A covered facility is comprised of several establishments. None of the establishments meet a chemical activity threshold separately, but together, the facility exceeds a chemical activity threshold. Since no single establishment exceeds the reporting quantities, is it necessary for the facility to file a Form R?
The covered facility, not the establishments, must report if the facility meets all of the reporting criteria. The threshold determination for manufacture, process, or otherwise use of the listed chemical must be made by adding the amounts of the chemical from appropriate activities of all the facility's establishments. Additional information on facility determinations can be found in the Toxic Release Inventory Reporting Forms and Instructions and the Revised 1998 EPCRA Section 313 Questions and Answers Document.