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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).
33. Does Facility A need to include in its employee threshold (10 FTE/20,000 hours) determination sales representatives that work for Facility A but are never/rarely physically working at Facility A?

Yes. For purposes of determining the EPCRA Section 313 employee threshold, employee hours for employees that directly support the facility, should be included in the employee calculation for the facility. Therefore, if the hours spent by sales staff directly support a facility, then their hours should be allocated to the facility they directly support, regardless of the amount of time those employees are physically at the facility.