Ask the Expert Question-and-Answer Archive (TRI)
by Joelie Zak, Scientific Control Labs, Inc.
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 ...at 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.