Every year, foundries that meet the applicability criteria under EPCRA Section 313 must report their releases of listed toxic chemicals to EPA by July 1. Working out which chemicals are reportable, and in what quantities, is rarely straightforward in a metalcasting facility — the same chemical may enter through scrap, alloy additions, binders, or coatings, and leave through stacks, fugitive emissions, wastewater, spent sand, or recycled returns.
The TRI Subcommittee of the AFS Air Quality Committee developed this guidance to help iron and steel foundries navigate that process. It walks through threshold determinations and Form A eligibility, maps TRI-listed chemicals to the specific foundry operations where they occur — melting, pouring, cooling, shakeout, sand handling, and finishing — and provides worked calculation examples drawn from typical foundry practice. It also addresses the exemptions foundries most often ask about, including the treatment of internal returns, the article exemption, and the de minimis exemption.
The guidance reflects the industry's collective experience with TRI reporting since the program's early years and is updated periodically to track changes in EPA's requirements.
No two foundries are alike. This document is intended as a starting point for your own threshold and release determinations, not as a substitute for review of 40 CFR Part 372 or consultation with your environmental staff or counsel.
American Foundry Society Reporting Guidance
Reporting guidance was developed by the TRI Subcommittee of the Air Quality Committee to assist iron and steel foundries with determining possible reportable quantiles of TRI chemicals. The document can be found below.
American Foundry Society/Casting Industry Suppliers Association Form R Reporting
The latest edition of the document entitled “Form R Reporting of Binder Chemicals Used in Foundries” prepared by AFS and CISA is provided below. The document assists foundries on the releases of binder system chemicals during chemically bonded core- and mold-making. Please note that this document does not address air pollutants that may be released during the pouring, cooling and shakeout operations.