1998 EPCRA 313 Q&A, Question # 31

31. Facility A manufactures and sells machinery. Facility A sends employees to customers’ sites to repair and service the machinery. These employees are not based at Facility A. For example, some of the employees pick up company vehicles and needed supplies from rented property before going to the clients site. Facility A also has employees who work directly for the facility, but work entirely from their homes. Should Facility A consider hours worked by these employees in making the employee threshold determination?
Yes. If an individual is employed by a covered facility and works for the covered facility, then all hours worked by that individual must be counted towards the 20,000 hour employee limit, regardless of where the employee works (i.e., on-site or off-site).

Additional Details

Question # 31 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-031 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.B. Employee Threshold
Keyword(s) Employee Threshold, Off-Site Employees
Updated Q&A Question Number 66
Revision
History
Prior Source: IG Letter 3/10/98 - AIG Letter indicates that the source of the 1998 Q"A is an EPCRA section 313 interpretive guidance letter. Type of Change: Converted to Q"A Format Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.