Question # 171

171. A covered facility consists of three establishments. If a warehouse located on a non-contiguous/adjacent site 20 miles away solely supports one of the covered facility’s establishments that is not within a covered NAICS code, is that warehouse considered a covered facility because of its status as an auxiliary facility?
No. The SIC system assigned SIC codes to auxiliary facilities according to the primary activity of the establishment that they served. However, the NAICS system does not recognize the concept of auxiliary facilities and assigns NAICS codes to all establishments based on their own activities. For the purpose of establishing consistency with the NAICS classification methodology, EPA changed its interpretation of the applicability of TRI reporting requirements to auxiliary facilities. As a result, some auxiliary establishments will no longer be subject to TRI reporting. Because the warehouse assumes a non-covered NAICS code, it is not a covered facility.

Additional Details

Question # 171 Source EPCRA Section 313 Questions & Answers 2019 Consolidation Document (PDF)(413 pp, 2.4 MB, April 2019)
ID 19-171 Status Current
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.H. Auxiliary Facilities
Keyword(s) NAICS (Industry Code)
Prior Q&A [Archived] Question Number 228, 1998 EPCRA 313 Q&A
Updated SIC codes to NAICS codes; Added updated information