Ordinance No. 20222 - Laserfiche WebLink

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If 'f" 27. QUESTION: A listed toxic chemical is used to clean a process-related tower at a manu- facturing facility. Is the use of the chemical exempt from threshold and materials account- ing calculations under the routine janitorial and facility grounds maintenance exemption? ANSWER: No. Materials used to maintain process-related equipment at a facility (e.g., cleaners and lubricants) are not exempt. Because the tower is process-related, the exemp- tion does not apply., This exemption only applies to the use of products that are specifi- cally used for routine janitorial, facility grounds maintenance, building maintenance, and office supplies. if r 28. QUESTION: Would lubrication of bearings on product mixing machines (assuming the lubricants had a reportable chemical) be considered part of the manufacturing process and therefore reportable? ANSWER: Yes. 29. QUESTION: We paint and sometimes don't paint our equipment. It is not necessary to the functioning or maintenance of the machine, but is more cosmetic in purpose. Would the paint used be reportable or would that come under facility maintenance? ANSWER: Substances not used in the manufacturing process, or to perpetuate the manufacturing process, are not reportable. Therefore paints used for cosmetic purposes, even on manufacturing equipment, are not reportable. 30. QUESTION: Would lubricating the wheel bearings on transport racks that carry the finished product to another part of the facility for shipping be reportable? What about lubrication of bearings on racks that do not contain finished product, such as proofing racks? ANSWER: Substances used to maintain racks, carts, etc., that transport articles PRIOR TO OR DURING manufacture are reportable. Substances used to maintain racks, carts, etc., that transport FINISHED PRODUCTS ONLY are not reportable, because these racks, carts, etc., are not being used in the manufacturing process. 31. QUESTION: Would a forklift that is used to transport product for further processing be considered part of the manufacturing process like a process conveyor, or would any hazardous chemicals used in its maintenance be exempt under a motor vehicle exemp- tion? ANSWER: Materials used to maintain or operate mobile motorized vehicles used in manufacturing are exempt from reporting. 32. QUESTION: What about welding or grinding on equipment? For example, we grind and weld on a hunk of steel to make a bump guard to protect the wall. Would this be reportable because it would be facility maintenance? On the other hand, we might weld F-I0