Administrative buildings at a military base are cleaned daily using cleaning materials that contain EPCRA section 313 chemicals. Can the facility claim the routine janitorial or facility grounds maintenance exemption for EPCRA section 313 chemicals used in these activities?
The routine janitorial or facility grounds maintenance exemption is applicable to non-process-related activities. Cleaning administrative offices is a non-process-related activity. The EPCRA section 313 chemicals used to clean the administrative offices at the federal facility are exempt from threshold determinations and release and other waste management calculations under the routine janitorial or facility grounds maintenance exemption. Additional guidance regarding federal facilities can be found in the EPCRA Section 313 Questions and Answers Addendum for Federal Facilities.