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Document Type: Incoming
To: Maria Doa
From: James Nolan
Date: 04/30/2002
Subject: Request for Clarification of an Interpretation of the Article Exemption for SARA 313 TRI Reporting for Lead
Keyword(s): Article Exemption
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Body:
Fibre Box Association
2850 Golf Road
Rolling Meadows, IL 60008 USA
847/364-9600
Fax 847/364-9639
www.fibrebox.org
April 30, 2002
Maria J. Doa, Ph.D.
Chief, Toxics Release Inventory Program Division
Mail Code 2844
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Dear Dr. Doa:
Subject: Request for Clarification of an Interpretation of the Article Exemption for SARA 313 TRI Reporting for Lead
This letter is being submitted to you on behalf of the Fibre Box Association (“FBA”) and the Association of Independent Corrugated Converters (“AICC”), as a request for clarification of the “article exemption” for SARA 313 TRI Reporting for lead.
The FBA is the manufacturer’s trade association representing and servicing the corrugated industry in the United States. Our industry manufactures and markets corrugated and paperboard products consisting of corrugated paperboard (combined board) as well as packaging and shipping containers. There are approximately 600 corrugator plants and over 850 corrugated board converting units manufacturing corrugated paperboard (combined board) containers, partitions, sleeves, display stands and other types of corrugated products. The FBA is made up of large and small operators with a wide spectrum of ownership and entrepreneurial activities, representing over 90% of the corrugated production in the United States.
The Association of Independent Corrugated Converters (“AICC”) is the manufacturer’s trade association that represents the interests of the independent sector of the corrugated industry in the United States.
As you are well aware, the recently announced TRI lead rule generally lowered the reporting threshold to 100 pounds and eliminated the de minimis exemption, for lead and lead compounds (except for lead in stainless steel, brass or bronze alloys). In light of that change, many of the FBA’s members have approached the FBA indicating a desire for confirmation of the interpretation of the article exemption as it applies to: (1) the paperboard (liner and medium) used to manufacture corrugated paperboard (combined board); and (2) to the corrugated paperboard (combined board) used to manufacture other corrugated products. Set forth below is pertinent background information regarding these materials, and the details of our request for clarification.
Corrugated paperboard (combined board) is produced by combining rolls of “linerboard” and “medium” in a “corrugator”. The corrugator forms a continuous sheet of medium into a fluted (undulated) shape and sandwiches it between two continuous sheets of linerboard. The sheets and fluted medium are “glued” together (generally with a starch paste of certain consistency) by applying gelled starch to the tips of the fluted medium. The combined board is then dried and cut into manageable sections. For some purposes, anti-skid or other coatings are applied to the surface of the combined board before drying. The combined board is then stored for sale to other converting plants or for further processing in house. In both instances, the “processing” in question consists of cutting, scoring, printing, folding, box joint gluing, etc. the combined board (either in the same or different facility) into corrugated products, such as boxes, sleeves, partitions, display stands, etc. On occasion, corrugated combined board is coated with wax or other materials to enhance certain design properties of the combined board. In 2001, single wall corrugated, as described above, represented almost 90% of corrugated production. For some purposes, additional layers of medium and liner are added to the basic “sandwich.” For example, “double wall” corrugated is made by sandwiching two sheets of fluted medium between three sheets of linerboard.
The linerboard and medium are delivered in rolls with specific thickness (caliper) and width as well as strength and porosity properties (burst, water resistance, crush, etc). Both the shape and the design of the linerboard and medium are critical in the manufacture of corrugated paperboard (combined board) and other corrugated products. The shape and design of the corrugated paperboard (combined board) is also critical for the manufacture of other corrugated products. For example, for use in the corrugator, the linerboard and medium must be in rolls of the required width and thickness to match the specific corrugator dimensions, as opposed to reams, rectangular pieces, or other forms. Similarly, the strength properties of the paperboard are essential to the end use function, the creation of corrugated paperboard (combined board) of a specific shape and design.
We are therefore asking EPA for clarification of the article exemption as it applies to (1) the paperboard (linerboard and medium) that are combined to form corrugated paperboard (combined board); and (2) the corrugated paperboard (combined board) that is used to manufacture other corrugated products.
Again, this is an important matter for our industry. Since we need to report back to our membership well before the July 1, 2002 reporting deadline, we would like, at your earliest convenience, to meet with you and/or others you deem appropriate to discuss our operations and obtain further clarification. If you require additional information, please do not hesitate to contact me by phone at 847-364-9635 or by e-mail at jnolan@fibrebox.org.
Expecting your kind and prompt consideration to this important request, we remain,
Yours truly,
James F. Nolan
Senior Vice President
cc: Amber L. Aranda, Esquire
Office of General Counsel
Pesticides and Toxic Substances Division
Mail Code 2333A
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Richard G. StolI
Foley & Lardner
Washington Harbour
3000 K Street, N.W., Suite 500
Washington, DC 20007-5109
Dr. Sergio Galeano
Task Force Leader
Georgia-Pacific Corporation
Link to response: 
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