EPA TRI Reporting – Activity thresholds for chemicals prepared one year and distributed the following year

A facility processes pipes, stores them for the remainder of the reporting year, and then ships them off site the following year to be distributed in commerce.  Are TRI chemicals in the pipes that were prepared but not actually distributed during the reporting year considered to be processed for threshold determination purposes?

For purposes of the EPCRA §313 TRI threshold determination, amounts of a TRI chemical prepared for distribution in commerce are considered processed in the year that they undergo the processing step.  Therefore, even though the pipes were not distributed into commerce until the following reporting year, the chemicals in the pipes would be counted towards the processing threshold for the year in which they were prepared for distribution.


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