Question # 114

114. A facility has two establishments, one in NAICS code 314110 (a covered NAICS code), and one in NAICS code 721120 (not a covered NAICS code). In determining the facility’s primary NAICS code, the facility must determine the value added of the services provided and/or products shipped from or produced by each establishment. Some of the employees who support the establishment in NAICS code 721120 work entirely off-site, either at home or at clients’ sites. Should the facility consider this off-site work when determining the value added of the services provided by NAICS code 721120?
Yes. In determining the primary NAICS code, the facility should consider the value added of services provided by each establishment, including services provided by employees who work for that establishment at home or who service that establishment’s products at clients’ sites (see 40 CFR Section 372.22(b)(3)).

Additional Details

Question # 114 Source EPCRA Section 313 Questions & Answers 2019 Consolidation Document (PDF)(413 pp, 2.4 MB, April 2019)
ID 19-114 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 7, 2004 Q&A Addendum
Updated SIC codes to NAICS codes; Updated citations or URL