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?
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.