In a move that could have serious negative repercussions on businesses
nationwide, the US Environmental Protection Agency (EPA) has proposed to
lower the reporting thresholds (from 25,000 lbs. to 10 lbs. per year) for lead and
lead compounds subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). This change would require all wire producing companies using
more than 83 tons of steel per year to start reporting for lead. EPA is also
proposing to eliminate the de minimis exemption granted to many AWPA members
and their customers, which excuses them from these cumbersome reports.
Although actual costs vary greatly among companies, it is estimated
those not currently filing for lead could have to expend upwards of $40,000 to
conduct the necessary analysis in order to comply. As a result, AWPA began an
aggressive effort to get member companies to submit comments to EPA
outlining their concerns with this proposed rule.
Despite very short notice from EPA, approximately 20 facilities sent in
comments opposing the rule, refuting many of EPA's budgetary and compliance
cost estimates. In addition, six companies sent representatives to the three public
hearings held for companies and organizations to give their views. AWPA
thanks each of these companies for their efforts on behalf of the industry.
AWPA also submitted detailed comments on the devastating effects this
rule would have on the US wire producing industry as a whole. Association
representatives will also be meeting with Senate staff members to discuss
legislative means of fighting this proposed regulation, if necessary. Finally, AWPA
will continue to monitor this issue through a coalition organized by the Lead
Industries Association to fight this proposal and report back to the membership
on any important developments.
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American Wire Producers Association
801 North Fairfax Street, Suite 211
Alexandria, VA 22314-1757
Tel (703) 299-4434 | Fax (703) 299-9233 | E-mail info@awpa.org | Web: www.awpa.org
