Ask the Expert Question-and-Answer Archive (TRI)
by Joelie Zak, Scientific Control Labs, Inc.
Clarification of the 100 lb. Threshold and the 0.5 lb. Release for Lead
Q. I am confused. It is my understanding that a Form R is required if we exceed the 100 lb threshold for lead (manufacturing, processing, or otherwise use)yet the TRI lead reporting threshold worksheet posted on this website states that we must report if we release greater than 0.5 pounds to the environment. If we release greater than 0.5 pounds but are under the 100 lb threshold, wouldnt we be exempt from filing?
A. It sounds as if you are exempt. You must only report if you exceeded the 100 pound threshold for manufacturing, processing or otherwise using the lead or lead compound. The 0.5 lbs. is with respect to actual release reporting once the threshold determination has been made.