function of the toxic chemical is not dependent upon becoming a part of a product. Beginning with reporting year 1998, otherwise use will include the on-site disposal, treatment for destruction and stabilization of toxic chemicals in wastes received from off site for the purposes of further waste management. Otherwise use will also include the on-site disposal, treatment for destruction, or stabilization of toxic chemicals produced from the management of wastes received from off site. Additional guidance regarding process and otherwise use threshold determinations can be found in Directive #7 of the Addendum to 1998 Question and Answer Document and the Toxic Release Inventory Reporting Forms and Instructions.