vvEPA
v
United States
Environmental Protection
Agency
Office of Toxic Substances April 1986
Information Management Division " TS-793
Washington DC 20460
Toxic Substances
Instructions for
Reporting for the
Partial Updating of the
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V
Instructions for Reporting for the Partial Updating
of the TSCA Chemical Inventory Data Base
U.S. Environmental Protection
Library, Boon 2404 PM-211-A
401 M Street, S.W.
•&5hln«ton. DC 20460
U.S. Environmental Protection Agency
Office of Toxic Substances
Washington, DC 20460
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Table of Contents
I. Introduction. 1
II. Determining the Substances for Which You Must Report...2
A. Report able substances 2
1. Inventory substances ...2
How to determine whether a chemical
substance is listed on the Inventory 2
2. Exempt substances 5
a. Determining whether a substance
is exempt. 5
b. When an exempt substance must
still be reported 5
Identifying substances subject
to section 5(a)(2) rules.. 5
Identifying substances subject
to section 4, 5(e)f 5(f) or 6
orders or rules 5
Chemical substances subject
to section 5(b){4) ......6
Current list of chemical
substances which are subject to
such rules and orders 6
B. Whether you are a manufacturer or importer
who is required to report a substance.. 6
1. 10,000 pounds or more ..6
Manufacturers 6
Importers 7
Companies that both manufacture
and import the same subs tance 7
Substances in a mixture... 7
Recordkeeping required. 7
2. Small manufacturers ' 7
When a small manufacturer
must still report 8
3. Circumstances under which reporting
is not required 8
Definition of an article 8
C. Decisionmaking 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 13
C. Duplicative reporting unnecessary 13
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IV. How to Report.. t. 14
r"
A. Form of submission '.. 14
B. Confidentiality... 14
C. Completing Form U 16
Report only using original copies of Form U...16
Block I: Certification Statement...,., 16
Block II: Technical Contact, Including
Company Identity 16
Block III: Plant Site... 17
Block IV: Chemical Substance Identity,
Activity, Confidentiality. 18
a. Line Number 18
b. CAS Registry or Other
Identifying Number .. 18
Procedures for obtaining CAS
Registry Numbers and Accession
Numbers from EPA 20
C. A, B, C, F, P, or T Codes 21
d. Specific Chemical Name. 22
e. Activity: -tManufacture or Import 22
f. Site Limited 22
g. Plant Site CBI Claim 22
h. Production Volume 23
D. Reporting by computer tape.... 23
1. When you may report by computer tape 23
2. Copies of Form U required 23
3. Data sets .23
4. Physical tape characteristics 23
5. Record layouts 24
6. Information on individual
chemical substances 24
E. Sending forms and tapes to EPA 24
F. Correcting errors in submissions for the
original Inventory 24
G. Recordkeeping requirements. 25
H. Special instructions for importers
and foreign suppliers. . 25
V. Obtaining Copies of Documents
Cited, in These Instructions 28
A. Obtaining copies of TSCA Regulations 28
B. Obtaining copies of the Inventory 28
1. Obtaining copies of the printed edition
of the Inventory . 28
. 2. Obtaining the Inventory in
computer-readable form.... 28
C. Obtaining copies of Form U 30
VI. Requesting Assistance in Reporting .31
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INSTRUCTIONS FOR REPORTING FOR THE PARTIAL UPDATING
OF THE TSCA CHEMICAL INVENTORY DATA BASE
I. INTRODUCTION
Under the authority of section 8(a) of the Toxic Substances
Control Act (TSCA), the Environmental Protection Agency (EPA) has
promulgated a rule for the partial updating of the TSCA Chemical
Inventory data base, comprising Subpart B of 40 CFR Part 710.
This rule, hereinafter referred to as the Inventory Update Rule,
requires manufacturers and importers of certain 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.
This booklet provides detailed instructions and illustrative
examples to assist manufacturers and importers in reporting under
.the Inventory Update Rule. However the booklet is not a
substitute for the rule, and 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; Subpart A of 40 CFR §?10 prescribes criteria for
inclusion of a substance on the inventory.
See section V below 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:
A) Is the substance reportable under the Inventory Update
Rule?
B) Are you a manufacturer or importer who is required to
report the substance?
A. Reportable substances*
To be reportable under the Inventory Update Rule, a chemical
substance must meet two requirements:
1) The substance must be included in the TSCA
Chemical Inventory,
2) The substance must not be of a type exempt from •
reporting under the Inventory Update Rule.
1. Inventory substances. Under section 8(b) of TSCA, EPA
maintains and keeps current the TSCA Chemical Inventory. The
scope of the Inventory is explained in the original Inventory
reporting rule (40 CFR Part 710). The Inventory contains
chemical substances reported as existing in commerce by
manufacturers, importers and processors in 1978, 1979, and 1980
under the Inventory reporting rule, and chemical substances whose
commencement of manufacture or importation has been reported to
EPA after these substances have undergone premanufacture
notification (PMN) review under section 5 of TSCA.
EPA keeps 'a Master Inventory File which contains all the
eligible chemical substances which have been reported to EPA for
inclusion in the Inventory. The Master Inventory File is the
authoritative list. EPA also makes available a public version of
the Inventory, in printed and computer-readable form. This
public version does not contain the specific identities of
chemical substances where these identities have been claimed as
confidential business information (CBI) and the CBI claims are
acceptable. However, the printed version does contain generic
chemical names for these CBI chemical substances. The public
version of the Inventory is updated periodically. Both the
printed and computer-readable versions are current as of July
1985. See section V, below, for information on obtaining copies
of the public version of the Inventory.
How to determine whether a chemical substance islisted, on
the Inventory. Many manufacturers and importers have already
determined that the substances they manufacture or import are on
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the Inventory. You may have been able to make such a
determination if:
you have located the substance in a previous edition of
the public Inventory;
you reported the substance to EPA in 1978, 1979 or 1'980
under the Inventory reporting rule;
the Agency has informed you that the substance is on
the Inventory, in response to a PMN, Test Market
Exemption Applicatipn, bona fide request, or other
communication; or
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 examine a
copy of the latest public version of the Inventory (see section
V, below, for instructions on how to obtain a copy). The printed
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 and indicate whether a given chemical
substance is;included on the Inventory. EPA cannot guarantee 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 substances are on the-
Inventory, you may proceed to section II.A.2 to determine whether
they.are of a type exempt from reporting under the Inventory
Update Rule.
If you are still uncertain as to whether a chemical
.substance is listed oh the Inventory you should write EPA at the
following address:
OTS Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
. Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
° Attn: Inventory Update Rule
i.
Your letter will cause EPA to search the Master Inventory
File, including confidential substances, to determine whether the
substance is listed. To request such a search, you must
substantiate the fact that you are actually manufacturing or
importing the substance in question. Include the following
information: .
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(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 Reigistry
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;
(5) an elemental analysis of the substance; and
(6) either
an X-ray diffraction pattern (for inorganic
substances),
- or a mass spectrum (for most other
substances),
- or an infrared spectrum of the particular
chemical substance,
or if such data do not resolve uncertainties
with respect to the specific identity of the
substance, additional or alternative spectra
(e.g. nuclear magnetic resonance: spectra) or
other data to identify the substance.,
If you are an importer and cannot provide all of the
required information because it is claimed as confidential by the
foreign manufacturer/supplier, the manufacturer/supplier can send
the information directly to EPA.
Information in these letters may be claimed as confidential
by circling or bracketing the text to be protected and marking
the page, "CONFIDENTIAL.11 Failure to so mark 'this information
may result in EPA making the information available to the public
without further notice to you.
Because searches of the Master Inventory File take a
considerable amount of time to process you are urged to request
them only if a search of the public version of the Inventory,
commercial databases, and your company's records fails to resolve
the 'question. Moreover, ifr your request is not received prior to
60 days before the end of the reporting period (see section III
for matters of timing), EPA cannot guarantee that you will
receive a response in time for you to complete the reporting form
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before the end of the reporting period.
2. Exempt substances. Four categories, of substances,
though included on the Inventory, are largely exempt 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 for more precise definitions of these
categories.
Be aware that the definition of polymers for purposes, of the
Inventory Update Rule is sufficiently broad to include virtually
all those substances that are generally considered polymers.
These include polysaccarides 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 exempt.
a. Determining whether a substance is exempt. To assist
identification of exempt substances, most of these substances are
labelled in the printed and computer-readable versions of the
Inventory with an "XU" flag. However, due to difficulties in
developing a computer algorithm for identifying all such
substances in the Inventory, EPA was not able to flag all exempt
substances. For example, inorganic substances and biopolymers
found in the UVCB Index section of the public Inventory (chemical
substances of janknown or jyariable composition, Complex reaction .
products, and Biological materials) are generally not labelled
with an XU flag.
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 exempted, you may request
assistance from EPA (see section VI, below, for inquiries).
b. When an exempt substance must still be reported. With
the -exception of naturally occurring substances, a chemical
substance which falls into one of the exempt 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.
Identifying substances subject to section 5(a)(2) rules.
The public Inventory identifies with an "S" flag substances which
were, as of July 1985, the subject of a proposed or promulgated
rule under section 5(a)(2) of TSCA (Significant New Use Rule).
Identifying substances subject to section 4, 5(e), 5(f) or 6
orders or rules. Indices to. chemical substances covered by
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section 4 rules, section 5{e) orders, and section 5(f)/ rules can
be found In volume V of the printed version of the Inventory. An
attachment to these reporting instructions lists chemical
substances covered by these rules and orders as of May 1986. The
Agency plans t,o issue .revised lists before each recurring
reporting period.
Chemical substances subject to section 5(b)(4). No chemical
substances are subject to section 5(b)(4) of TSCA as of the
publication of these instructions.
Current list of chemical substances which are subject to
such rules and orders. Because additional chemical substances .
have been regulated under these sections of TSCA since the lists
discussed above were created, these lists are not exhaustive. A
more current list is included as a supplement to these reporting
instructions.
B. 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. 10,000 pounds or more. 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. Reporting is required for a chemical
substance only if you manufactured 10,000 pounds (4,540
kilograms) or more of the substance at any single site during the
corporate fiscal year immediately preceding the reporting period
(see section III, below, regarding matters of timing). 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 report the substance only for those sites at which you
manufactured 10,000 Ibs. or more.
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Importers. The site of importation is defined.in section
710.28(c) of the Inventory Update Rule as the site of the
operating unit within your organization which is directly
responsible for importing the substance aha!"..which; controlsthe .
import transaction. In some* cases, this; may-be the. $ite;:, df^your
headquarters, in others a specific plant site. You need report
only for those sites which imported 10,000 pounds or more of the
reportable substance during the corporate fiscal year immediately
preceding the reporting period.
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.
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.
Substances in a mixture. Although mixtures 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.
Recordkeeping required. 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).
2. Small Manufacturers. (For the purposes of the following
discussion, the term "manufacturers" refers to both manufacturers
and importers.) Small manufacturers are in most cases exempt
from reporting under the Inventory Update Rule (but see below).
You qualify as a small manufacturer if you meet either one of the
following tests:
1) Your total annual sales, combined with those of your
parent company, domestic or foreign (if any), do not
exceed $40 million and your annual production volume
does not exceed 100,000 Ibs. (45,400 kg.) of-the
reportable substance at any, plant4site• If the annual
production volume of the substance at one site is over
100,000 Ibs., you are required to report only for the
substance at that site. Note that it is possible to
qualify as a small manufacturer with respect to a
substance with an annual production volume under
100,000 Ibs. while not qualifying with respect to a
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substance with an annual production volume over 100,000
Ibs.
2) 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.
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.
3. Circumstances under which reporting is not required.
Persons who manufacture or import reportable substances under the
following circumstances are not required to report for those
substances under the Inventory Update Rule:
a. The chemical substance is manufactured or imported
solely for research and development.
b. The chemical substance is imported as part of an
article.
c. 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).
Definition of an article. 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
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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.
C. Decisionmaking flow chart.
The following flow chart summarizes the questions which must
be answered to determine your reporting obligations for a
particular substance:
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DECISIONMAKING FLOW CHART FOR REPORTING
UNDER THE INVENTORY UPDATE RULE
Is-this substance listed I
on the TSCA Chemical Inventory?!
NO
YES
Is this substance a
polymerr inorganic substance,
microorganism, or
naturally occurring?
NO
YES
Is the substance
subject to a
special regulatory
action under TSCA?
NO
YES
Did you manufacture or import
10,000 Ibs. or more per year
at a single site?
YES
Are you a smal
NO
manufacturer
for this substance?
NO
YES
Is the substance
subject to a
special regulatory
action under TSCA?
NO
YES
Did you manufacture or import
the chemical substance under circumstances
for which reporting is not required?
NO
YES
You need not
report
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D« Manufacture or importation of chemical substances subjectto
TSCA but not :.ncluded 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.
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:
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circling or bracke
Director, Compliance Division
Office of Compliance Monitoring (EN-342)
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Attn: Document Control Officer
Information i.i your letter may be claimed as confidential by
:ing 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 nouice 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 afterjyou 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 an initial reporting
period and recurring reporting periods, which occur four years
after the initial reporting period and once every four years
therafter. A reporting period serves three functions:
A) It is a 120-day period during which reports for the
Inventory Update Rule must be filed.
B) It is used to determine the applicable fiscal year for
calculating annual production volume.
C) It defines the period during which submitting
information in response to another TSCA section 8(a)
rule exempts you from reporting under the Inventory
Update Rule for that reporting period.
A. You must report during the 120-day reporting period.
The initial reporting period begins 74 days after the
publication of the Inventory Update Rule in the Federal Register,
and lasts 120- days* (Because these reporting instructions were
written before publication of the rule in the Federal Register,
the exact dates cannot be given here. Please consult the
rule.) All submissions must be postmarked no later than the
closing date of the reporting period. If you are required to
report (see section II., above), failure to file your report
during this period is a violation of section 15 of TSCA.
EPA will notify persons submitting reports of minor errors
in their submissions and will allow 15 business days from the
date of receipt of the notification or the end of the reporting
period, whichever is later, to make the corrections. Persons
requesting searches of the Master Inventory File (see section
II.A.I. above) 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 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.
The next reporting period begins 4 years from the beginning
of the first; subsequent reporting periods begin every four years
after that. Each reporting period lasts 120 days. EPA will
publish reminder notices before these reporting periods begin.
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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 production/import volume for your last
corporate fiscal year which ends before .the reporting period
begins. If the initial reporting period were to begin on, for
example, July 1, .1986, someone whose fiscal year is the calendar
year would determine production or import volume for the period
January 1, 1985 - December 31, 1985, while someone whose fiscal
year is July 1 to June 30 would determine production or import
volume for the period July 1, 1985 - June 30, 1986.
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.
C. Duplicative reporting unnecessary*
If you have submitted the information on a reportable
substance 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,
promulgated in 1982), and a reporting period begins within one
year of such submission, you are not required to report under the
Inventory Update Rule for the same substance for that reporting
period. ' ..
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IV. HOW TO REPORT
A. Form of submission.
Information Reported -for the Inventory Update Rule must be
submitted either on Form U or by computer tape (see subsection
C., below). Form U has two copies; retain one copy for your
company records and submit the other copy to EPA (see subsection
E., below, for transmission instructions). Separate forms are
required for each site.
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.
You may assert a CBI claim for the specific identity of a
chemical substance only if EPA treats that substance as
confidential on the Inventory as of the time your report is
submitted. If you claim chemical identities as CBI, you must
report using Form U and not a computer tape. In additiOQr CJBI
and non-CBI chemical substances cannot be mixed on the same form;
separate forms must be used.
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.
t
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 this information may result in EPA making the information
available to the public without further notice to you..
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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?
a specific date, the occurrence of a specific event, or
permanently? Why?
Until
(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 oeen 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.
-------
C.
-16-
Completing Form U.
Report only using original copies of Form U.
Each copy of Form U bears an individual report number. Do
not report on a photocopy of Form U, because it will not have a
unique report .number. See section V, below, for obtaining copies
of Form U.
Block I: 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 Form U
for details). Sign in black ball-point pen to ensure that both
copies of Form U bear a legible signature which can be
microfiched.
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.
SAMPLE BLOCK I
{.Certification Statement: 1 hereby certify to the best of my knowledge and belief that (1 ) all information entered on
this form is complete and accurate, and (2) the confidentiality statements on the back of this form are true as to that
information for which 1 have asserted a confidentiality claim.
^"TVaMt &MAUL.
D*U» - 1 Name/Title (Type or Print)
9/14/86 1 Marie Curie, President
FORM
U
Block II; Technical Contact, Including Company Identity.
Enter the name, company, address, and telephone number of
the person(s) 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. Post
office box numbers are not sufficient.
Checking the CBI box in this block asserts a confidentiality
claim for the link between your company and the chemical
substances reported on the form. Claiming this link as
confidential is to be distinguished from claiming that the
substances reported on the form are confidential (see Block IV,
below). The claim in Block IV asserts as confidential the fact
that the chemical substances are on the Inventory (and requires
substantiation, as discussed above) while the claim in Block II
asserts as confidential the fact that your company is
manufacturing or importing the substances, and does not require
substantiation (other than signing the certification statement in
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-17-
Block I). Checking the CBI box in Block II also asserts a CBI
claim for the signatory in Block I, but not for the site in Block
III.
If there are some substances for which confidentiality is
not necessary for the link between them and your company, report
those substances on a separate form on which the CBI box in Block
II is not checked.
SAMPLE BLOCK II
II. Technical Conlact./Marne. Company. Street address. City. Stale. ZIP Code)
Niels Bohr, Mgr., Env. Affairs
Quantum Chemicals, Inc.
602 E. 23rd Street
Octet, MA 00000
Telephone No. (include Ant Coda)
617-555-3333
Slock III; Plant Site. n
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 and street address of that site and its Dun & Bradstreet
number here. Post office box numbers are not acceptable. If the
site is not recorded by Dun & Bradstreet, a Dun & Bradstreet
number assignment can be requested from your local office of Dun
& Bradstreet, free of charge. For questions concerning
determining the site of importation for purposes of this rule,
see section II.B.I. above and 40 CFR §712.3(d).
See Slock IV, column g for CBI claims for links between'
plant site and individual substances.
SAMPLE BLOCK III
111. Pteni SU» f Warns. Street address. City, State. ZIP Code)
Quantum Chemicals, Orbital Div.
123 Acetylene Avenue
Titrate, CA 99999
Dun & Bradstreet Number
98-765-4321
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-18-
Block IV; Chemical Substance Identity, Activity,
Cpnfidentlality•
Confidential and non-confidential chemical substances cannot
be reported on the same form. All confidential chemical
substances reported for one plant site should be submitted
together on one form (or more as appropriate) and all non-
confidential substances for that site on another. Check the
appropriate confidential/nonconfidential box at the top of column
d of Block IV to indicate whether the form reports CBI or non-CBI
substances (see sample form).
a. Line Number. Block IV is. divided into ten lines to
allow reporting of up to ten chemical substances per form. But
if the chemical identity will not fit on one line, you may use
several lines to report a single chemical substance.
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 line 8 of
sample form) or other identifying number. The printed editipn of
the Inventory contains detailed instructions on how to locate the
CAS Registry Number, for a substance listed therein.
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 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.
You are urged to 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.
(1) EPA Accession Number. (See line 1 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, 1979, or 1980 or following commencement of
manufacture or import of a substance for which you filed a
premanufacture notice.- If you use a generic chemical identity in
the printed Inventory to find the Accession Number, you may end
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-19-
SAMPLE BLOCK IV
IV. Chemical Substance Identity/Activity/Confidentiality
a
i
4
N
0
1
2
3
4
5
6
7
a
9
10
b \ c / d \ e
\ A ABCF.ParT
\0naina\ »=A«esstof
\ ?'Z\ B'Bona'ftde
\ l"«n-\ C^ASR^S,,
\ '^Y \ ( - fVimnal In
CAS Registry and.or \l fcportV JJ [jg^ „
Other \ Line \ p=PMNNo
Identifying Nurntar \ No VTMEANI
29735
59963
=;? ft^nm4c'.
33649773
53437422
P-85-131
T-85-35
5165-81-1
14679997 •
—
—
—
—
21
A
A
B
F
F
P
T
C
4.
F
Ho / • \ Activity
Kc / All Cnem>cal SuDSiance Identities or This Form Are Claimed \ M = Manufacture
1 No / ' ' \ 1 = Import
™~/ fxl Confidential LJ Noncontidemiai \
/ Swcilic Cnemcal Name \
.1-Napthalenanine , 4- [ ( 2-brono-4 , 6-dinitro-
phenyl) azo] -N-ethyl-
2,7-Naphthaleneciisuitanic add, 4-amino-
5-hydrc(xy-3- [ (4-riitrophenyl) azo] -
6- [ { 3-sulf ophenyl) azo] - , compound with
N-octyl-1-octanamine (1:3)
1 , 2-Ethanediamine , N-ethyl-N ' ,N ' -dimethyl-
1,3-Propanediarainium, N,N,N,N',N' ,-
pehta-methyl-N ' - [3- [ (tetramethylnonyl) oxy]
prppyl] -dichloride
Benzenamine, 4-^-heptyH'J-phenyl
2-llaphthalenecarboxylic acid, 3-hydroxy-
4- [ (2-methoxy-4-nitrophenyl) azo] -
.
Benzenamine, 4-heptyl-N^phenyl
2-Haphth-o-ansidine , 4 ' -chloro-3-hydroxy-
5'-methyl-
Methacrylic acid, 2-ethylbutyl ester
M
CBI
D
M
CBI
I
CBI
M
CBI
|xl
I
CBI
[x|
I
CBI
D
M
CBI
D
M
CB1
D
i
CBI
[xl
CBI
n
(
Sue
Limited,
CBI
CB1
D
CBI
X
CBI
fxl
CBI
CBI
D
CBI
D
CBI
CBI
D
CBI
D
g
Plant
Site
CBI
Claim
•
CB1
&SsS
CBI
(II
CB1
.D
11
CBI
s
•
CBI
[x]
CBI
mm
CBI
D
&'^&
CBI
%&&&
mm
CBI
D
:;:•:•:•:*:•:•:•;•
CBJ
D
h
Production
Volume
Ipounds)
11 ;000
CBI 0
17lU65
CBI G
24,000
CBI n
43,000
CBI [x]
20,000
CBI O
67,000
CBI H
170,000
CBI Q
93,000
CBI H
120,000
CBI n
CBI n
The substances on this sample form are listed as confidential
only for purposes of illustration. ^
-------
-20-
up reporting for the wrong substance. An Accession Number may
not be used for a non-confidential chemical substance. A typical
Accession Number is in the form "29735".
(2) Original Inventory Report Number. In 1978, 1979
and 1980, 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 an original Inventory report form
number as an identifying number. Since both "A" and "B" forms
allowed reporting of several chemical substances, if you use an
original Inventory report number, from an "A" or "B" form you must
also include the line number for that chemical substance in the
space marked "Original Inventory Report Line Number" (see line 9
oh sample form). If you originally reported on a "C" or "E"
form, leave the line number space blank (see line 4 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.
(3)
sample form.)
Premanufacture Notice Number^. (See line 6 of
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 is in the form
"P-85-243". Note that the fact that a chemical substance has a
PMN number does not necessarily mean that the substance is
reportable; it is included on the Inventory only if a Notice of
Commencement was received for the substance.
(4) Bona Fide Request Control Number. (See line 3 of
sample form.) If you filed a Bona Fide Intent to Manufacture or
Import (see 40 CFR §710.7(g) or §720.25(b)) a chemical substance
which is now reportable under the Inventory Update Rule, you may
use the document control number assigned that submission by EPA
as an identifying number. A typical Bona Fide document control
number is of the form "52-8500287". Note that the fact that a
chemical substance has a Bona Fide document control number does
not mean that the substance is on the Inventory and reportable;
you must have independent confirmation that the substance is on
the Inventory (e.g. 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 is in the form "T-85-27". You should use a TMEA number
only if you know that the chemical substance is on the Inventory
(e.g. the Agency told you so when you submitted the TMEA).
Procedures for obtaining CAS Registry Numbers and Accession
Numbers from EPA.If by one of the methods discussed in section
II.A., above, you were able to determine that the substances you
manufacture are on the Inventory, you should already have
-------
-21-
/•
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.
Nevertheless there may be some manufacturers or importers
who reported for the Inventory in 1978, 1979 or 1980 but no
longer have the original report forms. In this case you must
request an identifying number from EPA. Send a letter to the
following address:
OTS Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W. '
Washington, DC 20460
Attn: Inventory Update Rule
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 title, address,
and telephone number). The structure of the substance, if
available, should also be provided.
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, 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 45 days or more before the end of a reporting period;
otherwise the Agency cannot guarantee a response in time for you
to meet your reporting obligations.
c. A, B, C, F, P, or T Codes. Indicate in this column the
type of identifying number you entered in column b.'
-------
-22-
d. Specific Chemical Name. 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 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.
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 H., below.
e. Activity; Manufacture or Import. Enter "M" in the
space above the CBI box if you manufacture the reportable
substance, and "I" if you import it. 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.
f. Site Limited. Enter "X" in the space above the CBI box
if you manufacture the chemical substance at the plant site
identified in Block III and do not distribute the chemical
substance or any mixture containing that substance outside the
plant site for commercial purposes. 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.
g. Plant Site CBI Claim* The connection between an
individual chemical substance and its plant site may be claimed
as confidential .by checking the CBI box. Checking the CBI box
for company identity (Block II) does not claim the plant site as
confidential. Therefore if you have checked the CBI box in Block
II, and the name and address of the plant site would reveal the
identity of your company, you should also check the CBI box in
column g for this substance. Note that on one reporting form you
-------
-23-
may claim this connection,as CBI for some chemical substances
while not making that claim for others.
h. Production Volume. Enter your annual production volume
or importing volume (as appropriate), in pounds, for the. fiscal
year preceding the reporting period, in the space above the CBI
box. 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). If you wish to claim this information, as confidential
for this substance, check the CBI box.
D. Reporting by computer tape.
1. When you may report by computer tape. Computer tapes
may be .used only under the following circumstances:
a. All chemical substances reported on the tape must be
non-conf idential. EPA will not accept tapes containing
information on confidential chemical substances.
b. You must be reporting on at least 100 chemicals to
report by computer tape. The 100+ chemicals may be
spread over several plant sites, but you must establish
a separate data set for each site (see below).
2. Copies of Form U required. The tape must be accompanied
by a separate copy of Form U for each site reported on the
tape. Blocks I, II, and III on Form U must be filled out as
described in subsection C., above. Block IV on Form U should not
be filled in; in its place include a statement that the required
information is being submitted on tape as well as the tape number
and other pertinent tape identifier information (this should
match the information on the label affixed to the tape).
3. Dal:a sets. , .A separate data set must be established for
each site reported on the tape. For each site, include in Block
IV of the Form U for that site the data set name, the number of
chemicals reported, and the number of records for that site.
4. Physical tape characteristics. The following
characteristics are mandatory. Deviations will not be accepted,
and tapes not conforming to these specifications will be
• returned:
o 9-TRACK
o 6250 BPI
O EBCDIC •'."•'
O UNLABELED
O RECFM » VB -
O LRECL = 155 -
o BLKSIZB - 18,154
-------
-24-
All fields must be DISPLAY format.
5. Record layouts. Detailed information on record layouts
must be obtained by contacting:
OTS Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 382-3698 or (202) 755-4880
6. Information on individual chemical substances. See
instructions for completing Block IV in section C., above.
E. Sending forms and tapes to EPA.
Form U has two copies. Keep the yellow copy for your
records, and send the original, along with any accompanying
tapes, to the following address:
OTS Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
If you wish acknowledgement from EPA of receipt of your
forms and tapes, you must send with the forms and tapes a cover
letter listing the enclosed form numbers and tape reel numbers,
and a request for acknowledgement.
F. Correcting errors in submissions for the original Inventory.
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;
-------
-25-
you should file an Inventory Correction, following the procedures
outlined in the Federal Register notice of July 29, 1980 (45 PR
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:
OTS Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 382-3698 or (202) 755-4880
Inventory Correction requests should be filed with your
copies of Form U. Note that Form U should report the chemical
substance you are actually manufacturing or importing and should
reference the number of the correction form you submit.
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.
G. Recordkeeping requirements.
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
end 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.
H. 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:
-------
-26-
1.
2.
3.
4.
5.
Use a separate Form U for each foreign supplier who
dpes not inform you of the identity of the chemical
substances you are importing. Do not report by
computer tape. Do not use the same report form fpr
substances whose specific identities you do know.
.Separate the original and carbon copy of Form U before
entering any information on the form.
On the original copy, complete Blocks I and III, and
columns e, f, g, and h of Block IV, as described in
subsection C., above. In column b of Block IV, enter,
instead of the identifying number, the trade name or
other designation by which you know each chemical
substance. Leave column c blank. In column d, enter
the following statement: "The identifying numbers and
specific chemical identities for the substances on this
form and the technical contact will be submitted by our
foreign supplier." Check the "Confidential" box in
column d only if you wish to claim the identities of
the chemicals identified on the form as confidential
(you must answer the substantiation questions in
subsection B., above). Make a photocopy of this
document for your own records and send the original to
EPA.
On the yellow copy, complete only Block III.
copy to your foreign supplier.
Send this
The foreign supplier should complete Blocks I and II
(the technical contact here should be the foreign
supplier) and columns b and c of Block IV (see
subsection C. , above, for instructions) and should
enter the appropriate specific chemical identities in
column d. Make sure that your 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 column d 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 an importer.
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 the yellow copy of
Form U (including any relevant CBI claims) and that the supplier
-------
-27-
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.
-------
-28-
V. OBTAINING COPIES OF DOCUMENTS CITED IN THESE INSTRUCTIONS
A« Obtaining copies of TSCA regulations.
Copies of TSCA regulations can be obtained by contacting:
OTS Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 382-3.698 or (202) 755-4880
B. Obtaining copies of the Inventory.
1. Obtaining copies of the printed edition of the
Inventory"The official title of the five-volume printed edition
of the Inventory is "TSCA Chemical Substance Inventory: 1985
Edition." A copy may be purchased from:
Superintendent of Documents
Government Printing Office
Washington, D.C. 20402
Order Desk: (202) 783-3238
The price is $161.00 in the U.S. and Canada, $201.25
elsewhere. If ordering by mail use the order form on the next
page. GPO will also accept orders by telephone; MasterCard and
Visa are accepted. Refer to stock number 055-000-00254-1.
Please allow 4-6 weeks for delivery (longer outside the U.S.).
2.
rig the inventory in computer-readable form. The
liable in the form of three computer tapes. The
first tape lists the chemical substances by their Chemical
Abstracts Service (CAS) Registry Numbers, Index or Preferred
chemical names, and where appropriate, molecular formulas. An
alphabetical listing of chemical synonyms for the substances is
also included, as are "XU" flags for substances exempt from
reporting under the Inventory Update Rule (see section II.B.2.a.,
above). The listed synonyms include only those reported to EPA
for these substances (in contrast to the printed Inventory, which
also includes synonyms derived from CAS files). The tape
contains neither generic names nor Accession Numbers for
substances with confidential identities. The second tape
contains plant site names and addresses and Manufacturer
identification Numbers. The third tape contains submitter
identity information and production and import statistics. No
confidential information appears on any of these tapes. Copies
of the documentation for the computer tapes are included with the
tapes. Each of the three tapes may be ordered separately.
-------
T5CA CHEMICAL SUBSTANCE INVENTORY: 1985 Edition
The Toxic Substances Control Act (TSCA) Inventory
lists over 63,000 chemical substances (as defined by
TSCA) whose manufacture, importation, or processing for
commercial purposes in the United States has taken
place since January 1, 1975.
The printed inventory is a 5-volume set containing
TSCA Inventory substances listed by Chemical Abstract
Service (CAS) Registry Numbers or Accession Numbers
(Volume I). Indexes are provided for Substance Names
(Volumes II & III), Molecular Formulae (Volume IV) and
Substances,of Unknown or Variable Composition, Complex
Reaction Products and Biologicals, and Substances Subject
to Regulatory Action (Volume V).
Those who wish to purchase 5-volume sets should
fill out the attached order form and mail it to:
Superintendent of Documents, Washington, DC 20402.
>109
CHEREOM
Mail to: SLflperirtercferit of Qxxnents
Wtehirgten, DC 20402
(202) 783-3238
f~"| Yes, please send me sets of the 5-volume TSCA Inventory: 1985
Edition at $161.00 per set for the U.S. and Canada; and $201.25 for anyone outside
of the U.S. or Canada. (S/N 055-000-00254-1)
The total cost of my order is $ '
(Please type oar print.)
Please check method of papnert:
Q Check made out to the
• Superintendent of Qxxnents.
(Name)
(Aitass)
(AHiticnal address)
(Additional address)
(City, State and Zip Oxfe)
Q C3EO Deposit Axxxnt. | I I I I I
Q VISA, MasterCard cr Choice.
(Signature)
(Credit Card Expiration De
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Ordering information for these tapes may be obtained by
contacting:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4850
C. Obtaining copies of FormU.
Copies of Form U may be obtained from:
OTS Document Control Officer (Room E-201) . ,
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 382-3698 or (202) 755-4880
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VI. REQUEST-ING ASSISTANCE IN REPORTING
Should you need information on or assistance in the
following areas:
o determining your reporting obligations;
o the mechanics of completing Form U;
o entering data onto computer tape; or
o determining the status of forms/tapes you have
submitted to EPA,
you may write to or call the following address:
OTS' Document Control Officer (Room E-201)
U.S. Environmental Protection Agency
Office of Toxic Substances (TS-790)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 382-3698 or (202) 755-4880
*U.S, Govirnmtnt Printing Offiw. 19l«-sio-s»o/»OBB»
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