A facility whose NAICS code is outside the covered NAICS codes believes that their current NAICS code is misrepresentative of the facility's activities. In actuality, the facility may be better represented by an NAICS code within the covered NAICS codes. If the facility changes its NAICS code to a covered group, should they back report for previous reporting years under EPCRA Section 313?
If the facility has not altered its operations and should have been classified in a covered NAICS code and has met the threshold and employee criteria, it is required to report for all the previous years under EPCRA Section 313. If the mix of activities at the facility shifted from non-covered to covered NAICS codes, then it should begin reporting for the year in which the change occurred. Additional guidance on reporting materials and guidance can be found on the TRI Web site.