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Question Number: 13, 1998 EPCRA 313 Q&A: Activity Restricted to Company; SIC Code

13. Does a facility that is subject to RCRA Subtitle C, and just happens to manage waste generated by facilities within the same company, fall within the covered SIC code range for EPCRA Section 313 reporting?
Waste treatment facilities are classified in SIC code 4953 - Refuse Systems, which includes such activities as hazardous waste treatment and disposal sites. Hazardous waste treatment facilities that are regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. Section 6921 et seq. were added in the final rule published on May 1, 1997 (62 FR 23834). Provided that the facility is classified within SIC code 4953 or another covered SIC code and meets the employee requirement, the facility would be required to consider its chemical management practices for purposes of EPCRA Section 313 reporting. A facility's SIC code classification is not necessarily affected because it limits activities to facilities within the same company.