Item 3: Ordinance Adopting Hazardous Substance Tracking Instructions

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Attachment B. D. MANUFACTURING vs. MAINTENANCE USES General guidelines: Hazardous substances that are on a site, but whose use is not directly related to manufacturing or related research and development, are not reportable. This area is subject to considerable interpretation, mostly concerning maintenance and operation of equipment. In general, the Toxics Board has drawn a distinction between substances used for cosmetic purposes (not reportable) and those used for necessary maintenance (reportable); and between the maintenance of actual manufacturing equipment (reportable) and equipment with non-manufacturing purposes (not reportable). The Toxics Board has also drawn a distinction between materials used to maintain and operate motorized vehicles (e.g., forklifts) and those used to operate and maintain non-motorized vehicles (e.g., carts). Materials in the former category are not reportable, while those in the latter are. 27. QUESTION: A listed toxic chemical is used to clean a process-related tower at a manufacturing facility. Is the use of the chemical exempt from threshold and materials accounting 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 exemption does not apply. This exemption only applies to the use of products that are specifically used for routine janitorial, facility grounds maintenance, building maintenance, and office supplies. 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 dont 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? - 63-