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[Archived] Question Number 23, 1998 Newly Added Industries: Employee Threshold; Facility

More recent version available at: [Archived] Question Number 34, 1998 EPCRA 313 Q&A: Corporate Employees; Employee Threshold.
23. 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 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 its 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 were 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, it does not have to count the hours worked by these employees towards its employee threshold. The facility which these employees directly support would have to count the hours toward its employee threshold.

Additional Details

ID 12519; nai-023 Status Archived
Source 1998 Addendum for the Newly Added Industries Question # 23
Topic Sub-topic
Keyword(s) Employee Threshold; Facility