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ANSWER: Substances used to maintain racks, carts, etc., that transport articles PRIOR <br />TO OR DURING manufacture are reportable. Substances used to maintain racks, carts, <br />etc., that transport FINISHED PRODUCTS ONLY are not reportable, because these <br />racks, carts, etc., are not being used in the manufacturing process. <br />31. QUESTION: Would a forklift that is used to transport product for further processing be <br />considered part of the manufacturing process like a process conveyor, or would any <br />hazardous chemicals used in its maintenance be exempt under a motor vehicle <br />exemption? <br />ANSWER: Materials used to maintain or operate mobile motorized vehicles used in <br />manufacturing are exempt from reporting. <br />32. QUESTION: What about welding or grinding on equipment? For example, we grind and <br />weld on a hunk of steel to make a bump guard to protect the wall. Would this be <br />reportable because it would be facility maintenance? On the other hand, we might weld <br />or grind on our bread mixer, bulk flour silo, or bread oven. Would the fumes and <br />grindings be reportable? <br />ANSWER: If grinding and welding are needed on manufacturing equipment in order to <br />allow it to continue to function properly, then materials used in that type of equipment <br />maintenance are reportable, assuming they meet reporting thresholds. However, materials <br />used in similar maintenance on non - manufacturing - related equipment or structural <br />members are not reportable. <br />33. QUESTION: If I use a detergent with a reportable chemical in it to clean the exterior <br />side of the oven panels, is this facility maintenance? It does not affect the operation of the <br />oven. What about chemicals used to wash the outside of the mixers? <br />ANSWER: These applications are not integral to manufacturing, and so the substances <br />used would not be reportable. <br />34. QUESTION: Would there be a distinction between chemicals used for cosmetic <br />purposes and those that are needed for the manufacturing process? For example, we use <br />reportable chemicals to clean our yeast system (interior), and this is clearly not facility <br />maintenance, but what about cleaning the outside of the tank and the general area? Isn't <br />that facility maintenance or facility cleaning (janitorial)? <br />ANSWER: There is such a distinction, as noted above. Businesses should use their best <br />engineering judgment, available data, or actual measurements to calculate amounts used <br />to facilitate the manufacturing process, and report those amounts. <br />35. QUESTION: We have a kerosene - operated hot -water pressure washer. It is used to <br />steam -clean a number of items, such as bread troughs, the shipping and proofing racks, <br />