Question # 76

76. Should contractors who construct dikes, clean tanks, and perform inventory control activities conducted off-site, and who are all performing process-related activities in support of a covered facility, be included in the employee threshold determinations?
Yes. The hours worked on- or off-site by any contract employee for the facility must be counted toward the 20,000-hour threshold. Facilities should keep records that identify all hours that employees or contract employees work in support of facilities. EPA describes a contract employee as a person working on-site or off-site for the facility under a specific contractual agreement performing specific tasks or services for the facility, except intermittent service vendors such as trash pick-up.