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[Not Current] Question Number: 2, 1998 EPCRA 313 Q&A: Alternate Threshold; Form A; Form R; Reporting Criteria; Zinc

2. Is a facility which meets the employee and toxic chemical activity thresholds and is in a covered SIC code, as described in question one, required to report if it had no releases of the toxic chemical during the reporting year?
Yes, even if it releases no toxic chemicals into the environment and does not conduct any other waste management activities involving the listed toxic chemical, the facility must submit either the Form R or Form A (Alternate Threshold Certification Statement). If the facility meets the employee and chemical activity thresholds and is in a covered SIC code, but its annual reportable amount of the toxic chemical does not exceed 500 pounds and the facility has not manufactured, processed, or otherwise used more than one million pounds of the toxic chemical, the facility may submit the Form A (a two-page certification statement) instead of the Form R. However, if the facility exceeds either the 500 or one million pound limits, it must report on the Form R. (See Section 5A of this document on Alternate Threshold Reporting.)