Question # 54

54. A facility whose NAICS code is outside the covered NAICS codes believes that their current NAICS code is misrepresentative of the facility’s activities. In actuality, the facility may be better represented by an NAICS code within the covered NAICS codes. If the facility changes its NAICS code to a covered group, should they back report for previous reporting years under EPCRA section 313?
If the facility has not altered its operations and should have been classified in a covered NAICS code and has met the threshold and employee criteria, it is required to report for all the previous years under EPCRA section 313. If the mix of activities at the facility shifted from non-covered to covered NAICS codes, then it should begin reporting for the year in which the change occurred.

Additional Details

Question # 54 Source EPCRA Section 313 Questions & Answers 2019 Consolidation Document (PDF)(413 pp, 2.4 MB, April 2019)
ID 19-054 Status Current
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.A. Types of Facilities That Must Report
Keyword(s) Form R Revisions, NAICS (Industry Code)
Prior Q&A [Archived] Question Number 17, 1998 EPCRA 313 Q&A
Updated SIC codes to NAICS codes