184. If a facility exceeds an activity threshold for both the parent metal and the metal compounds category for the same metal, can that facility file both chemicals on one EPCRA §313 Form R report?
Only elemental metals without a chemical qualifier can be reported with their associated metal category compound on a combined Form R report. Elemental metals with qualifiers that are only reportable if they are manufactured, processed, or otherwise used in a specific form(s) cannot be reported with their associated metal compound category on the same Form R. For example, a facility that exceeds an activity threshold for both zinc (fume or dust) and zinc compounds must not report both zinc (fume or dust) and zinc compounds on the same Form R.
Additional information on reporting metal category compounds and their parent metal can be found in the Toxic Chemical Release Inventory Reporting Forms and Instructions.