Toxic Release Inventory Program - EPA

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A.1 Who Must Report

Section 313 of EPCRA requires that reports be filed by owners and operators of facilities that meet all of the following criteria.

”The facility has 10 or more full-time employee equivalents (i.e., a total of 20,000 hours or greater; see 40 CFR 372.3);

FPC Currently Exempted

and ”The facility is included in Standard Industrial Classification (SIC) Codes 10 (except 1011, 1081, and 1094), 12 (except 1241), 20–39, 4911 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4939 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4953 (limited to facilities regulated under RCRA Subtitle C, 42 U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in solvents recovery services on a contract or fee basis);

FPC is in the appropriate SIC Code

and ’The facility manufactures (defined to include importing), processes, or otherwise uses any EPCRA section 313 chemical in quantities greater than the established threshold in the course of a calendar year.
EPCRA section 313 reporting is required if threshold quantities are exceeded. Separate thresholds apply to the amount of the EPCRA section 313 chemical that is manufactured or processed at your facility in excess of the following threshold:
25,000 pounds per toxic chemical or category
This is the equivalent of 50 drums of material per year.

FPC Currently exempt based on this criteria ALSO

All of the exemptions notwithstanding FPC puts forth a good faith attempt to keep current information based on processing of toxic materials and waste stream (none) data.

FPC current list below

115-07-1 Propylene (Propene) 1.0 ---2005 Propylene Glycol 2005 quantities approx ___2 drums__::2006 __3 drums___
51-79-6 Urethane (Ethyl carbamate) 0.1 ---2005 & 2006 quantities approx 0
N982 Zinc Compounds (1.0) ---2005 quantities approx __50 Gal - All ZnOm____ :: 2006 ___50-gal All ZnOm____
Includes any unique chemical substance that contains zinc as part of that chemical’s infrastructure.For FPC this is ZnOmandine CAS# - 13463-41-7 from Arch
and zn powder

CAS Number List of Current FPC Products -

  • Laboratory Activities Exemption

    The exemption also applies to non-PBT EPCRA section 313 chemicals that are manufactured as impurities that remain in the Laboratory Activities Exemption. EPCRA section 313 chemicals that are manufactured, processed, or otherwise used in a laboratory at a covered facility under the direct supervision of a technically qualified individual do not have to be considered for threshold determinations and release and other waste management calculations. However, pilot plant scale and specialty chemical production does not qualify for this laboratory activities exemption, nor does the use of EPCRA section 313 chemicals for laboratory support activities, such as the use of chemicals for equipment maintenance.The de minimis exemption generally does not apply to the manufacturing of an EPCRA section 313 chemical. However, the de minimis exemption may apply to mixtures and other trade name products containing non-PBT EPCRA section 313 chemicals that are imported into the United States.
    The exemption also applies to non-PBT EPCRA section 313 chemicals that are manufactured as impurities that remain in the Laboratory Activities Exemption. EPCRA section 313 chemicals that are manufactured, processed, or otherwise used in a laboratory at a covered facility under the direct supervision of a technically qualified individual do not have to be considered for threshold determinations and release and other waste management calculations. However, pilot plant scale and specialty chemical production does not qualify for this laboratory activities exemption, nor does the use of EPCRA section 313 chemicals for laboratory support activities, such as the use of chemicals for equipment maintenance.



    For more information see