Under EPCRA, which threshold applies to 'otherwise used' toxic chemicals?

Under EPCRA, which threshold applies to 'otherwise used' toxic chemicals?

• A. 25,000 lbs
• B. 50,000 lbs
• C. 10,000 lbs
• D. 5,000 lbs

Answer: (C)

Under EPCRA reporting, the threshold you use depends on how the chemical is being used. For chemicals that are “otherwise used”—that is, not part of a manufacturing or processing operation—the threshold is 10,000 pounds per year. If a facility handles more than that amount in this non-manufacturing way, TRI reporting is triggered for that chemical at that facility. In contrast, thresholds for manufacturing or processing are higher, at 25,000 pounds per year, so those activities require reporting only if usage exceeds that larger amount. This distinction explains why 10,000 pounds is the correct threshold for "otherwise used" toxic chemicals: it captures significant non-manufacturing uses without equating them to full-scale manufacturing processes.

Under EPCRA reporting, the threshold you use depends on how the chemical is being used. For chemicals that are “otherwise used”—that is, not part of a manufacturing or processing operation—the threshold is 10,000 pounds per year. If a facility handles more than that amount in this non-manufacturing way, TRI reporting is triggered for that chemical at that facility. In contrast, thresholds for manufacturing or processing are higher, at 25,000 pounds per year, so those activities require reporting only if usage exceeds that larger amount. This distinction explains why 10,000 pounds is the correct threshold for "otherwise used" toxic chemicals: it captures significant non-manufacturing uses without equating them to full-scale manufacturing processes.