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printreg, August, 2001
Lead Reporting Requirements

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From: Debra Jacobson (djacobson@istc.illinois.edu)
Date: Fri, 03 Aug 2001 15:37:18

At a recent conference that I attended the topic of the revised lead reporting requirements came up in conversation. Just in case you are unfamiliar with the changes I have copied a summary of the changes in the TRI lead reporting rules which may affect some of you and a link to the section on EPA's web site and PNEAC's web site for more information. 

 Source: Environmental Resource Center's e-mail newsletter Environmental Tip of the Week 


If manufacture, process, or otherwise use as little as 100 pounds of lead per year, your site is now subject to the SARA Title III Section 313 Form R requirements. The Bush Administration has announced that it will proceed with a Clinton era rule that will vastly expand the number of facilities to Form R requirements. EPA says that this action will ensure that information on hundreds of thousands of pounds of lead emissions never previously reported will become publicly available. 

The new rule requires more companies to report on the lead they use and release into the air, water or land. Previously the rule required facilities report lead and lead compound emissions if they manufactured or processed more than 25,000 pounds annually or used more than 10,000 pounds annually. Under the new rule, the reporting threshold will be lowered to 100 pounds annually for each facility.

 Lead is highly toxic, persists indefinitely in the environment and bio-accumulates in humans and aquatic organisms. Even small amounts of lead that enter the environment can result in elevated concentrations that can result in adverse effects. The substance also causes health problems in adults, who can suffer pregnancy complications, high blood pressure, nervous disorders and memory and concentration problems.

 This action is a final rule under EPA's Toxics Release Inventory (TRI). The new requirements to report lead and lead compound emissions will begin in 2001. The reports on those emissions will be submitted in 2002. Recognizing industry concerns regarding the burden of this new TRI reporting and the uncertainty as to when reporting would begin, EPA plans to assist companies in their compliance efforts between now and July 2002 when the first reports are due. 

Toxic chemical emissions data reports are required under the Emergency Planning and Community Right-to-Know Act of 1986. EPA issues an annual report on the collected toxics data as part of the Agency's continuing effort to provide access to toxic chemical release information. Since EPA began collecting the information, toxic releases have been going down substantially and are expected to do so again this year. 

The final Toxics Release Inventory (TRI) rule on lead, issued Jan. 17, 2001, has been under review by the Administration as part of its broad-based review of new regulations put forth in the final days of the previous Administration. A broad description of the TRI program including chemicals and relevant industry sectors, guidance in reporting and other information is available at http://www.epa.gov/tri. or

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