A federal agency's facility is operated by a contractor. There are 9 employees working at this GOCO facility. The federal agency has employees who oversee the activities of the facility, but who are not physically located at the facility. When making the full-time employee determinations, must the facility consider the hours worked by these off-site federal employees?
Yes. The hours worked by federal employees directly in support of the activities of a facility must be counted towards the 20,000 hour employee threshold, regardless of the location of the federal employees (i.e., at the federal facility or off-site). Additional information on federal facilities can be found in the EPCRA Section 313 Questions and Answers Addendum for Federal Facilities.