Is FDA regulated flour bleaching exempt?

A facility owner/operator uses chlorine to bleach flour at his/her facility.  Would this facility owner/operator be exempt from reporting the chlorine used to bleach flour under EPCRA Section 311/312?

EPCRA Section 311 (e)(1) exempts any food, food additive, drug, or cosmetic regulated by the Food and Drug Administration (FDA).  EPA considers a substance to be regulated by the FDA as long as the substance is used in a manner which is consistent with the FDA regulations.  FDA regulations (21 CFR part 137) regulate the bleaching of flour with chlorine.  Chlorine, therefore is exempt from reporting under EPCRA Sections 311/312 when its use at a facility is consistent with this FDA regulation (i.e., the bleaching of flour). However, if the facility uses part of the chlorine stored on-site for other purposes, such as waste water treatment or for cleaning process equipment, then that amount of chlorine should be considered for threshold determination.