Lower Threshold TRI Reporting Requirements for Lead and Lead Compounds

EPA final TRI guidance document for lead and lead compounds

Persistent Bioaccumulative Toxins (PBTs) are chemicals that are stable for long periods of time, and build up in the environment, particularly in food chains. Small releases of such chemicals may accumulate in the environment. Lead and lead compounds are of concern not only because they are PBT chemicals but also because they are especially toxic to children. Children absorb lead more readily than adults. Once exposed they can suffer from damage to the brain and central nervous system, slow growth, hyperactivity, and behavior and learning problems. Adults can suffer difficulties during pregnancy, high blood pressure, nervous disorders, and memory and concentration problems.

Under current reporting requirements, facilities must report releases of lead and lead compounds if they manufacture, process or otherwise use 100 pounds or more of lead or any lead compounds annually (except when contained in steel, brass and bronze alloys).

Under the Emergency Planning and Community Right-to-Know Act, section 313, the de minimus exemption is no longer allowed for lead and lead compounds (except for lead contained in stainless steel, brass, and bronze alloys). No Form A and no range reporting for on-site releases and off-site transfers is allowed. Releases and waste management quantities greater than or equal to 0.1 pound must be reported for lead and lead compounds.