The number of full-time employees is dependent only upon the total number of hours worked by all employees and other individuals (e.g., contractors) for the facility during the calendar year and not the number of persons working. Therefore, a full-time employee, for purposes of reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), is defined as working 2,000 hours per year.

When making the full-time employee determination, the facility must consider all paid vacation and sick leave used as hours worked by each employee. In addition, the Environmental Protection Agency (EPA) interprets the hours worked by an employee to include paid holidays.

To determine the number of full-time employees working for the facility, add up the hours worked by all employees during the calendar year, including contract employees and sales and support staff, and divide the total by 2,000 hours. The result is the number of full-time employees. In other words, if the total number of hours worked by all employees for the facility is 20,000 hours or more, the facility meets the ten-employee threshold.

Here are two examples:

• A facility consists of 11 employees who each worked 1,500 hours for the facility in a calendar year. Consequently, the total number of hours worked by all employees for the facility during the calendar year is 16,500 hours. The number of full-time employees for this facility is equal to 16,500 hours divided by 2,000 hours per full-time employee, or 8.3 full-time employees. Therefore, even though 11 persons worked for this facility during the calendar year, the number of hours worked is equivalent to 8.3 full-time employees. This facility does not meet the employee criterion and is not subject to EPCRA 313 reporting.
• Another facility consists of six workers and three sales staff. The six workers each worked 2,000 hours for the facility during the calendar year. The sales staff also each worked 2,000 hours during the calendar year; although, they may have been on the road half of the year. In addition, five contract employees were hired for a period during which each worked 400 hours for the facility. The total number of hours is equal to the time worked by the workers (12,000 hours), plus the time worked by the sales staff for the facility (6,000 hours), plus the time worked by the contract employees (2,000 hours), or 20,000 hours. Dividing the 20,000 hours by 2,000 yields 10 full-time employees. This facility has met the full-time employee criterion and may be subject to reporting if the other criteria are met.