NCMSCompliance Assistance Centers

Funded by EPA
through a Cooperative Agreement


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.


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

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

Leaded Crystal Vases

Q. We market leaded crysal vases that are made off site. We may take about 100 of these vases a month and drill a hole at the base to make a lamp. The leaded drilled plugs are shipped off site as a D008. Is this reportable activity in reguards to Form R reporting? We already trip the 100 lb limit from our casting usage.

A. Yes, this activity would count both towards threshold determination and release reporting. However, for the releases you only need to count the per cent lead in the crystal .

| Compliance Assistance | Regulations | Directories | Resources | Hot Topics | News | Ask the Experts | Library | Online Training | About NMFRC | Search | Home |