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

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

Lab Data or MSDS?

Q. We are a foundry, lead is a trace element in the steel we melt. Our spectrometer results occasionally show lead in our base iron. No lead is listed on the MSDS for products used. The base iron chemistry lead levels range for .000 to.001 in gray iron, and from .000 - .003 in ductile iron. Do I use our lab results, or because the MSDS say nothing am I allowed to stop there?

A. Because there is no de minimus exemption for the lead contained in your steel, you should use your lab data.