Are hazardous chemicals used in equipment, such as an animal carcass digestor or incinerator, located on the grounds of a medical or veterinary facility exempt from the definition of hazardous chemical and, therefore, exempt from reporting under EPCRA Sections 311 and 312?

Any substance to the extent it is used in a research laboratory or a hospital or other medical facility (e.g., veterinary facility) under the direct supervision of a technically qualified individual is exempt from the definition of hazardous chemical in 40 CFR Part 370. The definition of facility includes all buildings, equipment, structures, and other stationary items that are located on a single site or on contiguous or adjacent sites and which are owned or operated by the same person. Therefore, if equipment on the grounds of a medical or veterinary facility is used for medical purposes, and its administration is carried out under the direct supervision of medical professionals (e.g., doctors, veterinarians), it is exempt from reporting under EPCRA Sections 311 and 312.