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<br />r <br /> <br />If" <br /> <br />17. QUESTION: We bring in raw sheets of99% pure copper, a reportable substance. We <br />. have the sheets water-cut by an outside business, and then use them as a part of our <br />product. We understand that our copper filings, dusts, and grindings are reportable, but <br />what about the raw copper and the pieces that go onto the product? <br /> <br />f' <br /> <br />ANSWER: Only the filings, dusts, and grindings are reportable, as long as all the rest of <br />the copper remains solid throughout the manufacturing process. <br /> <br />, <br /> <br />!f' <br /> <br />B. MIXTURES AND COMPOUNDS <br /> <br />" <br /> <br />General guidelines: ' Report only the weight of listed hazardous substances and characteristic <br />substances (see Appendix D) contained in mixtures and compounds used in manufacturing. Do <br />not report the weight of the entire mixture or compound unless reporting the entire weight is <br />easIer. <br /> <br />If a mixture or compound contains a characteristic substance, but the mixture or compound itself <br />is not characteristic and does not become characteristIc during its life cycle in Eugene, then the <br />characteristic substance contained in the mixture or compound is not reportable. <br /> <br />In other cases, it is necessary to calculate the percentages of reportable substances contained in <br />mixtures and compounds and report these amounts by weight. <br /> <br />18. QUESTION: Particleboard and certain plywood products are manufactured with <br />formaldehyde-based adhesives. Most manufacturers of these products provide MSDS's <br />stating the board contains formaldehyde, a listed EHS chemical, but they do not list <br />percentages. Does this exempt these products from being reportable by secondary manu- <br />facturers(cabinetshops)? <br /> <br />ANSWER: In this case, one cannot mow the amounts of formaldehyde. Most of the <br />formaldehyde reacts with the phenolic, hydroxyl or amine components of the adhesives <br />and thus is no longer formaldehyde, but there is no way to mow how much of the formal- <br />dehyde reacts and how much is residual or emitted to the air without very sophisticated <br />measurements, and thus any reported amounts would be meaningless. For 1999 and <br />beyond, the Toxics Board may revisit this question. <br /> <br />19. QUESTION: The MSDS for an ink lists three ingredients, but no percentages. One of <br />the ingredients is a reportable substance. What should we report? <br /> <br />ANSWER: While businesses are not required to do extra research, an inquiry to the <br />supplier would not be especially burdensome. Otherwise, it would be necessary to esti- <br />mate the percentage of the reportable substance in the ink, using best engineering judg- <br />ment, and report the substance accordingly. <br /> <br />F-6 <br />