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[Archived] Question Number 34, 1998 EPCRA 313 Q&A: Corporate Employees; Employee Threshold

More recent version available at: Question Number 69, 2019 QA Consolidation: Employee Threshold.
Topic: Determining Whether or Not to Report: Facility >> B. Employee Threshold: Corporate Employees; Employee Threshold
34. A covered facility that is part of a larger corporate entity has corporate employees located on-site. These employees do not directly support the activities that are conducted at the facility where they are located; rather, their time is spent working for that facility as well as for other facilities that are part of the same corporate entity. Does the facility where these employees are located have to count the hours worked by these employees toward its employee threshold?
Yes. The facility where these employees are located should count the hours worked by them toward the facility's employee threshold, unless the facility's time keeping system allows it to track the time worked by these employees according to the actual facility for which they are working. If a facility can demonstrate through time keeping records that the time worked by these employees was in support of another facility within the same corporate entity, then it does not have to count the hours worked by these employees towards its own employee threshold. The facility that these employees directly support would have to count the hours toward its employee threshold.

Additional Details

ID 11597; 98-034 Status Archived
Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) Question # 34
Topic Determining Whether or Not to Report: Facility Sub-topic B. Employee Threshold
Keyword(s) Corporate Employees; Employee Threshold
Updated Entry More recent version available at: Question Number 69, 2019 QA Consolidation: Employee Threshold.
Revision
History
Prior Source: [Archived] Question Number 23, 1998 Newly Added Industries: Employee Threshold; Facility. Addendum means that the source of the 1998 Q"A is the Addendum to the Guidance Documents for the Newly Added Industries (EPA 745-B-98-001).

Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer.

Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.
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