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Recommendations to Simplify Tracking and Reporting <br />Based on information and advice obtained from individuals who prepare reports for <br />participating businesses, the Toxics Board makes the following recommendations: <br />1. Persons preparing the reports should carefully review and take advantage of <br />existing policies that are intended to make reporting easier. These include: <br />a. Exemptions for articles. See page 14. Most metals purchased in bulk are <br />articles. Portions not converted into fumes, dust, filings, or grindings are not <br />reportable. <br />b. Threshold amounts for reporting. See page 15. If total inputs in a calendar <br />year are below 2.2 pounds for a hazardous substance or 0.022 pounds for an <br />extremely hazardous substance or extremely persistent bioaccumulative <br />toxin, then that substance need not be reported. <br />C. Threshold amounts for full materials balance accounting. See page 16. If <br />total inputs in a calendar year are between 2.2 pounds and 50 pounds for a <br />hazardous substance, or between 0.022 pounds and 5 pounds for an <br />extremely hazardous substance or extremely persistent bioaccumulative <br />toxin, only the total input quantity is required to be reported. <br />(Estimate total quantities first, to see whether they will meet reporting <br />thresholds, before proceeding with full calculations.) <br />d. Degree of precision. See page 20. For hazardous substances, reporting in <br />whole pounds is preferred unless the amount is less than 10 pounds, in which <br />case it should be reported to the nearest tenth of a pound. No greater <br />precision is required, except in the case of extremely hazardous substances or <br />extremely persistent bioaccumulative toxins. <br />e. Priority System for Determining Amounts. See page 20. Actual <br />measurements or calculations are required when available. When these are <br />not possible or not available, estimates based on best engineering judgment <br />of the manufacturer are allowed. <br />EXAMPLES: <br />1. A company uses a reportable substance to wash machinery. Some of <br />the substance goes down the drain, and the rest is wiped off with rags, <br />which are placed in a bin and later hauled away. The percentage of <br />the substance that is on the rags may be determined based on the <br />company's best engineering judgment, since it is unlikely that actual <br />measurements of either output are being made. <br />2. In the same scenario, if the company does have information allowing <br />it to calculate the amount of the reportable substance that is being <br />-5- <br />