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The U.S. Environmental Protection Agency (EPA) issued a final burden reduction rule in December 2006 that enables Toxic Release Inventory (TRI) filers to use the simplified Form A (instead of the more complicated Form R) to report annual usage of lead and lead compounds in certain instances. To qualify, a glass or ceramic decorator or other business must use less than 500 lbs of lead per year and release none of that lead either on- or off-site, which includes air, water and ground emissions, as well as transfers to waste disposal facilities. Form A use, for those who qualify, is an option for the 2006 TRI reporting year, with reports due on June 30, 2007.
This modest paperwork reduction effort has been targeted by some environmental groups, and legislation has been introduced in the U.S. House of Representatives and Senate that would reverse the EPA rule. The Senate Committee on Environment and Public Works (EPW) held a hearing on the rule in February 2007, and Nancy Klinefelter, president of Baltimore Glassware Decorators and a past president of the Society of Glass and Ceramic Decorators (SGCD), testified in support of the burden reduction steps. Klinefelter described the paperwork burdens of the TRI program for small companies that must complete the complex Form R even if they generate no releases. She also emphasized that the rule is a moderate step that does not impact the quality of public information.
EPA Administrator Stephen Johnson also testified before the committee on the TRI burden reduction rule and several other EPA initiatives. Sen. Barbara Boxer (D-CA) chaired the hearing, which was also attended by ranking Sen. James Inhofe (R-OK) and about 10 other senators. Sen. Frank Lautenberg (D-NJ) alluded to likely Senate majority efforts to reverse the burden reduction rule when questioning Administrator Johnson. Senators welcomed Klinefelter and expressed support for the concerns of small businesses.
When the EPA lowered the lead TRI reporting threshold in 2001 to 100 lbs/year, the agency listed lead as a persistent, bioaccumulative, toxic (PBT) substance, which meant that even companies that used extremely small amounts of lead were not eligible for burden reduction options, including Form A. While the EPA's Science Advisory Board (SAB) has indicated that a PBT classification is not justified for any metal, the agency has yet to refile the lead rule to change the reporting status.
SGCD has urged the EPA to enact burden reduction steps ever since it issued the TRI lead rule. Nancy Klinefelter and yours truly have testified several times before the House Small Business Committee and various subcommittees in the intervening years urging the EPA to act. For details, contact me at email@example.com.