NFFS recommends foundries NOT respond to EPA request regarding lead in aluminum
NFFS has become aware that the US Environmental Protection Agency (EPA) Region 6 has sent correspondence to aluminum foundries OUTSIDE OF REGION 6 seeking information regarding the aluminum foundry industry and the reporting of lead to the Toxic Release Inventory (TRI). This letter has been sent to firms with a primary North American Industry Classification Code (NAICS) of 331524 (Aluminum Foundries, Except Die-Castings) requesting foundries to volunteer information regarding when they first became aware of the potential for reporting lead at the lower 100 lbs/yr threshold for Persistent Bioaccumulative Toxins (PBTs). The letter then asks for a sample SDS (old MSDS) from one of the foundry’s vendors that cover lead and copper.
NFFS is strongly recommending that aluminum foundries NOT RESPOND to this letter from EPA region 6 without legal or professional advice. The request for information is strictly VOLUNTARY and there is no obligation to respond from foundries who receive this letter as there is no OMB number attached to the request. NFFS is concerned about the informal information request which is outside the normal methodologies used by EPA to request such information. We would also note that the EPA has not requested information on this topic from NFFS.
Please contact the NFFS staff if you receive a copy of this letter, or if you would like to discuss the topic or the recommendation from NFFS to not respond to the EPA request without legal or professional advice.