Question # 25

25. A recently constructed facility which has not begun production but is in a covered NAICS code has used several listed toxic chemicals in preparing a reactor bed and distillation columns for manufacturing. Is the facility required to report these chemicals if they exceed the threshold levels?
Yes, assuming the facility also meets the employee threshold of at least ten full-time employees or the equivalent. Once a covered facility has been constructed, any toxic chemicals used to prepare production equipment for manufacturing activities must be included towards the threshold determinations that reporting year. This includes start-up activities.