Question # 346

346. A covered facility uses a contact cleaner to clean relays that are used to control lights. For Section 313 purposes, is this use exempt as part of routine janitorial grounds maintenance or must the amount of the listed toxic chemical in the cleaner used be included in an applicable threshold?
The use of the cleaner is not exempt because it is not a routine janitorial use and does not relate to facility grounds maintenance (40 CFR Section 372.38(c)(2)). The use is integral to the production processes of the facility. Therefore, the amounts of the listed toxic chemicals in the cleaner must be included in the calculation of otherwise use for the facility.

Additional Details

Question # 346 Source EPCRA Section 313 Questions & Answers 2019 Consolidation Document (PDF)(413 pp, 2.4 MB, April 2019)
ID 19-346 Status Current
Category 2. Exemptions Subcategory 2.B. Facility Maintenance and Structural Components
Keyword(s) Facility Maintenance Exemption (Janitorial), Otherwise Use
Prior Q&A [Archived] Question Number 265, 1998 EPCRA 313 Q&A
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