Question # 192

192. The Toxic Substances Control Act (TSCA) does not regulate non-isolated reaction intermediates. Do these intermediates still need to be considered for threshold determinations and release and other waste management calculations for EPCRA section 313?
A covered facility owner/operator would need to consider the quantity of non-isolated reaction intermediates manufactured, processed, or otherwise used at the facility when determining thresholds and releases and other waste management activities for EPCRA section 313. There is no exemption for non-isolated intermediates under EPCRA section 313.