Question # 113

113. A multi-establishment facility grows wheat and mills it into flour. At the agriculture portion of the facility, all of the wheat grain is grown, harvested and placed into a silo. After leaving the silo, 20 percent of the wheat grain is sold, while the remaining 80 percent of the wheat grain is milled into flour and packaged. If the facility farms and sells more than it mills into flour and sells, is it a covered facility? What is the primary NAICS code of this facility?
In order to make the facility coverage determination, the facility must compare the value added of products shipped and/or produced at the two different establishments (i.e., agriculture versus the flour processing). The value added of the product produced at the agricultural establishment (not in a covered NAICS code) is the market value of all the wheat grain harvested during the reporting year. The value added of the product from the milling/packaging establishment (in a covered NAICS code) is the value added of the products shipped and/or produced minus the market value of the wheat grain used to produce the flour. In other words, you do not double count the value of the wheat grain as part of the value added of the products from the flour processing operation. If the value added of milled flour products is greater than the market value of harvested grain, then the facility’s primary NAICS code would be within a covered NAICS code and the facility would be subject to reporting under EPCRA section 313.

Additional Details

Question # 113 Source EPCRA Section 313 Questions & Answers 2019 Consolidation Document (PDF)(413 pp, 2.4 MB, April 2019)
ID 19-113 Status Current
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.D. Multi-Establishment Facilities
Keyword(s) Multi-Establishment, NAICS (Industry Code)
Prior Q&A [Archived] Question Number 6, 2004 Q&A Addendum
Revision
History
Updated SIC codes to NAICS codes