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Question Number: 17, 1998 EPCRA 313 Q&A: Form R Revisions; SIC Code

17. A facility whose SIC code is outside the covered SIC codes believes that their current SIC code is misrepresentative of the facility's activities. In actuality, the facility may be better represented by an SIC code within the covered SIC codes. If the facility changes its SIC code to a covered group, should they back report for previous reporting years under EPCRA Section 313?
If the facility has not altered its operations and should have been classified in a covered SIC code and has met the threshold and employee criteria, it is required to report for all the previous years under EPCRA Section 313. If the mix of activities at the facility shifted from non-covered to covered SIC codes, then it should begin reporting for the year in which the change occurred.