Advisory Notice to Consumers

TO: Consumers of Brass and Bronze Rod and Bar
FROM: CDA Environmental Science and Governmental Affairs

: Lower Reporting Threshold for Lead Content May Not Affect Your Business

: March 16, 2001

New reporting requirement

Effective April 17, 2001,* the U.S. EPA is lowering the EPCRA Section 313 reporting threshold for lead to 100 lbs. The lower reporting threshold applies to lead and all lead compounds but does not apply to lead contained in brass and bronze alloys.

Old requirements still in effect
Lead contained in brass and bronze alloys remains reportable under the 25,000 lb (lead, not alloy) manufacture and process reporting thresholds and the 10,000 lb (lead, not alloy) otherwise use reporting threshold. Detailed definitions of the terms, manufacture, process and otherwise use, are on EPA web site.

The brass and bronze alloy exemption may change
The U.S. EPA has not made a final decision on maintaining the current reporting threshold of lead in brass and bronze alloys. The U.S. EPA has simply deferred inclusion of these alloys until it completes an ongoing, scientific review of issues important to these alloys. No anticipated date of completion has been mentioned.

The specifics
Details of this action can be found in 40 CFR Part 372, Federal Register / Volume 66, Number 11 / Wednesday, January 17, 2001 / Rules and Regulations, pages 4500-4547. If you desire more information on whether your facility would be affected, carefully examine the applicability criteria in Part 372, Subpart B, Title 40 of the Code of Federal Regulations.

More information
The Copper Development Association Inc. would like to help you with environmental questions pertaining to the use of copper products. If you have any questions, contact us at (212) 251-7200, and visit our Environment section.

(*) The effective date was amended in the February 16, 2001, edition of the Federal Register.