Who is affected? Basically, anyone who uses or processes more than 100 pounds of lead per year. If your facility has more than 10 employees and exceeds the 100-pound threshold, you must track and report your lead usage, down to the very last molecule. Right now, the most commonly used solder is eutectic tin lead, which contains 35 percent lead. So as a general rule of thumb, the annual use of more than 285 pounds of eutectic tin-lead solder would trigger the 100-pound reporting threshold.

It's important to point out that this rule doesn't forbid the use of lead; it's really just an additional paperwork requirement with no environmental benefit. How much paperwork? Well, the EPA estimates 110 hours per year for each facility covered-all in service of an impossible-to-quantify benefit of the information that will be gathered.

Each company covered under the rule must submit a TRI report to local emergency-planning agencies and the federal government. For its part, the EPA will post the reports on the Internet so national and community environmental groups can target facilities producing or using large amounts of chemicals such as lead.

IPC and other industry associations are continuing to oppose this rule because it offers no environmental benefit and is based on poor science. EPA has come under fire for labeling certain chemicals, including lead, as PBTs. In fact, pressure from industry has led Congress to ask the agency to review the PBT metals criteria. EPA sent the rule to its Science Advisory Board for review, but only after issuing the Final Rule. The good news is that the review could change or stop this rule before the July 2002 reporting deadline.

IPC is pursuing all available avenues in its continued efforts to halt implementation of this rule before that date. However, we are advising affected companies to begin tracking lead usage and lead emissions immediately. IPC efforts may include a lobbying push to have Congress delay the law until completion of the review or a lawsuit seeking to overturn the rule in court on the basis of noncompliance with the requirements of the Small Business and Regulatory Enforcement Act.

You'll find more information on the lead TRI rule at the legislative/regulatory section of IPC's Web site, www.ipc.org/ html/fslegislative.htm.

Fern Abrams is Director of Environmental Policy for IPC, the Packaging Industry Trade Association. She is based in Washington and can be reached at (202) 638-6219 or at fabrams@ipc.org.