Potential Paperwork Pileup
Currently, the EPCRA section 313 reporting thresholds for lead and lead compounds are 25,000 pounds manufactured or processed, or 10,000 pounds otherwise used. The August 3, 1999, proposed action would lower the threshold for each category to 10 pounds. Many manufacturers previously exempt from TRI (Toxics Release Inventory) reporting for lead would be required to file a report under the new rule. Potentially affected segments of the ceramic industry include companies with 10 or more employees that manufacture piezoelectric ceramics, decorate using leaded glazes or inorganic pigments, or conduct any activities associated with lead and lead compounds.
The original comment period on the ruling was scheduled to end September 17, 1999. However, the comment period was later extended to December 16 to give interested parties more time to respond.
Three public meetings were held prior to December 16. On November 30, interested parties met in Los Angeles to discuss the issue. Jim Twerdahl, president of Mayco Colors, attended the meeting and spoke on behalf of the Contemporary Ceramic Studio Association. He said that it would be virtually impossible for small businesses to determine the exact amounts of lead used in a given year, and that the cost of reporting would be an extreme burden for the entire industry. He noted that the use of lead has been handled very responsibly in this industry, and that the industry has been good at self-regulation.
Other speakers at the November 30 meeting and at the December 2 meeting in Chicago echoed Twerdahl’s sentiments. A major point of contention is that the EPA has not been able to quantify the benefits that would result from actions that could potentially cost the industry millions of dollars—the cost of filing one report is estimated at $7,000. EPA’s goal is to collect data on lead use for distribution to communities and environmental groups, but there is some question as to the quality of that data, since no additional monitoring will be required.
A final hearing was scheduled for December 14 in Washington, D.C. Comments from that hearing were not available at press time. Updates on this topic will be presented in future issues of Ceramic Industry.