United States
Environmental Protection
Agency
Office of Prevention
Pesticides and
Toxic Substances (7407)
EPA 749-B-98-001
June 1998
&EPA Instructions for Reporting for the
1998 Partial Updating of the
TSCA Chemical Inventory Data Base
EPA REGION VII IRC
101812
U.S. Environmental Protection Agency
Region VII
Information Resource Center
901 N. 5th Street
Kansas City, KS 66101
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Instructions for Reporting
for the 1998 Partial Updating of the
TSCA Chemical Inventory Data Base
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
Washington, DC 20460
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HIGHLIGHTS OF THE 1998 IUR COLLECTION
The reporting period is from August 25, 1998 to December 23, 1998.
There are no substantive changes in the information required for the 1998 IUR reporting as compared
to the 1994 collection.
Manufacturers of TSCA Inventory chemical substances manufactured solely for export, which are not
otherwise exempt from reporting, have an obligation to comply with all IUR reporting requirements.
An appendix to the instructions, Appendix A, lists chemical substances which: are subject to a rule,
proposed or promulgated under TSCA sections 4, 5(a)(2), 5(b)(4), and 6; are subject to an order issued
under section 5(e) and 5(f); or are the subject of relief that has been granted under a civil action under
sections 5 or 7 of the Act. This list has been updated to include recent regulatory actions. All substances
on this list are subject to IUR reporting.
A current version of the non-confidential TSCA Inventory has been prepared in diskette and computer
tape formats. The printed and electronic versions of the Inventory are available from the National
Technical Information Service. (1-800-553-NTIS)
Use the Correction/Continuation Form 7740-C when submitting a correction or submitting continued
information.
Companies are encouraged to report to EPA using the 1998 IUR Electronic Form. The Flat
ASCII Files used in 1994 are not acceptable. There is no minimum number of chemical
substances required for electronic reporting.
Appendix B contains instructions for Electronic Form submissions.
For questions concerning IUR reporting or to request additional forms, contact the TSCA Hotline,
Monday through Friday, 8:30 am to 5:00 pm, East Coast time at (202) 554-1404.
The 1998 Instruction Manual and Form U can be obtained on the Internet. The 1998 IUR Internet
Address is: http://www.epa.gov/opptintr/iur98.
The 1998 Form U is available via FAX ON DEMAND. Call (202) 401-0527; Item: 5119.
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Table of Contents
I. INTRODUCTION 1
II. DETERMINING THE SUBSTANCES FOR WHICH YOU MUST REPORT 2
A. Reportable substances 2
1. Inventory substances 2
2. How to determine whether a chemical substance is listed on the
Inventory 3
3. Excluded substances 5
a. Determining whether a substance is excluded 5
b. When an excluded substance must still be reported 6
B. Determining whether you are a manufacturer or importer who is required
to report a substance 6
1. Manufacture or import of 10,000 pounds or more 6
a. Manufacturers and Importers 6
b. Meeting the 10,000 pound annual production volume
threshold 7
2. Small Manufacturers 7
3. Additional reporting exemptions 8
C. Decision making flow chart 9
D. Manufacture or importation of chemical substances subject to TSCA but
not included on the Inventory 11
III. WHEN YOU MUST REPORT 12
A. You must report during the 120-day reporting period 12
B. Determine annual production using the reporting period as a reference
point 12
IV. HOW TO REPORT 13
A. Form of submission 13
B. Confidentiality 13
C. Completing Form U 15
1. Report only using original copies of Form U 15
2. Certification Statement 15
a. Signature 15
b. Date 15
c. Name and Title 15
3. Technical Contact and Company Information 15
a. Technical Contact Name 15
b. Company Name, Address Line I, Address Line II,
Telephone Number 15
c. CBI 15
4. Plant Site Information 16
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a. Dun & Bradstreet Number 16
b. Address 16
5. Chemical Substance Identity/Activity/Confidentiality 16
a. Line Number 16
b. CAS Registry or Other Identifying Number 16
(1) EPA Accession Number 19
(2) Original Inventory Report Number 19
(3) Premanufacture Notice Number 19
(4) Bona Fide Request Control Number 20
(5) Test Market Exemption Application Number 20
c. A, B, C, F, P, or T Codes 21
d. Specific Chemical Name 21
e. Activity: Manufacture or Import 22
f. Site Limited 22
g. Production Volume 23
h. Plant site and Chemical CBI Claims 23
(1) Plant site CBI claim 23
(2) Chemical identity CBI claim 23
D. Reporting by diskette 23
1. General 23
2. Copies of Form U required 23
3. Diskette formats and physical characteristics 23
E. Sending forms and diskettes to EPA 24
F. Correcting errors in submissions for the original Inventory 24
G. Record keeping requirements 25
H. Special instructions for importers and foreign suppliers 25
V. OBTAINING COPIES OF DOCUMENTS CITED IN THESE INSTRUCTIONS . . 27
A. Obtaining copies of TSCA regulations 27
B. Obtaining copies of the Public Inventory 27
1. Obtaining copies of the printed editions of the Public Inventory 27
2. Obtaining the Public Inventory in computer-readable form 27
C. Obtaining copies of Form U 28
VI. REQUESTING ASSISTANCE IN REPORTING 29
Appendix A - Chemical Substances Subject to Proposed or Final TSCA Rules or Orders ... A-l
Appendix B - Instructions for Submitting IUR Reports on Magnetic Media B-l
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INSTRUCTIONS FOR REPORTING FOR THE PARTIAL UPDATING
OF THE TSCA CHEMICAL INVENTORY DATA BASE
(INVENTORY UPDATE RULE)
I. INTRODUCTION
The Environmental Protection Agency (EPA) in 1986 promulgated a rule, often referred to
as the Inventory Update Rule, for the partial updating of the TSCA Chemical Inventory data base.
The rule requires manufacturers and importers of selected chemical substances included on the TSCA
Chemical Substance Inventory to report current data on the production volume, plant site, and site-
limited status of these substances. The rule was promulgated under the authority of section 8(a) of
the Toxic Substances Control Act (TSCA), and is codified in Subpart B of Part 710 of Title 40 of the
Code of Federal Regulations (40 CFR Part 710).
Reporting under the Inventory Update Rule takes place at four-year intervals which began in
1986. These instructions pertain to reporting during 1998.
This booklet provides detailed instructions and examples to assist manufacturers and
importers in reporting under the Inventory Update Rule. These instructions, however, are not a
substitute for the rule. Manufacturers and importers of chemical substances should carefully review
the Inventory Update Rule to determine whether they are subject to its reporting requirements and
what information is to be reported.
Persons reporting under the Inventory Update Rule should have a thorough understanding
of the scope and organization of the TSCA Chemical Substance Inventory and of the criteria used
to determine whether a substance belongs on the Inventory. Information on the scope and
organization of the Inventory can be found in the introductory pages of the 1985 edition of the
Inventory and in the 1990 Supplement to the Inventory. Subpart A of 40 CFR Part 710 prescribes
criteria for inclusion of a substance on the Inventory.
See Section V (page 27) for instructions on how to obtain copies of the Inventory and of
TSCA regulations.
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II. DETERMINING THE SUBSTANCES FOR WHICH YOU MUST REPORT
To ascertain your reporting obligations, you must make two determinations for each chemical
substance that you manufacture in the United States or import into the United States:
1) Is the substance reportable under the Inventory Update Rule?
2) Are you a manufacturer, importer, or exporter who is required to report that
substance?
A. Reportable substances.
To be reportable under the Inventory Update Rule, a chemical substance must meet two
requirements:
1) The substance must be on the TSCA Chemical Substance Inventory as of August 25,
1998; and
2) The substance must not be of a type exempt from reporting under the Inventory
Update Rule.
1. Inventory substances. The TSCA Chemical Substance Inventory is a list of chemical substances
distributed in commerce in the United States. The Inventory was originally compiled from reports
submitted by manufacturers, importers and certain processors in 1978 and 1979. New chemical
substances are added to the Inventory when companies who have submitted Premanufacture
Notifications (PMNs) or Polymer Exemption Applications to EPA under section 5 of TSCA notify
the Agency that manufacture or import of the chemical substance has commenced.
EPA keeps a Master Inventory File, which is the authoritative list of all the eligible chemical
substances which have been reported to EPA for inclusion in the Inventory. EPA also makes
available both in printed and computer-readable form a public version of the Inventory, referred to
as the Public Inventory. The Public Inventory does not contain the specific identities of chemical
substances whose identities have been claimed as confidential business information (CBI). The
printed version of the Public Inventory does contain generic chemical names for these CBI chemical
substances. However, the computer-readable version does not. The Public Inventory has been
updated several times both in print and computer-readable form. The most complete edition of the
printed version of the Public Inventory was published in 1985, and a 1990 supplement to the 1985
edition is also available. The computer-readable version of the Public Inventory is being updated
biannually. Additionally, EPA will also be making available to the public a PC readable version before
the commencement of the reporting period, as referenced in the Federal Register
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announcement for the reporting period. See Section V of these instructions (page 27) for information
on obtaining copies of the Public Inventory.
2. How to determine whether a chemical substance is listed on the Inventory. Many
companies have already determined that the substances they manufacture or import are on the
Inventory. You may have been able to make such a determination if:
1) you have located the substance in the Public Inventory;
2) you reported the substance to EPA under the Inventory reporting rule in 1978 or
1979 or as an Inventory correction;
3) in response to a PMN, Test Market Exemption Application, bona fide request, or
other communication the Agency has informed you that the substance is on the
Inventory; or
4) you have submitted a Notice of Commencement of manufacture or import for a PMN
substance.
If you do not already know whether a substance you manufacture or import is on the
Inventory, you should consult a copy of the latest public version of the Inventory (see Section V,
below, for instructions on how to obtain a copy). The Public Inventory provides detailed information
on the organization of the Inventory and on how substances are named and listed.
Several commercial databases have incorporated the public version of the Inventory (which
does not include substances with confidential identities) and indicate whether a given chemical
substance is included on the Inventory. EPA can guarantee neither the currency nor the accuracy of
the information on these databases; however, there is no penalty for reporting a substance which is
not required to be reported.
If at this point you know that your substance is on the Inventory, you may proceed to Section
II.A.2. (page 3) to determine whether it is of a type exempt from reporting under the Inventory
Update Rule.
If after having checked the above sources you are still uncertain as to whether a chemical
substance is listed on the Inventory, you should write to EPA at the following address:
OPPT Document Control Officer
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
401 M Street, S.W.
Washington, DC 20460
ATTN: Inventory Update Rule/Bonafide
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Your letter should request that EPA search the Master Inventory File, including confidential
substances, to determine whether the substance is listed. You must substantiate the fact that you are
actually manufacturing or importing the substance in question by providing the following information:
1) company identification, address, and telephone number;
2) the specific chemical identity of the substance, preferably a Chemical Abstracts
Service Preferred or Index Name, a Chemical Abstracts Service Registry Number (if
available), and a structural diagram (if available);
3) a statement signed by a company officer that your company is manufacturing and/or
importing the chemical substance for commercial purposes;
4) a statement signed by a company officer that your company is requesting this search
pursuant to the Inventory Update Rule; and
5) an elemental analysis of the substance.
You may claim information in your letter as confidential by circling or bracketing the text to
be protected and marking "CONFIDENTIAL" on each page containing confidential information.
Failure to so mark this information may result in EPA making the information available to the public
without further notice to you.
Note that this procedure is similar but not identical to EPA's bona fide procedure codified in
40 CFR §710.7(g) and §720.25(b). If you intend to, but do not currently manufacture or import a
substance for commercial purposes and need a search of the Master Inventory File, you must follow
the procedures codified in those sections.
EPA's response will inform the manufacturer or importer whether the chemical substance is
on the Inventory and whether the substance is subject to reporting under the Inventory Update Rule.
If the chemical substance is found on the confidential Inventory, EPA will notify the person(s)
who originally reported the substance that another person has requested information pursuant to the
Inventory Update Rule procedures, and therefore was told that the chemical substance is on the
Inventory and that it is subject to reporting.
If you are an importer and cannot provide all of the required information because your foreign
manufacturer/supplier is maintaining it as confidential, the manufacturer/supplier can send the
information directly to EPA. Be advised that it is the obligation of the importer to insure that the
foreign manufacturer complies with the requirements of the IUR.
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Because searches of the Master Inventory File require a considerable amount of time to
process, you are urged to request such a search only if your search of the public version of the
Inventory, commercial databases, and your company's records fails to resolve your question.
Moreover, if your request is not received prior to October 25, 1998, EPA cannot guarantee that you
will receive a response in time for you to complete the reporting form before the end of the reporting
period.
3. Excluded substances. Four categories of substances, though included on the
Inventory, are largely excluded from reporting under the Inventory Update Rule. These categories
are polymers, inorganic substances, microorganisms, and naturally occurring substances. Refer to
section 710.26 of the Inventory Update Rule and to the preamble of the Federal Register notice
announcing the rule (51 FR 21438) for precise definitions of these categories.
The Inventory Update Rule definition of polymer is sufficiently broad to include virtually all
those substances that are generally considered polymers. These include polysaccharides such as agar
and gums, and all classes of proteins, enzymatic or structural. However, substances which result from
hydrolysis, depolymerization, or chemical modification of polymers such that the final products are
no longer polymeric (e.g., a mixture of amino acids which is the result of hydrolysis of a polypeptide)
are not considered to be polymers, and must be reported if not otherwise excluded. For reporting
purposes, salts of polymers are also considered to be polymers.
a. Determining whether a substance is excluded. To assist in identification of excluded
substances, most of these substances are labeled in the printed and computer-readable versions of the
Inventory with an "XU" flag. The "XU" flag should not be considered conclusive for purposes of
reporting. If there is a question about reportability, please contact the TSCA Hotline at (202) 554-
1404 for assistance.
Please note that a few of the polymerization gases which are not considered to be polymers
might have been incorrectly flagged because of the inclusion of the word "polymer" in the chemical
name. These substances are nevertheless reportable under the IUR.
Submitters are advised to utilize the flag only as a guide: submitters will be responsible for
verifying exemptions. If a substance does not bear an XU flag and section 710.26 of the
Inventory Update Rule does not provide sufficient guidance to determine whether the
substance is excluded, you may request assistance from EPA (see Section VI, below, for
inquiries). In addition, the following substances, though not flagged with the XU designation,
nonetheless belong to a category excluded from Inventory Update Rule reporting:
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Name CAS Registry Number
Carbon black 1333-86-4
Carbon 7440-44-0
Graphite 7782-42-5
Charcoal 16291-96-6
b. When an excluded substance must still be reported. With the exception of naturally
occurring substances, a chemical substance which falls into one of the excluded categories must still
be reported if it is the subject of a rule proposed or promulgated under section 4, 5(a)(2), 5(b)(4),
or 6 of TSCA, of an order issued under section 5(e) or 5(f), or of relief which has been granted under
a civil action under section 5 or 7. A list of all substances which fall into one of these categories is
contained in Appendix A at the back of these instructions. However, if you are unable to determine
whether the specific chemical substance you manufacture falls within one of the generic chemical
names listed in the appendix, you may ask EPA whether the specific substance is reportable by
following the procedures outlined on page 3 of this manual.
B. Determining whether you are a manufacturer or importer who is required to report a
substance.
Even if you manufacture or import a substance reportable under the Inventory Update Rule
you may be exempt from the reporting requirements for that substance. Questions relevant to
whether you must report include:
1) Did you manufacture or import 10,000 pounds (4,540 kilograms) or more of the
reportable substance at any single site during the corporate fiscal year immediately
preceding the reporting period?
2) Do you qualify as a small manufacturer with respect to the substance?
3) Did you manufacture or import the reportable substance under circumstances which
do not require reporting?
1. Manufacture or import of 10.000 pounds or more.
a. Manufacturers and Importers. Reporting for the Inventory Update Rule is done by
individual site of manufacture or by the organizational site which controls importation. For the
purposes of the following discussion, manufacturers and importers are treated separately.
Manufacturers. A manufacturer is defined at 40 CFR §704.3. The word "manufacture" is
defined at 40 CFR section 710.2(o) and also at 40 CFR section 704.3.
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Importers. The site of importation is defined in section 710.28© of the Inventory Update
Rule as the site of the operating unit which is directly responsible for importing the substance and
which controls the import transaction. In some cases this may be the site of your headquarters, in
others a specific plant site or a broker.
Importers under TSCA are defined in 40 CFR §704.3 and §710.2(1). Although for a given
substance that your company is importing at a given site more than one person may meet the criteria
in sections 704.3 and 710.2(1), only one should report.
Exporters. A manufacturer of an IUR reportable chemical substance manufactured solely for
export is required to report and otherwise comply with all IUR requirements applicable to
manufacturers of all IUR reportable chemicals.
b. Meeting the 10.000 pound annual production volume threshold.
Reporting is required for a chemical substance only if you manufactured or imported 10,000
pounds (4,540 kilograms) or more of the substance at any single site you owned or controlled during
the corporate fiscal year immediately preceding the reporting period (see Section III.B., below, for
more information about fiscal year). Moreover, if during the year you manufactured 10,000 Ibs. or
more of the substance at some sites and less than 10,000 Ibs. at other sites, you need to report the
substance only for those sites at which you manufactured or imported 10,000 Ibs. or more.
Companies that both manufacture and import the same substance. Such companies should
add the manufacturing and importation volume at each site (see above to determine site of
importation) to determine whether the 10,000 pound threshold has been met. For example, if you
manufacture 5,000 pounds of a reportable substance and import 6,000 pounds, you should report.
Substances in a mixture. Although mixtures as defined in 40 CFR §710.2(q) are not
reportable, the chemical substances of which a mixture is comprised are reportable. If you
manufacture the substances as part of a mixture, you must determine for each substance in the
mixture whether the production volume was over 10,000 pounds. Similarly, if you import a mixture
you must determine for each substance in the mixture whether its importation volume was 10,000
pounds or more. Note that a person who creates a mixture by combining existing substances without
a chemical reaction is not a manufacturer of those substances and therefore does not report those
substances under the Inventory Update Rule.
Record keeping requirement. Even if you manufacture/import less than 10,000 pounds of a
reportable substance at a site, you must maintain records documenting that fact (see Section IV.G.
below, page 25).
2. Small Manufacturers. (For the purposes of the following discussion, the term
"manufacturers" refers to both manufacturers and importers.) Small manufacturers are usually
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exempt from reporting under the Inventory Update Rule (but see below for a discussion of when
small manufacturers are not exempt). You qualify as a small manufacturer if you meet either one of
the following tests:
1) If your total annual sales, combined with those of your parent company, domestic or
foreign (if any), do not exceed $4 million, regardless of annual production volume you
qualify as a small manufacturer.
or
2) If your total annual sales, combined with those of your parent company, domestic or
foreign (if any), are less than $40 million, you qualify as a small manufacturer with
respect to a particular substance for those plant sites at which the annual production
volume of the substance does not exceed 100,000 Ibs. If the annual production
volume of the substance at any of your sites is over 100,000 Ibs., you are required to
report only for those sites. Note that it is possible to qualify as a small manufacturer
with respect to some substances and not others, or some plant sites and not others.
See 40 CFR §704.3 for a more complete discussion of the small manufacturer exemption.
When a small manufacturer must still report. Even if you qualify as a small manufacturer you
must still report if you produced 10,000 Ibs. or more of a reportable substance which is the subject
of (1) a rule proposed or promulgated under section 4, 5(b)(4), or 6 of TSCA, (2) an order under
section 5(e), or (3) relief granted under a civil action under section 5 or 7. A list of all substances
which fall into one of these categories is contained in Appendix A.
3. Additional reporting exemptions. Persons who manufacture or import reportable
substances under the following circumstances are not required to report for those substances under
the Inventory Update Rule:
1) The chemical substance is manufactured or imported solely in small quantities for
research and development.
2) The chemical substance is imported as part of an article.
3) The chemical substance is manufactured as an impurity, byproduct, or non-isolated
intermediate, or in a manner incidental to another operation or upon end use of
another substance or mixture, as described in 40 CFR §720.30(g) and (h) (see 48 Fed.
Reg. 21746, May 13, 1983).
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4) All the information required by the Inventory Update Rule was reported to EPA
pursuant to a rule under section 8(a) of TSCA between August 25, 1997 and August
24, 1998.
Articles. An article is defined in 40 CFR §710.2(f) as "a manufactured item (1) which is
formed to a specific shape or design during manufacture, (2) which has end use function(s) dependent
in whole or in part upon its shape or design during end use, and (3) which has either no change of
chemical composition during its end use or only those changes resulting in compositions which have
no commercial purpose separate from that of the article and that may occur as described in section
710.4(d)(5), except that fluids and particles are not considered articles regardless of shape or design."
EPA considers imported items as articles if they are manufactured in a specific shape or design
for a particular end use application, and this design is maintained as an essential feature in the finished
product. Thus, materials such as metal or plastic sheets, wire, coated fabric, rolled carpet, sheets of
plywood and other similar materials will be viewed as articles by EPA, even if, for example,
subsequent to import they are rolled or drawn thinner, cut, printed, laminated, or thermoformed, so
long as they meet the above criteria. Substances which are part of such articles are not subject to
reporting under the Inventory Update Rule.
If an item is manufactured in a particular shape for the purpose of shipping convenience and
the shape has no function in the end use, it would not be considered an article. Thus, chemical
substances which are part of items such as metal ingots, billets, and blooms are subject to reporting
under the Inventory Update Rule.
Duplicative reporting unnecessary. If between August 25, 1997 and August 24, 1998 you
submitted the information required by the Inventory Update Rule in response to another rule
promulgated under section 8(a) of TSCA (e.g. the Preliminary Assessment Information Rule, 40 CFR
§712, Subpart B, or the Comprehensive Assessment Information Rule, 40 CFR §704, Subpart D),
you are not required to report under the Inventory Update Rule for the same substance during 1998.
C. Decision making flow chart.
The following flow chart summarizes the questions which must be answered to determine
your reporting obligations for a particular substance. Detailed reporting obligations are discussed
throughout this Chapter.
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Decision Making Flow Chart for Reporting Under
the Inventory Update Rule
Is this substance listed on the
TSCA Chemical Inventory?
NO
YES
Is this substance a polymer, inorganic
substance, microorganism,
or naturally occurring?
NO
YES
Is this substance subject to a special
regulatory action under TSCA?
'\ YES
Did you manufacture or import
10,000 Ibs. or more per year
at a single site?
YES
Are you a small manufacturer
of this substance?
NO
i
YES
Is this substance subject to a special
regulatory action under TSCA?
YES
Did you manufacture or import the chemical
substance under circumstances for which
reporting is not required?
NO
You must report.
YES
NO
NO
You need not report.
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D. Manufacture or importation of chemical substances subject to TSCA but not included on the
Inventory.
When checking the chemical substances you manufacture or import against the TSCA
Chemical Substances Inventory you may discover that you are manufacturing or importing substances
which are not on the Inventory but which should have been reported to EPA and never were. Such
manufacture or importation is in violation of section 15 of TSCA and could subject you to
administrative or criminal penalties.
Note that hydrates are not listed on the Inventory. You are required to report the CAS
Registry number of the corresponding anhydrous form. Adjust the reported production volume to
exclude water.
If you are manufacturing or importing a substance which was previously on the Inventory but
which has subsequently been delisted, then you are in violation and must follow the directions below.
If you find that you have or may have manufactured or imported chemical substances in
violation of TSCA, you should contact the Agency at the following address:
Director
Toxics and Pesticides Enforcement Division
Office of Regulatory Enforcement (2245)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Information in your letter may be claimed as confidential by circling or bracketing the text to
be protected and marking the page, "CONFIDENTIAL." Failure to so mark this information may
result in EPA making the information available to the public without further notice to you.
Significant reductions in penalties are given for persons voluntarily disclosing violations.
Note, however, that continued manufacture or importation of such chemical substances remains
illegal even after you have contacted the Agency, until the requirements of TSCA have been met.
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III. WHEN YOU MUST REPORT
The Inventory Update Rule establishes reporting periods every four years. The first reporting
period was during 1986; the second was during 1990; the third period was during 1994; the fourth
period is during 1998. A reporting period serves two functions:
1) It is a 120-day period during which reports for the Inventory Update Rule must be
filed.
2) It is used to determine the applicable fiscal year for calculating annual production
volume.
A. You must report during the 120-day reporting period.
The next reporting period begins August 25, 1998 and ends December 23, 1998. All
submissions must be postmarked no later than December 23,1998. If you are required to report (see
Section II., page 2), failure to file your report during this period is a violation of section 15 of TSCA.
Persons requesting searches of the Master Inventory File (see Section H.A.2., page 2, 3) must
make their requests at least 60 days prior to the close of the reporting period. If you have made your
request in time you will be allowed 15 business days from the date of receipt of EPA's answer or until
the end of the reporting period, whichever is later, to submit the report for the substance which was
searched. Any other reports received after the end of the reporting period will be considered late and
will be subject to enforcement action.
B. Determine annual production using the reporting period as a reference point.
To determine whether you manufactured or imported 10,000 Ibs. or more of a reportable
substance at a site, you must determine your total manufacture/import volume for your last corporate
fiscal year which ends prior to August 25, 1998. For example, someone whose fiscal year is the
calendar year would determine manufacture or import volume for the period January 1, 1997 -
December 31, 1997, while someone whose fiscal year is July 1 to June 30 would determine
manufacture or import volume for the period July 1, 1997 to June 30, 1998.
Note that even though you may be exempt from reporting a chemical substance during one
reporting period because you manufactured or imported less than 10,000 Ibs. during the applicable
fiscal year, you may be required to report it during the next reporting period if during the next
applicable fiscal year the production volume increases to 10,000 Ibs. or more.
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IV. HOW TO REPORT
A. Form of submission.
Information reported for the Inventory Update Rule must be submitted by electronic means
or on a printed Form U. Separate forms are required for each plant site. (See subsections C., page
15 and D. Page 23).
B. Confidentiality.
Information submitted to EPA under the Inventory Update Rule may be claimed as
confidential business information (CBI) by checking the appropriate "CBI" boxes on Form U. Claims
of confidentiality will not be accepted and honored if they are not asserted at the time information is
submitted to EPA or submitted in a manner inconsistent with the rule and reporting instructions.
You may assert a CBI claim for the specific identity of a chemical substance only if EPA treats
that substance identity as confidential on the Inventory at the time your report is submitted (i.e., the
substance is not on the Public Inventory). Both confidential and non-confidential substances may be
reported on the same form, and confidential substances may be included in diskette submissions.
If you are manufacturing or importing a chemical substance which is currently listed on the
Inventory as confidential you are encouraged not to assert confidentiality claims if circumstances are
now such that confidentiality is no longer necessary. If you report a previously confidential substance
as non-confidential (see subsection C, below, for specific instructions) that substance will
subsequently be listed on the Inventory as non-confidential.
No CBI claim for chemical identity will be accepted unless accompanied by a separate written
substantiation for each chemical substance claimed as CBI, with detailed answers to the eleven
questions prescribed in section 710.38 of the Inventory Update Rule, and repeated below. The
answers must be complete and specific to the chemical substance in question. The substantiation
must be dated and signed by an officer of the company. If the required substantiation does not
accompany your Form U, EPA may make the chemical identities reported on the form available to
the public without further notice to you.
Information in a substantiation may itself be claimed as CBI by circling or bracketing the text
you wish to claim as confidential and marking the page "CONFIDENTIAL." Failure to so mark
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this information may result in EPA making the information available to the public without
further notice to you.
The eleven questions to be answered in the substantiation are:
1) What harmful effects to your competitive position, if any, do you think would result
from the identity of the chemical substance being disclosed in connection with reporting under this
subpart?
2) How long should confidential treatment be given? Until a specific date, the occurrence
of a specific event, or permanently? Why?
3) Has the chemical substance been patented? If so, have you granted licenses to others
with respect to the patent as it applies to the chemical substance? If the chemical substance has been
patented and therefore disclosed through the patent, why should it be treated as confidential?
4) Has the identity of the chemical substance been kept confidential to the extent that
your competitors do not know it is being manufactured or imported for a commercial purpose by
anyone?
5) Is the fact that the chemical substance is being manufactured or imported for a
commercial purpose publicly available, for example in technical journals, libraries, or State, local, or
Federal agency public files?
6) What measures have you taken to prevent undesired disclosure of the fact that this
chemical substance is being manufactured or imported for a commercial purpose?
7) To what extent has the fact that this chemical substance is manufactured or imported
for commercial purposes been revealed to others? What precautions have been taken regarding these
disclosures? Have there been public disclosures or disclosures to competitors?
8) Does this particular chemical substance leave the site of manufacture in any form, as
product, effluent, emission, etc.? If so, what measures have you taken to guard against discovery of
its identity?
9) If the chemical substance leaves the site in a product that is available to the public or
your competitors, can the substance be identified by analysis of the product?
10) For what purpose do you manufacture or import the substance?
11) Has EPA, another Federal agency, or any Federal court made any pertinent
confidentiality determinations regarding this chemical substance? If so, please attach copies of such
determinations.
IUR 1998 Page 14
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C. Completing Form U.
1. General. EPA encourages submitters to submit their 1998 reports using the new IUR
electronic form. In 1994, submitters were offered the option of submitting reports on diskette as a
flat ASCII file. The flat ASCII files are no longer acceptable. The windows-based 1998 electronic
form is a FOXPRO. DBF file which must be submitted on diskette.
2. Report Numbers
Each pre-printed copy of 1998 Form U bears an individual report number. The Agency will
assign report numbers to electronic submissions and forms obtained from the Internet or via Fax-On-
Demand when they are received by EPA. See Section V (page 28) for obtaining copies of Form U.
Detailed instructions for submitting IUR reports using the electronic form are provided in Appendix
B.
3. Certification Statement.
a. Signature. The certification statement must be signed by an officer of the company.
This statement certifies to the truth and accuracy of the information reported and of the
confidentiality claims made on the form (see the back of printed Form U for details). Note that by
certifying the truth and accuracy of the information on the form, you acknowledge that any knowingly
false or misleading statement may be punishable by fine or imprisonment or both under applicable law.
Sign in black ink to ensure that the form bears a legible signature which can be microfiched or
otherwise archived. A certification statement is on the Form U diskette. It must be printed,
signed and accompany all electronic submissions. (See Appendix B, p. B-7.)
b. Date. Enter the month, day, and year that the form was signed.
c. Name and Title. Enter the name and title of the person who signed the certification
statement.
4. Technical Contact and Company Information.
a. Technical Contact Name. Enter the name of the person whom EPA may contact for
clarification of the information submitted on Form U. The technical contact need not be located at
the site for which information is reported, but should be located in the U.S. If you wish to identify
more than one person as a technical contact, please include the extra name(s) in a separate cover
letter.
b. Company Name. Address Line I. Address Line II. Telephone Number. Use this block
to enter the company name and street address. Please use standard addressing techniques as
established by the U.S. Postal Service. Post office box numbers are only acceptable if also
accompanied by a street address. If a post office box is listed, it should be listed after the street
address on Address Line II. The telephone number listed should be that of the technical contact.
IUR 1998 Page 15
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c. CBI. Checking the CBI box in this block asserts a confidentiality claim for the link
between your company and all the chemical substances reported on the form.
Checking other CBI boxes on the form will not protect this link. If there are some substances whose
connection to your company you do not require to be kept as confidential, report those substances
on a separate form on which the CBI box in the Company block is not checked.
5. Plant Site Information.
Reporting under the Inventory Update Rule is done by individual site. Therefore all the
substances reported on one form must be manufactured/imported at the same site. Enter the name,
street address, and Dun & Bradstreet number of the site here. The plant site name should be listed
as a concatenation of the company name and plant site name (e.g., Acme Intl-Madison Pit). (See
sample form on page 18.)
a. Dun & Bradstreet Number. Dun & Bradstreet gives separate numbers to plant sites
and parent companies; make sure that the number you provide EPA belongs to the individual plant
site for which you are reporting. If the plant site does not have a Dun & Bradstreet number, a Dun
& Bradstreet number assignment can be requested from your local office of Dun & Bradstreet. Dun
& Bradstreet does not charge for this service, and does not require that you disclose sensitive
financial information in order to get a number. Do not report the headquarters Dun and
Bradstreet number unless the reporting site corresponds to that number.
b. Address. A street address, including Zip code, must be reported. Post office box
numbers are not acceptable. If the site does not have a street address, please provide what descriptive
site information you have, including the Zip code.
See Block G, below, concerning CBI claims for the link between plant site identity and individual
substances.
6. Chemical Substance Identity/Activity/Confidentiality.
a. Line Number (block AX This part of the form is divided into ten lines to allow
reporting of up to ten chemicals per form. Each line should represent one chemical. If the chemical
identity will not fit on one line, rather than using a second line, you should truncate the name with the
use of an ellipsis (...) indicating an omission of letters or words, (e.g., utilize the available space and
if you can not include the complete name, end it with a series of full stops or period dots.)
b. CAS Registry or Other Identifying Number. Every chemical substance reported on
Form U must be accompanied by its Chemical Abstracts Service (CAS) Registry Number (see lines
1,8, and 10 of sample form) or other identifying number. The printed edition of the Inventory
contains detailed instructions on how to locate the CAS Registry Number for a substance listed
therein. When you report a CAS Registry Number, please verify that the number you are
reporting is the correct number for your substance.
IUR 1998 Page 16
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You may be unable to find a CAS Registry Number in the Public Inventory either because the
substance is listed as confidential (in which case the specific identity is not present and the chemical
substance has an Accession Number rather than a CAS Registry Number) or because the substance
was not on the Inventory as of the date of printing. If this is the case, you may use one of the
following acceptable identifying numbers:
1) EPA Accession Number;
2) Original Inventory Report Form Number;
3) Premanufacture Notice Number;
4) Bona Fide Document Control Number; or
5) Test Market Exemption Application Number.
Use one of the above identifying numbers only if you cannot locate the CAS Registry Number for a
substance or you are uncertain whether the CAS Registry Number you have located is correct. The
CAS Registry number is the preferred identifier for chemical substances reported.
IUR 1998 Page 17
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SAMPLE 1998 IUR FORM
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(1) EPA Accession Number. (See line 2 of sample form.) If the identity of a chemical
substance on the Inventory is confidential, the printed Inventory lists an Accession Number for that
substance and uses a generic name rather than a specific identity. You may use an Accession Number
as an identifying number only if EPA has communicated the appropriate Accession Number to you,
e.g., following your report for the original Inventory in 1978 or 1979, or following commencement
of manufacture or import of a substance for which you filed a premanufacture notice. If you find a
generic chemical identity in the printed Inventory which you think belongs to your substance, and
report using the Accession Number which pertains to that substance, you may possibly report for the
wrong substance. An Accession Number may not be used for a non-confidential chemical substance.
A typical Accession Number would be "29735".
(2) Original Inventory Report Number. In 1978 and 1979, submissions for the Initial and
Revised TSCA Chemical Substance Inventories were filed on one of four forms, "A", "B", "C", or
"E". You may use that original Inventory report form number as an identifying number. A typical
Original Inventory Report Number would be "12345678".
Since both "A" and "B" forms allowed reporting of several chemical substances on a single
form, EPA needs to know the line number on the original "A" or "B" form that the substance
occupied. If you use an original Inventory report number from an "A" or "B" form (these form
numbers begin with "1" or "2") you must therefore include the original line number for that chemical
substance, separated from the form number by a slash. For example, if a chemical substance has been
reported on line number 3 of form 12345678, report the identification number as "12345678/003";
(see line 9 on sample form). Add leading zeroes to make the line number three digits long, e.g. #
"001", "012", or "123". If you originally reported on a "C" or "E" form (form numbers beginning
with "3" or "5"), include a slash and line number of 001 (see lines 4 and 5 on sample form).
If you submitted a correction to an original Inventory report, use the number of the form on
which you submitted the correction. Be sure to add a line number (001), as above.
(3) Premanufacture Notice Number. (See line 6 of sample form.) If you filed a
Premanufacture Notice (PMN) for a substance which is now reportable under the Inventory Update
Rule and that PMN was assigned a PMN number, you may use that as an identifying number. A
typical PMN number would be "P-85-0243" or "P-83-0001A". The four digit block of numbers must
be right justified with leading zeros as needed. The eighth space is reserved for an optional alpha
character suffix (A, B, etc.) and should be used only if one has been assigned by EPA. Please be sure
to include the dashes in the correct locations.
Please be aware that a chemical substance which has a PMN number is not automatically
reportable under the Inventory Update Rule. A PMN substance is reportable under the IUR only
IUR 1998 Page 19
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if it is included on the Inventory. A PMN substance is included on the Inventory only if a Notice of
Commencement was received by EPA for the substance.
(4) Bona Fide Request Control Number. (See line 3 of sample form, page 18) If you filed
a Bona Fide Intent to Manufacture or Import a chemical substance which is now reportable under the
Inventory Update Rule (see 40 CFR §710.7(g) or §720.25(b)), you may use the document control
number assigned to that submission by EPA as an identifying number. A typical Bona Fide document
control number would be "528500287".
The fact that you filed a Bona Fide for a substance does not necessarily mean that the
substance is on the Inventory and reportable; you must have independent confirmation that the
substance is on the Inventory (most likely in a communication from EPA).
(5) Test Market Exemption Application Number. (See line 7 of sample form.) If you filed
a Test Market Exemption Application (TMEA) for a substance which is now reportable under the
Inventory Update Rule, the number assigned by EPA to that application may be used as an identifying
number. A typical TMEA number would be "T-85-0243" or "T-83-0001A". The four digit block
of numbers must be right justified with leading zeros as needed. The eighth space is reserved for an
optional alpha character suffix (A, B, etc.) and should be used only if one has been assigned by EPA.
Please be sure to include the dashes in the correct locations. You should use a TMEA number only
if you know that the chemical substance is on the Inventory.
Procedures for obtaining CAS Registry Numbers and Accession Numbers from EPA when
you previously reported the substance to the Agency. If by one of the methods discussed in Section
II.A. (page 2), you were able to determine that the substances you manufacture are on the Inventory,
you should already have identifying numbers for them. If you do not know any of the above
identifying numbers for a substance you are unlikely to be certain that the substance is on the
Inventory. If this is the case you should reread Section II. A. Following the procedures in that section
should enable you to find an identifying number.
There may be some manufacturers or importers who reported for the Inventory in 1978 or
1979 but no longer have the original report forms. In this case you may request an identifying
number from EPA. Send a letter to the following address:
OPPT Document Control Officer
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
IUR 1998 Page 20
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The letter must include the specific identity of the chemical substance, must be signed by an
officer of the company, and must designate a technical contact (include name, title, address, and
telephone number). The structure of the substance, if available, should also be provided. Note that
this procedure can be used only when you have previously reported the substance to the Agency; if
you need EPA to tell you whether the substance is on the Inventory you must follow the procedures
in Section II.A.2. (page 3).
Information on this letter may itself be claimed as confidential by circling or bracketing the
text to be protected and marking the page "CONFIDENTIAL." Failure to so mark this information
may result in EPA making the information available to the public without further notice to you.
EPA will release information in response to these letters only to the company which originally
submitted the information. If company ownership has changed or the technical contact authorized
to receive confidential information has changed since you reported the substance to EPA during 1978
-1980, you must include a notarized letter by an officer of the current surviving chemical company
certifying to the change and designating the new technical contact.
EPA will send to the technical contact a CAS Registry Number (if the substance is listed as
non-confidential on the Inventory) or an Accession Number (if the substance is confidential).
EPA will release CAS Registry Numbers or Accession Numbers in response to these letters
only for substances which are reportable under the Inventory Update Rule. Your letter must be
received by November 12, 1998; otherwise the Agency cannot guarantee a response in time for you
to meet your reporting obligations.
c. Ar B. C. F. P. or T Codes (block C). Indicate in this column the type of identifying
number you entered in column B, as follows:
If the number you are Type this code
reporting in block B is a(n) in block C
Accession Number A
Bona Fide Number B
CAS Registry Number C
Original Inventory Report Number F
Premanufacture Notice (PMN) Number P
Test Market Exemption Application
(TMEA) Number T
d. Specific Chemical Name (block H). Enter the specific chemical identity of the
chemical substance you are reporting. Chemical Abstracts Index or Preferred Names should be used
if available. For non-confidential substances, these names can
IUR1998 Page 21
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be found in either the printed or the computer-readable version of the Public Inventory. If such
names are not available, you must use nomenclature which completely and accurately describes the
chemical substance.
If the chemical identity will not fit on one line, you should truncate the name at the end of the
line with the use of an ellipsis (...) indicating an omission of letters or words. Each line should
represent one chemical. (See line 4 of sample form, page 18) Do not continue the chemical identity
to the next line.
Trade names may not be used except where a trade name describes a reactant which is part
of the identity of a chemical substance you are reporting and your supplier will not disclose to you
the specific identity of the trade name reactant. Report all such chemical substances on a separate
form, entering the specific identities of reactants where you know them and the trade names where
you do not. You must also submit along with Form U a letter certifying that your supplier will not
disclose to you the specific identity of the trade name reactant and identifying the supplier of each
trade name reactant reported.
Information in this letter may be claimed as confidential by circling or bracketing the text to
be protected and marking the page, "CONFIDENTIAL." Failure to so mark this information may
result in EPA making the information available to the public without further notice to you.
If you are an importer whose foreign supplier will not reveal to you the identity of the
substance you are reporting, follow the procedures in subsection G. (page 25).
If you are claiming the chemical identity as confidential, check the Chemical CBI box in block
G.
e. Activity: Manufacture or Import (block Pi If you manufacture the substance, enter
"M" in the Activity box; enter "I" if you import the substance. If you both manufacture and import
the substance at the same site, use two lines to report, one for each activity. Check the CBI box if
you wish to claim the nature of the activity (i.e., manufacture vs. importation) as confidential for the
substance. Claiming activity as CBI does not protect the link between your company and the
substance; that will not be protected unless you check the CBI box next to Company Name.
f. Site Limited (block E). If you manufacture the chemical substance at the plant site
identified and do not distribute the chemical substance or any mixture containing that substance
outside the plant site for commercial purposes, enter "X" in the space next to the CBI box. Otherwise
leave the space blank. (Note: an imported chemical substance cannot be reported as site-limited.)
If you wish to claim this information as confidential for the substance, check the CBI box. You may
claim the fact that a substance is not site limited as confidential, if appropriate.
IUR1998 Page 22
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g. Production Volume (block F). Enter your annual manufacture volume or importing
volume, in pounds, for the fiscal year preceding the reporting period. If you both manufacture and
import a particular substance, report the manufacture and import volumes separately, on two lines.
The quantity should be reported to at least two significant figures, and should be accurate to the
extent known or reasonably ascertainable by you (if the figure reported is within ±10% of the actual
value, it is acceptable for purposes of the rule). Production volumes must be reported in numeric
format ("2 million" or "ExlO" are not acceptable): Abbreviations such as M or K are also not
acceptable. (Volumes reported in other than numeric format cannot be read by the Agency's
automated equipment.) If you wish to claim this information as confidential for this substance, check
the CBI box.
h. Plant site and Chemical CBI Claims f block GV
(1) Plant site CBI claim. If you wish to claim the site of manufacture/import as
confidential, check the "Plant CBI" box. Note that you may claim this connection as CBI for some
chemical substances on the form while not making that claim for others.
(2) Chemical identity CBI claim. The identity of a substance which is listed as confidential
on the TSCA Inventory may be claimed as confidential by checking this box. EPA will not honor
a chemical identity CBI claim for a substance which is Usted on the non-confidential Inventory.
Note that checking this box does not protect the link between your company and the substance; it
only asserts a CBI claim for the specific identity of the substance. If you wish to claim company
identity as CBI, check the CBI box next to Company Name on the upper portion of the form.
D. Submitting forms to EPA.
Send the submission, along with the accompanying Certification Letter and CBI
Substantiation Letter, to the following address:
OPPT Document Control Officer
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
E. Correcting errors in submissions for the original Inventory.
IUR 1998 Page 23
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In reporting under the Inventory Update Rule you may find that an error was made when you
reported for the original Inventory in 1978 or 1979. If that error falls into one of the following
categories:
1) the chemical identity originally reported was incomplete or inaccurate;
2) an isolated intermediate occurring during the manufacture of a substance previously
reported for the Inventory was not then recognized; or
3) EPA informed your company of a reporting error and requested a correction from
you, to which you did not respond;
you should file an Inventory Correction, following the procedures outlined in the Federal Register
notice of July 29, 1980 (45 FR 50544). Be sure to reference the original Inventory report form and
line number (if appropriate) when you file a correction.
For copies of the Federal Register notice or further assistance with an Inventory Correction,
you may contact:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Telephone: (202) 554-1404
Inventory Correction requests should be submitted to EPA with your copies of Form U. Note
that your Form U should report the chemical substance you are actually manufacturing or importing.
The correction should be explained in a cover letter by specifically referencing the number of the
correction form, the Form U number, and the Form U report line number.
The act of correcting errors in submissions to the Original Inventory does not grant to the
person making the correction immunity from enforcement action for any possible violations of the
Original Inventory Reporting Rule.
F. Record keeping requirements.
IUR1998 Page 24
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Persons subject to the Inventory Update Rule are required to maintain records that document
the information contained in their submissions. These records must be kept for four years after the
effective date of the applicable reporting period. As long as the records are maintained in a manner
consistent with normal business practice, you may determine their exact format. Required records
include those that show the production volume, plant site, and site-limited status of each substance
reported. If a substance is not reported because its site-specific annual production is less than 10,000
pounds, only the site-specific production records for that substance need to be kept. Persons who
qualify as exempt small manufacturers need to keep records only for those chemical substances which
they are required to report; however, in claiming an exemption they bear the burden of documenting
that they qualify for the exemption.
G. Special instructions for importers and foreign suppliers.
This section applies to importers who do not know the specific chemical identity of a
substance because the foreign supplier chooses to keep it confidential. If you are such an importer,
you are still responsible for ensuring that the information is submitted to EPA. You may accomplish
this by having your foreign supplier complete some of the information on Form U, as follows:
1) Include a cover letter with your submission, stating the following: "The identifying
numbers and specific chemical identities for the substances on this form and the
technical contact will be submitted by our foreign supplier."
2) Use a separate Form U for each foreign supplier who does not inform you of the
identity of the chemical substances you are importing. Do not report by diskette. Do
not use the same report form for substances whose specific identities you do know.
3) Make a photocopy of a blank Form U before entering any information on the form.
4) On the original copy, sign the certification statement, enter the technical contact, and
complete blocks D, E, F and G for each chemical substance. In block B, instead of
entering the identifying number, enter the trade name or other designation by which
you know each chemical substance. Leave column C blank. Check the "Chemical
CBI" box in block H only if you wish to claim the identities of the chemicals identified
on the form as confidential (you must answer the substantiation questions described
in subsection B., page 13). Your foreign supplier is responsible for his own CBI
claim. Send this copy to EPA.
5) On the photocopy of the blank form, enter only the plant site information. Send this
copy to your foreign supplier.
6) The foreign supplier should enter technical contact-company information on his copy
(the technical contact here should be the foreign supplier), complete blocks B and C
and enter the appropriate specific chemical identities in block H. Make sure that your
IUR 1998 Page 25
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supplier understands which chemical identities belong with each line number on Form
U. If the foreign supplier wishes to claim the chemical identities as confidential, the
supplier should check the "Confidential" box in block G and submit a substantiation
as described in subsection B., above. The supplier should include with Form U a
letter stating that this information is being submitted by a foreign supplier on behalf
of the importer, who should be identified. Information in the letter may be claimed
as confidential by circling or bracketing the text to be protected and marking the page,
"CONFIDENTIAL." Failure to so mark this information may result in EPA making
the information available to the public without further notice to the supplier. The
supplier should then send the form and letter to EPA.
Note that it is your responsibility to ensure that your foreign supplier understands how to
complete his copy of Form U (including any relevant CBI claims) and that the supplier sends the
information to EPA by the end of the reporting period. If the supplier fails to submit the information,
your company may be subject to an enforcement action.
IUR 1998 Page 26
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V. OBTAINING COPIES OF DOCUMENTS CITED IN THESE INSTRUCTIONS
A. Obtaining copies of TSCA regulations.
Copies of TSCA regulations can be obtained by contacting:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Telephone: (202) 554-1404
B. Obtaining copies of the Public Inventory.
1. Obtaining copies of the printed edition of the Public Inventory. Non-confidential
Inventory listing can be found in the TSCA Chemical Substance Inventory: 1985 Edition, a complete
version of the Public (non-confidential) Inventory current as of July 1985, and in the TSCA Chemical
Substance Inventory: 1990 Supplement, a supplement to the 1985 edition current as of February 1,
1990. This printed version contains the CAS Registry Number, Preferred CA Index Name, molecular
formula, and if applicable, the substance definition and appropriate EPA flags (including the "XU"
flag for substances exempt from reporting under the Inventory Update Rule) for non-confidential
substances. For chemical substances whose chemical identity has been claimed as confidential,
generic chemical names and EPA accession numbers are listed. Copies may be purchased from:
Superintendent of Documents
Government Printing Office
Washington, D.C. 20402
Order Desk: (202)783-3238
The price for the 1985 edition is $161.00 in the U.S. and Canada, $201.25 elsewhere; the
price for the 1990 supplement is $15.00 in the U.S., and $18.75 outside the U.S. If ordering by mail
use the above address. GPO will also take orders by telephone; MasterCard and Visa are accepted.
Refer to stock number 055-000-00254-1 for the 1985 edition, and 055-000-00254-1 for the 1990
supplement. Please allow 4-6 weeks for delivery (longer outside the U.S.X
2. Obtaining the Public Inventory in computer-readable form. The Public Inventory is
available in the form of computer tapes or PC diskettes. Both can be obtained from the National
Technical Information Service (1-800-553-NTIS). The computer tape version consists of two tapes.
The first tape, the Inventory Preferred Name File, is sorted by CAS Registry Number. It contains the
CAS Registry Number, Preferred CA Index Name, molecular formula, and if applicable, the substance
definition and appropriate EPA flags (including the "XU" flag for substances exempt
from reporting under the Inventory Update Rule) for non-confidential substances. The second tape,
the Inventory Synonym Name file, contains the same data elements as the first tape but differs in two
IUR 1998 Page 27
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ways. First, it is sorted by chemical name, not CAS Registry Number. Second, in addition to the
Preferred CA Index names, this file is expanded by the inclusion of valid names (synonyms) as
supplied to EPA by Inventory submitters. In contrast to the printed version of the Public Inventory
which includes CAS derived synonyms, the synonyms listed on this tape are only those reported to
EPA by Inventory submitters.
The PC diskette version is a set of diskettes containing the information on both computer
tapes merged together with duplicate information removed. It is in CAS Registry Number order.
The tapes and diskettes only contain information on chemical substances which have not had
confidentiality claims made on the chemical identity. They do not reference in any way chemicals on
the TSCA Inventory claimed as confidential.
Ordering information for these products may be obtained by contacting:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650 or (800) 553-NTIS
C. Obtaining copies of Form U.
Electronic and Printed copies of Form U may be obtained from:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Telephone: (202) 554-1404
Printed copies of Form U may also be obtained from:
. Internet: http://www.epa.gov/opptintr/iur98
. FAX ON DEMAND : (202) 401-0527; Item: 5119
IUR 1998 Page 28
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VI. REQUESTING ASSISTANCE IN REPORTING
Should you need information on or assistance in the following areas:
1) determining your reporting obligations;
2) the mechanics of completing Form U;
3) entering data onto computer diskette for submission; or
4) determining the status of forms/diskettes you have submitted to EPA,
you may write to or call the following address:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 554-1404
IUR1998 Page 29
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IUR 1998
Page 30
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Appendix A
Chemical Substances Subject to
Proposed or Final TSCA Rules or Orders
Following is a list of CAS Registry Numbers (for non-confidential chemical substances) or Accession
Numbers (for confidential substances) of substances which are subject to proposed or final rules or
orders under TSCA sections 4, 5(a)(2), 5(b)(4), 5(e), 5(f), 6, and 7, as of April 1994 (see sections
710.26 and 710.29 of the rule and pages 6 and 8 in these reporting instructions). All chemical
substances appearing on this list are subject to IUR reporting. The usual exclusions for polymers,
inorganic substances, microorganisms, or small businesses do not apply for substances on this list.
The exclusion for naturally occurring substances is still valid, as referenced on page 6 of this
instruction manual. If after consulting the list you are uncertain as to the regulatory status of a
chemical substance, contact EPA at the address given on page 29 of these reporting instructions.
This document is intended to be an information resource. Since it may contain errors and omissions,
it should not be used in lieu of FR documents or the CFR for purposes of compliance.
CAS
Registry
Number
50-07-7
50-29-3
50-55-5
51-79-6
56-04-2
56-49-5
56-53-1
60-29-7
62-44-2
62-50-0
62-53-3
67-63-0
67-64-1
70-25-7
71-36-3
71-55-6
74-87-3
74-93-1
74-95-3
75-00-3
75-02-5
75-25-2
75-34-3
75-38-7
Regulated Under
TSCA Section^)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
5(a)(2)
5(a)(2)
4
4
4
5(a)(2)
4
4
4
4
4
4
4
4
4
4
CAS
Registry
Number
75-56-9
75-88-7
76-01-7
76-01-7
78-83-1
78-87-5
79-06-1
79-10-7
79-34-5
79-94-7
79-95-8
80-05-7
84-65-1
84-66-2
84-74-2
85-22-3
85-44-9
87-10-5
87-61-6
87-63-8
87-65-0
88-74-4
92-52-4
92-66-0
Regulated Under
TSCA Section^
4
5(a)(2)
5(a)(2)
4
4
4
6(a)
4
4
4
4
4
4
4
4
5(a)(2)
4
4
4
5(a)(2)
4
4
4
5(a)(2)
IUR 1998
A - 1
-------
CAS
Registry
Number
92-86-4
94-04-2
94-58-6
94-75-7
95-48-7
95-50-1
95-51-2
95-54-5
95-69-2
95-76-1
95-77-2
95-94-3
95-95-4
96-23-1
96-29-7
97-02-9
97-63-2
98-82-8
98-86-2
99-28-5
99-30-9
99-35-4
100-01-6
100-02-7
100-40-3
101-55-3
104-76-7
106-44-5
106-46-7
106-47-8
106-50-3
106-91-2
107-04-0
108-10-1
108-39-4
108-45-2
108-60-1
108-67-8
108-90-7
108-95-2
109-06-8
Regulated Under
TSCA Sectionfs)
5(a)(2)
5(a)(2)
4
4
4
4
4
4
5(a)(2)
4
4
4
4
4
4
4
4
4
4
4
4
5(a)(2)
4
4
4
5(a)(2)
4
4
4
4
4
4
5(a)(2)
4
4
4
4
4
4
4
4
CAS
Registry
Number
109-77-3
109-99-9
110-80-5
110-82-7
111-40-0
111-91-1
112-34-5
112-35-6
112-50-5
112-90-3
116-14-3
116-15-4
117-81-7
118-75-2
118-79-6
120-36-5
120-82-1
120-83-2
123-31-9
123-33-1
123-54-6
123-86-4
124-17-4
126-72-7
126-73-8
131-11-3
141-78-6
141-79-7
143-22-6
143-33-9
149-30-4
149-57-5
320-72-9
328-84-7
354-21-2
354-25-6
428-59-1
460-70-8
460-92-4
541-70-8
Regulated Under
TSCA Section^
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5(a)(2)
4
4
5(a)(2)
4
4
4
4
4
4
4
4
4
4
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
IUR 1998
A - 2
-------
CAS
Registry
Number
541-73-1
576-24-9
583-78-8
591-78-6
606-20-2
608-71-9
608-93-5
608-93-5
615-53-2
615-58-7
616-23-9
622-86-6
628-63-7
640-19-7
680-31-9
690-27-7
693-38-9
822-06-0
872-50-4
924-42-5
930-55-2
931-35-1
933-75-5
994-05-8
1116-54-7
1129-42-6
1163-19-5
1187-03-7
1332-21-4
1333-82-0
1336-36-3
1489-69-6
1511-62-2
1634-04-4
1649-08-7
1660-95-3
1675-54-3
1705-60-8
1737-93-5
1888-71-7
1940-42-7
Regulated Under
TSCA Sectionfsl
4
4
4
5(a)(2)
4
4
5(a)(2)
4
5(a)(2)
4
4
5(a)(2)
4
4
5(a)(2)
5(a)(2)
5(a)(2)
4
4
6(a)
5(a)(2)
5(a)(2)
4
4
5(a)(2)
5(a)(2)
4
5(a)(2)
6(a)
6(a)
6(a)
5(a)(2)
5(a)(2)
4
5(a)(2)
5(a)(2)
4
5(a)(2)
5(a)(2)
5(a)(2)
4
CAS
Registry
Number
2052-07-5
2113-57-7
2368-80-1
2417-04-1
2432-99-7
2615-25-0
2682-20-4
2716-10-1
2716-12-3
2837-89-0
2840-00-8
3052-70-8
3083-25-8
3089-19-8
3132-64-7
3165-93-3
3377-92-2
3389-71-7
3618-72-2
3648-20-2
3772-94-9
4162-45-2
4170-30-3
4369-14-6
4694-91-1
5216-25-1
5344-82-1
5397-03-5
5958-25-8
6196-98-1
6304-39-8
6752-33-6
7345-69-9
7439-92-1
7440-66-6
7738-94-5
7775-11-3
7778-50-9
7789-00-6
7789-99-3
8068-03-9
Regulated Under
TSCA Section^
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
4
4
4
4
5(a)(2)
5(a)(2)
4
4
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
6(a)
6(a)
6(a)
6(a)
6(a)
6(a)
5(a)(2)
5(a)(2)
IUR 1998
A - 3
-------
CAS
Registry
Number
9030-09-5
10333-53-6
10588-01-9
11103-86-9
12027-96-2
12031-65-1
12036-37-2
12056-51-8
12057-17-9
12141-67-2
13439-89-9
13530-65-9
13530-68-2
13654-09-6
14018-95-2
15827-56-2
16068-37-4
16079-88-2
16096-31-4
16245-77-5
16298-38-7
16532-79-9
18241-31-1
19019-43-3
19201-36-6
19372-44-2
19721-22-3
19829-42-6
21160-95-2
21807-69-2
21850-44-2
25327-89-3
25550-98-5
25608-40-6
26172-55-4
27603-25-4
27610-48-6
27753-52-2
27858-07-7
27970-79-2
28554-31-6
Regulated Under
TSCA Section^
5(a)(2)
5(a)(2)
6(a)
6(a)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
6(a)
6(a)
5(a)(2)
6(a)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
5(a)(2)
4
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
4
4
4
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
CAS
Registry
Number
29091-20-1
30025-38-8
30486-37-4
30813-81-1
31775-16-3
32534-81-9
32536-52-0
32539-16-5
34415-31-1
34621-99-3
36355-01-8
37853-59-1
37853-61-5
41240-76-0
47758-37-2
51160-97-5
51868-46-3
52495-71-3
54423-67-5
58576-98-0
58577-08-5
58965-66-5
59789-51-4
60466-61-7
62435-71-6
64712-27-2
64723-18-8
65992-66-7
66988-04-3
68515-47-9
68515-48-0
68515-49-1
68515-50-4
69938-76-7
70693-06-0
71526-07-3
72804-49-0
73231-04-6
73936-91-1
75405-06-0
75980-60-8
Regulated Under
TSCA Section^
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
4
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
4
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
4
4
4
4
5(a)(2)
4
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
IUR 1998
A - 4
-------
CAS
Registry
Number
76114-73-3
77939-50-5
78245-94-0
79771-08-7
79771-09-8
80584-91-4
80584-92-5
81517-07-9
81711-69-5
82799-44-8
83048-65-1
83748-27-0
83748-28-1
84268-08-6
84583-67-5
84583-77-7
84852-15-3
85029-61-4
85137-09-3
85204-21-3
85204-21-3
85712-26-1
85712-27-2
87676-07-1
89610-32-2
90884-29-0
92044-87-6
92484-07-6
93589-69-6
94054-35-0
94148-67-1
94213-53-3
94317-64-3
94933-05-8
95732-35-7
95823-36-2
96478-09-0
96549-95-0
99742-80-0
Regulated Under
TSCA Sectionf s")
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(f)
5(0
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(e)
4
5(a)(2)
5(a)(2)
5(f)
6(a)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(e)
CAS
Registry
Number
100545-50-4
100912-15-0
101646-62-2
101646-63-3
102093-68-5
103490-06-8
103490-08-0
103580-64-9
103697-96-7
104503-68-6
104983-85-9
105658-30-8
106569-82-8
106790-31-2
1 10726-28-8
110843-97-5
110843-98-6
116671-32-0
118716-61-3
118716-62-4
119438-11-8
119462-56-5
119535-63-6
120547-52-6
121144-97-6
121255-03-6
121776-57-6
122035-71-6
124993-63-1
125630-94-6
125904-10-1
125904-11-2
125997-20-8
126213-50-1
126505-35-9
129733-59-1
130097-33-5
130169-66-3
130353-62-7
Regulated Under
TSCA Sectionf s^l
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
4
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
IUR 1998
A - 5
-------
CAS
Registry
Number
130728-76-6
132299-20-8
132739-31-2
132767-86-3
133911-74-7
134701-20-5
134818-69-2
136504-96-6
137873-52-0
138495-42-8
138859-29-7
141420-50-0
142828-65-7
144761-93-3
145556-04-3
145899-78-1
147129-86-0
147170-38-5
147170-47-6
147732-58-9
147783-69-5
148124-42-9
148373-01-7
148462-57-1
148993-99-1
149564-65-8
151686-36-1
151717-27-0
151911-53-4
152007-82-4
153454.44.5
153590-17-1
153699-23-1
157627-99-1
157707-95-4
161717-32-4
163206-29-9
163292-61-3
163436-84-8
Regulated Under
TSCA Section^
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
CAS
Registry
Number
163702-07-6
163702-08-7
163879-69-4
163961-32-8
163961-34-0
166432-57-1
166432-58-2
166514-73-4
168113-88-0
168811-65-2
170678-69-0
172928-53-9
174125-27-0
174125-28-1
174125-95-2
174333-80-3
174974.45.9
175205-96-6
177528-09-5
180031-79-2
180685-86-3
182238-09-1
182238-10-4
182635-99-0
183562-46-1
184719-88-8
186321-98-2
190525-00-9
192587-38-5
192726-23-1
193635-72-2
195888-92-7
199487-82-6
206886-68-2
Regulated Under
TSCA Section^
5(e)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(e)
5(e)
5(a)(2)
5(a)(2)
5(e)
5(e)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(e)
IUR 1998
A - 6
-------
Accession
Number
30309
32178
38585
39168
40950
41259
42741
43313
44292
45002
49435
49457
50567
52381
52676
53215
53862
55904
56236
57397
58118
58834
59531
59622
60787
62283
62625
62705
62705
64621
65328
65599
66387
66503
66616
66898
67993
68101
68474
71546
72414
Regulated
Under TSCA
Sectionfs)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(f)
6(a)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
Accession
Number
73484
73542
73906
73939
75015
76972
77511
77668
77759
77873
78581
79164
80376
80912
81426
84083
84801
87560
87968
88063
88472
90212
91680
93835
94076
96378
97008
97291
97859
101510
101601
101974
102057
102422
102966
103094
103378
103798
105090
105249
105578
Regulated
Under TSCA
Section(s)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
IUR 1998
A - 7
-------
Accession
Number
106720
106877
107450
108260
108737
109525
112233
112380
112766
113236
113372
114024
115981
116439
116531
116917
119585
120208
121585
121621
121972
122395
122704
122908
123116
123296
123401
123650
123785
123898
123912
124540
124595
125792
125883
126002
126615
127992
Regulated
Under TSCA
Section(s)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
Accession
Number
128111
128155
128520
129147
129169
129487
129750
129829
130291
130348
130428
131103
131125
132355
132537
132651
132811
132855
132968
133201
133256
133336
133370
134077
134179
134704
135649
136335
136722
136880
137361
137963
138104
138217
138262
138455
138499
138557
Regulated
Under TSCA
Section(s)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(e)
5(a)(2)
IUR 1998
A -
-------
Accession
Number
139674
139787
140502
141889
141925
142086
143034
143410
143501
143636
143896
143965
144388
144402
144719
144797
145165
145756
146453
146588
146646
146975
147036
147229
147570
147923
148084
148459
148835
149021
149281
149907
150595
151247
151690
152115
152386
152897
153174
153196
153232
Regulated
Under TSCA
Section^
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
Accession
Number
153312
153889
154473
154688
154917
156128
156413
156424
156526
157825
158511
158635
158715
159003
159138
159570
160044
160180
160840
161070
162415
163929
163985
165141
165403
165505
165538
166519
166597
166735
167181
167261
167512
167910
167943
168162
168377
168504
168935
169290
170059
Regulated
Under TSCA
Section(s)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(e)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(e)
5(a)(2)
5(e)
5(a)(2)
5(a)(2)
5(a)(2)
IUR 1998
A - 9
-------
Accession Regulated
Number Under TSCA
Sectionfs)
170219 5(a)(2)
171063 5(a)(2)
172055 5(a)(2)
172691 5(a)(2)
172737 5(a)(2)
173014 5(a)(2)
173296 5(a)(2)
173310 5(a)(2)
173343 5(a)(2)
173489 5(a)(2)
173876 5(a)(2)
174131 5(a)(2)
174313 5(a)(2)
174324 5(a)(2)
174722 5(a)(2)
175032 5(a)(2)
176853 5(e)
176875 5(a)(2)
176911 5(a)(2)
178097 5(a)(2)
178495 5(a)(2)
179090 5(a)(2)
190762 5(a)(2)
211871 5(a)(2)
The following chemical categories were subject to TSCA Section 6 actions and are
reportable substances for the IUR:
. Metalworking Fluids
. Polychlorinated Biphenyls (PCBs)
. Dibenzo-Para-Dioxins/Dibenzofurans
IUR 1998 A - 10
-------
Appendix B
Instructions for Submitting IUR Reports by Electronic Form
EPA is encouraging all 1998 IUR submitters to file their IUR reports in an electronically
readable format. Magnetic media submissions are preferred because handling and archiving are more
efficient and there is less likelihood of transcription error than with paper copies.
These instructions are furnished for two purposes: to allow companies to determine whether
they are able to comply with the general instructions for electronic form submissions, and to provide
the responsible computer professionals the technical specifications they need to actually prepare the
IUR electronic reports.
GENERAL INSTRUCTIONS
An electronic IUR submission is produced by a plant site or company mailing to EPA the
.DBF files produced by the software. Instructions in this appendix describe who can report by such
files, how to prepare the reporting packet, and specifications for the installation and use of the
software. Finally, instructions for mailing the submission are included.
Minimal Magnetic Media Reporting Restrictions in 1998
In the 1994 reporting cycle, no form U's containing over 999 chemicals could be submitted
via magnetic media; however, this restriction is no longer valid. There is no longer a minimum or
maximum number of chemicals to qualify for electronic reporting; any number is acceptable.
There are only two magnetic media restrictions remaining:
1) Importers who are unaware of the chemical identity of the substance which they are
importing must report via hard copy; no magnetic media reporting is permitted. In
this case, the foreign supplier must have a hard copy of the Form U to provide the
identity information to the EPA.
2) Any chemical with production volume exceeding 999,999,999,999 Ibs. must be
reported on hard copy.
IUR 1998 B - 1
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INSTALLATION INSTRUCTIONS FOR THE 1998 ELECTRONIC FORM
System Requirements
• 80386SX processor (or higher)
• Mouse
• 6 MB RAM if virtual memory is set to none or 4 MB RAM if virtual memory is set to
temporary or permanent
• MS-DOS version 3.1 or higher
• Microsoft Windows version 3.0 or higher running in 386 enhanced mode
• VGA or higher resolution monitor recommended
• 4.8 MB hard disk space
Quick Setup
1. Start Microsoft Windows.
2. Insert the disk labeled "Disk 1" in drive A.
3. For Windows 3.1
Select the Program Manager icon.
From the File menu, choose Run.
For Windows 95
Select Start at the bottom left of the screen.
Select Run.
4. In the Command Line text box, type A:\SETUP.EXE and press Enter.
5. Follow the instructions on the screen. Insert Disk 2 when prompted.
6. Double click on the IUR98 Electronic Form icon to begin.
IUR 1998 B - 2
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COMPLETING A FORM WITH THE IUR ELECTRONIC SOFTWARE
Five introductory screens will come up when you begin running the software...
The Title Screen, with the EPA Logo - hit PgDn for the next screen.
A Menu Selection Screen, summarizing the menu options - hit PgDn
A Helpful Hints Screen, with important pointers for using the software - hit PgDn
A Paperwork Reduction Act Screen, explaining the Act - hit PgDn
The Start Application Screen, including contact information. Hit Enter or click on the
Begin button to bring up the menu bar.
The menu bar that appears at the top of the screen will give you the following options...
REGULATIONS - This series of screens summarizes the IUR reporting requirements. Select a YES
or NO button to answer a question, then PgDn for the next question. When you reach the final
screen, you may select CANCEL to abort the process or EVALUATE to get an analysis on whether
or not you need to file a report. ESC will also abort the screen set. Selecting UNSURE on any
question will refer you to the IUR Instruction Booklet.
CREATE FORM - This option allows you to create a new form. The three types of forms available
are the Standard Form, the Long Form, and the Correction/Continuation Form. You may only
work with one form at a time.
EDIT FORM - This option will allow you to use an existing form to make changes or to print a copy
for your files.
SAVE FORM - In order to permanently save the information you input to a form, whether you are
creating or editing, you must use this menu option. The available selection will depend upon which
type of form you are using.
PRINT FORM - You may obtain hard copies of your forms by selecting this option. You must also
print the Certification Letter to include with your submission to EPA. You may not submit a printed
copy as an original submission, but you may use one in a reference letter in any future correspondence
with EPA.
HELP - Select this menu item or press Fl at any time to get assistance on several topics.
QUIT - When you wish to exit the application, select this menu option. You will be prompted to
make sure you are ready to exit.
IUR 1998 B - 3
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FILLING OUT THE STANDARD FORM
The Standard Form should be used when you are reporting 10 chemicals or less at a specific
plant site. It is set up with 10 reporting lines, just like the paper form. Selecting Standard Form from
the Create Form or Edit Form (if you supply a name) menu items will bring up the form.
IMPORTANT! Do NOT use to try to exit the form! Doing so will not allow you to select
any menu items except Regulations, Help, or Quit. Any information entered will be lost.
The initial screen will be for Company and Plant site information. After each field is entered,
the cursor will advance to the next field. You may also use the mouse to go directly to a field, but be
sure that you are starting at the leftmost side to eliminate leading blanks. When you reach the bottom,
do not save or exit until you have filled in the chemical information screens.
PgDn will take you to the first 5 lines for chemical information. The first field entered will be
the Id Code. Valid codes are A, B, C, F, P, and T. You may tab from the field without entering a
value, but an edit check will not be performed on the identifying number you enter.
Following the input of an Id Code, the cursor moves to the Identifying Number field. You
must enter a valid value corresponding to the Id Code you entered, or you will be unable to exit the
field. If you are unsure of the format or need a dummy value to allow you to continue, see the HELP
item for that specific identity type. Hint - CAS Number is numeric; no dashes, leading zeroes, or
blanks should be used.
Fill in the other line items just as you would with the paper form, except you must answer "Y"
or "N" where you would have used "X" or "-". Production Volume is also numeric; do not use
commas or scientific notation. For detailed instruction on items, use HELP or go to the 1998 IUR
Instruction Booklet.
When you reach the chemical name field on Line 5, hitting ENTER will take you to the next
screen, where you can fill out lines 6 thru 10. If you are in a chemical name field, you must TAB or
hit ENTER to escape the field before using PgUp or PgDn.
When you have completed the form, return to the first screen (Company Information). Select
Save to keep your data in the background buffer, then Exit to leave the form input screens. You may
then print or permanently save the form to a file for transfer to other facilities that have the Electronic
Form Software, or for submission to EPA.
IUR 1998 B - 4
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FILLING OUT THE LONG FORM
The Long Form should be used when you want to report more than 10 chemicals for a
specific plant site. You may report as many chemicals as you wish.
The initial screen shows the chemical information for Line 1 of the form. The ADD button
will allow you to create new lines in the form. The NEXT and PREVIOUS buttons will allow
you to scroll through existing lines on the form. The COMPANY button will bring up a screen
which will allow you to enter the company/plant site information. Upon completion, you should
select SAVE, to store the information, then EXIT to return to the chemical information screen.
Selecting EXIT on that screen will take you out of the Long Form. If you have not saved the
company information, you will be prompted before you can exit the chemical information screen.
IMPORTANT! As with the Standard Form, do NOT use to exit the form.
FILLING OUT THE CORRECTION/CONTINUATION FORM
The Correction/Continuation form should be used to correct errors in reporting or to add
additional chemicals to a previously submitted form. You should already know the Report
Number of the form to which you are making corrections/additions. This form is filled out just
like the Standard Form, with the exception that you must supply the Line Numbers.
IMPORTANT! As with the Standard Form, do NOT use to exit the form.
EDITING AN ELECTRONIC FORM
To print or make changes to an existing electronic form, you may select the EDIT
FORM menu item. When you select the type of form you wish to work with (ie. Standard, Long
or Correction/Continuation), you will enter a form name retrieval screen. For the Standard and
Correction/Continuation forms there is one directory button that will give you assistance in
selecting the name of your form. The default directory is C:\CUS98, which is where the software
background forms are saved. A form stored with the software is automatically saved to the C:\
directory, but you can access any drive/directory that your computer will allow. When you have
selected a name, click the Edit button and the name will be transferred to the retrieval screen. If
you wish to continue select Retrieve, otherwise select Cancel. You may also cancel by using the
ESC button at any time during the process.
The Long Form uses 2 files: one beginning with an N (Company information) and the
other with an S (chemical information). If you choose to work with a Long Form, 2 directory
IUR 1998 B - 5
-------
buttons will appear to allow you to select both files. In this case, any file you may have saved will
have already been attached with the N/S prefixes (See the section on Saving A Form).
Once an edited form comes up, proceed just as if creating a new form. When you have
finished and exited the form, you must select the SAVE FORM menu item if you wish to
permanently save your changes. You could print out the changed information and then not save
the form, in which case the edits you made will not appear in the permanent file.
IMPORTANT! As emphasized before, do NOT use to exit the form while editing.
SAVING AN ELECTRONIC FORM
The SAVE buttons on the form input screens save the information to a background buffer
file. In order to store that data in a permanent, retrievable file, you must use the SAVE FORM
menu option. Note that this option is not available while you are doing data entry to a form; you
must exit the form properly (NOT using ) to be able to use the menu item.
The options available will depend upon the form that is in use. Whenever a form is exited,
it is still in the background until you use another form. If you try to use a new form without
saving the current one, you will be prompted to make sure you want to continue. If a Standard
Form is in use, then the only available option under SAVE FORM will be the Standard Form.
Thus there is no need to worry about what type of form you are saving. If you are editing a form,
the name will automatically appear in the form name box; you may change it if you wish.
If you are saving a Standard or Correction Form, you will be prompted for a drive
(available options are A, B, or C) and a name containing 1-8 characters. The default drive is set
to C; if you want another drive, click on that option. Do not include a prefix, nor the .DBF suffix
to the name. Once you save a form, you may call it back up through the EDIT FORM menu
option.
The screen for saving the Long Form is identical to the one for the Standard Form,
except for the length of the name allowed, which is 1 - 7 characters. This is because the form uses
2 files to store the information. The company/plant site file is prefixed with an "N", and the
chemical identity file is prefixed with an "S". As with the Standard Form, you need not include
the prefix or the .DBF suffix. When you wish to retrieve a form, you will be looking for the name
you chose when you saved it, prefixed by an "N" and an "S"; both files are critical for the form to
work.
A permanently saved form can be moved, renamed, or deleted using Windows or DOS. If
you rename a Long Form, be sure to include the proper prefix ("N" or "S"). When transferring
the Long Form to another facility, or submitting to EPA, be sure to include both files.
IUR 1998 B - 6
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PRINTING AN ELECTRONIC FORM
You can obtain hard copies of a form after creating or editing it by choosing the PRINT
FORM menu option. The type of form in use will determine which option is available. Note that
the menu item is not available while you are in the data entry screens.
You may not submit this printed form to EPA as an original submission. You may,
however, include a printed version in future correspondence with EPA.
The other print option available other than the type of form in use is the Certification
Letter. The company/plant site information from the form in use is automatically transferred to
the certification letter when you print it. Each electronic form submitted to EPA must be
accompanied by a signed Certification Letter.
The type of printer will be determined by the one that is use during the Windows session.
If there is a problem with the way the form prints, be sure that the printer you are trying to print
to is the same one defined by Windows.
GETTING HELP
If a question arises while using the electronic software, you can get help on a wide variety
of subjects by selecting the HELP menu item, or by pressing Fl at any time. The fourth screen in
the beginning sequence and a help menu item also direct you to a contact at EPA if you need
further information.
The information provided in this section is only intended as an overview to assist in using
the electronic form software. For specific instructions on filling out the form, you should consult
the appropriate pages in this instruction manual.
IUR 1998 B - 7
-------
MAILING INSTRUCTIONS
If the diskette contains confidential business information (CBI), it must be physically
labeled indicating that it "Contains TSCA CBI". It should be identified with the company name
and, if appropriate, the plant site. Read-only tab protection should be applied. If more than one
diskette is submitted by a company, the labels should also indicate the number and the total
number, e.g., disk 1 of 2, disk 2 of 2.
Diskettes should be placed in a durable mailing container. Damaged diskettes will be
returned to the submitter without further attempt by EPA to recover data. It is advisable to send
a backup diskette, in case of damage to the primary diskette.
All feasible precautions in mailing magnetic media containing CBI should be adopted by
the submitter for its protection, such as double wrapped envelopes, registered mail, etc., just as
one would apply to the hard copy submission. The signed Certification Statement should also
be included in the same mailing packet.
Cover letters accompanying any magnetic media submission should refer to the CBI status
of the submissions, and should list plant site, Form U numbers and the corresponding file names.
Number of records (chemicals) per file may also be specified. A technical contact name for data
processing matters, if different from the contact on the form, should be identified in the cover
letter.
Questions about the magnetic media submission instructions should be addressed to:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 554-1404
IUR 1998 B -
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