Item 3: Ordinance Adopting Hazardous Substance Tracking Instructions

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Attachment B. 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 exemption? 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 or grind on our bread mixer, bulk flour silo, or bread oven. Would the fumes and grindings be reportable? ANSWER: If grinding and welding are needed on manufacturing equipment in order to allow it to continue to function properly, then materials used in that type of equipment maintenance are reportable, assuming they meet reporting thresholds. However, materials used in similar maintenance on non-manufacturing-related equipment or structural members are not reportable. 33.QUESTION: If I use a detergent with a reportable chemical in it to clean the exterior side of the oven panels, is this facility maintenance? It does not affect the operation of the oven. What about chemicals used to wash the outside of the mixers? ANSWER: These applications are not integral to manufacturing, and so the substances used would not be reportable. 34.QUESTION: Would there be a distinction between chemicals used for cosmetic purposes and those that are needed for the manufacturing process? For example, we use reportable chemicals to clean our yeast system (interior), and this is clearly not facility maintenance, but what about cleaning the outside of the tank and the general area? Isn't that facility maintenance or facility cleaning (janitorial)? ANSWER: There is such a distinction, as noted above. Businesses should use their best engineering judgment, available data, or actual measurements to calculate amounts used to facilitate the manufacturing process, and report those amounts. 35.QUESTION: We have a kerosene-operated hot-water pressure washer. It is used to steam-clean a number of items, such as bread troughs, the shipping and proofing racks, - 64-