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

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

Carbon Steel and Lead

Q. Does the release of lead (0.5%)contained in carbon steel from cutting and welding operatioins at our facility fall under the 100 or 25,000 pound reporting criteria?

A. There is no longer a deminimus exemption for lead contained in carbon steel. The exemption to the 100 lb. threshold only applies to lead that incorporated into brass, bronze alloy and stainless steel.

Remember that in order to determine if you need to report, you first must do threshold determination calculations. For your facility, you would need to weld or cut more than 20,000 lbs. of carbon steel at 0.5% in the calendar year 2001 to exceed the 100 lb. threshold. Once this threshold is triggered, you need to report for lead and/or lead compounds.

The lead releases from the cutting and welding operations would need to be estimated or measured and reported under the "release" column on the Form R for Lead.

Thank you for your question. I hope this helps.