Frequent Questions

Multiple activities within the same threshold activity

How does a facility consider multiple activities within the same threshold activity, such as multiple repackaging steps, or blending followed by repackaging?

Amounts of a listed toxic chemical undergoing multiple activities on-site within a single threshold activity are counted only once during the activity sequence. For example, if a facility receives a bulk quantity of a chemical that it then places in a storage container from which amounts are subsequently blended and placed in smaller containers that are sold, the facility has prepared for distribution in commerce the entire amount of the chemical, and therefore, the facility has processed the entire amount of the listed toxic chemical. Additional information on packaging and processing thresholds can be found in the Revised 1998 EPCRA Section 313 Questions and Answers Document.

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