Is an animal refuge exempt from 311 and 312?

An animal refuge sprays herbicides and pesticides on its grounds to better the quality of the area for the animal inhabitants.  Is the spraying of these pesticides exempt from the requirements of Sections 311 and 312 of Title III under the exception to the definition of "hazardous chemical" for any substance to the extent it is used in routine agricultural operations?

The exemption for routine agricultural use under Sections 311 and 312 is designed to eliminate the reporting of fertilizers, pesticides, and other chemical substances when applied, administered, or otherwise used as part of routine agricultural activities (October 15, 1987, 52 FR 38344).  The term “agricultural” is a broad term encompassing a wide range of growing operations, farms, nurseries and other horticultural operations (52 FR 38344).  The spraying of chemicals on the grounds of the animal refuge is not considered part of routine agricultural activity.  Therefore, this activity is not exempted under sections 311 and 312 reporting.