U.S. industry, including PWB manufactures, are required to submit a Toxic Chemical Release Inventory (TRI) Form (also known as Form R) if their facility has 10 or more full-time employees (or the equivalent 20,000 hrs/year), and if the facility "manufactured, processed, or otherwise used" any of the listed toxic chemicals in amounts greater than threshold quantities. The threshold for most toxic chemicals including lead and lead compounds was previously set at 25,000 pounds (for chemicals "manufactured" or "processed") or at 10,000 pounds (for chemicals "otherwise used"). Under the new lead rule, the threshold has been lowered to 100 pounds of lead or lead compounds for each use category. Chemicals other than lead and lead compounds are unaffected by the change. The lead rule is retroactive to January 1, 2001 and TRI reports due on July 1, 2002 should have reflected the lower lead threshold.

If the amount of lead or lead compounds you manufacture, process or otherwise use equals or exceeds 100 pounds, then your facility meets the threshold requirement and must submit a report for lead. If the amount of lead or lead compounds does not exceed 100 pounds for any single category, taken separately, you do not have to submit a report for lead.

There is one other change in the rule for lead, which may affect some previously calculated quantities. In previous years, materials that contain a low concentration of lead (less than 1%) could be excluded by the so-called "de minimis" exemption. With the new rule, the de minimis exemption no longer applies to lead in most cases (the only exception is brass which is unlikely to be used by PWB manufacturers). If you use a material with a low lead content, and if you previously determined that you did not have to consider the material because the lead concentration was below 0.1%, you will have to include these quantities in your threshold and release and other waste management quantities. With very few exceptions, all sources of lead, even at very low concentrations, now count, even if it is not found on a MSDS.

The survey results summarized below are from 12 respondents. Six additional responses were received, however, these were not used because they were either incomplete or they were submitted by non-PWB manufacturers (e.g., assembly facilities).

The following are responses to several basic yes - no questions relevant to the respondents past and current TRI reporting practices.

The following table summarizes responses to the following question: If your company reported for lead this year indicate the sources of lead that caused you to report (select one or more).

The above survey results suggest that PWB manufacturers may not have consistently evaluated potential sources of lead. For example, only three sources (dross from solder pots, air emissions, wastewater and sludge) were reported by more than one-half of the survey respondents.

Prompted by the variability found in the TRI-Lead survey, the PWBRC staff examined Year 2000 TRI submissions from PWB manufacturers (Year 2000 is the latest reporting year for which data are publicly available). In year 2000, the lead threshold was set at 25,000 pounds (for chemicals "manufactured" or "processed") or at 10,000 pounds (for chemicals "otherwise used"). Therefore, lead was less frequently reported. However, what we found was that there were substantial differences in reporting of other chemicals. One would suspect that facilities within the PWB sector would report approximately the same chemicals. Granted, there are different processes and chemistries employed, but more so than most industry sectors, all PWB facilities produce approximately the same product, printed wiring boards.

To check on Year 2000 TRI data, we used EPA’s TRI data query feature (http://www.epa.gov/enviro/html/tris/tris_query.html) and searched for companies in SIC 3672 (printed wiring boards). This query retrieved 495 facility reports. This is the total number of facilities in SIC 3672 that have submitted TRI reports for at least one year starting in 1989. We took a sample of this group and identified which chemicals they reported for in Year 2000. To get a sample, we selected companies that submitted a Year 2000 TRI report and appeared to be bare board manufacturers rather than assembly or OEMs. We differentiated between facilities somewhat unscientifically, based on company names. We chose companies with names that appeared to be independent board manufacturers (e.g., ABC Circuit Boards, Quality Circuit Boards). There were 41 companies in our sample. Below are the results from this work.

Some reporting differences are due to process chemistry changes taking place in the PWB industry (Companies using direct metalization are probably not using formaldehyde. Similarly not all companies use chlorine for etching and most have eliminated use of glycol ethers.). However, as with the TRI Lead Survey results, there appears to be more variability in reporting than one would expect with a fairly homogenous sector. One exception was copper/copper compounds, which were reported by 90% of the facilities. However, even here, about one-half of the facilities reported "copper" while the other half reported "copper compounds." No other chemicals were reported by 50% of selected facilities.

EPA publishes detailed instructions each year for making threshold determinations and completing Form R. Additionally, in the past they have published various guidance documents, including chemical-specific materials. The Form R instructions for 2001 and some recent TRI reporting guidance documents can be downloaded from the flowing list:

• TRI Lead Final Rule (1/17/01)

• TRI Guidance Document for Reporting Releases of Lead and Lead Compounds - Final (12/01)

• TRI Lead Fact Sheet (4/01)

• TRI Lead Rule - Q&A

• TRI Lead Rule - EPA Web Site

• Certain Glycol Ethers (12/2000)

• Hydrochloric Acid Aerosols(12/99)

• Nitrate Compounds (12/2000)

• Aqueous Ammonia (12/2000)

• Wave Soldering Emissions Factor Guidance (Oct. 30, 2002)

• TRI Reporting Materials and Guidance - EPA Web Page

• Current TRI Reporting Forms and Software