Toxic release inventory, lead and lead components

The Toxic Chemical Release Inventory (TRI) rule lowers reporting thresholds for lead and lead compounds from 25,000 or 10,000 lbs. down to 100 lbs. if a facility manufactures, processes, or uses more than 100 lbs. of lead or lead compounds per year, it would now be subject to annual TRI reporting

Despite extensive information on these chemicals, the reporting thresholds are not based on any quantitative analysis of the magnitude of releases that will be accounted for under different thresholds, nor the risks posed by releases. EPA recognized this, but only after it issued the final rule did it refer the rule to its Science Advisory Board for review.

Under the rule, facilities must identify the number of pounds of lead "released" into the environment. The term "released" refers not only to chemicals that are transferred off-site as waste or released (routinely or accidentally) on-site into the air, land or water, but also to chemicals that are recycled or treated. A reviewer of the TRI data cannot easily ascertain whether a "release" reflects responsible management and recycling, emissions allowed by regulation, or accidental spills; so, data on pounds of chemicals released, as provided by TRI, fail to provide communities with relevant data on risks that may be present.