- In this Issue:

- TSCA Reporting: Violations May Never Lapse, But Corroborative Information Is Better Understood

- South Carolina Generator Inspection Schedule Increases

- Frequent Questions: Form R

- Comparable Fuels Now Hazardous Waste When Burned for Energy Recovery

- Excerpt from Frequent Questions: Form R:

EPCRA 313 requires certain facilities manufacturing or “processing” more than 25,000 lbs. or otherwise using 10,000 lbs or more of a listed toxic chemical to annually file a Form R on or before July 1. These Frequent Questions will assist preparation of the Form R for your facility.

Question: If a solvent is a listed toxic chemical and used to clean equipment but does not become part of the final product, is the chemical considered “processed” or “otherwise used”?