Presented in Partnership with:

Ask the Expert Question-and-Answer Archive (TRI)

by Joelie Zak, Scientific Control Labs, Inc.
June, 2002

Carbon Steel and Lead

Q. (In regard to your response concerning TRI reporting of lead content in carbon steel - March 2002): The Articles Exemption language contained in the 2001 TRI Insruction booklet states, "EPCRA Section 313 chemicals contained in articles that are processed a covered facility are exempt from threshold determinations and other waste management calculations".

A. This may be true in some facilities. It depends on the operations at the fabrication plant. Part of the article exemption is demonstrating that there were less than 0.5 lbs. of releases. So, if there was any grinding, polishing, welding, plating onto, acid pickling, etc. These may cause the article exemption to not be met.



| Home | Subscribe | Regulations | Compliance Assistance | News | Resources | Resource Locators | Directories | Online Training | About | Search | |

The information contained in this site is provided for your review and convenience. It is not intended to provide legal advice with respect to any federal, state, or local regulation.
You should consult with legal counsel and appropriate authorities before interpreting any regulations or undertaking any specific course of action.

Please note that many of the regulatory discussions on STERC refer to federal regulations. In many cases, states or local governments have promulgated relevant rules and standards
that are different and/or more stringent than the federal regulations. Therefore, to assure full compliance, you should investigate and comply with all applicable federal, state and local regulations.