A covered facility has purchased in excess of 100,000 pounds of aluminum material in block form to make a mold which stays on site. When making the mold, fumes and dust are byproducts. Do we report these as the toxic chemical?
Aluminum appears on the list of toxic chemicals as "aluminum (fume or dust)." You must determine if you manufacture, process, or otherwise use aluminum fume or dust. In this case you do not process or otherwise use the fume or dust, but you do manufacture aluminum fume or dust coincidentally as a byproduct of making molds. Therefore, you must report for aluminum (fume or dust) if you exceed the 25,000 pound manufacture threshold for the reporting year. Additional information is available in the Toxic Release Inventory Reporting Forms and Instructions.