Question # 341

341. An EPCRA section 313 toxic chemical is used to clean a process-related tower at a manufacturing facility. Is the use of the chemical exempt from threshold and release and other waste management calculations under the routine janitorial and facility grounds maintenance exemption of 40 CFR Section 372.38(c)(2)?
No. Materials used to maintain process-related equipment at a facility (e.g., cleaners and lubricants) are not exempt under Section 372.38(c)(2). Because the tower is process-related, the exemption does not apply. This exemption only applies to the use of products that are specifically used for routine janitorial or facility grounds maintenance.