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Question Number: 48, 1998 EPCRA 313 Q&A: Employee Threshold; Reporting Responsibility

48. Facility A stores oil at Facility B. Facilities A and B have different owners. Facility A sends personnel to Facility B to load oil onto Facility A’s trucks using Facility B’s truck rack. Facility A then distributes the oil in commerce. Who processed the oil and does Facility B have to count Facility A’s hours?
Facility B has processed the oil that was taken from Facility B’s truck rack located on Facility B’s property. Facility A’s use of product at Facility B must be considered toward Facility B’s threshold, release and other waste management calculations, where appropriate. The hours spent by Facility A’s truck drivers while at Facility B do not directly support Facility B but instead directly support Facility A and should be accounted for by Facility A.