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Question Number: 30, 1998 EPCRA 313 Q&A: Employee Threshold; Truck Drivers

30.A facility employs drivers to pick up and deliver its products. Some of the drivers use the facility's trucks, while other drivers use trucks not owned by the facility. Should the facility count all driver hours towards its employee threshold, regardless of whose trucks the drivers use?
Yes. Hours worked directly for the facility by drivers that are employed by the facility are counted, regardless of whose truck they use.