New Lower Threshold TRI Reporting Requirements for Lead and Lead Compounds

More information from EPA on the lead and lead compounds rule including a link to EPA's final TRI guidance document for lead and lead compounds.

Persistent bioaccumulative toxins are chemicals that are stable for long periods of time, and build up in the environment, particularly in food chains. Small releases of such chemicals may accumulate in the environment. Lead and lead compounds are of concern not only because they are persistent bioaccumulative toxic chemicals but also because they are especially toxic to children. Children absorb lead more readily than adults. Once exposed they can suffer from damage to the brain and central nervous system, slow growth, hyperactivity, and behavior and learning problems. Adults can suffer difficulties during pregnancy, high blood pressure, nervous disorders, and memory and concentration problems. Under prior reporting requirements facilities had to report lead and lead compounds only if they manufactured 25,000 pounds or more annually OR processed 25,000 pounds or more annually OR otherwise used 10,000 pounds or more annually. The Environmental Protection Agency (EPA) finalized a rule effective April 17, 2001 to lower the reporting threshold to 100 pounds for lead and lead compounds (except when contained in steel, brass and bronze alloys). This rule applies to Toxics Release Inventory (TRI) reports for reporting year 2001 which are due by July 1, 2002.

The rule also modifies certain reporting exemptions and requirements for lead and lead compounds. For EPCRA (Emergency Planning and Community Right-to-Know Act) section 313 lead and lead compounds (except for lead contained in stainless steel, brass, and bronze alloys), the de minimis exemption is no longer allowed, no Form A and no range reporting for on-site releases and off-site transfers is allowed. The final rule also requires that releases and waste management quantities greater than or equal to 0.1 pound be reported for lead and lead compouds.