From: Jeff Adrian(firstname.lastname@example.org)
Date: Tue, 7 May 2002 08:21:21
As to the TRI, this is a tricky question to answer. If this printer has lead type that has been manufactured for him by an outside supplier, then this type would be classified under the "article exception" as long as the printer did not in any way change its nature by grinding it or melting it, for example. If on the other hand, this printer is actually creating the lead type (using a linotype machine at his facility) from lead bar stock, then he would have a reportable TRI item under the new lower threshold (100 pounds for lead) that would apply. This would require several filings: 302, 311, 313.
So it is critical to determine whether this printer is just using lead type provided by an outside supplier and thus would be exempted under the "article" provision of the PBT Rule, or if he is manufacturing type (by heating bar lead and thus presumed to cause a "release" in the form of air emissions (fumes). In the later case, the lead used would NOT be exempted as an "article" and would be reportable.
I hope this adds some clarity to your issue.
Incidentally, the lead in lead acid batteries (for forklifts and power dollies) is exempt under the "article provision", but one must remember to account for the electrolyte solution (sulfuric acid/water) contained in the batteries which is not exempt, assuming you have enough batteries to meet the threshold for reporting.