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<br />n <br /> <br />n <br /> <br />or grind on our bread mixer, bulk flour silo, or bread oven. Would the fumes and grind- <br />ings be reportable? <br /> <br />fl <br />II <br /> <br />rl' <br />1 <br /> <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, materi- <br />als used in similar maintenance on non-manufacturing-related equipment or structural <br />members are not reportable. <br /> <br />11 <br /> <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 <br />the oven. What about chemicals used to wash the outside of the mixers? <br /> <br />! <br /> <br />ANSWER: These applications are not integral to manufacturing, and so the substances <br />used would not be reportable. <br /> <br />, J <br /> <br />34. QUESTION: Would there be a distinction between chemicals used for cosmetic pur- <br />poses 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 Ganitorial)? <br /> <br />f l <br /> <br />~- <br /> <br />"! l <br /> <br />., I <br /> <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 /> <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 />pieces of manufacturing equipment, and non-manufacturing-related cleaning. Would the <br />kerosene used to fuel the steam cleaner be reportable? <br /> <br />ANSWER: In this instance, because kerosene is a characteristic (ignitable) substance, it <br />would be necessary for the business to calculate and report amounts used for purposes <br />directly related to the manufacturing process. <br /> <br />36. QUESTION: At the beginning of the year, we have on hand 1,000 pounds ofa cleanser <br />containing 10 percent ammonia (a reportable substance). Our best engineering judgment <br />indicates that we use 30 percent of the cleanser on cleaning related to manufacturing, and <br />the other on janitorial or cosmetic cleaning. All of the cleanser that we use is ultimately <br />washed down the drain and into the sanitary sewer system. During the year, we purchase <br />an additional 1 ,000 pounds of the same cleanser. At the end of the year, we have 500 <br />pounds of cleanser still on hand. What inputs and outputs of ammonia should we report? <br /> <br />ANSWER: Report only the ammonia used for manufacturing-related purposes. Inputs <br />would be: <br /> <br />F-l1 <br />