318. A facility adds chlorine to its water supply system. The chlorinated water is used only for drinking purposes by employees. Is this use of chlorine reportable under EPCRA section 313?
Chlorine that is added by a facility to its water supply system to prepare potable water for consumption at the facility is exempt from reporting under the personal use exemption, which exempts as ‘personal’ use, by employees or other persons at the facility, the use of foods, drugs, cosmetics, or other personal items containing toxic chemicals, including supplies of such products within the facility such as in a facility operated cafeteria, store, or infirmary (40 CFR Section 372.38(c)(3)). Since chlorine is used to prepare an item (i.e., potable water) that will be used only for drinking purposes by facility employees, it is exempted from reporting under EPCRA section 313.