Q. An EHS chemical, Sulfuric Acid, exceeds 500 pounds. Therefore aggregation of Sulfuric Acid containing compounds is required in TRI reporting. In that aggregation, are lab chemicals included or exempted?
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A. There is a conditional laboratory exemption found at 40 CFR 372.38(d):
Toxic chemicals that are manufactured, processed, or used in a laboratory at a facility under the supervision of a qualified technician are not included in determining the threshold amount. However, this does not apply to:
- Specialty chemical production laboratories
- Chemicals manufactured, processed, or used in pilot plant scale operations
- Activities conducted outside a laboratory.