Ask the Expert Question-and-Answer Archive (TRI)
by Joelie Zak, Scientific Control Labs, Inc.
Lead found in lead-acid batteries
Q. If the only lead, or lead compound, at a facility is the lead found in hi-low (or other equipment) batteries, my guess is this does not constitute "otherwised used" and would not require a facility to submit a Form R report. Is this correct? (assuming there is more than 100 pounds of lead in these batteries for this example.)
Batteries containing lead are eligible for an "article exemption", provided that you meet some criteria: 1) you must use the battery without changing its design and 2) your use of the batteries does not result in the release of more than a 1/2 pound of lead per reporting year. If you meet these criteria, the lead in the batteries does not get counted towards threshold determination.