1998 EPCRA 313 Q&A, Question # 5

5. A recently constructed facility which has not begun production but is in a covered SIC code has used several listed toxic chemicals in preparing a reactor bed and distillation columns for manufacturing. Is the facility required to report these chemicals if they exceed the threshold levels?
Yes. Once a covered facility has been constructed, any toxic chemicals used to prepare production equipment for manufacturing activities must be included towards the threshold determinations that reporting year. This includes start-up activities.

Additional Details

Question # 5 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-005 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.A. Types of Facilities That Must Report
Keyword(s) Definition of Facility, Facility Construction
Updated Q&A Question Number 25
Prior Q&A [Archived] Question Number 5, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 5, 1997 EPCRA 313 Q&A: Facility-Definition of; Facility-Facility Construction. Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.