Hi Compliancenetters:

I have just received an inquiry from a member who asks:

"When preparing my TRI Form R, what reporting threshold do I use for ammoniacal etchant? The "otherwise use" threshold of 10,000 pounds or the "process" threshold of 25,000 pounds?"

Because ammoniacal is a reactant, she states that it may be eligible for the "process" threshold. Any comments?

I will forward all clarification to the member.

Thanks
Holly Evans
Director of Environmental and Safety Programs
IPC
1400 Eye St., N.W., Suite 540
Washington, D.C. 20005-2208
phone: 202-638-6219
fax: 202-638-0145
e-mail: HollyEvans@ipc.org

Date: Mon, 22 Jun 1998 14:44:03 -0400
Reply-To: "ComplianceNet E-Mail Forum." , lwilmot@HADCO.COM
Sender: ComplianceNet Mail Forum
From: Lee Wilmot
Subject: Re: TRI reporting of ammoniacal etchant
X-To: Holly Evans HollyEvans@IPC.ORG

Holly,
Since the etchant does not end up in the product (as a reactant typically does chemically), the otherwise use category applies. We have consistently used this classification, as well as the "chemical processing aid" subcategory in the otherwise use category.

Lee Wilmot

Date: Mon, 22 Jun 1998 11:53:21 -0700
Reply-To: "ComplianceNet E-Mail Forum." , "Sharp, John"
Sender: ComplianceNet Mail Forum
From: "Sharp, John"
Subject: Re: TRI reporting of ammoniacal etchant
X-To: "HollyEvans@IPC.ORG" HollyEvans@ipc.org

Holly,

I would say that the "otherwise use" threshold applies here. (see page 23 of the 1997 TRI Guidance book). The distinction between "process" and "otherwise use" depends on whether the chemical is incorporated (processed) into the product, or is not incorporated (otherwise used) into the product. However, you do coincidentally manufacture ammonia compounds (as a byproduct) in the etcher also.

Since the otherwise use threshold is lower, it applies. However, remember that in aqueous solutions, only 10% of the ammonia is reportable. Anhydrous forms of ammonia are reported at 100% of use. Therefore, to be under the 10,000 pound threshold that applies to otherwise use, you would have to ensure that the sum of your anhydrous use (multiplied by 100%) plus your aqueous use (multiplied by 10%) didn't exceed 10,000 pounds.

John Sharp
Merix Corp., Forest Grove, OR
503-992-4351 Telephone
503-359-1040 FAX
john.sharp@merix.com