On June 17th, at the request of the US Environmental Protection Agency, the Office of Management & Budget removed from its list of Submissions Under Review (http://www.reginfo.gov/public/do/eoDetails?rrid=119517 ) the EPA proposed final “Toxics Release Inventory (TRI) Articles Exemption Clarification Rule.”
The proposed rule would have eliminated the articles exemption under TRI and required manufacturers to report releases from finished goods in storage.
Finished goods in storage!
 Here’s the rest of the story:
Last July PMPA attended a meeting in Washington D.C. with OMB and EPA over a proposed EPA “Clarification” regarding the article exemption in TRI.
We were joined at that meeting by a number of other involved parties with similar concerns. The meeting was hosted by Jeff Miller of the Treated Wood Council.
We opposed the change and challenged the EPA’s estimate of Paperwork Burden, demonstrated impact on smaller businesses, and made other technical points.

Paperwork burden and manhours to prepare were just the tip of the iceberg.

You can see our Business Intelligence on this issue here .
The EPA’s proposed  change in the “clarification” could have made finished precision machined products with rust preventives subject to TRI release reporting.
At EPA’s request, this submission was removed from review.
We are pleased that our attention to this regulatory issue  with other affected industries has resulted in its withdrawal at the current time. Our position was that the EPA cannot change the TRI rule without formal rulemaking.    Members of Congress have echoed that same concern.   
EPA may ultimately decide to initiate that rulemaking process.  
We do not know exactly why EPA withdrew the proposed rule, nor do we know EPA’s next steps.  
There is nothing transparent about regulation of  small business in Washington D.C.
But for now, as a result of our “effective associating”  and engagement with the federal agencies involved, this ill-considered change to TRI has been withdrawn.
 We will continue to monitor this issue and keep you informed of any developments.
Paperwork Photo :

2010 PMPA Federal EPA Toxic Release Inventory (TRI) Reporting Webinar
Join us for a Webinar on May 25You should attend if your operations have a NAICS code Associated with manufacturing (Old SIC codes 20-39) AND your company had more than 10 fulltime employees (or the equivalent of 20,000 employee hours the prior year).
Space is limited.
Reserve your Webinar seat now at:
Changes that have evolved in TRI reporting need to be fully understood so that you can be best informed about your company’s reporting obligations. This webinar will cover changes in how the article exemption is treated, threshold quantities,reportable elements other than lead, and other topics will be covered. Barbara Knecht, Senior Compliance Specialist with HzW Environmental Consultants will be the main presenter for this hour long workshop on TRI as it impacts our precision machining shops.There is no charge to participate in this free webinar. All shops are invited to attend to learn about this reporting requirement. Handouts-  including a materials calculator spreadsheet- will be available to PMPA members after the webinar on the PMPA website.This presentation and Q&A should last about an hour; we are reserving an additional half hour to take questions after this presentation.If you are not responsible for regulatory compliance, please forward this to the person who handles regulatory issues for your company
Title:   2010 PMPA Federal EPA Toxic Release Inventory (TRI) Reporting Webinar
Date:   Tuesday, May 25, 2010
Time:   10:00 AM – 11:30 AM EDT
After registering you will receive a confirmation email containing information about joining the Webinar.