Ask the Expert Question-and-Answer Archive (TRI)

by Joelie Zak, Scientific Control Labs, Inc.
March, 2002

Leaded Crystal Vases

Q. We market leaded crysal vases that are made off site. We may take about 100 of these vases a month and drill a hole at the base to make a lamp. The leaded drilled plugs are shipped off site as a D008. Is this reportable activity in reguards to Form R reporting? We already trip the 100 lb limit from our casting usage.

A. Yes, this activity would count both towards threshold determination and release reporting. However, for the releases you only need to count the per cent lead in the crystal .