Inside CI: A Fine Line...

As many companies know, the EPA announced plans in August 1999 to drastically lower the reporting thresholds for lead and lead compounds that are subject to reporting under section 313 of the Emergency Planning Community Right-to-Know Act (EPCRA) and section 6607 of the Pollution Prevention Act (PPA). (See Ceramics in the News, January 2000.) This statement immediately put the small business community up in arms.

It isn’t that the EPA is wrong. Data have shown that lead in any form is a toxin and is biopersistent in the environment. Even small levels can accumulate over time, causing potential problems for future generations. Who can argue with the fact that more information is needed on toxins in the air and water that might be harming our children? The question is, what type of information is needed? And is the EPA looking in the right place?

Many would argue “no.” Most of the lead used in manufacturing today is in recycled products, such as metal materials and rubber tires. The lead would be more of a problem if it were dumped in landfills; yet the companies recycling that lead—and therefore benefiting the environment—would be penalized for their efforts. The cost—ranging from $7,000 to $10,000 per report—would be troublesome for most and staggering for some. More staff and resources would need to be allocated to tracking the lead, and the end result may just be the company’s “best guess,” since trace quantities of lead will be virtually impossible to track. The EPA would end up with data that is fuzzy at best and downright inaccurate in some cases.

A fine line often exists between economic interests and the good of communities and the environment. In many cases, government decisions are made without enough research to determine the results. If legislation continues to be made in this “us against them” fashion, it will become increasingly difficult to solicit voluntary industry participation in any environmental matters in the future.

Interestingly enough, hardly any ceramic representatives were at the three public meetings held in November and December to discuss the matter, despite urging from the Ceramic Manufacturers Association (CerMA) and the Society for Glass and Ceramic Decorators (SGCD). While these organizations will continue to fight such battles on the industry’s behalf, it appears that ceramic manufacturers are generally unconcerned. Our voices cannot be heard if we do not speak out on such matters.

The comment period on the lead reporting requirements was scheduled to end December 16. It will be interesting to see what develops based on comments and suggestions from other industries. As always, Ceramic Industry will keep you informed both in print and on our website at Please feel free to send us your comments at or by fax at 248-244-6429.

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