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Question Number: 38, 1998 EPCRA 313 Q&A: Contractors; Employee Threshold

38. A facility employs several contractors for various types of work, on-and off-site. Which contractors should the facility consider in its employee threshold determination?
The facility must include maintenance contractors, such as those for general building structure maintenance, process equipment maintenance, and lawn care, in its employee threshold determination. Major contractors for services such as tank building/wrecking and tank painting are also included in the employee threshold. The facility should not include hours worked by minor on-site intermittent service vendors such as trash haulers, vending machine servicers, and service repair persons for utility-owned equipment that are not employed by the covered facility.