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Question Number: 31, 1998 EPCRA 313 Q&A: Employee Threshold; Off-Site Employees

31. Facility A manufactures and sells machinery. Facility A sends employees to customers’ sites to repair and service the machinery. These employees are not based at Facility A. For example, some of the employees pick up company vehicles and needed supplies from rented property before going to the clients site. Facility A also has employees who work directly for the facility, but work entirely from their homes. Should Facility A consider hours worked by these employees in making the employee threshold determination?
Yes. If an individual is employed by a covered facility and works for the covered facility, then all hours worked by that individual must be counted towards the 20,000 hour employee limit, regardless of where the employee works (i.e., on-site or off-site).