1998 EPCRA 313 Q&A, Question # 264

264. It appears that janitorial type chemicals are exempt. Does this mean that if I use formaldehyde as a disinfectant in a sterile area in excess of the threshold, it is exempt?
No. The use of the disinfectant described in the question seems to be process-related and is therefore not exempt. Also, 'janitorial type chemicals' are not exempt; rather, toxic chemicals used for routine janitorial or facility grounds maintenance are exempt.

Additional Details

Question # 264 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-264 Status Archived
Category 2. Exemptions Subcategory 2.B. Facility Maintenance and Structural Components
Keyword(s) Facility Maintenance Exemption (Janitorial)
Updated Q&A Question Number 345
Prior Q&A [Archived] Question Number 171, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 171, 1997 EPCRA 313 Q&A: Facility Maintenance Exemption. Type of Change: No Change to the Original - No Change to the Original indicates that either no change was made between the original Q"A and the 1998 version of the Q"A or that the only edits that were made involved punctuation changes. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.