vvEPA
United States
Environmental Protection
Agency
Office of
Toxic Substances
Washington, DC 20460
June 1979
Toxic Substances
Contractor's Report
An Analysis of the
EPA Chemical Use
Classification System
and the OTS Exposure
Estimation Methodology
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Foreword
The EPA Chemical Use Classification System (CUCS) has been
under development in the Office of Toxic Substances (OTS) for
approximately a year and a half. This complex and difficult task
has been through several phases, and through this effort OTS has
learned a great deal about how chemicals are used and how they
flow through the market. Development of CUCS will continue for
several more months before it is proposed for use under TSCA
reporting rules.
This report includes an independent evaluation of CUCS by
Stanford Research Institute (SRI), an EPA contractor. SRI
received the system from the Technical Monitor in early May 1979,
and completed the evaluation in late June 1979. During this two-
month period, conversations and review sessions with this
contractor revealed several problems that are detailed in this
final report. OTS has been actively working on CUCS development
since receiving it from another contractor in mid-April 1979, and
had independently identified many of the problems noted by SRI.
The most significant problems relate to the instructions for
using the system and the list of applications. SRI identified
several inadequacies in the instructions. Unfortunately, some
ambiguities in the instructions led SRI to make assumptions which
affected much of the rest of their analysis — assumptions that
were not representative of actual OTS intentions for CUCS. The
SRI analysis, in combination with an ongoing analysis by OTS,
proved very beneficial in completely revising these
instructions. The other major area of concern for SRI was the
list of applications. OTS has plans for extensive revision of
the applications list both in response to SRI's criticisms and as
a result of other concerns identified by OTS. Thus, many of the
problems that SRI identified have been or will be resolved as OTS
completes development of CUCS.
In summary, CUCS is under continuing development. This
report analyzes the system at about the halfway point in its
development and should be read in that light. OTS believes that
this report has been a useful contribution in the development of
CUCS.
Steven L. Wilhelm, (Technical Monitor)
Chemist, Program Integration Division
August 20, 1979
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EPA 560/13-79-007
AN ANALYSIS OF THE EPA CHEMICAL USE
CLASSIFICATION SYSTEM AND THE OTS
EXPOSURE ESTIMATION METHODOLOGY
June 1979
Contract No. 68-01-4109
Research Request No. 4
Project Officer: James Darr
Technical Monitor: Steve Wilhelm
Prepared for:
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
iii
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NOTICE
This report has been reviewed by the Office of Toxic Substances,
EPA, and approved for publication. Approval does not signify that the
contents necessarily reflect the views and policies of the Environmental
Protection Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use.
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PREFACE
This report was prepared by an interdisciplinary team under the
general guidance of the Project Officer, James Darr, the initial EPA
Technical Monitor, Henry Lau, and the EPA Technical Monitor during most
of the work, Steve Wilhelm. The SRI International team consisted of
Jeffrey Allport, Sharon Casey, Janet Hardy, Buford Holt (Task Leader),
and Kirtland McCaleb (Project Leader). Assistance was also provided in
certain areas by Stephen Brown, Eleanor Connolly, David Cox, Mary Doeltz,
Douglas Fowler, Richard Gerry, Alexi Miller, Benjamin Suta, Laurie Swett,
and John Toevs.
Vll
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CONTENTS
NOTICE v
PREFACE vii
I INTRODUCTION 1-1
Background 1-1
Objective 1-2
II SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS 2-1
Summary 2-1
Task 1 2-2
Subtask A. Review of Industry Comments 2-2
Subtask B. Trial Run on Selected Chemicals
and Product Types 2-2
Subtask C. Overall Evaluation of the Use
Classification System 2-2
Task 2 2-3
Conclusions 2-4
Task 1 2-4
Task 2 2-4
Recommendations 2-5
III EVALUATION OF THE USE CLASSIFICATION SYSTEM 3-1
Subtask A: Review of Industry Comments 3-1
General Comments 3-2
Specific Suggestions for Changes 3-3
Suggestions for Using Different Sources 3-4
Suggestions of Alternative Approaches 3-5
Subtask B: Trial Run on Selected Chemicals and
Product Types 3-6
Classification of Uses of Five Selected Chemicals . . . 3-6
Classification of Functions and Applications of
Chemicals in Selected Product Types 3-10
Subtask C: Overall Evaluation of the Use Classification
System 3-29
Instructions for Reporting Chemical Uses 3-30
List I (Functions) 3-35
Index to List I 3-39
List II (Applications) 3-42
Index to List II (Applications) 3-46
ix
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IV EVALUATION OF THE OTS EXPOSURE ESTIMATION METHODOLOGY. ... 4-1
Introduction ........................ ^~1
The Exposure Estimation Methodology ............ 4~2
Modification of Methodology ................ ~
Applications of Methodology to New Chemicals/New Uses ... 4-8
Probability That Estimate Components Are Accurate . . . 4-8
Significance of Scoring Errors ............ A IT
Accuracy of Methodology ................
Application of Methodology to Old Chemicals/Old Uses .... 4-14
APPENDICES
A CHARACTERISTICS OF INDUSTRY COMMENTS BY TYPE OF RESPONSE . . A-l
B CLASSIFICATION OF USES OF FIVE SELECTED CHEMICALS ...... B-l
C CLASSIFICATION OF FUNCTIONS AND APPLICATIONS OF CHEMICALS
IN SELECTED PRODUCT TYPES ................. c~[
D INSTRUCTIONS FOR REPORTING CHEMICAL USE
E FUNCTION TERMS DEFINED AS CONTAINING TWO OR MORE
FUNCTIONS ......................... E-l
F SIGNIFICANCE OF THE ASSUMPTIONS .............. F-l
TABLES
1 OTS Modification of Factors to be Used in Measuring the
Amounts of Contact 4-3
2 Proposed Factors to be Used in Measuring the Amounts
of Contact 4-6
x
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I INTRODUCTION
Background
As part of its responsibilities under the Toxic Substances Control
Act (TSCA), the Environmental Protection Agency (EPA) may ask manu-
facturers, importers, and processors of commercial chemicals to report
on the uses of these chemicals. In anticipation that such use informa-
tion will be sought and that it will need to be collected and stored in
a logical manner, EPA's Office of Toxic Substances (OTS) contracted with
Auerbach Associates, Inc. (now known as Calculon) to prepare a Use
Classification System. The system developed by Calculon in 1977
identifies the use of a particular chemical by combining a unique
function with a unique application. It was used to produce a Chemical
Use List, containing approximately 800 function/application combinations,
which was published with a request for public comment, in the Federal
Register on July 25, 1978.
During the development of the Chemical Use List, the EPA also asked
Calculon to develop an exposure estimation methodology based on its Use
Classification System, in which chemical use categories are used as
surrogates for exposure data on individual chemicals. The methodology
developed by Calculon and subsequently modified by OTS considers
aspects of occupational, consumer, and environmental exposure to
chemicals and provides an Exposure Estimation Methodology in which
scores are assigned to the individual components so that an overall
score can be obtained for each chemical.
A combination of concerns expressed by EPA staff members and the
public comments received in response to the Federal Register request
led EPA's Office of Toxic Substances to seek a third party evaluation
of both the Use Classification System and the Exposure Estimation
Methodology. SRI International (SRI) was asked to do these evaluations
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in Research Request No. 4 under Contract No. 68-01-4109; the results of
this work are described in this report.
As originally presented to SRI, the task to be carried out under
Research Request No. 4 consisted of four subtasks. The first of these
was to be an evaluation of the Chemical Use List as described in the
Federal Register. The other three subtasks called for: (1) an
evaluation of the Exposure Estimation Methodology (including the
development of an alternative methodology, if appropriate), (2) scoring
of the uses in the Chemical Use List by the methodology, and (3) using
the scores to rank the uses into a limited number of groups.
At the outset of the work on this Research Request, the Chemical
Use List was being revised by Calculon to incorporate some changes
suggested in the Federal Register responses. Consequently, the EPA
Project Monitor directed SRI to delay working on the Chemical Use List
until the revised version became available and to proceed with the sub-
tasks involving an evaluation of the Exposure Estimation Methodology.
One major change made by Calculon as a result of the public
comments was to abandon the combination of specific functions with
specific applications. This meant that the approximately 800 uses
characterized by the combinations were eliminated (replaced by an
unknown number because any function could now, at least theoretically,
be combined with any application). The impact of this change on the
subtasks of this Research Request was that two of the subtasks—using
the methodology to score uses and then ranking the uses into groups—
were deemed inappropriate by the EPA Technical Monitor. The work on this
Research Request was therefore concentrated on Task 1, the evaluation of
the Use Classification System, and Task 2, the evaluation of the
Exposure Estimation Methodology.
Objective
The objectives of the two studies reported in this document were
as follows:
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Evaluation of the Use Classification System
To provide a sound and carefully reasoned independent assessment
of the virtues and failings of this system. Consideration of
the public comments on the system and the difficulties encountered
in carrying out selected trial runs on the system were to be used
in the evaluation but were not to be the sole basis on which
conclusions and recommendations are based.
Evaluation of the Exposure Estimation Methodology
To evaluate the reasonableness and technical correctness of
this methodology, suggest modifications designed to improve it,
and characterize the utility of the resulting methodology for
estimating human exposure to new chemicals, to old chemicals
in new uses, and to old chemicals in old uses.
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II SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS
Summary
The work carried out under Research Request No. 4 consisted of the
following two separate studies:
• Task 1
An evaluation of the merits of the EPA Chemical Use Classifica-
tion System, which had resulted from revising the Chemical Use
List published in the Federal Register of July 25, 1978.
* Task 2
An evaluation of the merits of the OTS Exposure Estimation
Methodology, which had resulted from modifying the original
exposure estimation methodology developed by Calculon.
Task 1 (described in detail in Chapter III) was carried out in
three subtasks. The first of these was a review of the comments on the
Chemical Use List received from industry in response to the request for
public comments on July 25, 1978. The second was a trial run of the Use
Classification System on five selected chemicals and four selected product
types. The last subtask was an overall evaluation of the five components
of the system.
Task 2 (described in detail in Chapter IV) consisted of a review of
the OTS Exposure Estimation Methodology, the development of a modified
methodology to eliminate the major problems uncovered in this review,
and an assessment of the likely results of applying the modified method-
ology. For application to new chemicals or new uses of old chemicals,
the assessment included consideration of the probability that the
components of the exposure estimate could be accurately determined, the
significance of scoring errors in making decisions based on the scores,
and the accuracy of the methodology. Similar considerations were also
taken into account in evaluating the utility of the methodology for
application to old chemicals in old uses.
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Task 1
The. principal findings of the three subtasks are described in the
following summaries.
Subtask A. Review of Industry Comments
The chief general concerns centered on what the system would
be used for, its confusing nature, and the apparent necessity for
producers rather than end users to identify uses. Suggestions for
improvements ranged from better instructions and definitions to adoption
of SIC Codes and reorganization of the format. Alternative approaches
stressed systems that focused on chemicals and exposure situations to
provide more useful information.
Subtask B. Trial Run on Selected Chemicals and Product Types
These exercises in using the system, uncovered problems in the
instructions (particularly the examples cited for illustration) as well
as missing entries in the Indices, missing terms in the functions and
applications lists, and confusing groupings of terms (particularly in the
applications list). Numerous instances arose where the most appropriate
terms for classifying a use could not be determined or the only function
or application term available was not sufficiently specific to characterize
the use to the degree of detail that the information available on the
chemical or product permitted.
Subtask C. Overall Evaluation of the Use Classification System
This subtask disclosed likely future problems when new uses are
added (resulting from the use of both consecutive code numbers and
alphabetical listings and from the procedures for reporting new functions
and applications). In addition, the necessity for a hierarchy in the
functions list was brought into question. A need for more entries and
cross references in both'the functions Index and the applications Index
became evident. Several problems related to the hierarchy of the
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applications list, the variability of the use of the hierarchy to
subdivide major application categories, and additional instances of
application terms that lack specificity were found during the subtask.
Task 2
The principal finding of the evaluation of the OTS Exposure
Estimation Methodology was that the chances for its success in estimating
human exposure to chemicals (without having exposure data on individual
chemicals) would be greatly increased if the scales and the relationships
of the component measures of exposure were more consistent. A modified
methodology involving eight parameters was subsequently developed and
its ability to provide accurate results was evaluated by a panel of SRI
staff members. This evaluation indicated that the probability of
correctly assessing all eight parameters was only about 0.006. In
addition, it was estimated that the probability was more than 0.9 that
data provided by manufacturers, importers, and processors would provide
more accurate scores on specific chemicals.
Taking into consideration that the scores would only be used to
decide which chemicals should be included in the group chosen for further
study, it was illustrated that the errors in scoring probably only had
a slight effect on the accuracy of the decision. However, the probability
that the score assigned to a use category would be a reliable indicator
of the exposures associated with individual chemicals within the category
was estimated to be quite low. Even with an optimistic estimate for
this probability, the overall probability that the exposure estimate for
a given new chemical or new use of an old chemical would be correct was
only 0.06, or one in sixteen.
When the methodology was applied to old chemicals in old uses, the
inaccuracies of the methodology did not eliminate its utility. The
evidence indicated that the methodology could probably be used to select
the upper tail (e.g., the top 10%) of a large group with scores showing
a normal or log normal distribution without missing many high exposure
chemicals. Using the scores for selected components of the scoring
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methodology as a basis for screening out chemicals on a systematic
basis was also investigated as a way to reduce the cost of applying
the methodology to a large number of chemicals.
Conclusions
Task 1
The chosen method for describing a particular use of a chemical
as a combination of a function and an application is a logical approach
to distinguishing between different uses and, in fact, is the core of
the typical textual descriptions of uses. Such narrative descriptions
frequently become long and involved, however, in an effort to define
the use adequately and differentiate it from similar uses. When one
attempts to simplify these descriptions and present them in an
abbreviated form such as that used in the Use Classification System,
the problem is one of retaining in the description those aspects of
the use that illustrate its uniqueness. Consequently, the terms must
have very precise meanings not subject to a variety of interpretations.
In spite of some problem areas (e.g., an unneeded hierarchy and
terms that describe more than one function), the Use Classification
System appears to have done quite well in achieving both brevity and
accuracy in its treatment of the functions of chemicals and in instructing
the user of the system about the selection of the appropriate function
term. Unfortunately, in the section on the applications for chemicals,
the system provides neither adequate terms to specify unique applications
nor satisfactory instructions to assure that the available terms will be
used in essentially the same way by the various users of the system.
Task 2
Even with the modified methodology represented in Table 2 and with
a relatively high probability that individual chemicals will be
correctly assigned to use categories and that correct exposure estimates
will be assigned to the use categories, the utility of the methodology
is marginal. This occurs because of the low probability that the
exposure estimates for use categories will accurately reflect the
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exposures associated with individual chemicals. If the methodology is
used as the basis for deciding which new chemicals or new uses of old
chemicals should be studied further, we believe that the probabilities
of erroneous decisions will be quite high. Consequently, although the
use categories and associated exposure scores may have some utility for
use by the EPA staff in evaluating the reasonableness of assessments of
exposure made by industry, they do not provide a satisfactory surrogate
for such data. In fact, far more accurate assessments of exposures
could likely be obtained by analysis of the data submitted with
premanufacture notices than could be obtained with the exposure estima-
tion methodology.
For old chemicals in old uses, the situation is not much more
encouraging. It appears that the methodology could be useful to
identify the old chemicals with the highest exposures but not consis-
tently useful for discriminating among these high ranking chemicals.
However, the cost of using the methodology on a large number of chemicals
even if done in a stepwise manner using selected components of the
scoring methodology, might be prohibitive considering the quality of
the information likely to be obtained.
Recommendations
It appears that the initial interest of the Office of Toxic
Substances in a system for classifying the uses of chemicals stemmed
from a need for a method by which manufacturers, importers, and
processors could report on the uses of chemicals. The use information
could then be used to estimate exposure to chemicals. Assuming the
need still exists, then the OTS might better approach the problem by
suspending further effort on the current Use Classification System until
the method by which exposure estimates will be made is clarified. Once
this is done, it might well prove more cost effective to construct an
alternative system focused on individual chemicals, selected product
groups, or exposure situations than to attempt to use even an improved
version of the current classification system in the new context.
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For any other purposes to which a Use Classification System is to
be put, we recommend that all of these purposes be carefully developed
and analyzed to determine exactly what is needed from the classification
system before proceeding with the current system. If uses are to be
identified in very specific terms, then considerable work is needed on
the current system to achieve this goal. If the relationship of new
uses to the functions and applications in the current system are of
importance, then a procedure to permit users to add new functions and
applications in the appropriate places throughout the whole hierarchy of
the lists (rather than just to special "Other" and "Miscellaneous"
categories) will be needed.
In the belief that the EPA plans to put the Use Classification
System and the data received from industry into a computerized data base,
we recommend that the EPA reconsider how code numbers are used in the
system. The present combination of consecutive code numbers and alpha-
betical listings will require extensive revisions each time new uses
are added to the system. The following three alternatives are suggested
for consideration (others might result from additional analysis beyond
the scope of this task) : (a) use a non-consecutive numbering system so
that new numbers could be inserted for new functions and applications;
(b) use a numbering system that is independent of the alphabetic sort
sequence; and (3) drop the numbering system.
Based on the results of the evaluation of the OTS Exposure Estima-
tion Methodology, we recommend that this methodology be replaced by a
combination of case-by-case analysis of data" submitted on individual
chemicals and a more flexible system for estimating exposure to the
chemicals in the use categories based on narrative characterizations of
these use categories. Such narrative accounts would provide a richer,
more useful set of observations on which to base decisions. They could
include details on the manner in which chemicals within the use cate-
gories are handled, the environments within which they are used, the
variations in the known properties of the chemicals within these
categories (and, consequently, the variations in the physical forms
in which the chemicals are used), the route of exposure (dermal, oral,
etc.), and the duration of exposure.
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Ill EVALUATION OF THE USE CLASSIFICATION SYSTEM
In Task 1, SRI International assessed the merits of the revised
Use Classification System supplied by the EPA Technical Monitor in
May 1979. This assessment is based on the results of a study consisting
of the following three subtasks, which are described in greater detail
below:
• A review of the industry comments on the original Chemical
Use List published in the Federal Register of July 25, 1978.
(Public comments have not yet been sought on the revised Use
Classification System.)
• A trial run using the Use Classification System to classify
the uses of five selected chemicals and to check the accuracy
and completeness of the system against the known functions and
applications of the component chemicals in four selected types
of products.
• An overall evaluation of the system with respect to its format,
content, and utility.
Subtask A; Review of Industry Comments
The Use Classification System developed by Calculon was published
in the Federal Register for July 25, 1978. Public comment was solicited
on the issues and problems identified below, or on any other issues
related to the list, including alternative approaches to chemical use
classification.
• Are there uses of chemicals not covered in Appendix I? If
so, what are these uses? Please describe them, if possible,
in terms of a "function" and an "application," and provide
a suitable brief statement describing each such use.
• Are the uses in Appendix I clearly understandable? How can
the definitions of the function terms be improved?
• Are any uses cited in Appendix I so ambiguous that a given
use might fall into more than one function/application
combination? How can any such ambiguity be resolved?
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• To what extent, if any, should the Chemical Use List be
changed by modifying, aggregating, or expanding the existing
uses?
• Can this list be used by persons with only a moderate technical
background to easily and accurately determine how to classi±y
a chemical use?
The responses received from industry were assigned response numbers
by EPA and forwarded by the initial EPA Technical Monitor so that these
responses could be analyzed as part of the assessment of the Use
Classification System. This section of the final task report describes
the results of this analysis.
In the following synopsis of the industry comments, only those
comments related to an evaluation of the system were reviewed because
Calculon has already addressed the 69 comments covering changes in the
listed functions and applications, and the EPA is considering a complete
formal review of the revised list at a later date.
General Comments
Prior to discussion of specific suggestions for improvement or for
alternative schemes, those industrial comments of a more general nature
related to the proposed classification scheme are enumerated. The
numbers appearing in parentheses in the following text are the numbers
assigned to this type of industrial comment in Appendix A, where the
respondents submitting comments of this type are identified by the
response number assigned to them by EPA.
• Fifteen respondents prefaced their comments by noting the
difficulty of evaluating a proposed classification scheme
without knowledge of its scope, purpose, and intended uses (1) .
• Five respondents concluded that the use list is usable and
understandable (2).
• Only one respondent suggested abandoning the whole scheme out-
right (3), although ten questioned the usefulness of such a
classification system to the EPA because function and applica-
tion yield no exposure information and are irrelevant from a
risk evaluation standpoint (4).
• Six replies emphasized the burdens of reporting uses and of
updating and maintaining such a classification system (5).
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Eighteen of the responses included comments that end-users, not
primary manufacturers, should define use. Applications of a
chemical are frequently unknown to a manufacturer, and, in
situations where applications are known, confidential market
information, trade secret arrangements, etc. would be violated
by disclosure C6)•
Twenty-one respondents judged the system to be too confusing for
persons of moderate technical background to comprehend (7).
Among the difficulties of use, the ambiguity of the terms
"functions" and "applications" was the one most often mentioned
(.8). The chief concern was that some people will interpret the
terms differently and assign different use designations for the
same chemical where, in fact, the uses are the same. This
situation would be aggravated by the fact that the nomenclature
used by the EPA is not necessarily that used by industry, and
also by variations in nomenclature from one industry to another.
Separating the lists of functions and applications (a modifica-
tion subsequently accomplished by Calculon) was suggested by
seven respondents as a step to reduce ambiguity (9). Another
possible solution (recommended in seven responses) to the
ambiguity problem was the suggestion that the reporting of
chemical uses be done in the industry's own words rather than
in the EPA's function-application terms (.10).
Nine respondents mentioned the relationship of the proposed
classification scheme to Significant New Use Rules (SNURs).
Most commented on the prematurity of developing a chemical
use list without first defining significant new use and
developing SNURs in parallel with development of a use classifi-
cation system. Some respondents pointed out that criteria for
significant new uses involve exposure considerations beyond
the scope of a chemical use list (11).
Specific Suggestions for Changes
Twenty-four responses offered specific suggestions for changes to
improve the proposed classification system. An abbreviated list of
these suggestions follows.
• Simplify the instructions to enable a person of moderate
technical background to use the system easily and accurately
(12).
• Define function and application more clearly to avoid mis-
interpretation and incorrect assignment of chemicals to
categories (13).
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• Broaden and generalize categories of use to bring them more
in line with present industrial practices (14) .
• Include an "unknown" category for those chemicals for which
the manufacturer does not know the final application (15) .
• Include a "starting material" category to describe a chemical
raw material that is used in a chemical reaction to sub-
sequently form a product (16).
• Use an alphabetical rather than a numerical system so that new
entries may be made easily and flexibly (17).
• Do not use alphabetical arrangements (in direct opposition
to the preceding suggestion). Rather, use a three- or four-
level hierarchy with similar functions and applications
grouped together (use alphabetical order only when there is
no other basis for ordering) (18).
• Base applications on all 99 major groups listed in the SIC
Manual rather than on only 39 groups (19) .
• Correlate both functions and applications with SIC codes to
increase the usefulness of this scheme to OSHA. (Compliance
officers need to know what chemical substances are likely to
be associated with a particular type of industrial process)
(20).
• Reverse format to make functions subheadings of applications
(21).
• Reorganize the function/application use term combinations in
Appendix I into major classes in order to make list more use-
ful (22).
• Expand the codes and eliminate aggregated function and
application codes to counteract ambiguity and better serve
more precise classification (23).
• Use less detail in the applications listing to avoid superfluous
categorization of unimportant differentiations (24) .
• Redesign the use list to be more comprehensive with regard to
the industries affected and not a model designed merely for the
chemical industry. This would reduce the confusion resulting
from nomenclature variations of function/application combina-
tions in different industries (25).
Suggestions for Using Different Sources
Two respondents recommended that different sources be used for
development and refinement of a use list reflective of today's
technology (26).
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Develop a list from EPA-funded computer searches of Chemical
Abstracts, which would include large-scale uses as well as the
many specialized uses disclosed in patents.
Use U.S. Patent and Trademark Office information, which would
be a good source of functions and applications of new chemical
compounds. It was noted that there is, in addition, an
International Classification System used for classifying patents,
which might provide additional pertinent information.
Suggestions of Alternative Approaches
Six replies included alternative approaches to the proposed
classification scheme, which would, in the opinion of these respondents,
be better adapted to the regulatory objective of making risk assess-
ments (27). A brief description of the suggested schemes follows.
• Make listing by chemical, not by function. (Typical rule-
making targets a chemical or category of chemicals; therefore,
a chemical-based list makes more sense for EPA than a use-
based list).
• Simplify the function component; relate it to the presence of
a chemical in a process or product, which is more important to
its possible regulation than is indication of its actual
function. Therefore, functions can be reduced to raw material,
intermediate, by-product, etc.
• Compile exposure-related information directly by chemical
rather than to infer it from functions and applications.
Exposure data are quantifiable by individual respondents and
would lend themselves to further summation.
• Reorient the use list to emphasize information on chemical
exposure. Such a list, more properly entitled "Chemical
Exposure List," could be developed in three sections:
- Type of exposure (i.e., industrial, commercial, household,
personal)
- Frequency of exposure (i.e., intermittent, continuous,
confined environment, dispersed environment)
- Extent of exposure (i.e., number of people exposed,
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environmental exposure)
The above information could be analyzed in some type of ranking
system that would focus on uses that result in significant
exposures.
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• Modify the use list to focus directly on exposure. Specifically,
delete the function list as it is not a satisfactory indicator
of exposure, eliminate subdivisions for functions and applica-
tions because they convey no unique meaning for exposure, and use
application terms having significance for exposure.
Subtask B: Trial Run on Selected Chemicals and Product Types
As a method of sampling the number and types of problems that
industrial users might encounter in using the Use Classification System,
a trial run was carried out. In this trial run the system was used to
classify the known uses (as identified in existing SRI data bases) for
the following five commercially significant chemicals: ammonia, ethyl
acetate, ethylene, urea, and sulfuric acid. In addition, the system
was checked for accuracy and completeness against the known functions
and applications of the component chemicals of the following product
types: industrial adhesives, household detergents, rubber processing
chemicals, and trade sales paints. The results obtained from this
trial run are described in this section.
Classification of Uses of Five Selected Chemicals
The description of the uses of ammonia, ethyl acetate, ethylene,
urea, and sulfuric acid in industry terms and the Use Classification
System function and application terms to which these uses were assigned
are summarized in Appendix B.
Problems Encountered During Trial Run on Selected Chemicals
Format—No particular problems attributable to the format of
the Use Classification System were encountered.
Content—The nomenclature used by industry is not necessarily
the same as that used by the Use Classification System. For example,
the term "ripening agent" for fruits and vegetables is commonly used
in industry to define a function of ethylene. The listing of functions
does not include "ripening agent" nor does it include a cross reference
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to this term. Therefore, "growth regulator" had to be selected from
the function listing as the most appropriate descriptor, although it is
not the term of common industrial usage.
The listing of application terms was found in many instances
to be lacking in specificity. Of the many examples of this problem
encountered in classifying the uses of the five selected chemicals, a
limited number are given below:
• Although coal mining is included in the listing of
applications, no entries are related to activities
beyond the mine site. Consequently, no terms are
available for applications in the refining of coke
oven products.
• No polymer listing appears in the application index.
In the classification of uses of ethylene in which
the function assigned was "monomer," to a reporter
unfamiliar with plastic and synthetic materials, the
term "polymer" would follow as the logical application
descriptor. An Index listing of "polymer" with a
cross reference to "plastic and rubber materials and
synthetics (not fabricated)" would clarify the
classification.
• No chemical mixture entry appears in the application
listing so chemicals used to make products that are
chemical mixtures cannot be assigned an adequate applica-
tion. Specific situations in which a chemical mixture
designation could have been applied in this trial run were
in such industrial uses of sulfuric acid as its use in
coke oven light oil refining and tall oil recovery -
• No entry exists in the application list for shellacs.
The term "bleached shellacs" does appear under related
paint products, but this term describes only a subset of
shellacs and should not be used to classify shellacs as
a whole. The particular problem of classifying shellacs
is further discussed in the trial run on Trade Sales
Paints which is described below.
• No subcategory exists under the heading "Metal processing
operations" to specify the nitriding of ferrous alloys.
This common industrial practice, which produces surface
hardening, involves the heating of the alloy in the
presence of ammonia or other nitrogenous material. None
of the given application terms specifically describe such
a use in meaningful terms.
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• Although burial services is included in the listing of
application descriptors, there are no specific entries for
such burial-related uses as embalming fluids. One use of
ethyl acetate is as a component of such fluids. Because
the available application term, burial services, seemed
too generalized to describe embalming fluids appropriately,
this application term had to be assigned to "Miscellaneous
Products and Services."
The definitions given for function descriptors in some cases
lack precision and completeness. This problem was encountered in the
classification of the use of both ammonia and sulfuric acid in phosphate
rock flotation. The Use Classification System definition of flotation
agent describes only the function of a collector. Although this is a
key function of flotation agents, the term is generally used to cover
such other functions as depressants and frothers. Therefore, the
function, "flotation agent," was assigned to the sulfuric acid use with
some reservations. "Chemical raw material" was selected for the ammonia
use because the "flotation agent" definition was not broad enough to
include modifying agent as a function.
In some cases, the application listings are difficult to define
without reference to the SIC Code on which the listing appears to be
based. For example, to determine that parchment paper (the processing
of which involves sulfuric acid) should be assigned to the application
"Packaging and industrial converting paper," it was necessary to refer
to the SIC Classification. Because the Use Classification System
listings and the SIC listings are not in the same order, comparison of
the two for purposes of application identification can be a problem.
Utility—The instructions for the Use Classification System
include directions for the addition of new application terms when no
appropriate term is found in the existing list. Such an addition is
to be reported under "Miscellaneous Products and Services." This leads
to misplacement of terms, which in most cases properly belong in an
already existing application category. For example, the addition of a
term to describe the nitriding of ferrous alloys should be added under
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the heading of "Metal Processing Operations" and not under "Miscellaneous
Products and Services."
The trial run was characterized by several examples of a
problem relating to the basic question of how far a manufacturer of
industrial chemicals can or should go in identifying and classifying
uses of these chemicals. If a chemical is used to make another chemical,
apparently the classifying stops there. However, if a polymer results,
the sample on page one of the instructions seems to indicate that
classification should be based on the end-use application (or, more
likely, applications) of that polymer.
Conclusions from the Trial Run on Selected Chemicals
Format—The alphabetical index listing accompanied by organiza-
tion of terms into a hierarchy ranging from general to specific made
the classification of uses of the five chemicals logical and straight-
forward .
Content—Several modifications of the content of the classifi-
cation system are suggested:
• The nomenclature should be made to be consistent with
that of industry.
• Another level of hierarchy under certain function terms
should be added to increase the degree of specificity,
precision, and completeness of the classification of an
industrial chemical.
• Addition of either new levels of hierarchy or new terms
under existing levels should be undertaken to improve the
specificity of application descriptors. If such a Use
Classification System is to prove valuable to the EPA as
a basis for making risk assessments, specificity is of the
utmost importance.
• Additional cross references in the Index of applications
would simplify use of the system by persons unfamiliar
with the terminology of the industry in question.
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• A more direct correlation of applications with the SIC
Code should be attempted to simplify assignment of an
accurate application descriptor to a chemical use.
Perhaps listing as subsets under an application heading
all products and services which appear in the SIC Code
under that same heading should be considered. This would
encourage uniformity of reporting between industries.
Utility—Instructions should include directions for adding
new terms to all levels of the hierarchy of existing application
categories. Instructions should include an example of a chemical, to
replace the acrylonitrile example, for which the function and application
assignments are straightforward.
Classification of Functions and Applications of Chemicals
in Selected Product Types
In this portion of the trial run, information was gathered on the
functions of the component chemicals in four product types (industrial
adhesives, household detergents, rubber processing chemicals, and trade
sales paints) and on the applications for the different products within
these product types. The resulting information, described in terms
normally used in the industry, was then converted into the function/
application terms used in the Use Classification System to check the
system for accuracy and completeness and to note the number and types
of difficulties experienced in making the conversions.
Product Type; Industrial Adhesives
The following five terms were found to be the ones in most
common use within the industry for describing the functions of the
component chemicals in industrial adhesives:
• Filler (Extender)
• Plasticizer
• Solvent
• Tackifier
• Thickener.
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The applications in which these functions are performed as
described in industry terms and the trial run assignments to Use
Classification System function and application terms are summarized in
Appendix C, pages C-3 to C-39.
The problems encountered and conclusions reached from this
part of the trial run are described in this section.
Format—No problems were encountered that were specifically
due to the format of the Use Classification System although some changes
in format are suggested below which relate to problems of content and
utility.
Content—The definitions of function terms seem to differ
between the adhesives industry and the Use Classification System. For
example, the industry tends to group extenders and fillers together
whereas the Use Classification System provides separate definitions.
Because both of these definitions could be considered applicable to the
function of such chemicals in adhesives, the manufacturer, accustomed
to using industry terminology, may select one or the other without
considering the fine distinctions made by the Use Classification System.
Adhesives are used for attaching filters to cigarettes; how-
ever, in the Use Classification System, "Tobacco production" is the only
application term related to tobacco applications. Because this term
refers only to the agricultural production of tobacco and not to the
production of tobacco products, no satisfactory application term exists
for describing the operation of cigarette tipping.
Carpet laying, as an activity, also employs the use of certain
adhesives but no application term was found to classify this operation.
The closest possible term appeared to be "Floor laying, scraping and
finishing," but this term is a subset of "Carpentry and floor laying,"
which implies the construction of wood floors. Thus, carpet laying is
without an adequate applications descriptor.
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Even though the user is seeking the most specific term for a
particular application, Use Classification System terms often must be
selected that encompass a wide range of applications. For example, the
application term, "Pressure sensitive tapes," is listed as a subset of
"Paper and coated paper products." Consequently, those pressure
sensitive tapes that are not based on paper—vinyl tape (for electrical
purposes), cloth tape (for surgical use), and foil tape—had to be
assigned application terms other than "Pressure sensitive tape." When
this was done, only nonspecific terms were available, e.g., "Unsupported
plastic film, sheet, rod and tube" appeared to describe vinyl electrical
tape best but it also includes many other plastics applications.
Similar problems resulted with surgical tape, best described by
"Medical and dental instruments and supplies," and foil tape, best
described by "Metal foil and leaf."
Occasionally, adhesive products are used by a particular
industry in operations that use products of other industries and these
situations create classification problems. For example, the food
industry uses adhesives to seal cartons produced by the packaging
industry and to apply labels obtained from label manufacturers to
bottles and cans that are made by bottle and can manufacturers. These
situations proved difficult to handle in a consistent and logical manner
in the trial run. The use of adhesives in carton sealing was assigned
to "Paperboard containers and boxes," even though the actual sealing is
done by food and other packaged goods industries. This assignment was
made because of the prospect that an extremely long list of applications
would be associated with carton sealing if every industry using cartons
for packaging was listed. In the case, of bottle labeling, the products
of the user industries doing the actual labeling were selected in the
trial run even though the terms available—"Food and kindred products,"
"Drugs and other Pharmaceuticals," and "Cosmetics and toilet prepara-
tions"—include numerous products that do not require bottle labeling.
Similarly, can labeling was assigned to "Food and kindred products"
even though subsets of this product category include cereal breakfast
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foods and other noncanned products. Thus, the assignment of applications
can result in an extensive list of specific terms or a short list of
general terms, which includes application subsets not originally
intended.
Another problem related to the level of detail implied by
generic application terms is illustrated in the use of adhesives in
furniture. Dowel gluing, for example, is an operation applied to wood
furniture. Wood furniture applications are described in the Use
Classification System by seven separate terms. Inclusion of all of
these applications to cover dowel gluing operations did not seem
appropriate. Therefore, in the trial run, furniture adhesives were
classified under the general application term, "Household furniture,"
because it describes most wood furniture, and also under "Wood partitions
and fixtures," because it includes plastic-laminated wood fixture tops.
Unfortunately, the use of the application term, "Household furniture,"
implies inclusion of unintended subsets such as "Mattresses and bed-
springs."
Utility—In some cases, an application can be defined by more
than one of the application terms listed in the Use Classification
System. Mobile homes, for example, could be classified either under
"Miscellaneous transportation equipment" which includes recreational
vehicles, or under "Prefabricated wood buildings." The listing for the
latter indicates that the Use Classification System intends for mobile
homes to be included under it. The user cannot find this out readily,
however, because mobile homes are not listed in the applications Index;
consequently, he may select "Miscellaneous transportation equipment."
Thus, if an important term is not in the Index, a user of the system
may not search through the Index enough to find the most appropriate
term and, as a result, may use a term other than the one desired.
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Summary of Conclusions from the Trial Run on Industrial
Adhesives—-The following conclusions are evident from the trial run on
industrial adhesives:
• Format
The extent of coverage intended for several of the general
terms used in the applications list is explained in
parentheses after the applications term. For example,
the term, "Public building furniture and related furniture,"
has a three-digit code number and is explained as including
"furniture for schools, theaters, restaurants, religious
buildings, and libraries, as well as seats for public
conveyances and automobiles." No four-digit code
applications are listed as subsets of this application,
however. To keep the user from having to select a term
that implies usage in automobile seats when only theater
furniture is intended, it is recommended that the individual
specific applications mentioned in parentheses be assigned
four-digit codes and be listed as subsets of "Public
building furniture and related furniture." This greater
specificity in the application terms would achieve greater
clarity in the resulting data than possible with the
present parenthetical explanations.
• Content
Appropriate application terms for the operations of
cigarette production and carpet laying should be added
to the applications list.
When an effort was made to select appropriate application
terms for a given use, the definition of the preferred
term sometimes prevented its use because that definition
was too restrictive. Thus, "Pressure sensitive tape" is
defined in the Use Classification System as a paper product,
which prohibits using the term to classify usages in other
types of pressure sensitive tapes, such as cloth surgical
tape. Consequently, a term such as "Medical and dental
instruments and supplies" had to be chosen for this
application. However, it can then be improperly concluded
that adhesives perform a function in the whole range of
medical and dental instruments. Mistakenly associating
a function with products that never use the function is a
potential problem when a general application term is used
because a more appropriate term is defined too restrictively.
Because differences in function terminology between
industry and the Use Classification System exist, it is
recommended that consideration be given to changing the
instructions to allow the use of two function terms when
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the industry makes little or no distinction between two
similar terms. For example, because industry generally
considers extenders and fillers as providing the same
basic function in a product, the opportunity to use both
terms would avoid having the same use reported one way by
one reporter and the other way by another reporter.
Utility
It is recommended that the instructions suggest that users
of the System have on hand a 1977 Census of Manufactures,
Numerical List of Manufactured Products, which explains in
greater detail many of the categories in the application
list. This publication breaks down manufactured products
according to the hierarchy of the SIC Code System. Because
the Use Classification System is based on the SIC system,
the Census publication can help by providing the SIC
origin of the application descriptor terms, by showing the
intended scope of the various application descriptors, and
what changes and combinations of SIC categories have been
made in compiling the application descriptions.
"Mobile homes" should be made an entry in the Index with
a cross reference to "Prefabricated wood buildings" where
they are included in the parenthetical explanation.
Perhaps an overall expansion of the cross referencing of
the index should be undertaken to cover as many problems
of this type as can be identified.
Product Type: Household Detergents
The following 16 terms were found to be the ones in most
common use within the industry for describing the functions of the
component chemicals in household detergents:
• Antiredeposition agents • Fabric softeners
• Antistatic agents • Fillers and diluents
• Bleaching agents • Foam regulators
• Buffers • Opacifying agents
• Builders • Optical brighteners and
• Colorants bluing agents
• Corrosion inhibitors * Perfumes
_ „ • Solubilizers
• Enzymes
• Surfactants.
The applications in which these functions are performed as
described in industry terms and the trial run assignments to Use
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Classification System function and application terms are summarized in
Appendix C, pages C-40 to C-45.
The problems encountered and the conclusions reached from
this part of the trial run are described in this section.
Format—Only minor difficulties were experienced with the
format of the list of functions and its index (e.g., no Index entry for
"Perfumes" giving a cross-reference to "Fragrances"; the unusual Index
entry for "Bleaches" referring the user to see two other functions also,
"Bluing Agents" and "Optical Brighteners," which are seldom considered
as bleaches because their action is one of masking, not removing, colors;
and the reference in the Index under "Suds Control Agents" to "Foam
Inhibitors" but not to "Foam Stabilizers").
The format of the applications list caused problems because
of the unusual arrangement of the hierarchy and the selection of
descriptors used .for the applications. Although the list appears to be
generally based on the SIC codes, the hierarchy, groupings, and terms
have been changed significantly and the purpose of the changes is not
apparent.
The SIC major category, "Soaps, Cleansers and Toilet Goods,"
has been replaced by "Sanitizing Agents, Polishes and Cosmetics," even
though the applications covered are essentially the same as those
covered by the SIC term. This change has eliminated one of the main
components of the category, "Soap and Other Detergents," from any
specific mention in the category title. (It is not even mentioned
indirectly because, by the SIC categories and by industry practice,
soaps and detergents are not usually considered to be subcategories of
either sanitizing agents, polishes, or cosmetics.)
This problem is further compounded when the application,
"Detergents, Soaps, and Disinfectants," is listed under the subcategory
"Polishes and Sanitizing Agents." In the SIC hierarchy, "Soaps and
Other Detergents" and "Polishes and Sanitation Goods" are given equal
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status as separate subcategories. The use of the term, "disinfectants,"
presumably as a replacement for "sanitizers," is a possible source of
further confusion. It is used only once in the SIC hierarchy and this
is for one small application under "Specialty Cleaning and Sanitation
Products," a subcategory treated separately as "Specialty Cleaners" on
the Use Classification System applications list.
Some applications that are quite different (e.g., scouring
cleansers and presoaks) are combined in the applications list. The
Index contains some entries not commonly used in the industry (e.g.,
"Household Cleaners") yet lacks entries for commonly used application
terms (e.g., household detergents, laundry detergents, heavy duty
laundry detergents) and lacks cross-references to descriptors in the
list (e.g., no listing for "hand cleaners, waterless" comparable to
that for "hand cleaners, except waterless").
The choice of the descriptor "Soap Bars and Flakes, and Soap
and Detergent Powders" is unfortunate because it prohibits placement of
liquid products in this application and no other appropriate application
descriptor other than the more general term "Detergents, Soaps and
Disinfectants" is available.
Content—The function list contained descriptors that were
either identical or very similar to the industry terms for all of the
functions chemicals perform in this product category.
Largely because of the rearrangement of the SIC hierarchy,
the grouping of applications, and the choice of terms, no application
descriptors are available for specific applications that represent
major unique uses for chemicals. The absence of (1) a division of
detergents into household and non-household, (2) a descriptor for
laundry detergents, and (3) the common industry terms, heavy duty,
light duty, and liquid detergents, means that classification into the
usual industry application areas such as "Heavy Duty Powdered Laundry
Detergents" or "Light Duty Dishwashing Liquids" cannot be made and
only general application descriptors can be used. Most of these general
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descriptors include several types of applications (some of which are
entirely unrelated especially in terms of exposure potential).
Utility—The need to use general rather than specific
application descriptors for 18 of the total of 55 application descriptors
indicates the lack of utility of the applications list to adequately
describe the uses of chemicals in this product type. It is difficult
to see how classification into these general applications will yield
information useful in risk assessment.
The instructions for reporting chemical uses using the Use
Classification System mentions that "applications" include chemical
processes, products, or activities but no guidance is provided for
selecting one of these three types of application when the application
could be described as either a process, a. product, or an activity. For
example, the application for the chemicals in the household laundry
detergent products could be classified by the products, as we have
done, or they could be classified as the activity, "04122 Laundering,"
which is defined as including home laundering. (It was noted that
another instance of this source of confusion exists with the applica-
tions "04123 Rug and Upholstery Cleaning" and "25124 Rug and Upholstery
Cleaners." If some users report one way and some the other way, the
utility of the resulting information will be in doubt.
The failure to provide a mechanism to add applications to the
existing list of specific applications for a product type such as
"Household Detergents" appears to decrease the potential utility of the
information gathered because such additions must be made to "16
Miscellaneous Products and Services."
Conclusions from the Trial Run on Household Detergents—The
following conclusions are evident from the trial run on household
detergents:
• Format
The format of the applications list for "251 Polishes and
Sanitizing Agents" will need considerable revamping. A
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framework is needed to permit the use of descriptors that
provide data useful for even the crudest of risk assess-
ments.
Content
Using a revised format for treatment of the detergent
products, a series of new specific descriptors—more
consistent with the SIC code and industry usages—will be
needed to cover the individual applications in a complete
and accurate manner.
Utility
In its present form, the applications list -in inadequate
for classifying the applications of the component chemicals
that provide functions in the household detergent products.
After revamping the format and providing specific
descriptors for applications, a more useful tool for
characterizing this product type would be available.
Product Type; Rubber Processing Chemicals
The following 46 terms were found to be the ones in most
common use within the industry for describing the functions of the
component chemicals in rubber processing chemicals:
Accelerators
Activators
Antiblocking agents
Anticracking agents
Antihydrolysis agents
Antiozonants
Antioxidants
Antiscorching agents
Antistatic agents
Blowing agents
Biocides
Bloom inhibitors
Bonding agents
Colorants
Corona resistants
Coupling agents
Desiccants
Detackifiers
Devulcanizing agents
Dispersants
Dusting agents
Emulsifiers
Extenders
Fillers (reinforcement)
Finishing materials (surface)
Flame retardants
Heat resistants
Lubricants
Modifying agents
Odorants
Peptizers
Physical property improvers
Plasticizers
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• Polymerization regulators • Softeners
• Radiation absorbents • Stabilizers
• Reclaiming agents • Stiffening agents
• Reinforcing agents • Surfactants
• Retarders • Tackifiers
• Saturants • Vulcanizing agents
• Shortstops and inhibitors
We found that the evaluation of all uses of rubber processing
chemicals by their function/application components would result in
extremely long tables with a large amount of repetition. Consequently,
with the approval of the EPA Technical Monitor, only two functions—
vulcanizing agents and blowing agents—were chosen to be included in
the trial run. Vulcanizing agents were chosen because they are used
in all rubbers except reclaimed rubber and will have essentially all of
the applications associated with them. Blowing agents were chosen as
an example of a function with applications that are unique to a specific
rubber product type (i.e., sponge-rubber products). The applications in
which these two functions are performed as described in industry terms
and the trial run assignments to Use Classification System function and
application terms are summarized in Appendix C, pages C-46 to C-60.
The problems encountered and the conclusions reached from this
part of the trial run are described in this section.
Format—No problems were encountered that were specifically
due to the format of the Use Classification System.
Content—Using sources commonly used in the rubber industry,
such as the Rubber Red Book, we identified 46 rubber processing function
terms. Our list of functions includes those that are unique to rubber
processing (such as vulcanizing agents, accelerators, and peptizers)
as well as terms for functions performed not only in rubber processing
but also elsewhere in the chemical industry (such as biocides, flame
retardants, and surfactants). The Use Classification System's list of
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functions found under the heading "Rubber compounding agents" includes
only 21 functions. Two of the function terms, "Antislip finishing agents"
(defined in the functions list as applied to textile fibers or yarns) and
"Optical brighteners" (defined as used only in textiles, papers, detergents,
and plastics), were inappropriate for inclusion, and the term, "Catalysts,"
is not unique to rubber processing. Of the 30 function terms on the
industry term list that are not included under the heading "Rubber
compounding agents," 22 were included elsewhere in the Use Classification
System functions list. The majority of these 22 functions are not consid-
ered to be unique to rubber processing and thus are correctly excluded
from this heading. However, function terms such as "blowing agents" and
"anti-scorching agents" are unique to rubber processing and should be
included with "Rubber compounding agents." The eight function terms not
found in the Use Classification System are general terms, except for
"Physical property improvers" and "Polymerization regulators," which are
relatively common rubber processing terms. Satisfactory definitions
could not be found for the terms, "Pre-vulcanization inhibitors" and
"Vulcanization leveling agents," that were in the Use Classification
System but did not appear on the industry term list. Thus, in spite of
the apparent significant difference in the number of terms between the
two lists, the Use Classification System's list of function terms is not
considered to be inadequate coverage of rubber processing functions.
A very common application of rubber is in the manufacture of
gaskets and sealing devices. In the Use Classification System, the
application, "Gasket, packing and sealing devices" exists only as a
subheading under "Stone, clay, ceramic, glass and concrete products."
Because of the limitation on this latter subheading to the materials
in the major heading, a general application term for rubber products,
"Mechanical rubber goods," had to be used for rubber gaskets and seals.
Another common application of rubber is in the manufacture of
automotive parts. This application and its subcategories were usually
included in the general category of "Motor vehicles and equipment."
For example, automotive spark plug boots and power steering hose liners
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and jackets were classified in this manner, because there is no classi-
fication for rubber products used for motor vehicles and equipment;
however, plastic products for motor vehicles are explicitly defined as
being included in the three-digit code, "Industrial plastic products."
In addition, the classification of rubber automotive parts
presents a problem in the choice of application terms. For example,
automotive primary and ignition wire coatings could be classified as
either "283 Motor vehicles and equipment" or "0655 Miscellaneous
fabricated wire products." Automotive steering hose liners and jackets
could be classified as either 283 or "075 Rubber and plastic hose and
beltings." In both examples, the specificity of the two appropriate
application terms is equivalent. In instances where there were choices
of EPA application terms, both applications were entered in the trial
run in order to point up the problem. Similar double entries were made
in the cases of "280 Aircraft and parts" vs. "075 Rubber and plastic
hose and belting," 280 vs. "0710 Mechanical rubber goods," "1493 Food
processing machinery" vs. 075, and "286 Railroad cars and equipment"
vs. 075.
Two additional application terms needed as subheadings under
"Miscellaneous fabricated rubber products" are terms for rubber insula-
tion and for miscellaneous fabricated cable products. Wire and cable
insulation is a common application of rubber, but no appropriate term
exists in the applications list. The insulation application terms that
are included in the Use Classification System are limited to asbestos,
foamed plastic, insulation board, and mineral wood products.
Rubber rollers are used to apply lacquer, paint, and inks;
however, there is no appropriate specific application term for rollers
in the Use Classification System. Although we found that the SIC Code
System includes paint rollers under "Brooms and brushes," this did not
seem appropriate. Therefore, because the Use Classification System
listed "rolls" under "Mechanical rubber goods," rollers were assigned
to this application.
The specificity of available application terms does not seem
consistent among the general application headings. For example, medical
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applications of rubber include surgical implants, prosthetic devices,
and dental impressions. The most specific application term available
in the Use Classification System is the three-digit code "Medical and
dental instruments and supplies." In contrast, "Food and kindred
products" seems to have been assigned numerous specific four-digit code
subheadings for applications (e.g., "Dairy products" includes "Butter,"
"Cheese," "Condensed and evaporated milk," "Fluid milk products," and
"Ice cream and frozen desserts" as subheadings).
Utility—The Use Classification Systems is basically consistent
with the SIC classification of rubber and plastics products. However,
its utility is diminished by two factors: (1) the lack of specificity
of subheadings and (2) the lack of opportunity to add subheadings to
the appropriate 2-digit code lists (rather than adding terms only to
"Miscellaneous products and services").
Identification of the uses of rubber products using industry
terms was achieved quite easily. The uses were defined more specifically
than the Use Classification System terms permitted. This lack of
specificity in the application terms diminishes the utility of the system
by limiting the choice of terms. The net result was that classification
of many applications had to be done by very general terms even though
more specific information was available.
The lack of opportunity to add subheadings to the list of
headings in each 2-digit code listing reduces the quality of the data
that is produced. For example, because seals and gaskets are common
rubber products, it would seem appropriate to be able to add the applica-
tion "Gasket, packing, and sealing devices" (as it is shown under "Stone,
clay, ceramic, glass, and concrete products") to the "Fabricated rubber
and plastic products" list rather than be limited to the more general
term "Mechanical rubber goods." The alternative of using the term
"Miscellaneous Products and Services" seems even less desirable because
the fact that it belongs with the fabricated rubber products could not
be brought out.
Conclusions from the Trial Run on Rubber Processing Chemicals—
The following conclusions are evident from the trial run on rubber
processing chemicals:
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• The trial run for classifying rubber processing chemicals
was relatively straightforward for uses that involved
applications in fabricated rubber products, once it was
realized that only general terms were usually available
for classifying applications where more specific information
was available. When the uses were described in industry
terms as particular fabricated rubber products used in the
products of another industry, e.g., radiator hose in
automobiles, then the format and the instructions created
confusion as to how best to classify a use. In the example
cited, a case could be made that the user would be using
the more specific term by classifying the application as
"075 Rubber and plastic hose and belting" or as "283 Motor
vehicles and equipment." Guidance in the instructions for
handling such cases would help to achieve consistent
reporting of the same uses.
• Content
The application descriptors should be more specific, to
take advantage of the detailed information that is available
on rubber products.
The level of detail of the application descriptors as
provided by subheadings should be made more consistent
among the various 2-digit code categories, particularly
where logical subheadings are available from the descrip-
tions provided as parenthetical explanations of the
application terms.
It would be helpful if the user were able to add sub-
headings to the lists for the individual 2-digit code
categories rather than being required to add such applica-
tions under "Miscellaneous products and services."
* Utility
The Use Classification System instructions call for the
user to report the product in which a chemical is used,
which has been done in this trial run on vulcanizing
agents (e.g., coated fabrics). However, such a classifica-
tion loses what may be a more important bit of information
for assessing the extent of human exposure to the vulcanizing
agent, namely, the type of elastomer (polybutadiene,
silicone, etc.) produced by the use of the vulcanizing
agent and used to coat the fabric. This failure to provide
a method by which both the elastomer type and the fabricated
rubber product can be included in the classification of the
use appears to be a significant shortcoming of the Use
Classification System when used to classify rubber processing
chemicals.
Product Type: Trade Sales Paints
The following nine terms and their subdivisions were found to
be the ones in most common use within the industry for describing the
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functions of the component chemicals in trade sales paints:
• Antifoaming agents
• Antiskinning agents
• Driers
• Pigments
- Colored and black
- Corrosion inhibitors
- Extenders (nonopaque)
- White (opaque)
• Preservatives and mildewcides
• Propellants
• Resin binders (film-forming agents)
• Solvents
• Surfactants and dispersing agents
• Thickeners.
The applications in which these functions are performed as
described in industry terms and the trial run assignments to Use
Classification System function and application terms are summarized in
Appendix C, pages C-61 to C-69.
The problems encountered and the conclusions reached from this
part of the trial run are described in this section.
Format—No problems were encountered that were specifically
due to the format of the Use Classification System.
Content—Trade sales paints include some aerosol products that
contain chemicals functioning as propellants. In the Use Classification
System, no application such as "Aerosol paints" exists. The closest
application to be found is "Interior oil base paint products," although
the SIC Code System includes a separate heading for aerosol paints in
the category "Paints and allied products." Because the Use Classifica-
tion System appears to be based on the SIC System, aerosol paints seem
to have been overlooked.
From the industrial point of view, shellacs are normally
classified with varnishes and the SIC Code System includes them there.
However, the Use Classification System does not classify shellacs as
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related to varnishes. In fact, only "Bleached shellacs" are listed,
and only under "Miscellaneous related paint products," along with such
products as pigment dispersions and ink vehicles. As a consequence of
these changes, it is difficult to know how to classify shellacs as an
application.
The absence of the term "trade sales" from the major headings
under "Paints and allied products" (e.g., "Exterior oil type paint
products") is misleading. The SIC System views the products not listed
under "Industrial product finishes" as trade sales products and includes
"trade sales" in its terminology. The paint industry considers the
distinction important because some industrial uses are very similar to
trade sales uses and could be misclassified if the distinctions were
not worded clearly. This could result in a specialty industrial interior
paint product (e.g., a special formulation for special conditions such
as high temperature) being classified as an ordinary trade sales interior
wall paint.
Function terms also seem to differ between the industry and
the Use Classification System. What the industry would term as "anti-
foaming agents" could be classified on the function list as "defoamers"
or as "foam inhibitors." According to the function definitions in the
Use Classification System, defoamers are a function related to treat-
ments or processes while foam inhibitors are related to liquid products.
However, the manufacture of antifoaming agents is not necessarily going
to make these distinctions nor is the manufacturer likely to know
whether the chemical will be used in processes or products.
In the Use Classification System, pigments are classified as
a subdivision under coloring agents. However, the industry refers to
pigments not only as coloring agents but also as extenders and corrosion
inhibitors. The Use Classification System recognizes and lists these
other functions at the same level as coloring agents but classifies
pigments as a subset of coloring agents, thereby reversing the usual
industry hierarchical scheme.
The industry uses both "resin binders" and "film formers" as
terms for the principal chemical base of a paint; however, a user of
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the Use Classification System may misclassify functions if he chooses
to pursue "resin binders" rather than "film formers." "Resin binders"
is not included in the Index to the Use Classification System; however,
the term "binders," which seems likely to come to mind, is included and,
in general, the definition given to the function "binders" appears
appropriate for the function of resin binders in paints. "Film formers"
is listed in the Index and the user is referred to the function "Coating
agents." Depending on the choice of industry terminology and the
reporter's technical knowledge, the use of the term "resin binder" may
lead to a different classification of the function, i.e., the same
function may be classified as "Binder" or "Coating agent."
Utility—According to the instructions for reporting an appli-
cation, the most appropriate and specific term should be chosen. Deter-
mining the appropriate level of specificity can present a problem. For
example, the application, "Automotive and machinery refinish paints and
enamels," characterizes a group of paint products. Chemicals are used
in formulating the paint, which is subsequently used for particular
purposes. A more complete description of the use of these paints can
be made by citing "Motor vehicles and equipment" as an application
because it describes the resultant use of "Automotive and machinery
refinish paints and enamels." However, such a description may be more
detailed than intended by the EPA. Page 1 of the instructions touches
upon this issue but does not provide clear guidance for determining
appropriate levels of detail.
The instructions give directions for the addition of a mis-
cellaneous application not found on List II. The Use Classification
System directs such applications to a whole class labeled "Miscellaneous
products and services." However, it may sometimes be appropriate to add
an unlisted application to an already existing class. For example, if
one wanted to add aerosol paints as an application, the instructions do
not presently provide a procedure by which the addition could be included
in the class, "Paints, coatings and allied products."
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Conclusions from the Trial Run on Trade Sales Paints—The
following conclusions are evident from the trial run on trade sales
paints:
• Format
The trial run for classifying trade sales paints was rela-
tively easy because the SRI formulation data was organized
on the SIC code pattern and this appears to have been the
basic organization of the Use Classification System
applications (although some exceptions were noted). The
alphabetical system for organizing the function and applica-
tion lists made the term search relatively easy.
• Content
Existing application descriptors should be more inclusive
or new application descriptors should be added to cover
applications found to be unlisted. The cases of aerosol
paints and shellacs,, other than bleached, are examples of
unlisted applications.
The EPA application terms seem to be fairly accurate when
they follow the SIC breakdown of products. Problems are
encountered, however, when SIC terms are rearranged.
Examples of such rearrangements are: (1) the case of
shellacs no longer being associated with varnish and
(2) the removal of the term "trade sales" from the major
headings under "Paints and allied products."
The Use Classification System may present function terms
at a level of detail that is greater than that used by
industry. For example, as the industry defines the function
of an antifearning agent, the distinction between defearners
and foam inhibitors is blurred, but the function Index
requires that the function be reported as only "Defearners"
or only "Foam inhibitors." These two functions are assigned
function codes that are not related numerically, (i.e.,
160 "Defoamers" and 246 "Foam inhibitors"), thereby making
them appear to be unrelated. To allow the option of
reporting both definitions of antifoaming agents, the term
"Antifoaming agents" could be assigned a function code,
and "Defoamers" and "Foam inhibitors" could be assigned
four-digit codes and listed as subsets of "Antifoaming
agents."
This discussion raises the larger question of whether there
are other cases where the Index requires single terms that
are subsets of the terms normally used by the industry.
Inorganic pigments, according to the industry, function as
extenders and corrosion inhibitors as well as coloring
agents, while organic pigments function only as coloring
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agents. However, in the Use Classification System,
"Pigments" are listed as a subset of coloring agents. The
function hierarchy would be more consistent with the indus-
try if a new function, "Inorganic pigments," was added and
assigned a three-digit code with its own subsets. The sub-
sets would be (1) "Corrosion inhibiting pigments,"
(2) "Extending pigments," and (3) "Coloring pigments."
"Coloring agents" would be changed to "Organic coloring
agents" with the subset "Dyes" and "Organic pigments."
• Utility
The function and application lists should not be expected
to be 100% complete. Therefore, instructions should be
included to direct the addition of new or miscellaneous
applications to their generic category rather than directing
the user to "Miscellaneous products and services."
The SIC numerical breakdown of manufactured products, as
contained in the 1977 Census of Manufactures Numerical List
of Manufactured Products, published by the Bureau of the
Census, is a helpful aid to understanding the application
terms as listed in the Use Classification System. With
this publication in hand, a reporter can understand some
of the assumptions behind the EPA descriptors, because the
Use Classification System is principally based on the SIC
System. For example, it will direct the reporter to note
that the SIC terms, "Sash, trim, and trellis enamels and
tinting bases" or "Porch and deck enamels and tinting
bases, including interior-exterior floor enamels" belong to
application 1802 "Exterior house paints." It will also aid
in finding that shellacs, except bleached, may have been
intended to be associated with varnishes, and indicate a
need to add a category such as aerosol paints.
Subtask C: Overall Evaluation of the Use Classification System
In this subtask, the positive and negative features of the Use
Classification System were assessed, based on information obtained in
the other two subtasks and on a separate study of the following five
parts of the system:
• Instructions for Reporting Chemical Uses
• List I (Functions)
• Index to List I
• List II (Applications)
• Index to List II.
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The results of this overall evaluation are described in this section.
The assessment of each of the five parts focuses on the three areas of
greatest concern to the EPA (as identified by the EPA Technical Monitor),
namely, format, content, and utility.
Instructions for Reporting Chemical Uses
The instructions reviewed in this part of the subtask, supplied by
the EPA Technical Monitor in May 1979, are reproduced in Appendix D of
this report.
Format
The format of these instructions is straightforward and under-
standable. No problems attributable to the format occurred during the
trial runs.
Content
It is assumed that an introduction, describing the background
of the development of the Use Classification System and indicating how
the information provided will be used by the EPA, will precede the
instructions for reporting chemical uses in the package of material
supplied to manufacturers, importers, and processors. Such an intro-
duction is considered essential to achieving the desired quality of input
from the reporting firms.
In Section 2.1, Definition of Chemical Use (Page D-3 in
Appendix D) the explanation of the term "function" cites "adhesives" as
the first example. This is an unfortunate choice because many if not
all users are likely to consider adhesives as an application for chemi-
cals rather than as a function. In fact, the instructions later cite
"adhesives" again, but as an example of an application for a chemical.
Use of a different function example without this confusing aspect is
recommended.
Section 2.2.1 (page D-4) directs the user to look for an appro-
priate "term (or terms)" for the function. No explanation is given for
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the inclusion of "(or terms)" and it appears to be in conflict with the
instructions in Section 2.4.4 (p. D-ll), which state that one function
term should be chosen rather than reporting two alternative terms.
Section 2.2.2 (p. D-5) indicates that a few function term codes
contain letters, but no such codes were found in the list of functions.
However, many function codes include a plus (+) sign or an asterisk (*)
or both and no explanation of these symbols is provided in the
instructions.
Section 2.2.3 (p. D-7) states that a definition must be pro-
vided for all new terms added to "315 Other," but no information is
given about where this definition is to be added or what it should
include. The latter is particularly important because the user could
be asked to: (1) name any three-digit function terms under which the
new term would fall or (2) name the function term to which the new term
is most closely related. Such information would help in adding the new
term to the functions list in its proper place.
Section 2.6.2 (p. D-13) indicates that use of nitrobenzene to
make aniline should be reported by using the function term "chemical
intermediate," which is consistent with industry usage of this term.
However, the definitions of "chemical intermediates" and "chemical raw
materials" in the list of functions are not consistent with this usage.
These definitions would require that the nitrobenzene be described as a
chemical raw material when used to make aniline. This situation is
created by the definition of "chemical intermediates," which is far more
restrictive than its meaning as normally perceived in the industry.
In Section 2.1 (p. D-3), the term "application" is defined as
"what a chemical is used in—a chemical process, product or activity in
which the chemical is employed" and "petroleum distillation" is cited as
an example of a chemical process. It is recommended that either "chemi-
cal process" be shortened to "process" (as is done in Section 2.5,
p. D-ll) or that a different example be cited, because "petroleum
distillation," although a "process," is not usually considered to be a
"chemical process."
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The explanation of defining chemical use as a combination of
a function and an application continues by stating: "For example, a
chemical may function as a soil release agent for application to yarns
and fabrics." This use of the word "application" is not in keeping with
the definition given just above and is likely to confuse the reader.
It is recommended that this sentence be reworded to say "in the applica-
tion 'finished textile products."1
The next example cited in the explanation (p. D-3) is likely
to cause even more confusion. After stating that a production or
formulation operation should not be reported as a use if it results
in a product that does not contain the chemical being reported, the
example cited appears to contradict this instruction. The use of
acrylonitrile as a polymerization monomer to make polyacrylonitrile,
which is used to formulate coatings for yarns and fabrics, is explained
as requiring that the function be reported as a monomer and the applica-
tion be reported as finished yarns and fabrics. Most users would likely
consider that both polyacrylonitrile and any coating formulation con-
taining it do not contain acrylonitrile (even though trace amounts
admittedly could be present). Consequently, whether the application
term "213 Plastic materials and resins" (to cover the product polyacry-
lonitrile) or "2701 Other finished fibers, yarn and fabrics" (to cover
the coated yarns and fabrics) is used, the directions are not being
followed. Further, this example raises several other problems: (1)
the recommended application "finished yarns and fabrics" is not a valid
term from List II; (2) if the combination "1290 Monomers" and "2701 Other
finished fibers, yarn and fabrics" is reported as describing this use,
then the fact that the polyacrylonitrile was used as a coating on the
yarns and fabrics will be completely lost because use of the polyacry-
lonitrile to make the yarns and fabrics themselves, rather than just the
coatings, would also be reported by using the same combination, and
(3) as illustrated by this example, the statement (p. D-4) that each
unique combination of a function and an application constitutes a distinct
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use is not accurate if the application term selected is not specific
enough to characterize the uniqueness of the particular application.
Section 2.3.1 (p. D-7) directs the user to look for an appro-
priate "term (or terms)" for the application. No explanation is given
for the inclusion of "(or terms)" and it appears to be in conflict with
the instructions in Section 2.4.4 (p. D-ll), which imply that only one
application term should be chosen.
Section 2.4.1 (p. D-9) describes the procedure for adding a
new application term but does not require that a definition of the term
be provided. This is a serious oversight because the user could be
asked to: (1) name any application terms already in the list under
which the new term would fall or (2) name the application term to
which the new term is most closely related. Such information would
help in adding the new term to the applications list in its proper place.
Section 2.5, Special Situation Rule for Using a Double Function,
states that a chemical may have another function as its application and
cites a use where a solvent is used to formulate an adhesive as an
example because the term "adhesive" is used to describe a function in
the Use Classification System. This so-called "double function" is
an artificial construction necessary to counteract the results of using
terms to describe functions that are normally used solely to describe
applications (most frequently formulated or unformulated products). It
is recommended that consideration be given to revising the list of
function terms by using the suffix "-ing" and the word "agent" as part
of the term and freeing the existing terms for use in the applications
list. A review of the combinations published in the Federal Register
on July 25, 1978, provided the following limited number of examples of
the types of changes being suggested here:
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Function Term Used As Proposed Replacement
Application in Federal Register Function Term _
Lachrymators Lachrymating agents
Sealants Sealing agents
Coolants Cooling agents
Dyes Dyeing agents
Fertilizers Fertilizing agents
Lubricants Lubricating agents
The further explanation (p. D-ll) of the example of using a
double function, after indicating that "adhesive" is the appropriate
application term, states parenthetically that the adhesive may later be
used to laminate materials such as fabrics and as such would have a
valid application in the context of the system. This parenthetical
statement was the source of considerable confusion in carrying out the
trial run. If "adhesives" is the acceptable application term, what is
the relevance of the subsequent use of the adhesive in laminating fabrics?
If laminating fabrics is the "ultimate" application, why not list "270
Finished textile products" and dispense with "adhesives" altogether?
Taken together with the example of acrylonitrile (p. D-3), the reader is
likely to be completely confused about whether he should cite the first
product in which the chemical performs its function or follow it through
subsequent steps to the ultimate product. In the first instance,
information is gained on the immediate fate of the chemical but nothing
is learned about the final product in the chain. In the second instance,
information on the nature of the early products in the sequence (e.g.,
the type of polymer used to make a plastic part) is lost. If the chain
is carried through fabricated products such as rubber radiator hose all
the way to a "final product" such as "283 Motor vehicles and equipment,"
then even the nature of the fabricated product is lost. A constant
bombardment of questions concerning the proper application terms to use
may result if considerably more guidance is not provided in the
instructions.
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In addition to indicating how far the user should go down the
product chain, further clarification is needed on the criteria to be
used when choosing between a process, a product, and an activity. One
example of this problem would be a chemical intended for use as a
bactericide in a disinfectant product used in cow barns. Assuming that
the proper function term is "102 Bactericides," the choice of application
term could be made from (at least) the following possibilities:
F 1020 Bactericidal cleaners (cleaning
agents that contain bactericides)
F 190 Disinfectants (substances used on
inanimate objects that destroy or
inhibit microorganisms but not
bacterial spores)
25100 Dairy, farm and food plant cleaners
and disinfectants
0150 Dairy farming (includes indirect
operations involving the physical
plant, e.g., barn disinfecting)
In the absence of satisfactory guidelines, this one use might be reported
in four different ways.
Utility
The instructions provide useful directions for carrying out
the mechanics of the classification process. Because of the confusion
likely to be created by the examples cited in the explanations, the
instructions are not likely to assist the user in arriving at the proper
function-application combination, however. This problem is not viewed
as insurmountable. In fact, the quality of the explanations and examples
could be upgraded to a level where any failure of a user to classify
a chemical's uses properly would probably be due to inadequacies of the
indexes to the lists and of the lists themselves rather than to
deficiencies in the instructions.
List I (Functions)
The list of functions reviewed in this part of the subtask was
supplied by the EPA Technical Monitor in May 1979 and consisted of
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50 typewritten pages on which valid function terms were listed along
with their definitions and code numbers. Although six random terms are
included at the end of the list, the remainder is in alphabetical order
except for a limited number of more specific function terms placed at a
second level of hierarchy as subsets of more general function terms.
The hierarchy has no third level and no general term has more than eight
subset terms listed under it. The code numbers are in numerical sequence
from 001 to 425 (except for two missing numbers) at the higher level of
the hierarchy. The subset terms are listed in alphabetical order under
the more general terms and assigned consecutive code numbers by the
addition of a fourth digit (starting with zero) to the three-digit code
of the general function term (e.g., the subsets of the general term
coded as 117 are coded as 1170, 1171, 1172, etc.)
Format
The listing of functional terms in alphabetical order and the
use of code numbers, which appeared at first to make the functions
list easier to use, were found on further consideration to be a source
of future problems. When the new function terms reported under "315
Other" are incorporated into the list, either the code numbers of existing
functions will need to be revised or the alphabetical listing will need
to be abandoned (as has already been found necessary for functions
420-425 at the end of the current list).
The code numbers appear to be necessary only because of the
two-level hierarchy of the list (i.e., if all function terms were on a
single level, they could all be listed in alphabetical order and the
Index could direct the user to them on the basis of their names alone).
However, the necessity for the hierarchy is not explained in the instruc-
tions or elsewhere. Examination of those entries in the functions list
where the hierarchy has been employed indicated that the hierarchy could
be eliminated by merely adding cross-references to the functions Index,
which would direct the user to the other terms now listed in the
hierarchy either above or below the listed term.
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In some cases, the more general term might even be eliminated
from the functions list (but not the functions Index) because it appears
to be either: (1) an artificial combination of several functions with,
at best, a tenuous relationship (e.g., "003 Absorbents," "128 Chemical
intermediates," and "291 Leveling agents"), or (2) unnecessary, because
the listed subset term or terms describe all the functions covered by
the general term (e.g., "019 Analgesics," "117 Cardiovascular agents,"
"141 Coloring agents," "178 Dermatologicals," "244 Fluorescent agents,"
"245 Fluxing agents," "257 Fungistats," "263 Heat transfer agents,"
"265 Hematological agents," "281 Insulating materials," "308 Nutrients,"
"314 Opthalmologicals," "327 Pesticides," "343 Psychotropics," "369
Sequestrants," "390 Strippers," and "409 Uterine contractants").
Some general terms were found to contain one or more subset
terms that did not qualify as subsets according to the definition of
the general term (e.g., "102 Bactericides," "109 Blowing agents,"
"137 Cloud point depressants," "175 Deodorants," "275 Immunological
agents," "393 Surfactants," "396 Tanning agents," and "310 Odorants").
The utility of still other general terms is questionable because
the definitions given indicate that the subset terms shown represent
only a portion of the terms (some of which are listed elsewhere in the
functions list), which could, or should, be listed, e.g., "118 Carriers,"
"157 Dechlorinating agents," "187 Dietary supplements," "223 Extenders,1
"282 Intensifies," "293 Lubricating additives," and "386 Stabilizers".
Content
The completeness of the hierarchy is brought into question by
the lack of subset terms for those numerous function terms that are
specifically defined as combinations of two or more functions. These
terms are listed in order of code numbers in Appendix E. Although having
two or more functions included in one function term admittedly shortens
the list of terms, it means that the information reported by the users
will not be as specific as it would be if individual terms were used.
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The EPA will not know which of the functions covered by the general
function term is the actual function performed by the chemical.
The hierarchy is used much more extensively for function terms
related to pesticides and drugs than for other function terms, but no
explanation is given for this. Because these two areas are covered by
other legislation, one would think that these non-TSCA functions would
be presented with equal or less detail, not greater detail, than functions
covered only by TSCA.
The following additional aspects of the content of the functions
list were noted in the course of reviewing the individual function terms:
• The definition of "023 Anticaking agents" would seem to
include "226 Fertilizer conditioners" as a subset.
• One component in the definition of "075 Antiprecipitants"
appears to include the function covered by "150 Crystal
distortion agents."
• The function term, "283 Ion exchange compounds," could be
subdivided into "Ion exchange resins" and "Liquid ion
exchange agents."
• The function, "183 Detergent builders," is defined as
including builders for soap but a separate term, "376 Soap
builders," is also listed.
• There is no entry for the function term, "Stickers," which
is commonly used in the pesticides industry.
• The definition of "180 Desiccants" does not cover the
function of chemicals used to dehydrate plants.
During the trial run, the function term, "Ripening agent,"
which is commonly used in the industry, was found not to be included in
the functions list and the definitions of the following function terms
were found to be incorrect:
• 1411 Pigments (defined as a subset of coloring agents but
some are extenders or corrosion inhibitors)
• 3933 Flotation agents (definition is for a collector; the
term flotation agent is a general one that includes
activators, collectors, depressants, flocculants,
frothers, and modifiers, many of which are not
surfactants)
• 356 Rubber compounding agents (defined as including two
inappropriate functions—antislip agents and optical
brighteners)
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Utility
The utility of the current functions list is diminished by the
variable usage of the hierarchical system for listing the functions.
Abandoning the hierarchy appears to be the best way to improve the
usefulness of the list and this would also simplify the job of adding
new functions as they are reported. If the hierarchy is to be retained,
then considerable modification would be needed to assure that it will
provide the users with a satisfactory method for characterizing the
functions of chemicals.
Index to List I
The Index reviewed in this part of the subtask was supplied by the
EPA Technical Monitor in May 1979 and consisted of 48 typewritten pages
on which function terms (including code numbers for valid function
terms from List I) were listed in alphabetical order along with appro-
priate cross-references when needed. For function terms not included in
List I, the user is directed to see the valid function term or terms
that are used in List I instead of the listed term. The user may also
be directed to valid function terms that are considered to be related
to the listed term.
When cross-references are included for valid terms, the user is
directed to see also a limited number (up to 13 in one case, but usually
only 1-3) of other valid function terms that are related to the listed
term. The code numbers for these valid terms are included. The Index
does not identify those valid function terms in the list that have other
valid terms as subsets as a result of the hierarchy of the functions
list. The only indication given in the Index that a valid function term
is a subset of another term is the fact that the subset terms have four-
digit code numbers. The user does not learn the term under which the
listed term is a subset until the function list itself is consulted.
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Format
The alphabetical listing of all function terms makes the
Index quite easy to use. As stated in the instructions (p. D-4), all
terms are listed in direct (e.g., Cyclic Chemicals), rather than inverted
form (e.g., Chemicals, Cyclic). Although the exclusion of inverted terms
results in a shorter Index, a shorter list may well make the Index more
difficult to use than a longer list, which would lead the user directly
to the correct function term with less searching for the proper term.
Because the two-level hierarchy of the functions list requires
that code numbers of valid function terms be included in the Index, these
code numbers will need to be revised when new function terms are added
to the functions list. Elimination of the hierarchy would permit
deletion of the code numbers from the Index. If this were done, cross-
references would be needed from function terms to all other function
terms currently listed as their subsets in the hierarchy and vice versa.
This would probably aid the users, because related terms could then be
noted while searching the Index rather than not becoming apparent until
the functions list was consulted.
Content
The failure to show in the Index the valid function terms that
are above and below the listed term in the functions list hierarchy is
undoubtedly based on the belief that the users will note the relation-
ships when the functions list is consulted. However, because this may
not be the case, the inclusion of cross-references to such related terms
in the Index may be at least as useful as the cross-references to other
terms not associated with the listed term in the hierarchy.
Numerous function terms are defined in the functions list as
containing functions that are not listed separately in the second level
of the hierarchy of the functions list. These functions are not listed
in the Index with a cross-reference to the appropriate valid function
term (e.g., "Minerals" is included in the definition of "187 Dietary
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supplements" but is not listed in the Index; other examples can be found
in the definitions for the function terms listed in Appendix E). In
some cases, these functions appear in the function term definition as a
lengthy description (e.g., "materials added to plastic forming compounds
to prevent discoloring of the final product upon aging" is contained
in the definition of "049 Antifogging agents"). However, the potential
usefulness of having such information available in the Index would seem
to outweigh the work involved in converting the descriptions to brief
Index entries.
Although the function term, "020 Analytical and product testing
agents," appears in the Index, there is no entry in the Index for "Product
testing agents" with a cross-reference to the valid function term.
To further clarify how the function term, "315 Other," is to
be used, consideration should be given to the addition of Index entries
for "Functions not listed," "Miscellaneous functions," and "Unknown
functions," with appropriate cross-references to "315 Other."
The following additional aspects of the content of the functions
Index were noted in the course of reviewing the individual entries:
• No explanation is given for the plus (+) signs and
asterisks (*) that precede many entries in the Index.
• No entries for "Smoke screens" giving a cross-reference to
"309 Obscuring agents" or for "Liquid ion exchange agents"
with a cross-reference to "283 Ion exchange compounds."
• No cross-references between "023 Anticaking agents" and
"226 Fertilizer conditioners" and no cross-reference from
"166 Dehumidifiers" to "167 Dehydrating agents."
• Incorrect cross-references from "393 Surfactants" to the
unrelated "218 Evaporation control agents" and from
"Depressants" to "3937 Wetting agents."
During the trial run, the following items were noted with
regard to the content of the functions Index:
• No entries for the common term "Perfumes" giving a cross-
reference to "3100 Fragrances" or for the common term
"Resin binders" with a cross-reference to "140 Coating
agents."
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No cross-reference from "Suds control agents" to "3861 Foam
stabilizers."
Incorrect cross-references from "Collectors" to "250
Frothing agents" and from "105 Bleaches" to "110 Bluing
agents" and "2440 Optical brighteners."
Utility
The utility of the current functions Index is diminished con-
siderably by the absence of entries in inverted form, an indication of
the function terms above or below the listed term in the function list
hierarchy, and functions contained in the function terms in List I but
which are not listed separately in the second level of the functions
list hierarchy. An Index containing these additional entries would
probably permit quicker, more useful classifications by users.
List II (Applications)
The list of applications reviewed in this part of the subtask was
supplied by the EPA Technical Monitor in May 1979 and consisted of 41
typewritten pages on which valid application terms were listed along with
their descriptions and code numbers. The list is presented in a four-
level hierarchy. A new page is started for each of the 28 first-level
application terms, which are listed in alphabetical order and have code
numbers in numerical sequence from 01 to 28. The terms at the other
levels are listed in alphabetical order under the more general terms
and assigned consecutive code numbers by the addition, starting with
zero, of a third digit for the second-level terms, a fourth digit for
the third-level terms, and a fifth digit for the fourth-level terms.
The first-level terms have two to ten second-level subsets. Some
second-level terms have no third-level subsets but one ("273 Miscellane-
ous textile products") has eleven, which has necessitated the use of a
letter in place of the fourth digit (i.e., "273A Tire cord and fabrics").
Most third-level terms have no fourth-level subsets and only one
("2512 Specialty cleaners") has as many as nine such subsets.
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Format
The listing of application terms in alphabetical order with
consecutive code numbers will be a source of problems when new applica-
tions are added. Either the code numbers of existing applications will
need to be revised or the alphabetical listing will need to be abandoned.
Because of the multilevel hierarchy of the applications list, eliminating
the hierarchy (as suggested earlier for the functions list) does not
appear to be a feasible way of solving this problem. If the use of code
numbers is considered necessary, abandonment of the alphabetical listing
would allow additions to be made as needed. The resulting system would
then be very similar in format to the SIC Code System upon which the
applications list appears to be based.
Content
List II includes no applications for products covered by the
SIC Major Group 21, Tobacco Products, or for the coal-derived products
included in SIC Major Group 29, Petroleum and Coal Products. Their
absence is not explained nor are the plus (+) signs and asterisks (*)
that follow many function code numbers.
Although the four-level hierarchy would appear to provide
ample opportunity to identify applications in very specific terms, the
hierarchy is used in a highly variable way. Further, no evidence is
given of the guidelines used to select the level of detail provided.
At the one extreme are the two-digit terms, "05 Drugs and
other Pharmaceuticals" and "02 Chemicals." The only subsets of the
former are human and veterinary drugs and the latter has only two subsets,
"020 Inorganic chemicals" and "021 Industrial organic chemicals," one of
which has no subsets and the other has only three (there is no fourth-
level hierarchy). This treatment of drugs is not consistent with the
considerable detail provided in List I for the functions of chemicals
used as drugs and it does not use the readily available subcategories
provided by either the SIC Code System or the U.S. International Trade
3-43
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Commission's annual publication "Synthetic Organic Chemicals, U.S.
Production and Sales." These same two sources also provide bases
for subdividing chemicals into numerous more specific categories.
At the other extreme, two SIC Major Groups—"35 Machinery,
Except Electrical" and "36 Electric and Electronic Equipment"—have been
combined in the two-digit function term, "14 Machinery and equipment."
The result is three pages of listings with ten subsets at the second
hierarchy level, up to ten subsets at the third level, and as many as
five subsets at the fourth level. Even with this much detail, some
terms at the third level are defined as combinations of applications
(e.g., "1463 Engines and turbines"), yet do not have subsets at the
fourth level.
Although the above-described treatment of "14 Machinery and
equipment" illustrates a desire to shorten the applications list by
combining major groups, it also illustrates a desire to provide very
specific applications by means of the multilevel hierarchy. The instances
of steps taken to combine and shorten the list are much more prevalent
throughout the whole applications list than cases where subdivision into
specific applications has been carried out. Numerous examples of the
following two situations were noted:
• The name of the application term indicates that it includes
more than one application (e.g., "0703 Phonograph records
and recording tape" and "0715 Rubber floor and wall
coverings"), but no subsets are listed.
• The name of the application term is followed by an explana-
tion of the applications that are included (sometimes for
as many as ten applications, e.g., "0710 Mechanical rubber
goods"), but no subsets are listed.
These procedures have the net effect of shortening the list
while making it much more difficult for the user to find the most
U.S. International Trade Commission, Synthetic Organic Chemicals.
U.S. Production and Sales, U.S. Government Printing Office,
Washington, D.C.
3-44
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appropriate application term. By providing mostly general terms, these
procedures also increase the chance that an application for which the
user has a specific description will be classified under one of the
general terms and valuable information about the specific application
will be lost. (This occurred on many occasions during the trial run.)
Because of the numerous slots available in the hierarchy, the separate
functions mentioned in application terms that are actually combinations
of applications and in parenthetical explanations of the application
terms should be listed individually.
The SIC Code System also combines two or more product types
into one category, which is undoubtedly the source for many of the
application terms that describe multiple applications. However, many
other combinations appear to have been constructed for the current
applications list, and the SIC hierarchy has been adjusted in the
applications list hierarchy to accommodate these combinations. Several
common results are: (1) unrelated products may be combined (e.g.,
"25104 Scouring cleansers and presoaks"), (2) whole SIC categories may
be lost (e.g., liquid heavy duty household detergents) and the products
covered by them must be described by general application terms, and
(3) terms are misclassified as subsets of other terms (e.g., in common
usage, "2510 Detergents, soaps and disinfectants" is not considered a
subcategory of "25 Sanitizing agents, polishes and cosmetics"). For
the user of the applications list who is familiar with the SIC Code
System and hopes to use it to assist in correctly classifying applica-
tions, these changes, (particularly when combined with the change to
alphabetical listing of the subset terms) are likely to cause consider-
able confusion.
The following additional aspects of the content of the applica-
tions list were noted in the course of reviewing the list:
• No explanation is given for the plus (+) signs and asterisks
(*) that precede many entries in the list.
• The definition for "021 Industrial organic chemicals"
includes the following parenthetical explanations:
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"(does not include plastic materials and synthetics.)"
The term, "plastic materials and synthetics," appears to
be a shortened version of the valid application term, "21
Plastic and rubber materials and synthetics (not fabricated),"
which has second-level subsets for "210 Cellulosic manmade
fibers," "211 Natural rubber," "212 Noncellulosic organic
fibers," 213 Plastic materials and resins," and "Synthetic
rubber." If the intention of the parenthetical explanation
is to point out that all of these applications are excluded,
then the complete valid application term, "21 Plastic and
rubber materials and synthetics (not fabricated)," is needed
to convey this thought.
The definition of "05 Drugs and other Pharmaceuticals"
includes a parenthetical explanation that the definition
"includes medicinal chemicals." However, the fact that
"medicinal chemicals" are excluded from "02 Chemicals" is
not stated in a parenthetical explanation of that applica-
tion term.
Utility
The utility of the present applications list is severely
limited by: (1) the absence of some major product groups; (2) the
variable usage of the hierarchy in subdividing major application
categories; (3) the use of application terms that combine several
applications but that do not have subsets in the hierarchy; (4) the
absence of subsets for applications mentioned in the parenthetical
explanations of application terms; (5) unusual combinations of applica-
tion terms and questionable hierarchies constructed to accommodate them.
Consequently, the job of using the applications list to locate the most
appropriate application term is particularly burdensome. Further, the
likelihood is very high that the selected term will be far more general
than the detailed information that the user could report if an appro-
priate specific application term were provided in the applications list.
Index to List II (Applications)
The Index reviewed in this part of the subtask was supplied by the
EPA Technical Monitor in May 1979 and consisted of 71 typewritten pages
on which application terms (including code numbers for valid application
terms from List II) were listed in alphabetical order along with
3-46
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appropriate cross references when needed. For application terms not
included in List II, the user is directed to see the valid application
term or terms listed in List II that are most closely related to the
listed term. For valid terms from List II, the user may be directed to
see also a limited number (up to six in one case, but usually only one
to three) of other valid application terms that are considered to be
related to the listed term. The code numbers for these valid terms are
included.
The Index does not identify those valid terms in the list that have
other valid terms as subsets because of the hierarchy of the applications
list. The only indication given in the Index that a valid application
term is a subset of another term is the fact that the subset terms have
three-, four-, or five-digit code numbers. The user does not learn the
term under which the listed term is a subset until the applications list
is consulted.
Format
The alphabetical listing of all application terms makes the
Index quite easy to use. As stated in the instructions (p. D-4), all
terms are listed in direct (e.g., Cyclic Chemicals), rather than inverted
form (e.g., Chemicals, Cyclic). Although the exclusion of inverted terms
results in a shorter Index, a shorter list may well make the Index more
difficult to use than a longer list (which would lead the user directly
to the correct application term with less searching for the proper term).
Because the multilevel hierarchy of the applications list
requires that code numbers of valid application terms be included in the
Index, these code numbers will need to be revised when new application
terms are added to the applications list.
Content
The failure to show in the Index the valid application terms
that are above and below the listed term in the applications list hierarchy
is not a significant shortcoming because the multilevel nature of the
3-47
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applications list might require repetition of a very large number of
entries in the Index.
Numerous application terms are defined in the applications
list (either in the application title or in parenthetical explanations)
as containing applications that are not listed separately as subsets in
the applications list hierarchy. These applications are not listed in
the Index with a cross reference to the appropriate valid application
term (e.g., "Medicinal chemicals" and "Botanicals" are both included in
the definition of "05 Drugs and other Pharmaceuticals" but neither is
listed in the Index so that a cross reference to "05 Drugs and other
Pharmaceuticals" can be made).
The definitions of many application terms include a statement
of what applications are excluded from the definition. Once the user
learns that a particular application is specifically excluded from one
application term, the user will probably then look in the Index for a
listing of the actual words used in the definition to describe the
excluded application. Unfortunately, most if not all of these excluded
applications do not appear as entries in the Index. Consequently, the
user knows where the application should not be classified but is given
no guidance on where it should be classified (e.g., "Testing laboratories
associated with manufacturing plants" is excluded from the definition of
"0401 Commercial testing" but no entry is listed in the Index so that a
cross reference to an appropriate classification can be given).
To further clarify how the application term, "16 Miscellaneous
products and services," is to be used, Index entries for "Applications
not listed," "Other applications," and "Unknown applications," with
appropriate cross references to "16 Miscellaneous products and services,"
should be added.
During the trial run, the following problems with the content
of the applications Index were noted:
• There were no entries for the common term, "Polymers,"
giving a cross reference to "21 Plastic and rubber materials
and synthetics (not fabricated)," or for "Mobile homes,"
3-48
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with a cross reference to "135 Prefabricated wood buildings,"
or for "Parchment," with a cross reference to "1924 Packaging
and industrial converting paper."
There were no entries for the following common terms with
appropriate cross references: "Shellac (except bleached),"
"Metal nitriding," "Embalming fluids," "Carpet laying,"
"Rubber electrical insulation," "Rubber rollers," "Aerosol
paints," and "Appliances."
Because the applications list includes "19115 Pressure
sensitive tape" as a subset of "19 Paper and allied products"
and includes "2642 Gasket, packing and sealing devices" as a
subset of "26 Stone, clay, ceramic, glass and concrete
products," any such products not made from these materials
could not be classified under these valid application terms.
No Index entries directing the user to alternative valid
application terms were available so more general terms had
to be selected.
Utility
The utility of the current applications Index is severely
limited by the absence of: (1) entries for applications contained in
the valid application terms or in the parenthetical explanations of
these application terms but not listed separately in the various levels
of the applications list hierarchy; (2) entries for applications that
are described in the applications list as being excluded from specific
valid application terms; and (3) entries for applications that cannot be
classified in certain valid application terms because the valid term is
restricted to products based on a particular material of construction.
Because of the deficiencies of the existing applications list,
even if the missing entries just described were added to the existing
applications Index, it is very doubtful that the combination of the
existing applications list and an improved index would assure that users
would be able to classify chemicals into meaningful specific applications
in an efficient manner.
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IV. EVALUATION OF THE OTS EXPOSURE ESTIMATION METHODOLOGY
Introduction
The EPA-OTS and its contractor, Calculon, have developed an exposure
estimation methodology based on the Use List described in Federal Register
of July 25, 1978, in which chemical use categories are used as surrogates
for exposure data. This methodology requires that three assumptions be
met, or that their violation be shown to be unimportant. These assump-
tions are: (1) chemicals will be correctly assigned to use categories;
(2) correct exposure estimates will be assigned to each use category; and
(3) exposures actually associated with individual chemicals will be
adequately characterized by the exposure estimates assigned to the use
categories to which these chemicals belong.
This chapter describes the results of Task 2 and includes discussions
of the exposure estimation methodology, the modifications in the method-
ology, the probabilities of violation of the three assumptions, the
probability that these errors will lead to erroneous decisions when
applied to either new or old chemicals, and an alternative approach.
The assessment of the third and fourth of these five items forms the
core of the chapter.
This assessment of the importance of errors assumes that the three
assumptions are independent, and hence that their probabilities of
error can be multiplied to estimate the probability of error for the
methodology as a whole. The independence of the first two assumptions
is plausible because the assignments of chemicals to use categories and
the computation of exposure estimates for those categories will be
performed by different people operating with different data bases. The
third assumption depends on the variability in the physical and chemical
properties possessed by chemicals that occur in a given use category and
hence is influenced more by the manner in which categories are defined
4-1
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than by anyone's ability to estimate an average exposure for the category
or anyone's understanding of the terminology of the Use List.
The Exposure Estimation Methodology
The exposure estimation methodology developed by Calculon contained
eight variables grouped into four factors: mode of human exposure, mode
of environmental exposure, amount of human exposure, and amount of
environmental exposure. This methodology included indices for the number
of routes and the number of forms of exposure, but did not distinguish
between the contexts, occupational versus consumer, in which these
exposures occurred. The methodology also included an implicit mechanism
for differentially weighting the eight variables.
The Calculon methodology was subsequently modified by the OTS to
the form presented in Table 1. This version omits the two factors in
the Calculon version that were concerned with the mode of exposure, but
differentiates between occupational and consumer exposures. The OTS
version omits the explicit weighting mechanism of the Calculon procedure,
but implicitly weights occupational exposures 200 times as heavily as
consumer exposures, because the numbers of people associated with
comparable index values under occupational and consumer exposures differ
by a factor of 200.
The indices for magnitude of contact also differ between occupa-
tional and consumer exposure in the OTS methodology. Occupational
contacts can be scored from 1 to 3, whereas consumer exposures can be
scored from 1 to 4, meaning that heavy consumer exposures are scored
more highly than the comparable occupational exposures. Moreover, the
magnitudes of contact for both types of exposures are defined in the
explanatory notes as percentages of the final product, and consequently
require that users of the methodology know the nature of the finished
product to ascertain whether a light contact, with a score of 1, means
that a person has been in contact with a product containing 1 yg, 1 mg,
or 1 gm of the chemical of concern.
4-2
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Table 1
OTS MODIFICATION OF FACTORS TO BE USED IN MEASURING THE AMOUNTS OF CONTACT
Factor 1
Amount of Human Occupational
Contact
•e-
UJ
No. of Persons Exposed
1. <1,000
2. 1,000-10,000
3. 10,000-100,000
4. >100,000
B. Magnitude of Contact
1. Trace
2. Light
3. Heavy
C. Duration of Annual Contact (hr/yr)
1. <200
2. 200-2,000
3. >2,000
Factor 2
Amount of Human Consumer
Contact
A. No. of Persons Exposed
1. <200,000
2. 200,000-2,000,000
3. 2,000,000-20,000,000
4. >20,000,000
B. Magnitude of Contact
1.
2.
3.
4.
Trace
Light
Moderate
Heavy
Frequency of Contact
1.
2.
3.
4.
Yearly
Monthly
Weekly
Daily
Factor 3
Amount of Environmental
Contact
Amount of Discharge
1. As constituent of a
bulk solid
2. Up to 1% of substance
3. 1-10% of substance
4. 10-100% of substance
Extent of Geographic
Discharge
1. One location
2. Limited
3. Widespread
-------
The measures of number of contacts differ between occupational and
consumer exposures, both with respect to the manner in which they are
expressed and the ranges in the scores that can be assigned to these
two variables. Occupational exposures are expressed as the duration
of contact in hours per year with a maximum score of 3 whereas the
consumer exposures are expressed as the frequency of contacts with a
maximum score of 4. The scale for occupational contact begins with a
score of 1 for contacts up to five work weeks in duration, and extends
to contacts in excess of a normal work year. Although the highest scores
for the duration of occupational contacts could only be obtained by
extended contact each day, the lowest score could occur in several
patterns (e.g., a single period of continual contact or in weekly
contacts of approximately four hours duration). Thus, the scale for
the occupational contact is generally more ambiguous than the scale for
consumer contacts, which specifies either daily, weekly, monthly, or
yearly contacts.
The OTS methodology omits indicators of the route of exposure
(e.g., respiratory, dermal) or the form of exposure (e.g., solid,
liquid), both of which influence the seriousness of exposure. However,
it is not clear how one should weight the various forms and routes of
exposure and consequently it is not evident that multiple routes of
exposure should necessarily be weighted more heavily than single routes
of exposure. The alternatives taken by the Calculon methodology that
gave each route and form of exposure equal weight and the OTS methodology
that ignores these phenomena therefore seem to be of equal value.
The scale for magnitude of environmental contact (amount of discharge)
parallels the scale for consumer exposures, both with respect to the
reliance on percentage data and the use of a scoring range from 1 to 4.
The scale for the number of contacts (extent of geographic discharge)
differs from the scales for consumer exposure with respect to the range
of possible scores (3 versus 4 points), but is no more ambiguous than
the scales for the numbers of people exposed, given the wide range in
the numbers of people represented by the scores in the latter scales.
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The overall effect of the uneven features of the OTS methodology
is to obscure the relative weight given to occupational versus consumer
human exposures and to human versus environmental exposures. The use
of the percent present in a product as a measure of magnitude of contact
without knowledge of the quantity of the product involved prevents
measurement of the total magnitude of exposure for different products
(i.e., 0.1% present in a product produced in million pound quantities
represents more exposure in absolute terms than a level of 10% in a
product where the quantity of product is only a few thousand pounds).
The net effect is that the methodology is harder to interpret than is
necessary.
Modification of Methodology
In view of the above described problems with the OTS methodology,
we suggest that the methodology be further modified by:
• Putting numbers of people for occupational and consumer
exposures on a common scale
• Putting magnitude of contact on the same numerical scale for
both occupational and consumer exposure
• Putting the duration/frequency scales on a single basis
• Making the number of possible scores consistent among the
components of exposure
• Making the scales for environmental exposures as nearly equal
to the other two as possible.
These changes have been made in the SRI-developed version shown
in Table 2; however, occupational and consumer exposure are still
weighted more heavily than environmental exposures, because these two
classes of exposure can contribute four times more to the overall
score than can the environmental exposures. Although we did not
reinstate the explicit weighting methodology that had been present in
the Calculon version because of significant difficulties in obtaining
weights upon which all interested parties can agree, this differential
can be easily removed, if desired. Either two more components can be
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Table 2
PROPOSED FACTORS TO BE USED IN MEASURING THE AMOUNTS OF CONTACT
Factor 1
Amount of Human Occupational
Contact
Factor 2
Amount of Human Consumer
Contact
Factor 3
Amount of Environmental
Contact
of Persons Exposed
<105
105-106
106-107
No.
1.
2.
3.
4.
B. Magnitude of Contact
1. <10 mg
2. 10-100 mg
3. 100 mg-lg
4. >lg
Frequency of Contact
1. Yearly or less
2. Monthly
3 . Weekly
4. Daily
Duration of Contact
1. Seconds
2. Minutes
3. Hours
4 . Days
B. No. of Persons Exposed
<105
A. No. of Locations of Discharge
105-106
106-107
1.
2.
3.
4.
B. Magnitude of Contact
1. <10 mg
2. 10-100 mg
3. 100 mg-lg
4. >lg
C. Frequency of Contact
1. Yearly or less
2. Monthly
3. Weekly
4. Daily
D. Duration of Contact
1. Seconds
2. Minutes
3. Hours
4. Days
1.
2.
3.
4.
1-10
10-100
100-1,000
>l,QOO
B. Amount of Discharge (Metric Tons)
1. <1
2. 1-10
3. 10-100
4. >WO
-------
added to the environmental factor or the scores for the number of
locations of discharge and the amount of discharge can be doubled. We
did not add extra scoring components because the phenomena that seemed
most important—rapidity of transformation and measures of the ease of
transport—both required more data or sophistication of judgment than
we felt could be readily provided. We elected not to double the weight
given to the two environmental components that were included since it
would have meant a further departure from the version developed by the
OTS and Calculon without clearly improving or clarifying the scoring
methodology.
Because the ranges in magnitude of each of the ten variables included
in the modified system differ from adjacent ranges by one order of
magnitude, or approximately so, the scoring system is effectively based on
logarithms. Hence, adding scores for the ten components to obtain an
overall score is equivalent to multiplying the numbers that they
Q
represent. Thus, a score of 26 would represent roughly 10 more units
of exposure than would a score of 18.
Although these very large differences in units of exposure are
associated with rather modest differences in overall scores, transforming
the scores into linear scales of exposure is not necessary. Indeed, to
do so would simply make the awkwardness of the units conspicuous, thereby
raising questions that are irrelevant to the establishment of relative
measures of exposure. The units of exposure are unconventional due to
the merging of environmental exposures with occupational and consumer
exposures. The result is a meaningless unit for absolute measures of
risk, but this is of no concern when only relative measures are needed.
Indeed, for purposes of assessing the relative magnitudes of exposure,
it is far more important to keep in mind that the methodology leaves
out many nuances which are important when one is attempting to obtain
precise estimates of risks. Some of these omissions will surely be
sources of error in the screening methodology. For example, if the
number of persons exposed is based on exposure to a class of chemicals,
the exposures of most individual chemicals in classes containing large
4-7
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numbers of chemicals will be grossly overestimated. The exposures of
chemicals in classes with few members will be less severely over-
estimated. Similarly, the scoring system will work better for those
classes of use that necessarily require a fairly rigid set of physical
or chemical properties to satisfy the need of the user than for those
classes of use in which various combinations of properties are effective
in the particular application. For example, if the chemicals that met
a user's needs varied one or more orders of magnitude in volatility, the
exposures associated with these chemicals would be poorly represented
by any one estimate.
Applications of Methodology to New Chemicals/New Uses
Probability That Estimate Components Are Accurate
To better evaluate the utility of the scoring system for application
to new chemicals and new uses of old chemicals, expert opinion was
sought on the probability that the individual components would be
accurately determined. Three Senior Industrial Economists in the
Chemical Industry Economics Program of SRI's Chemical Industries Center
and a Senior Industrial Hygienist in the Environmental Group of SRI's
Center for Occupational and Environmental Safety and Health were
surveyed for this purpose. The derivation of the Use List and the
components of the scoring system were explained to them. To solicit
their comments on the components of the modified scoring system depicted
in Table 2, they were each asked the following four questions in the
sequence shown (opportunity was given for further discussion of each
aspect of the system before the next question was asked):
(1) What is the probability of assigning a chemical to the correct
use category using the Use List?
(2) What is the probability of assigning correct exposure estimate
scores to the individual use categories if the assignment is
made by: (a) an industry expert or (b) a generalist with no
experience in the area involving the particular use?
(3) What is the probability that the exposure situation for a
specific new chemical will be accurately reflected by the
exposure estimate score of the use category to which it is
assigned?
4-8
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(4) What are the relative merits of using the exposure estimates
for use categories as a measure of exposure to a specific
chemical versus obtaining exposure estimates on the specific
chemical directly from the manufacturer and/or processor?
A summary of their answers and the subsequent discussions follows.
Question 1. Assigning Chemicals to Use Categories
The consensus was that assigning chemicals to use categories
should cause no problem if:
• Combinations of function and application components beyond
those given in the July 25, 1978 Federal Register were
permissible.
• Additional functions and applications could be added to the
lists to further subdivide the categories as needed to
properly characterize uses.
The estimates of probability of success ranged from 90 to 100%.
Question 2. Assigning Scores to Use Categories
The estimates of the probabilities of assigning correct scores
to use categories varied considerably. The lower estimates appear to have
been based largely on disbelief in one premise for assigning scores to a
use category—namely, that single values could be assigned for the whole
class of chemicals covered by the use category. For example, in a use
category containing a total of 30 chemicals, if one or two represented
70-90% of the total quantity used and the number of people exposed to
these two (or the magnitude, frequency, or duration of exposure) was
dramatically different from the values for the other members, would the
scores be estimated to represent all 30 chemicals, only the most signifi-
cant two, or some combination of these (i.e., what basis would be used
to estimate a typical value)?
Not unexpectedly, the estimates of success for assignments by
an expert were uniformly much higher than for those by a generalist, but
even the estimates for an expert were not very high: from a low of less
than 25% to a high of only 85%. The range for a generalist was 1% to
4-9
-------
30% with some feeling that a generalist would probably come closer to the
expert in the area of consumer exposure than in the occupational exposure
area. The opinion was expressed that a higher probability of accurate
estimates would be possible for applications that had been subcategorized
in sufficient detail to pinpoint a particular use area (i.e., where a
single market was identified, not several similar but different markets
covered by a more general description).
Question 3. Appropriateness of Use Category Scores for
Specific Chemicals
Estimates were sought for each of the four major components
of the exposure estimates for occupational and consumer exposure. The
four staff members estimated that the probability of the use category
estimate components being appropriate for the specific chemical were as
follows:
Exposure
Type
Occupational
Consumer
Number of
People
Exposed*
50,50,50,10
90,50,50,10
Magnitude
50,<50,30,80
40,<50,30,80
Contact
Frequency
70,>50,>60,90
50,<50,>60,90
Duration
90,>50,30,90
70,<50,30,90
The probability estimates of individuals are given in a consistent
position; for example, one individual was responsible for the first
probability estimate in each set of four.
The 10% estimate for the number of people was based on the
belief that the applications were not sufficiently subdivided to assure
that the typical value for the use category would come close 'to that of
individual chemicals in the use category. The 80% estimate for the
magnitude of contact was based on a belief that the relative efficiency
of the chemicals in carrying out the function in the particular applica-
tion would be the major influence on the magnitude of exposure and that
changes in efficiency exceeding the 100-fold range represented by each
score would be very unlikely. Although the estimates vary somewhat, the
4-10
-------
general feeling was that magnitude, frequency, and duration estimates
were sufficiently related that the probabilities of appropriateness of
the use category estimates for a specific chemical would be about the
same for all three of these components.
If the eight probability estimates of each expert are multiplied,
and the four resulting products are averaged, the resulting value of the
probability of correctly assessing all eight parameters is about 0.006.
Question 4. Relative Merits of Use Category Scores vs.
Estimates on Specific Chemicals
There was unanimous agreement that the characterization of a
specific chemical by the exposure estimate scores developed for a use
category was a very inefficient way to accurately assess the exposure
possibilities of a specific new chemical compared to seeking estimates
for that chemical. The probability that estimates by manufacturers
and/or processors of the number of people, and the magnitude, frequency,
and duration of contact would provide more accurate scores for the
specific chemical was estimated at greater than 90% for both occupational
and consumer exposure.
Significance of Scoring Errors
Despite the preceding estimates of high probability of errors in
scoring if the methodology were to be used with new chemicals, the
usefulness of the scoring methodology is impaired only if many of the
errors cause poor decisions. Because it is anticipated that the 800-1000
chemical use categories will be grouped into 10-15 groups according to
the scores assigned by the scoring methodology, and because it is probable
that resource constraints will prohibit examination of chemicals assigned
to categories outside the group or groups with the highest scores, only
those errors that determine the presence or absence of a use category
from this top group or top set of groups will affect decisions regarding
subsequent actions.
4-11
-------
The probability that such an error will occur is most simply
appraised by determining the .probability that a one-point error in the
total score for a chemical use category will occur and will cause an
erroneous decision. This probability is itself the product of two
probabilities. The first is the probability that a one-point scoring
error will cause the chemical use category to be placed in the wrong
group. The second is the probability that this will be a move from the
group just below the decision threshold to the group just above, or from
the group just above to the group just below.
Because the scoring methodology allows a maximum score of 40 and a
minimum score of 10, the scores for the 800-1000 use categories will
span a range of 30 points. If they are grouped into ten groups, with a
spread of 3 points in each group, then an error of one point in scoring
would have one chance in three (p = 0.33) of causing an error in placement
of that chemical use category. Two points of error in the same direction
would have two chances in three of causing an error (p = 0.66), and three
in the same direction would ensure it. Multiple errors in varying
directions would either act an unidirectional errors or simply not affect
the score, depending on the extent to which errors in opposing directions
are balanced.
If we assume, for the moment, that only one-point errors occur and
that the 800-1000 use categories are evenly distributed among the ten
groups, then only 1/9 or 11% of the errors in assigning use categories
to the ten groups of use categories will move a chemical use category
from one side of the decision threshold to the other. Thus, under these
simplifying assumptions, the probability that a one-point error in
scoring of use categories will cause a poor decision is 0.33 (the
probability of a shift from one group of use categories to another)
x 0.11 (the probability that the shift from one group to another will
affect a decision) or 0.04.
The probability that a one-point error in scoring will occur can be
computed in a similar manner. Given that the scoring methodology
requires the input of ten numbers, if the probability of a correct
4-12
-------
assessment for each is 0.9, the probability that all ten will be correct
is 0.9 or 0.35. Hence, the probability of an error is 0.65, if this
relatively optimistic assumption is used. If the probability of estimat-
ing each of the ten numbers is assumed to be 0.5, then the probability
of all being correct is 0.5 or 0.001, and the corresponding probability
of error is 0.99. Hence, these assumptions, which bracket the expert's
estimates, suggest that the probability of error lies between 0.65 and
0.99.
The significance of these high probabilities of error diminishes
greatly, however, when these estimates of the probability of an error in
scoring are combined with the relatively low probability that an error
will affect decisions. Thus, under the assumptions used, the probability
that a poor decision will be made due to an error in scoring and grouping
use categories will lie between 0.03 and 0.04 (i.e., 0.04 x 0.65 and
0.04 x 0.99) if only those uses falling within the highest scoring groups
or perhaps the higher two to three groups are retained for further study.
This may also be stated as being a probability of 0.96 to 0.97 that the
decision will be correct.
The implications of the six assumptions used in the preceding four
paragraphs are discussed in Appendix F.
Accuracy of Methodology
The net effect of the preceding analysis is to rule out, as serious
problems, the first two assumptions set forth in the Introduction of this
chapter. Thus, the utility of the scoring methodology stands or falls
upon the probability that the scores assigned to categories of chemical
use will be reliable indicators of the exposures associated with
individual chemicals within those categories. Using the expert opinion
described above as an approximation, the probability that high exposure
chemicals will be identified by the scoring methodology can be
optimistically set at 0.99 (the experts gave 0.9-1.0 as the probability
that a chemical will be assigned to the correct use category) x 0.97 (the
probability, computed above, that the use category will be correctly
4-13
-------
placed with respect to the decision threshold) x <0.1 (the average of
products of the eight estimates, given by each expert, of the proba-
bilities of correctly scoring individual components of exposure) or
<0.1. Even if the experts were unduly pessimistic and each of the eight
probabilities given in response to the third of the four questions which
they were asked was actually 0.7, the probability of a correct decision
would still be only 0.06, or one in sixteen. Thus, even an optimistic
estimate of the accuracy of the overall performance of the scoring
methodology implies that assessments of the exposures associated with
the individual chemicals will be wrong about 15 out of 16 times, with
the failure of scores for the use categories to accurately reflect the
exposure associated with individual chemicals being the decisive factor.
Application of Methodology to Old Chemicals/Old Uses
The arguments regarding the inaccuracies of the scoring methodology
when applied to new chemicals/new uses apply equally well to old
chemicals/old uses. However, for old uses of old chemicals, where the
EPA lacks the authority to require submittal of data, and yet must cope
with an estimated 40,000 chemicals, the inaccuracies of the scoring
methodology do not necessarily destroy all utility of this system. It
might be useful if it could be shown to be sufficiently accurate to
separate out some subset of chemicals that unquestionably have higher
than average exposures. This would be true even though the ability of
the scoring methodology to reliably discriminate among the chemicals
within this high exposure subset seems highly questionable given the
arguments presented in the preceding section on new chemicals/new uses.
Two arguments can be made in support of the ability of the method-
ology to usefully narrow the estimated 40,000 chemicals to a more
manageable number. First, if we use a rough approximation of the
estimates of the SRI experts that the probabilities that the scores for
chemical classes for the ten components of exposure will correctly
reflect the scores that individual chemicals should receive, and assume
that the probabilities of any one of the ten factors correctly represent-
ing the exposure for individual chemicals is 0.5, then we can expect the
4-14
-------
probability of misrepresenting all ten factors to be equal to the
probability of correctly representing all ten factors. The probabilities
of either correctly or incorrectly representing all ten would then be
0.5 or less than 0.01. Hence, ignoring multiple point scoring errors,
there would be less than one chance in one hundred that the difference
of 10 points will exist between the score a chemical should receive and
the score assigned to it by virtue of its use category's score. Thus, if
one retains for further study chemicals with a score of more than 30,
we can expect to retain: (1) those chemicals that correspond closely to
the scores assigned to the use categories to which they belong, when those
use categories are scored between 31 and 40; (2) virtually all of those
chemicals that are misscored but actually warrant a score of 40 (i.e.,
those uses for which all components would have to be misscored or for
which a few would have to be very poorly scored, to reduce the score to
30); and (3) a significant fraction of those chemicals that have high but
not the highest exposures, for example those with exposures corresponding
to scores of 37-39 (i.e., those chemicals for which 8 or 9 points of
error are needed to exclude them from further study). Thus, the
chemicals with the highest exposures will probably fall within the score
range from 31 to 40 and be retained.
Secondly, given the tendency for distributions of large numbers of
items to be either normal or log-normal (rather than uniform as assumed
in the analyses in prior sections), it is probable that the potential
for separating a relatively small number of high exposure chemicals from
the larger number of moderate and low exposure chemicals is high—much
higher than under the assumption of a uniform distribution. With
either a normal or log-normal distribution, a user of the scoring
methodology could examine only the upper tail of the distribution
(e.g., the top 10% of the chemicals at the most and probably only a
few hundred chemicals) without missing many high exposure chemicals.
These probabilities and the resultant decisions on how many chemicals
should be retained can be determined once the distribution of the
appropriate categories scores for the 40,000 chemicals is known.
4-15
-------
Because each point in this scoring system corresponds to roughly
an order of magnitude variation in one component of exposure, the
9-point spread (scores of 31-40) would correspond to about 9 orders of
magnitude variation in the actual units of exposure, if one gives equal
weight to variations in the numbers of people exposed, the duration of
exposure, the frequency of exposure, and the amount of contact per
exposure (as in the proposed methodology shown in Table 2). The highest
exposures among those retained (scores close to 40) would be much higher
than the exposures for those excluded from further study. Thus, the
methodology, when combined with toxicity information, can be expected to
capture most if not all chemicals characterized by exceptionally high
exposures and exceptionally high potential for damage per unit of exposure.
However, given the experts' lack of confidence in the estimates of the
scoring elements, it is probable that the methodology would be of little
use in ranking chemicals within the set of the chemicals with the highest
exposure.
It is also probable that the methodology would perform very poorly
for less hazardous chemicals characterized by the combination of
moderate exposure and high potential for damage per unit of exposure;
intermediate scores can be obtained in numerous ways as a result of
partially compensating errors.
If a decision were made to investigate further only those chemicals
in the highest of the ten scoring groups (i.e., those with scores of 38,
39, or 40), then the cost of using the scoring methodology on all 40,000
chemicals could be reduced by proceeding in a stepwise fashion to
eliminate categories from further scoring if their scores for a few
selected subfactors indicated that their total scores could not be in
the 38-40 range. For example, the number of persons exposed occupationally
could be determined first. The possible scores for this subfactor range
from 1-4, so that any use categories found to have a score of 1 (categories
where less than 100,000 persons are exposed occupationally) could be
dropped from further consideration, because the total score could no
longer amount to 38, 39, or 40. The categories found to have scores of
2-4 for the number of persons exposed occupationally could then be scored
4-16
-------
for the number of persons exposed in consumer contacts. Only those
categories having a total score of 6-8 (out of the possible combined
score of 8 for persons exposed from both occupational and consumer
contact) would be retained for further scoring. By continuing this
process through the remainder of the subfactors, the number of categories
of continued interest could be systematically reduced until some preferred
number was reached. At that point, scoring of all remaining categories
for all remaining subfactors might be appropriate.
4-17
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APPENDIX A
CHARACTERIZATION OF INDUSTRY COMMENTS BY TYPE OF RESPONSE
A-l
-------
CHARACTERIZATION OF INDUSTRY RESPONSES BY TYPE OF COMMENT
Type of Industry Comment
1. Purpose of list
2. List is usable
EPA Response Number
34, 48, 49, 52, 53,
54, 58, 61, 64, 68,
71, 79, 82, 83, 89
25, 28, 37, 62, 72
3. Abandon the system
4. Not useful for EPA objectives
5. Burden to report
6. Use should be defined by end users
7. Confusing for persons of moderate
technical background
8. Ambiguity of functions and applica-
tions
9. Separate lists of functions and
applications
11
11, 16, 19, 47, 65,
79, 82, 89, 94, 95
11, 22, 32, 50, 58,
83
3, 11, 12, 15, 22, 47,
48, 49, 51, 55, 61, 65, 76,
79, 82, 83, 85, 86
7, 10, 19, 30, 34, 38,
40, 47, 48, 51, 53, 68,
73, 74, 78, 79, 82, 83,
85, 89, 95
34, 47, 48, 49, 50, 51,
52, 53, 65, 67, 68, 78,
79, 82, 89
56, 65, 73, 82,
84, 89, 91
A-3
-------
10. Report in industry's own words 19, 47, 49, 52, 58
79, 91
11. Application to SNUR 3, 47, 48, 49, 50,
52, 61, 71, 86
12. Simplify instructions 14, 15, 84
13. Redefine function and application 2, 21, 52, 63, 82
14. Broaden categories of use 16, 48, 70, 84
15. Include an "unknown" category 12
16. Include a "starting material" category 61
17. Use alphabetical system 21
18. Do not use alphabetical arrangement 63
19. Base applications on entire SIC code 73
20. Correlate both functions and applications 37
with SIC code
21. Reverse format of Appendix I 52
22. Reorganize Appendix I with major classes 70
23. Expand codes 7
24. Less detail in applications 34
25. List should be more comprehensive 26
26. Different sources 22, 82
27. Alternative approaches 46, 36, 11, 34, 64
A-4
-------
APPENDIX B
CLASSIFICATION OF USES OF FIVE SELECTED CHEMICALS
B-l
-------
w
I
OJ
CHEMICAL: AMMONIA
SOURCE: Chemical Economics Handbook, SRI International
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
PAGE
756.1006 B
B
C
C
C
I
J
M
Y
Y
X
X
X
X-Y
Y
Y
Y
Y
USE AS DESCRIBED USING EPA DESCRIPTORS
Function
Code Name
Production of nitric acid 129 Chemical raw material
Production of acrylonitrile 129 Chemical raw material
Production of urea 129 Chemical raw material
Production of ammonium sulfate 129 Chemical raw material
Production of ammonium nitrate 129 Chemical raw material
Production of caprolactam 129 Chemical raw material
Production of hexamethylenediamine (in mfr. of
nylon 6/6 fibers & plastics) 129 Chemical raw material
Nitrogen fertilizer (i.e., direct application of
anhydrous & aqua ammonia) 227 Fertilizer
Dilute solutions for household cleaning uses 136 Cleaner
Ingredient of household cleanser formulations 136 Cleaner
Extraction of vanadium from its ores 129 Chemical raw material
Extraction of tungsten from its ores 129 Chemical raw material
Extraction of molybdenum from its ores 129 Chemical raw material
Used in metallurgical market to provide a reducing
atmosphere or source of nitrogen (by dissociation)
for nitriding or carbonitriding 129 Chemical raw material
Modifying reagent in the froth flotation of
phosphate ores 129 Chemical raw material
Refrigerant in industrial refrigeration facilities 2632 Refrigerant
Nutrient in secondary wastewater treatment ponds 3080 Bacteriological nu-
trients
Solvent for casein in pigmented coatings for
Code
020
0210
0210
020
020
0211
0210
012
2512
2512
1528
1527
1527
064
15302
1A84
04320
Application
Name
Industrial inorganic
chemical
Acyclic chemical
M
Industrial inorganic
chemical
H
Cyclic chemical
Acyclic chemical
Crop production
Specialty cleaner
Specialty cleaners
Uranium-radium-vana-
dium ore mining
Misc. metal ore mining
ii
Metal processing
operations
Phosphate rock mining
Refrigeration, air con-
dioning & heating equip-
ment
Industrial water treat-
ment systems
pulp & paper industry
Used in sulfite or semichemical pulping processes
for pulp & paper industry
384
Solvent
1911 Coated & glazed
paper products
129 Chemical raw material 195 Pulp mill products
-------
CHEMICAL: AMMONIA ~ continued
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
PAGE
Z
Z
Z
Z
611.5030 A
w
1 642.5030 B
760.5001 A-D
733.6000 B
756.1000 D
D
535.8001 C
Reduces taste & color of chlorine in purified
USE AS DESCRIBED USING EPA
Function
Code Name
water supplies 129 Chemical raw material
129 Chemical raw material
Used for sludge digestion control in sewage treatment 129 Chemical raw material
For pH adjustment, in secondary wastewater treatment
ponds for various industries 329 pH control agent
Processing of uranium ores to produce uranium
concentrate 129 Chemical raw material
Production of lower alkyl (Cj-C4) amines 129 Chemical raw material
Production of ethanolamines (mono, di, and tri) 129 Chemical raw material
Production of ethylene amines (ethylene diamine,
diethylene triamine, etc.) 129 Chemical raw material
Production of hexamethylene tetramine 129 Chemical raw material
Production of fatty nitriles and amines 129 Chemical raw material
Production of monoammonium phosphate 129 Chemical raw material
Production of diammonium phosphates 129 Chemical raw material
Production of sodium carbonate 129 Chemical raw material
Leaching agent in copper ore processing 129 Chemical raw material
Solvent for sulfur in ammonia-sulfur fertilizer
solutions 384 Solvent
pll control in urea-formaldehyde solutions to
prevent polymerization during storage and shipping 328 pH control agent
DESCRIPTORS
Application
Code
04070
04071
04321
04320
1528
0210
0210
0210
0211
0210
020
020
020
1521
012
0210
Name
Water purification
(industrial)
Water purification
(municipal)
Sewage treatment systems
Industrial water
treatment systems
Uranium-radium-vana-
dium ore mining
Acyclic chemicals
u
ii
Cyclic chemicals
Acyclic chemicals
Industrial inorganic
chemicals
u
M
Copper ore mining
Crop production
Acyclic chemicals
-------
CHEMICAL: ETHYL ACETATE
SOURCE: Chemical Economics Handbook
USE AS NORMALLY DESCRIBED IN THE
PAGE
, SRI Intel
INDUSTRY
•national; Publicker Product
USE AS DESCRIBED
Catalog, p
USING EPA
Function
Code
Name
87 (1971)
DESCRIPTORS
Application
Code
Name
Cd
I
Ui
PPC
CEH,p.643.
5030C
PPC
Solvent for nitrocellulose
Solvent for ethyl clellulose
Solvent for cellulose acetate
Solvent for suellac
Solvent for plastics (e-8-> synthetic
384
Solvent for ink
rubber and vinyl resins)
law material for manufacture of ethyl acetoacetate
Solvent for purification of ethyl acetoacetate
and medicines
Solvent in manufacture of candy glaze
Solvent in manufacture of cleaning compounds & fluids
Solvent in manufacture of embalming fluids
Solvent in manufacture of flavors
Solvent in manufacture of nail polish remover
Solvent in manufacture of paint & varnish removers
Solvent in manufacture of perfumes
iolvent in manufacture of spirit varnishes
penaturant for denatured alcohol (29, 35, 35A)
Solvent
2131
384
384
384
384
384
129
384
384
384
384
384
384
384
384
384
384
113
Solvent
Solvent
Solvent
Solvent
Solvent
Chemical raw material
Solvent
Solvent
Solvent
Solvent
Solvent
Solvent
Solvent
Solvent
Solvent
Solvent
Denaturant
2131
2131
1880
2131
214
24
0210
05
0983
04120
16
0911
2504
1861
2505
1809
1832
F384
Thermoplastic resins
& plastics
Bleached shellacs
Thermoplastic resins
& plastics
Synthetic rubber
Printing inks
Acyclic chemical
Drugs & other pharma-
ceuticals
Confectionery products
Dry cleaning
Misc. Products & Services
Flavoring extracts
Manicuring prepara-
tions
Paint & varnish
removers
Perfume, cologne, &
toilet water
Varnishes (exterior)
Varnishes (interior)
Solvents
-------
CHEMICAL:
ETHYLENE
SOURCE
USE AS NORMALLY
PAGE
: Chemical Economics Hi
DESCRIBED IN THE INDUSTRY
indbook,
SRI International
USE AS DESCRIBED USING EPA
Function
Code
Name
DESCRIPTORS
Application
Code
Name
CEH, p. 648.
5053P
Q
R
505AM
P
P
V
X
5055A
A
B
E
G
H
I
J
J
J
K
K
K
K
K
5053Z
Production of low density polyethylene
Production of high density polyethylene
Production of ethylene oxide
Production of ethylbenzene (all of which is used
to make styrene)
Production of alpha-olefins
Production of alphatic alcohols
Production of ethyl alcohol
Production of acetaldehyde
Production of vinyl acetate
Comonomer in ethylene-vinyl acetate resins &
emulsions (contain <60% vinyl acetate)
Production of ethyl chloride
Production of ethylene-propylene e astomers
Production of propionaldehyde
Production of ethylene dibromide
Comonomer for modified polypropylene (having
improved impact resistance for use in
injection molding and wire & cable applications,
as well as film)
Comonomer in vinyl acetate
adhesives which contain > 60% vinyl acetate
Production of vinyl toluene
Production of triethylaluminum
Production of ethylaluminum chlorides
Production of ethylanilines
Production of diethyl sulfate
Production of 1,4-hexadiene
Ripening agent for fruits & vegetables
Production of ethyl bromide
Production of ethylene dichloride
1290 Monomer
1290 Monomer
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
1290 Monomer
129 Chemical raw material
1290 Monomer
129 Chemical raw material
129 Chemical raw material
1290 Monomer
1290 Monomer
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
261 Growth regulator
261 Growth regulator
129 Chemical raw material
2131
2131
0211
0211
0210
0210
0210
0120
0210
2131
0210
214
0210
0210
2131
2131
0211
0210
0210
0211
021Q
0210
0122
0124
0210
Thermoplastic resins
& plastics
ii
Cyclic chemicals
Acyclic chemicals
Thermoplastic resins
& plastics
Acyclic chemicals
Synthetic rubber
Acyclic chemicals
ii
Thermoplastic resins
& plastics
Cyclic chemical3
Acyclic chemicals
If
Cyclic chemicals
Acyclic chemicals
Fruit production
Vegetable production
Acyclic chemicals
129 Chemical raw material 0210
-------
to
I
CHEMICAL: UREA
SOURCE: Chemical Economics Handbook, SRI International
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
PAGE
756.2004 H
J
Q
Q
R
Z
756.2005 C
E
E-F
F
K
K
K
K
K
USE AS DESCRIBED USING EPA
Function
Code 1 Name
Direct application nitrogen fertilizers 227 Fertilizer
Bulk blended nitrogen fertilizer 227 Fertilizer
Fertilizer for closed stands of conifers in
forest fertilization 227 Fertilizer
Production of ureaforms (slow release nitrogen
fertilizers) 129 Chemical raw material
Non-protein nitrogen source in cattle feeds 3081 Foodstuffs
Used for urea- formaldehyde adhesive resins 129 Chemical raw material
Used for urea-formaldehyde paper treating & coating
resins 129 Chemical raw material
Used for urea-formaldehyde textile treating resins 129 Chemical raw material
Used for urea- formaldehyde surface coating resins 129 Chemical raw material
Production of melamine 129 Chemical raw material
In urea mixtures as chemical deicing agents on
airport runways 168 Deicer
Production of cyanuric acid 129 Chemical raw material
Production of urea hydrogen peroxide 129 Chemical raw material
Production of barbituric acid 129 Chemical raw material
Manufacture of sulfamic acid 129 Chemical raw material
Code
012
012
0140
0210
0151
2132
2132
2132
2132
0211
DESCRIPTORS
Application
Name
Crop production
"
Forest nurseries
Acyclic chemicals
Livestock production
Thermosetting resins
& plastics
if
H
H
Cyclic chemicals
2881 Transportation terminals
0211
0210
0211
020
Cyclic chemicals
Acylic chemicals
Cyclic chemicals
Industrial Inorganic
chemicals
Manufacture of ammonium sulfamate
760.5001 E Production of urea-ammonium phosphates
535.8001 B |Production of isobutylidene diurea
129
Chemical raw material 020
227 Fertilizer 012 Crop production
129 Chemical raw material 0210 Acyclic chemicals
-------
CHEMICAL: SULFURIC ACIP
SOURCE: Chemical Economics Handbook, SRI International
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
PAGE
CEH, p. 780
1005 F
F
I
J
L
M
USE AS DESCRIBED USING EPA
Function
Code Name
"reduction of isopropyl alcohol 129 Chemical raw material
Production of sec. butyl alcohol 129 Chemical raw material
'reduction of aluminum sulfate 129 Chemical raw material
deduction of ammonium sulfate 129 Chemical raw material
Slectrolyte in lead-acid storage batteries 207 Electrolyte
Conversion of viscose into rayon 129 Chemical raw material
Code
0210
0210
020
020
14651
2101
DESCRIPTORS
Application
Name
Acyclic chemicals
H
Industrial inorganic
chemicals
11
Sli-type storage
batteries
Rayon, viscose &
cupra ammonium
processing
CXI
M
M
N
0
0
0
p
R
R
R
S
T
onversion of viscose into cellophane
atalyst in production of cellulose acetate
reduction of sodium dichromate
reduction of chro ic acid 129
caching copper from oxide ores in deposits, 129
mine dumps & wastes
:ondensing agent in manufacture of DDT 129
)ehydrating agent in manufacture of chloral 167
'recessing of phosphate rock to wet process 129
phosphoric acid & normal superphosphate
'reduction of hydrochloric acid 129
•reduction of hydrochloric acid from potassium.chloride 129
'reduction of sodium sulfate 129
reduction of hydrofluoric acid 129
ickling (usually batch pickling) of iron 6, steel 330
Jkylation of olefins & alkanes in petroleum
refining
.ube oil refining
129 Chemical raw material 2101
120 Catalyst 2100
120 Catalyst 2101
129 Chemical raw material 020
Chemical raw material 020
Chemical raw material 0521
Chemical raw material 0211
Dehydrating agent 0210
Chemical raw material 020
Chemical raw material 020
Chemical raw material 020
Chemical raw material 020
Chemical raw material 020
Pickling agent 0645
120 Catalyst 201
129 Chemical raw material 203
Acetate fibers
Thermoplastic resins
& plastics
Industrial inorganic
chemical
M
Copper ore mining
Cyclic chemicals
Acyclic chemical3
Industrial inorganic
chemicals
Surface cleaning &
conditioning
Petroleum cracking &
other catalytic
processes
Catalytic treatment
-------
CHEMICAL: SULFURIC ACID ~ continued
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
PAGE
USE AS DESCRIBED USING EPA
Function
Code Name
DESCRIPTORS
Application
Code
Name
00
1005 V
V
V
V
Y
Y
Z
1006 A
A
A
A
A
A
A
A
A
A
A
A
A
Production of phenol via the benzene sulfonation
process
Production of copper sulfate
Production of nickel sulfate
Production of zinc sulfate
Production of benzenoid & non-benzenoid
synthetic surfactants
Production of titanium dioxide
Leaching uranium from ores
Production of citric acid
Production of furfural
Production of hydrofjuinones
Production of oxalic acid
Production of miscellaneous pigments
Production of resorcinol
Production of explosives (e.g., mannitol
hexanitrate)
Production of boric acid & oxide
Production of medicinals (e.g., dichloroprene,
sulfanilic acid)
Dry chlorine
Coke-oven light oil refining
Fat splitting
Processing parchment paper
Phospha IE rock flotation
Kraft & ground wood pulping
129 Chemical raw material 0211 Cyclic chemicals
129
129
129
129
129
129
129
Chemical raw material 020
Chemical
Chemical
Chemical
Chemical
Chemical
raw material
raw material
raw material
raw material
raw material
129 Chemical raw material
167 Dehydrating agent
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
3933 Flotation agent
129 Chemical raw material
020
020
0211
0210
020
Chemical raw material 1528
129
129
129
129
129
129
129
129
Chemical
Chemical
Chemical
Chemical
Chemical
Chemical
Chemical
Chemical
raw
raw
raw
raw
raw
raw
raw
raw
material
material
material
material
material
material
material
material
0210
0211
0211
0210
F1A11
0211
0210
020
05
020
020
0210
0211
0210
1924
15302
195
Industrial inorganic
chemicals
Cyclic chemicals
Acyclic .chemicals
Industrial inorganic
chemicals
Uranium-radium-vana-
dium ore mining
Acyclic chemicals
Cyclic chemicals
Cyclic chemicals
Acyclic chemicals
Pigments
Cyclic chemicals
Acyclic chemicals
Industrial inorganic
chemicals
Drugs and other pharma-
ceuticals
Industrial inorganic
chemicals
Industrial inorganic
chemicals
Acyclic chemicals
Cyclic chemicals
Acyclic chemicals
Packaging & indus-
trial converting paper
Phosphate rock mining
Pulp mill products
-------
CHEMICAL:
SULFURIC ACID - continued
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
PAGE
1006 A
A
A
A
A
SBR elastomer coagulation
Solvent for vat dyes
Tall oil recovery & deodorizing
Treatment of sodic soils
Water treatment (pH control)
USE AS DESCRIBED USING EPA
Function
Code Name
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
129 Chemical raw material
380 Chemical raw material
328 pH control agent
Code
214
2702
0210
0211
012
0407
DESCRIPTORS
Application
Name
Synthetic rubber
Plain, dyed, and
finished fibers, yarns,
and fabrics
Acyclic chemicals
Cyclic chemicals
Crop production
Water supply treat-
ment
Cd
I
-------
APPENDIX C
CLASSIFICATION OF FUNCTIONS AND APPLICATIONS
OF CHEMICALS IN SELECTED PRODUCT TYPES
C-l
-------
PRODUCT TYPE: Industrial Adhesives
SOURCES: Skeist Laboratories, Inc.; Adhesive & Sealants II. 1972; AdhesivesRed Book. 1978, Palraerton Publishing Co.,
Inc., N.Y.
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Nane
Red Book '78
SRI Staff
Skeist
Fillers
(Extenders
n
I
u>
*When EPA apj
more than
code is rep<
lication is
ce on page,
ated.
Furniture adhesives
1. Vinyl film laminating
A. Epoxy type
B. Neoprene cement type
2. Plastic laminating
A. Neoprene cement type
B. EVA hot melt type
C. Urea-formaldehyde type
3. Wood & vinyl veneering
A. Urea-formaldehyde type
B. EVA hot melt type
4. Assembly
A. Urea-formaldehyde type
5. Edge-gluing
A. Urea-formaldehyde type
Footwear adhesives
1. Aftermarket repair
A. Neoprene cement type
2. Manufacture
A. Natural rubber latex
1) Canvas
2) Box toe
3) Sock, heel pad
4) Counter
5) Doubling & combining
6) Soft sole
7) Heel cover
listed
only
223
229
Extenders
Fillers
1032 Wood partitions &
fixtures
100 Household furniture
0444 Shoe & leather
repair work
0214 Rubber & plastic
footwear
1212 Leather footwear
-------
PRODUCT TYPE: Industrial Adheaives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Code |
Function
Name
Code
Application
Name
Red Book '78
Skeist
SRI Staff
Fillers
Extenders)
n
B. Neoprene cement
1) Sole attaching
Bookbinding adhesives
I. Edition books
A. PVAc type
B. EVA hot melt type
C. Animal glue type
2. Magazines
A. Animal glue type
B. EVA hot melt type
3. Directories
A. Animal glue type
B. EVA hot melt type
4. Catalogs
A. Animal slue type
B. EVA hot melt type
5. Stationery
A. Animal glue type
B. EVA hot melt type
C. PVAc type
6. Softcover books
A. EVA hot melt type
Automobile adhesives
1. Original equipment
A. Nitrile based type
B. Neoprene cement type
C. SBR cement type
D. PVC plastisol
1212 Leather footwear
2301 Bookbinding
2301
2301
2303
1913 Envelopes & sta-
tionery products
2301
283 Motor vehicles
equipment
-------
PRODUCT TYPE: industrial Adhesives
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
Red Book '
Skeist
SRI Staff
78
n
I
FUNCTION
Fillers
(Extenders)
APPLICATION
2. Aftermarket
A. Polyester type
B. Nitrile based type
Textile adhesives
1. Carpeting
A. EVA hot melt
B. Vinyl acetate ethylene type
C. PVC plastisol
D. SB/SBR latex type
E. Nitrile latex type
2. Coatings
A. PVC latex type
B. PVAc type
C. Acrylic type
D. Neoprene latex type
E. SBR latex type
F. PVC plastisol
3. Nonwovens
A. EVA hot melt
4. Fiberfill, wadding
A. PVC plastisol
Wood adhesives
1. Exterior softwood plywood
A. Phenolic resin type
2. Exterior softwood plywood
A. Phenolic resin type
3. Particleboard
A. Urea-formaldehyde type
Function
Code |
Nan
Code
llcation
Na
2880 Transportation equip-
ment services &
repair facilities
271 Floor coverings
2730 Coated fabrics'
except rubberized
2736 Nonwoven fabrics &
products
2737 Padding & upholstery
filling
132
132
Millwork, plywood &
structural members
134 Particleboard
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
Red Book '78
SkeisC
SRI SCaff
Fillers
(Extenders)
n
I
4. Hardwood plywood
A. Urea-formaldehyde type
5. Lumber laminating
A. Resorcinol-formaldehyde type
B. Casein type
Electrical adhesives
1. TV picture tubes
A. Epoxy type
2. Refrigerators & freezers
A. SBR cement
3. Air conditioners
A. Neoprene cement
4. Dishwashers
A. Neoprene cement
Aircraft & aerospace adhesives
1. Structural films
A. Nitrile/phenolic type
Friction materials adhesives
1. General binders
A. Phenolic resin type
Foundry binders
1. CC>2 gas process
A. Silicate based
2. Conventional
A. Oleoresinous type
132
132
1484
1484
1481
280
Mi1Iwork, plywo od,
& structural members
1430 Cathode ray tele-
vision picture tubes
Refrigeration, air
conditioning, &
heating appliances
Household electrical'
& electronic appli-
ances
Aircraft & parts
28 Transportation
equipment & faci-
lities
212 Iron & steel foundry
products
224 Nonferrous foundry
products
-------
PRODUCT TYPE* Industrial Adheslves
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
n
i
Construction adheslves
1. Glued floors
A. SB/SBR cement
B. Neoprene cement
2. Panels & partitions
A. Neoprene cement
B. PVAc type
3. Gypsum wallboard
A. PVAc type
B. Reclaim rubber cement
C. Natural rubber latex
4. Glass fiber insulation
A. Neoprene cement
5. Vinyl film lamination
A. PVAc type
6. Ceramic tile
A. SB/SBR latex
B. Reclaim rubber cement
7. Resilient flooring
8. Carpet installation
A. SBR latex
B. Neoprene latex
5. Concrete binders
A. Epoxy type
03201 n°or
ping & finishing
103 Partitions & fix-
tures
03231 Plastering, drywall,
acoustical & in-
sulation work
03231
S2602 Gypsum products
1032 Wood partitions &
fixtures
03232 Terrazzo, tile,
marble, & mosaic
work
03201 Floor laying, scra-
ping & finishing
16 Miscellaneous - car-
pet laying
260 Concrete gypsum &
plaster products
-------
PRODUCT TYPE:
Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
Red Book '78
Skeist
SRI Staff
Fillers
[Extenders)
O
00
10. Wood doors
A. Urea-formaldehyde type
Packaging adhesives
1. Paper tubes
A. Aaimal glue
B. PV alcohol type
C. PVAc type
2. Composite cans
A. Dextrin type
B. Animal glue
C. PVAc type
D. Neoprene latex
3. Envelopes
A. Dextrin type
B. Starch type
C. PVAc type
4. Gummed tapes & labels
A. Animal glue
B. PVAc type
5. Fiber drums
A. PV alcohol type
6. Fiberboard
A. PVAc type
B. Starch type
7. Corrugated board
A. Starch type
1032 Wood partition &
fixtures
1914 Pressed & molded
pulp goods
193 Paperboard contain-
ers & boxes
1913 Envelopes & station-
ery products
19112 Gummed products
193
1941
1941
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code j
Name
Application
Code
Ipp
Name
Red Book '78
Skeist
SRI Staff
Fillers
[Extenders)
O
I
8. Carton sealing
A. Polyethylene/polypropylene hot melt
9. Folding cartons
A. Polyethylene/polypropylene hot melt
B. EVA hot melt
C. PVAc type
10. Bottle labeling
A. PVAc type
11. Specialty bags
A. EVA hot melt
B. PVAc type
C. Starch type
12. Multi-wall bags
A. Polyethylene/polypropylene hot melt
B. EVA hot melt
C. Starch type
13. Grocery bags
A. Starch type
14. Binderboard
A. Starch type
15. Parry liners
A. Starch type
193 Paperboard contain-
ers & boxes
193
09 Food & kindred
products
05 Drugs & other pharraa-
ceuticals
250 Cosmetics & toilet
~" preparations
1910
0651
0706
1910
0706
1910
193 .
1913
230
193
230
Bags, except textile
bags
Metal foil & leaf
Plastic packaging &
shipping containers
Envelopes & station-
ery products
Bookbinding & re-
lated operations
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
Red Book '78
Skeist
SRI Staff
Fillers
(Extenders)
n
i—•
o
16. Paper cups & tubs
A. PVAc type
17. Capliner
A. PVAc type
18. Glassine
A. PVAc type
19. Aluminum foil
A. PVAc type
B. Neoprene latex
20. Metal can sealing
A. SBR type
21. Government postage stamps
A. Dextrin based
Pressure-sensitive adhesives
1. PTFE, high temperature
A. Silicone type
2. Reinforced impregnated
3. Foil
A. Natural rubber
4. Double-faced
A. Natural rubber
5. Felt and cork
6. Surgical
7. Roll label
1914 Pressed & molded
pulp goods
1912 Die cut paper &
board products
19114 Oiled, waxed & wax
laminated paper
0651 Metal foil & leaf
0021 Metal cans
19112 Gummed products
0709 Unsupported plastic
film, sheet, rod &
tube
19115 pressure sensitive
tape
0651
19115
2732 Felt goods
130 Cork
112
19115
Medical & dental in-
struments & supplies
-------
PRODUCT TYPE!
Industrial Adheslves
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
f
Naa
Red Book '78
Skeist
SRI Staff
Fillers
(Extenders)
O
I
8. Sheet stock
9. Floor tile
10. Paper
11. Cellophane
12. Vinyl
13. Polyester
19115 Pressure sensitive
tape
163 Hard surface floor,
wall & counter cover-
ings
19115
0703 Regenerated cellulosic
products, except
rayon
0709 Unsupported plastic
film, sheet, rod &
tube
0709
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Name
Application
Code
Name
Skeist
SRI Staff
Plasticize
O
(—•
K>
*When EPA
more than
code is is
pplication
once on a
repeated.
Packaging & labeling adhesives
1. Paper cups & tubs
A. PVAc type
2. Envelopes
A. PVAc type
3. Composite cans
A. PVAc type
B. EVA hot melts
4. Bottle labeling
A. PVAc type
B. EVA hot melts
5. Can labeling
A. PVAc type
6. Case & carton sealing
A. PVAc types
B. EVA hot melts
7. Folding cartons
A. PVAc type
B. SBR latex type
8. Specialty bags
A. PVAc type
B. SBR latex type
9. Multi-wall bags
A. SBR latex type
s listed
riage, only
333 Plasticizers
1914 Pressed & molded pulp
goods
1913 Envelopes & stationery
products
193 Paperboard containers
& products
09 Food & kindred products
05 Drugs & other pharma-
ceuticals
250 Cosmetics & toilet
preparations
09
193
1910 Bags, except textile
bags
0651 Metal foil & leaf
0706 Plastic packaging &
• shipping containers
1910
0706
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
f
Name
Skeist
SRI Staff
'lasticizer
O
I
10. Gummed tapes & labels
A. PVAc type
11. Capliners
A. PVAc type
12. Glassine
A. PVAc type
14. Paper tubes
A. PV alcohol type
15. Fiber drums
A. PV alcohol type
Construction adhesives —
1. Concrete binders (cement additives for interior & exterior joints)
A. PVAc type
B. SBR latex type
C. Acrylic type
2. Vinyl film lamination (e.g., wallboard made by continuous lamination
of vinyl wall coverings & gypsum board)
A. PVAc type
3. Smoothing of gypsum wallboard tape joints
A. PVAc type
4. Gypsum wallboard
A. Neoprene latex type
5. Spackling paste
A. PVAc type
19112 Gummed products
1912 Die cut paper & board
products
19114 Oiled, waxed & wax
laminated paper
1914 Pressed & molded pulp
goods
193 Paperboard containers
& boxes
260 Concrete, gypsum &
plaster products
2602 Gypsum products
1032 Wood partitions &
fixtures
0321 Plastering, drywall,
acoustical & insulation
work
0321
0321
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SQURCE: Skeist Laboratories, Inc.,
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
Adheslves & Sealants II, 1972
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Code I
Function
Name
Code
Application
Name
Skeist
SRI Staff
Plasticizer
579.5022 Y
Skeist
SRI Staff
O
I
o
i
6. Wooden floors
A. PVAc type
7. Panels & partitions
A. PVAc type
B. Neoprene latex type
8. Mobile home & recreational vehicle component
construction
A. PVAc type
Textile adhesives —
1. Textile coatings
A. PVC plastisol type
2. Carpet backing
A. PVC plastisol type
3. Fiberfill & wadding
A. PVAc type
4. Nonwoven fabric binding
A. EVA hot melts
B. Acrylic type
5. Flocking
A. Acrylic type
6. Laminating & bonding
A. Acrylic type
Electrical appliance adhesives —
1. Dishwashers
A. PVC plastisol type
2. Refrigerators & freezers
A. SBR cement
1032 Wood partitions &
fixtures
103 Partitions & fixtures
282 Miscellaneous trans-
portation equipment
135 Prefabricated wood
buildings
2730 Coated fabrics except
rubberized
231 Floor coverings
2737 Padding £, upholstery
filling
2736 Nonwoven fabrics &
products
2701 Other finished fibers,
yarns & fabrics
080 Apparel
1481 Household electrical &
electronic appliances
1484 .Refrigeration, air
conditioning &
heating equipment
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants 11,1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY | USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Na
Code
Application
Name
579.5022 Y
Skeist
SRI Staff
O
I
580.1883 K
Automobile adhesives —
1. Body assembly
A. PVC plastisol
B. SBR cement
2. Safety glass
A. Polyvinyl butyral film
Bookbinding adhesives —
1. Edition books
A. PVAc type
2. Stationery
A. PVAc type
Furniture adhesives —
1. Dowel gluing
A. PVAc type
2. Edge gluing
A. PVAc type
3. Chair & table top assembly
A. PVAc type
4. Plastic laminating
A. PVAc type
5. Wood & vinyl veneering
A. PVAc type
6. Felt saturation
A. PVAc type
Footwear adhesives
1. Shoe assembly
A. Leather shoes
1) PVC type
2) PVAc type
283 Motor vehicles &
equipment
2620 Laminated glass
283 Bookbinding & related
operations
1913 Envelopes & sta-
tionery products
100 Household furniture
100
100
100
100
2732 Felt goods
1212 Leather footwear
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY | USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Code
Application
Name
580.1883 K
O
579.5022 X
B. Simulated leather shoes
1) PVC type
Other leather and simulated leather
goods adhesives —
1. Leather luggage
A. PVC type
2. Leather handbags & purses
A. PVC type
3. Simulated leather luggage
A. PVC type
4. Simulated leather handbags & purses
A. PVC type
Plastic products adhesives —
1. Toys
A. PVC type
2. Novelties
A. PVC type
3. Swimming pool liners
A. PVC type
Pressure sensitive tape adhesives —
1. Industrial
A. PVC type
074 Rubber & plastic
footwear
1214 Leather luggage
1213 Leather gloves (in-
cludes handbags,
wallets, key & glass
cases, change purses
and other leather
cases)
070 Miscellaneous fab-
ricated plastics
products
070
168 Toys & sporting goods
162 Costume jewelry &
notions
070
19115 Pressure sensitive
tapes
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
top.
Name
579.5022 X
Skeist
2. Electrical
A. PVC type
3. Surgical
A. PVC type
Cigarette tipping adhesives
1. PVAc type
0709 Unsupported plastic
film, sheet, rod &
tube
112 Medical & dental
instruments &
supplies
n
-------
PRODUCT TYPE: Industrial Adhesives
SOURCES: DeBell & Richardson, Inc. The Decline & Fall of Solvent-Based Adhesives. 1974;
Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
Skeist Laboratories, Inc.,
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
Skeist
SRI Staff
Solvent
n
I
00
*When EPA af
more than
code is rej
lication li
ice on page
ated.
Construction adhesives
1. Gypsum wallboard
A. Neoprene cement
B. SBR cement
C. Natural rubber cement
2. Panels & partitions
A. Neoprene cement
3. Mobile homes
A. Neoprene cement
B. PVAc adhesives
4. Recreational vehicles
A. Neoprene cement
5. Metal doors
6. Glass fiber insulation
A. Neoprene cement
7. Glued floors & other wood framing
A. Neoprene cement
B. SBR cement
C. Polyurethane type
8. Prefabricated buildings
A. SBR cement
9. Insulating materials
A. SBR cement
'B. Nitrile adhesives
listed
only
384
Solvent
03231 Plastering, drywall,
acoustical & in-
sulation work
103 Partitions 6. fixtures
135 Prefabricated wood
buildings
282 Miscellaneous trans-
portation equipment
061 Fabricated struc-
tural metal products
03231
0320 Carpeting & flooring
(0614 Prefabricated metal
buildings
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Code
Application
Name
Skeist
SRI Staff
DeBel.1
-n
I
DeBell
Skeist
10. Acoustical ceiling panels
A. SBR cement
11. Ceramic floor & wall tile
A. SBR cement
B. Reclaim rubber adhesives
12. Anti-skid coatings & vinyl stair treads
A. Nitrile adhesives
13. Roofing
A. Nitrile adhesives
14. Plastic pipe
A. Acrylonitrile-butadiene-styrene copolymer type
Automotive adhesives
1. Vinyl roofs
A. Neoprene cement
B. Nitrile adhesives
2. Vinyl & fabric door components
A. SBR cement
3. Vinyl weather stripping
A. Nitrile adhesives
4. Brake lining to shoes
A. Nitrile adhesives
5. Clutch linings
A. Nitrile adhesives
6. Sound insulating
•A. Nitrile adhesives
B. SBR cement
7. Windshields & windows
A. Nitrile adhesives
03231 Plastering, drywall,
acoustical & in-
sulation work
03232 Terrazzo, tile,
marble & mosaic work
03201 Floor laying, scra-
ping, & finishing
0327
0326
283
283
283
283
283
283
283
Roofing & sheet
metal work
Plumbing, heating
& air conditioning
work
Motor vehicles &
equipment
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
f
t.'aroe
DeBell
Skeist
n
N>
o
8. Fuel tank sealing
A. Nitrile adhesives
9. Oil filter side seams
A. Nitrile adhesives
10. Floor & trunk carpeting
A. SBR cenent
11. Headliners
A. SBR cement
12. Firewall insulation
A. SBR cement
13. Exterior trim
A. SBR cement
14. Assembly
A. SBR cement
B. Nitrile adhesives
C. Reclaim rubber cement
D. Polyurethane type
E. PVC plastisol type
15. Aftermarket/repairing
A. SBR cement
B. Nitrile adhesives
Footwear adhesives
1. Sole attaching
A. Neoprene cement
B. Polyurethane type
2. Injection molded shoes
A. Polyurethane
283 Motor vehicles &
equipment
283
283
283
283
283
283
2880 Transportation equip-
ment service &
repair facilities
1212 Leather footwear
074 Rubber & plastic
footwear
-------
PRODUCT TYPE:
Industrial Adhesives
USB AS NORMALLY DESCRIBED IN THE INDUSTRY US
SOURCE FUNCTION
DeBell
Skeist
APPLICATION C(jde j
3. Heel covering
A. Neoprene cement
4. Sock-lining & heel pad
A. Natural rubber cement
5. Doubling & combining
A. Natural rubber cement
6 . Counter
A. Natural rubber cement
7. Box toes
A. Natural rubber cement
8 . Canvas
A. Natural rubber cement
9. Miscellaneous
A. Nitrile adhesives
10. Repairing
A. Neoprene cement
Textile adhesives
1. Flocking
A. Neoprene cement
2 . Nonwovens
A. Nitrile adhesives
Furniture adhesives
1. Assembly
A. Neoprene cements
B. Urea- formaldehyde resin type
2. -Vinyl film lamination
A. Polyester type
B. Polyurethane type
3. Plastic/wood lamination
A. Neoprene cements
Z AS DESCRIBED USING EPA DESCRIPTORS
notion Application
Name Code [ Name
1212 Leather footwear
1212
1212
1212
1212
074 Rubber & plastic
footwear
1212
1213
2701 Other finished fi-
bers , yarn and fabrics
2736 Nonwoven fabrics &
products
f 100 Household furniture
) 1032 Wood partition &
fixtures
1032
1032
1032
n
i
N)
-------
PRODUCT TYPE: industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Code
llcatlon
Name
DeBell
Skeist
O
ro
to
4. Wood/vinyl veneering
A. Urea-formaldehyde resin type
5. Edge-gluing
A. Urea-formaldehyde type
Electrical goods adhesives
1. Air conditioners
A. Neoprene cement
B. Epoxy type
2. Refrigerators & freezers
A. SBR cement
B. Epoxy type
C. Asphalt type
3. Printed circuits
A. Nitrile adhesives
B. Polyester type
4. Radio & TV components
A. Nitrile adhesives
5. Food disposers
A. Epoxy types
6. Small appliances
A. Epoxy type
7. Battery sealants
A. Epoxy type
1032
1032
1481
1481
1464
1465
Wood partition &
fixtures
1484 Refrigeration, air
conditioning &
heating equipment
1484
1436 Semiconductors &
related solid state
devices
1400 Radio & television
communication
equipment
Household electrical
& electronic appli-
ances
Primary batteries
Storage batteries
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
DeBell
Skeist
n
l
N)
UJ
Abrasive product adhesives
1. Bonded abrasives
A. SBR cement
B. Natural rubber cement
C. Nitrile adhesives
D. Phenolic resin type
2. Coated abrasives
A. Phenolic resin type
Friction materials adhesives
1. Natural rubber cement
2.. Nitrile adhesives
Pressure sensitive tape
1. Paper
2. Polyethylene
3. Reinforced & impregnated
4. Felt
5. Cork
6. Foil
7. Laminated foil
8. Vinyl
9. Cellophane
10. Polyester
11. Cloth
12. Surgical tape
13. Labels
14. Decals
15. Wall & s,helf covering
2460 Abrasive products
2460
28
19115
0709
19115
2732
130
0651
0651
0709
0708
Transportation equip-
ment & facilities
Pressure sensitive
tape
Unsupported plastic
film, sheet, rod
& tube
Felt goods
Cork
Metal foil & leaf
0708
273
113
19115
19115
1916
Regenerated cellulosic
products, except
rayon
Miscellaneous textile
products
Medical & dental in-
struments & supplies
Wall paper
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Application
Code
Name
DeBell
Skeist
n
Aircraft adhesives
1. Frame bonding
A. Nitrile adhesives
2. Walkways & rugs
A. Nitrile adhesives
3. Helicopter rotor blades
A. Nitrile adhesives
4. Brake bonding
A. Nitrile adhesives
5. Assembly
A. Nitrile/phenolic structural film
B. Epoxy/nitrile structural film
Foundry binders
1. Shell core & mold
A. Phenolic resin type
2. Hot box
A. Phenolic resin type
3. Conventional
A. Phenol-formaldehyde type
Packaging adhesives
1. Case sealing
A. EVA adhesives
2. Carton sealing
•A. EVA adhesives
280 Aircraft & parts
280
280
280
280
, 222
224
193
193
Iron steel foundry
products
Nonferrous foundry
products
Paperboard boxes &
containers
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
DeBell
Skeist
3. Composite cans
A. PVAc type
4. Paper tubes
A. PVAc type
5. Bottle labeling
A. PVAc type
6. Can labeling
A. PVAc type
7. Envelopes
A. PVAc type
8. Paper cups & tubs
A. PVAc type
9. Folding cartons
A. PVAc type
10. Specialty bags
A. PVAc type
11. Gummed tapes & labels
A. PVAc type
B. Asphalt type
12. Cap liners
A. PVAc type
AS DESCRIBED USING EPA DESCRIPTORS
ctlon Application
Name Code | Name
193 Paperboard boxes &
containers
1914 Pressed & molded
pulp goods
09 Food & kindred
products
05 Drugs & other pharma-
ceuticals
250 Cosmetics & toilet
preparations
09
1913 Envelopes & sta-
tionery products
1914
193
S1910 Bags except textile
bags
0651 Metal foil & leaf
193
19112 Gummed products
1912 Die cut paper &
board products
n
i
ro
-------
PRODUCT TYPE:
Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Codef
Name
Application
Code
Name
DeBell
Skeist
DeBell
13. Glassine
A. PVAc type
14i. Aluminum foil
A. PVAc type
15. Film to film lamination
A. Nitrile adhesives
B. Polyurethane type
16. Paper to film lamination
A. Butyl rubber type
Wood adhesives
1. Lumber laminating
A. Resorcinol-phenol-formaldehyde
Bookbinding adhesives
1. Edition books
A. PVAc type
2. Notebooks
A. PVAc type
3. Tablets & pads
A. PVAc type
4. Business forms
A. PVAc type
Miscellaneous adhesives
1. Insecticide spray tanks
A. Nitrile adhesives
2. Paper coating
A. Nitrile adhesives
19114 Oiled, waxed, &
laminated wax
paper
0651 Metal foil & leaf
19113 Laminated or coated
paper rolls &
sheets
19113
132 Millwork, plywood &
structural members
230 Bookbinding & re-
lated operations
1913 Envelopes & sta-
tionery products
1913
1913
062 Metal cans & shipping
containers
1911 Coated & glazed
paper products
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
DeBell
3. Ironing board covers
A. Nitrile adhesives
4. Film/foil lamination
A. Nitrile adhesives
273 Miscellaneous tex-
tile products
0651 Metal foil & leaf
O
I
to
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc. Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
Skeist ?ackifier
SRI Staff
O
N>
00
*When EPA jpplication
more than once on a f
code is repeated.
APPLICATION - CoQe |
Packaging adhesives
AS DESCRIBED USING EPA DESCRIPTORS*
ction Application
Name Code | Name
1. Envelopes 395 Tackifier _ Envelopes & stationery
A. PVAc
2. Paper tubes
A. PVAc
B. PV alcohol
3. Composite cans
A. PVAc
B. EVA hot melt
4. Bottle labeling
A. PVAc
E. EVA hot melt
5. Can labeling
A. PVAc
6. Case sealing
A. Polyethylene/polypropylene hot melt
B. EVA hot melt
C. PVAc
7. Carton sealing
A. Polyethylene/polypropylene hot melt
B. EVA hot melt
8. Folding carton
A. Polyethylene/polypropylene hot melt
B. EVA hot melt
C. PVAc
D. SBR latex
is listed
age, only
products
1914 Pressed & molded pulp
goods
^93 Paperboard containers
& boxes
05 Drugs & other pharma-
ceutals
250 Cosmetics & toilet
preparations
09 Food & kindred products
09
193
193
193
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc. Adheslves & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
Skeist
SRI Staff
vo
FUNCTION
Tackifier
APPLICATION
Function
Code
Name
Application
Code
Name
9. Multi-wall bags
A. EVA hot melt
B. Polyethylene/polypropylene
C. SBR latex
10. Specialty bags
A. EVA hot melt
B. PVAc
C. SBR latex
11. Gummed tapes & labels
12. Capliner
A. PVAc
13. Glassine
A. PVAc
14. Aluminum foil
A. PVAc
B. SBR latex
15. Paper cups & tubs
A. PVAc
16. Fiber drums
A. PV alcohol
17. Metal can sealing
A. SBR cement
1910 Bags, except textile
bags
0706 Plastic package &
shipping cartons
1910
0651 Metal foil & leaf
0706
19112 Gummed products
1912 Die cut paper &
board products
19114 Oiled, waxed &
laminated paper
0651
1914 Pressed & molded
pulp goods
1914
0621 Metal cans
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc. Adheslves & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Code
Applicatii
! T N
tion
Skeist
SRI Staff
Tackifier
n
I
Bookbinding adhesives
1. Edition books
A. EVA hot melt
B. PVAc
2. Softcover books
A. EVA hot melt
B. PVac
3. Stationery
A. EVA hot melt
B. PVAc
4. Magazines
A. EVA hot melt
5. Directories
A. EVA hot melt
6. Catalogs
A. EVA not melt
Textile adhesives
1. Carpet backing
A. EVA hot melt
2. Fiberfill & wadding
A. PVAc
B- Acrylic
3. Nqnwovens
A. EVA hot melt
B- Acrylic
230 Bookbinding operations
230
1913 Envelopes & stationery
products
230
230
230
271 Floor covering
2727 Padding & upholstery
filling
2736 Nonwoven fabrics &
products
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc. Adhesives & Sealants II, 1972
USB AS NORMALLY DESCRIBED IN THE INDUSTRY | USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Na
Application
Code
Name
Skeist
SRI Staff
Tackifier
O
I
u>
4. Flocking
A. Acrylic
5. Coatings
A. PVC plastisol
B. Acrylic
6. Laminating & bonding
A. Acrylic
Construction adhesives
1. Resilient flooring
A. SBR latex
2. Panels & partitions
A. SBR latex
B. Neoprene cement
3. Glass fiber insulation
A. Neoprene cement
4. Ceramic tile
A. SB/SBR latex
5. Glued floors
A. SBR/SBS cement
B. Polyurethene
C. Neoprene cement
6. Vinyl film laminating
A. PVAc
2701 Other finished fibers,
yarn & fabrics
2730 Coated fabrics except
rubberized
220 Finished textile
products
03201 Floor laying, scrap-
ing & finishing
103 Partitions & fixtures
03231 Plastering, drywall,
acoustical & insul-
ation work
03232 Terrazzo, tile, marble
& mosaic work
03201
2602 Gypsum products
1032 Wood partition &
fixtures
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Name
Application
Code
Name
Skeist
SRF Staff
Tackifier
N>
7. Carpet installation
A. Neoprene latex
B. SBR latex
8. Gypsum wallboard
A. Reclaim cement
9. Concrete binders
A. PVAc
B. Acrylic
C. SB/SBR latex
Foundry binders
1. Conventional
A. Oleoresinous
2. No Bake
A. Oil/alkyd/phenolic type
Wood adhesives
1. Softwood interior plywood
A. Phenolic resin type
2. Hardwood plywood
A. Urea-formaldehyde resin based
Electrical adhesives
1. Air conditioners
A. Neoprene cement
B. Epoxy
03231 Plastering, drywall,
acoustical & insul-
ation work
260 Concrete, gypsum, &
plaster products
222 Iron & steel foundry
products
224 Non-ferrous foundry
products
132 Millwork, plywood &
structural members
132
1484 Refrigeration, air
conditioning & heat-
ing equipment
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc.,
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
Adhesives & Sealants II, 1972
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Na
Application
Code
Name
Skeist
SRI Staff
Tackifier
O
u>
OJ
2. Dishwasher
A. Neoprene cement
3. Food disposers
A. Epoxy
4. Small appliances
A. Epoxy
5. Battery sealants
A. Epoxy
Automotive adhesives
1. Original equipment
A. Nitrile cement
B. Neoprene cement
2. Aftermarket
A. Polyester type
Pressure-sensitive adhesives
1. Foil
A. Natural rubber
2. Double-faced
A. Natural rubber
3. Felt, cork, other substrates
4. Roll label
5. Sheet stock
1481 Household electrical
& electronic
appliances
1481
1481
1464 Primary batteries
1465 Storage batteries
283 Motor vehicles &
equipment
2880 Transportation equip-
ment services &
repair facilities
19115 Pressure-sensitive
tape
-------
PRODUCT TYPE: INDUSTRIAL ADHESIVES
SOURCE: Skeist Laboratories, Inc., Adhesives & Sealants II, 1972
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Name
Skeist
SRI Staff
Tackifier
n
6. Floor tiles
A. SBR Cement
7. Paper
8. Cellophane
9. Vinyl
10. Polyester
11. Polyethylene
12. Cloth
13. Reinforced & impregnated
163
Hard surface, floor,
wall
19115 Pressure-sensitive
tape
0708
0709
0709
0709
273
19115
Regenerated cellulosic
products, except rayon
Unsupported plastic
film, sheet, rod &
tube
Miscellaneous textile
products
-------
O
PRODUCT TYPE: Industrial Adhesives
SOURCES: Skeist Laboratories. Inc.: Adhesives & Sealants II. 1972: Adhesives Red Book. IS
SOURCE
Red Book '78
Skeist
SRI Staff
*When EPA ap
OA a page, o
FUNCTION
Thickener
alication is
ily code is
USB AS NORMALLY DESCRIBED IN THE INDUSTRY USE AS DESCR
inriTi-ATTnii Function
APPLICATION - Co(Je | Ha
Packaging adhesives 401 Thickener
1. Envelopes
A. Starch
B. Dextrin
C. PVAc
2. Government postage stamps
A. Dextrin
3. Corrugated board
A. Starch
4 . Fiberboard
A. Starch
B. PVAc
5. Multi-wall bags
A. Starch
6. Specialty bags
A. Starch
B. PVAc
7 . Binderboard
A. Starch
8. Parry liners
9. Paper tubes
A. PVAc
10. Composite cans
A. PVAc
B. Dextrin
listed more than once
repeated.
78; Palmer ton Publishing Co. , N.Y.
IBED USING EPA DESCRIPTORS*
Application
me Code | Name .
1913 Envelopes & station-
ery products
19112 Gummed products
1941 Packaging & indus-
trial converting
paperboard
1941
glo Bags, except textile
bags
0706 Plastic packaging
& shipping containers
( 0651 Metal foil & leaf
\ 0706
230 Bookbinding & re-
lated operations
1913
193 Paperboard contain-
ers & boxes
( 230
\ 193
1914 Pressed & molded
pulp goods
193
-------
PRODUCT TYPE: Industrial Adhesives
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Nan
Red Book '78
Skeist
SRI Staff
Thickener
O
11. Bottle labeling
A. PVAc
12. Can labeling
A. PVAc
13. Folding containers
A. PVAc
14. Gummed tapes & labels
A. PVAc
15. Capliner
A. PVAC
16. Glassine
A. PVAc
17. Aluminum foil
A. PVAc
18. Paper cups & tubs
A. PVAc
19. Cigarette tipping
A. PVAC
B. Casein
20. Case sealing
A. PVAC
21. Carton sealing
A. PVAC
09
05
250
09
193
Food & kindred
products
Drugs & other phar-
maceuticals
Cosmetics & toilet
preparations
Paperboard containers
& products
19112 Gummed products
1912 Die cut paper &
board products
19114 Oiled, waxed, &
wax laminated paper
0651 Metal foil & leaf
1914
16
193
193
Pressed & molded
pulp goods
Miscellaneous - ciga-
rette production
-------
PRODUCT TYPE: Industrial Adhesives
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Code
App
L-4-
lication
Name
Red Book
Skeist
SRI Staff
'78
Thickener
o
CO
22. Paper/film laminating
A. PVAc
23. Film/film laminating
A. PVAc
Construction adhesives
1. Panels & partitions
A. PVAc
2. Vinyl film lamination
A. PVAc
3. Glued floors
A. SBR/SBS cement
4. Carpet installation
A. Neoprene latex
5. Gypsum wallboard
A. Natural rubber latex
B. Casein
C. PVAc
6. Ceramic tile
A. Reclaim rubber cement
Textile adhesives
1. Fiberfill & wadding
A. PVC
2. Coatings
A, PVC latex
B. PVC plastisol
C. PVAc
D. Neoprene latex
E. Acrylic
19113
19113
103
Laminated or coated
paper rolls &
sheets
Partition & fixtures
( 2602 Gypsum products
11032 Wood partitions
& fixtures
03201 Floor laying, scra-
ping & finishing
16 Miscellaneous - car-
pet laying
03231 Plastering, drywall,
acoustical & in-
sulation work
03232 Terrazzo, tile, &
mosiac work
2737 Padding & up-
holstery filling
2730 Coated fabrics,
except rubberized
-------
PRODUCT TYPE: Industrial Adhesives
USB AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
Red Book '78 Thickener
Skeist
SRI Staff
Fun
APPLICATION ' QO(je I
3 . Nonwoven
4. Flocking
A. Acrylic
Bookbinding adhesives
1. Edition books
A. PVAC
2. Stationery
A. PVAc
Foundry binders
1. Conventional types
A. Oleoresinous
Electrical adhesives
1. Air conditioners
A. Neoprene cement
2. Dishwashers
A. Neoprene cement
3. Clotheswashers
A. Nitrile/phenolic type
Pressure-sensitive adhesives
1. Foil
A. Natural rubber
2. Double faced
A. Natural rubber
3. Floor tile
A. SBR cement
AS DESCRIBED USING EPA DESCRIPTORS
ctlon Application
Name Code | Name
2736 Nonwoven fabrics &
products
2701 Other finished
fibers , yarns &
fabrics
230 Bookbinding & re-
lated operations
1913 Envelopes & sta-
tionery products
| 222 Iron & steel foundry
< products
I 224 Nonferrous foundry
products
1484 Refrigeration, air
conditioning &
heating equipment
1481 Household electrical
& electronic appli-
ances
1482 Laundry equipment
0651 Metal foil & leaf
19115 Pressure sensitive
tape
163 Hard surface floor,
wall & counter
coverings
00
-------
PRODUCT TYPEi industrlai Adhesives
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Na
Red Book '
Skeist
SRI Staff
78
Thickener
I
CJ
4." Polyester
5. Polyethylene
6. Cloth
7. Vinyl
3. Reinforced & impregnated
9. Cellophane
10. Paper
11. Felt & cork
12. Roll labels
13. Sheet stock labels
0709
0709
273
0709
19115
0708
Unsupported plastic
film, sheet, rod,
& tube
Miscellaneous tex-
tile products
Pressure sensitive
tape
Regenerated cellu-
losic products,
except rayon
19115
130
19115
2732
19115
19115
Cork
Felt goods
-------
PRODUCT TYPE:
Household Detergents
SOURCES:
Chalmers, L., Household and Industrial Chemical
Specialties, Chemical Publishing Co., Inc.
New York, 1978
Chemical Economics Handbook, SRI International,
Menlo Park, California
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
Fuchs, R.J. , et^ a±. , "Agglomerated Automatic Dishwasher
Detergents", Chemical Times & Trends, October 1977,
pp. 37-42
Summer, C.A., "Agglomeration of Dishwasher Detergents",
Soap. Cosmetics. & Chemical Specialties. July 1975,
pp. 29-50
USE AS DESCRIBED USING EPA DESCRIPTORS *
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code |
Name
-p-
o
CEH, p.
583.8001F
\ntiredepos
tion
Agents
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Unbuilt
CEH, p.
583.800D
CEH, p.
583.8001F
SRI Staff
.ntistatic
Agents
Jleaching
Agents
Laundry Detergents
Heavy Duty
Powders
Presoaks
*When EPA
more than
code is
pplication
once on a
repeated.
.s listed
dage, only
3936 Soil Suspending
Agents
092 Antistatic Agents
105 Bleaches
25105 Soaps, bars and flakes,
and detergent powders
2510 Detergents, soaps &
„..._ disinfectants
25105
25104 Scouring cleansers
and presoaks
-------
PRODUCT TYPE:
Household Detergents
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
n
CEH, p.
583.8001H
Chalmers,
p. 35
Summer
CEH, p.
583.8001H
CEH, p.
583.8001D
Buffers
Chalmers,
P. 35
Chalmers,
p. 48
CEH, p.
583.8001G
Builders
Colorants
Laundry Detergents
Light Duty
Powders
Dishwashing Detergents
Machine
Light Duty Liquids
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Light Duty
Powders
Dishwashing Detergents
Machine
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Unbuilt
328 pH Control Agents
25105
25101 Machine and hand
dishwashing compounds
25101
183
Detergent Builders
25105
2510
25105
25101
1410 Dyes
25105
2510
2510
-------
PRODUCT TYPE: Household Detergents
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Na
o
.p-
NJ
Fuchs
CEH, p.
583.8001H
CEH, p.
583.8001G
Corrosion
Inhibitors
SRI
Staff
CEH, p.
583.8001D
SRI Staff
CEH, p.
583.8001D
CEH, p.
583.8001G
inzymfis
abric
ofteners
illers and
iluents
Dishwashing Detergents
Machine
Light Duty Liquids
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Dishwashing Detergents
Machine
Laundry Detergents
Heavy Duty
Powders
Presoaks
Laundry Detergents
Heavy Duty
Powders
Laundry Detergents
Heavy Duty
Powders
25101
25101
144 Corrosion Inhibitors
215 Enzymes
25105
2510
25101
25105
25104
379 Softeners
25105
229 Fillers
25105
-------
PRODUCT TYPE: Household Detergents
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
Summer
CEH, p.
583..8001G
0
1
Chalmers ,
p. 48
CEH, p.
583.8001H
SRI Staff
CEH, p.
583.8001G
FUNCTION
i'oam
Regulators
Dpacifying
(Vgents
ptical
(Tighteners
& Bluing
Agents
• priTriTTnii Function Application
APPLICATION Code | Hame code f Name
Liquids
Built 2510
Unbuilt 2510
Dishwashing Detergents
Machine 25101
I 246 Foam Inhibitors
I 3861 Foam Stabilizers
Laundry Detergents
Heavy Duty
Powders 25105
Liquids
Built 2510
Unbuilt 2510
Dishwashing Detergents
Machine 25101
Light Duty Liquids 25101
313 Opacifiers
Dishwashing Detergents
Light Duty Liquids 25101
< 2440 Optical Brighteners
\ 110 Bluing Agents
Laundry Detergents
Heavy Duty
Powders 25105
Liquids
Built
Unbuilt I^Q
-------
PRODUCT TYPE: Household Detergents
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
-p-
-C-
SRI Staff
Chalmers,
p. 35
CEH, p.
583.8001G
Perfumes
Fuchs
CEH, P.
583.8001H
CEH, p.
583.8001G
olubilizers
CEH, p.
583.8000H
Presoaks
Light Duty
Powders
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Unbuilt
Dishwashing Detergents
Machine
Light Duty Liquids
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Unbuilt
Dishwashing Detergents
Light Duty Liquids
3100 Fragrances
3820 Hydrotropic Agents
25104
25105
25105
2510
2510
25101
25101
25105
2510
2510
25101
-------
PRODUCT TYPE: Household Detergents
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
CEH, p.
583.8000G
Surfactants
3930 Detergents
O
-P-
SRI Staff
Chalmers,
P- 35
Chalmers,
p. 48
CEH, p.
583.8000H
Laundry Detergents
Heavy Duty
Powders
Liquids
Built
Unbuilt
Presoaks
Light Duty
Powders
Dishwashing Detergents
Machine
Light Duty Liquids
25105
2510
2510
25104
25105
25101
25101
-------
PRODUCT TYPE: Rubber-Processing Chemicals
SOURCES:
EPST= Canterino, P.J., 1967, "Ethylene Polymers". In: RT= Morton, M., ed., 1973, Rubber Technology,
Encyclopedia of Polymer Science and Technology, Second Edition, New York, Van Nostrand Reinhold
Volume 6, New York, John Wiley & Sons, Inc. Company.
USE AS NORMALLY DESCRIBED IN THE INDUSTRY ] USE AS DESCRIBED USING EPA DESCRIPTORS*
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Code
llcation
Name
n
-p-
RT, pp.
193-194
RT, p. 242
Blowing
Agent
RT, p. 297
RT, p. 335
EPST, jj,
p. 449
RT, pp.
400-401
RT, p. 433
*When EPA
on a page
application
, only code
Styrene-butadiene rubber
A. Sponge and related
1. Rug underlay
B. Footwear
1. Shoe soles
Ethylene/Polypropylene rubber
A. Sponge
B. Automotive
1. Auto weatherstripping
2. Trunk lid gaskets
Polyisoprene rubber
A. Sponge (oil-extended polyisoprene only)
Neoprene rubber
A. Sponge
B. Automotive
1. Door gaskets
Chlorosulfonated polyethylene rubber
A. Footwear
1. Shoe heels & soles
Silicone rubber
A. Sponge
Fluorocarbon rubber
A. Sponge
Is listed more than once
is repeated.
109
Blowing agent
0715 Rubber floor & wall
covering
0716 Rubber heels & soles
0718 Sponge & foam
rubber goods
0710 Mechanical rubber goods
0710
0718
0718
0710
283 Motor vehicles and
equipment
0716
0718
0718
-------
PRODUCT TYPE: Rubber Processing Chemicals
SOURCES:
RT= Morton, M. (ed.), Rubber Technology. Second
Edition, Van Nostrand Reinhold Company,
New York, 1953
EPST = Encyclopedia of Polymer Science and Technology.
John Wiley & Sons, Inc., New York, Volume 2 (1965),
Volume 4 (1966), Volume 6 (1967), Volume 7 (1967),
Volume 11 (1969), Volume 12 (1970)
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
o
-p-
RT, p. 21
EPST 2,
p. 737
Vulcanizing
Agent
RT, p. 218
*When EPA
more than
code is
application
once on a p
peated.
Styrene-butadiene rubber
1. Tires and tire-related products
A. Truck tires
B. Passenger tires
C. Off-road tires
D. Tread
2. Mechanical goods
3. Hard rubber
4. Wire and cable coatings
5. Floorings
6. Footwear and shoe products
7. Adhesives
8. Waterproofed goods
9. Medical
A. Drug sundries
10. Toys and athletic goods
11. Sponge
12. Foamed products
13. Manufacture of impact resistant polystyrene
is listed
age, only
413 Vulcanizing agents
076 Tires and inner tubes
0710 Mechanical rubber goods
0710
0655 Miscellaneous fabri-
cated wire products
0715 Rubber floor & wall
coverings
074 Rubber & plastic
footwear
F009 Adhesives
0713 Rubber coated fabric's
0714 Rubber druggist and
medical sundries
168 Toys & sporting goods
0718 Sponge & foam rubber
goods
0718
2131 Thermoplastic resins
& plastics
-------
PRODUCT TYPE:
Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
o
I
-p-
00
EPST _2,
p. 737
RT, pp.216-
218
EPST 2^
p. 737
EPST 6^,
pp. 383-4
RT, p. 242
Polybutadiene rubber
1. Tires and tire-related products
A. Truck and bus tires
B. Passenger tires
2. Mechanical goods
A. Motor mounts
B. Belting compounds
3. Footwear and shoe products
A. Heels and shoe soles
4. Toys and athletic googs
A. High rebound toy balls
B. Golf balls
5. Manufacture of impact resistant polystyrene
Ethylene/propylene rubber
1. Tires and tire-related products
A. Sidewalls
B. Coverstrips
2. Automotive
A. Weatherstripping
B. Window seals
C. Caulking
D. Radiator hoses
E. Engine mountings
F. Truck lid gaskets
3. Appliances
4. Carpet underlay
076 Tires & inner tubes
0710 Mechanical rubber goods
075 Rubber & plastic hose
and belting
0716 Rubber heels & soles
1681 Games, toys and chil-
dren 's vehicles
1682 Sporting and athletic
goods
2131 Thermoplastic resins
and plastics
076
283
(283
10710
283
/283
(075
283
(283
10710
1481
0715
Motor vehicles and
equipment
Household electrical
& electronic appliances
Rubber floor & wall
coverings
-------
PRODUCT TYPE: Rubber Processing Chemicals
USB AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Code
Application
Name
RT, p. 242
RT, p. 242
EPST 2_,
p. 291
5. Belting
6. Wire and cable coating
7. Footwear
8. Waterproofed goods
A. Weather-resistant sponge
B. Water-proof coated fabrics
9. Sponge
Butyl and chlorobutyl rubber
1. Tires and tire-related products
A. Inner tubes
B. Tire-curing bladders and bags
C. Tractor tires
D. Automotive tires
2. Automotive
A. Car-heater and radiator hose
B. Distributor nipples
C. Spring boosters
D. Starter buttons
E. Steering-rod stabilizers
F. Axle and body bumpers
G. Pedal pads
H. Auto topping
I. Brake bellows
J. Spark-plug nipples
K. Bushings
L. Truck-cab mounts
075
0655
074
0718
Rubber and plastic
hose and belting
Miscellaneous fabri-
cated wire products
Rubber and plastic
footwear
Sponge & foam rubber
products
0713 Rubber coated fabrics
0718
076 Tires & inner tubes
075
283 Motor vehicles and
equipment
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
RT, p. 242
EPST 2,
P- 791
APPLICATION Code j
3. Tapes
A. Wrapping and slicing tapes
B. Pressure-sensitive tapes
4. Seals
A. Domestic appliance seals
B. Window channels and seals
C. Home-canning seals
D. Diaphragms
E. Gearshift seals
F. Bottle-cap seals
G. Gaskets
1. Sterilizer gaskets
5. Textiles
A. Linesmen's blanket
B. Protective clothing
6. Footwear
A. Chemical-resistant boots
7. Mechanical goods
A. Conveyor belts
B. Pads
1. Rail pads
2. Bridge bearing pads
RT. P- 276 0
,8. Hose
EPST 2,
p. 791
A. Garden hose
B. Steam hose
9. Medical
A. Hospital sheeting
B. Heating pads
C. Pharmaceutical stoppers
AS DESCRIBED USING EPA DESCRIPTORS
ction Application
Name Code | Name
0710 Mechanical rubber
goods
0710
0713 Rubber coated fabrics
074 Rubber and plastic
f oo twear
075 Rubber & plastic
hose and belting
0710
075
0713
0714 Rubber druggist and
medical sundries
0714
n
i
Ul
o
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Code |
Function
Name
Code
Application
Name
EPST 2,
p. 791
RT, p. 297
O
ui
10. Toys and athletic goods
A. Football bladders
Polyisoprene rubber
1. Tires and tire-related products
A. Truck tires
B. Aircraft tires
C. Off-road tires
D. Passenger tires
2. Mechanical goods
A. Gaskets
B. Flat belts
C. 0-rings
D. Sheet rubber
E. Rubber bands
F. Cut thread
G. Battery separators
H. Rubber-covered rolls
3. Automotive
A. Bushings
B. Motor mounts
4. Medical
A. Hospital sheeting
B. Pharmaceutical sundries
5. Food-related
A. Baby bottle nipples
B. Milk tubes
6. Sponge
1682 Sporting and
athletic goods
076 Tires & inner tubes
Mechanical & rubber
goods
Rubber & plastic hose
and belting
Rubber stationers'
sundries
0710
075
0710
0710
0717
0717
0710
0710
283 Motor vehicles and
equipment
0713 Rubber coated fabrics
0714 Rubber druggist and
medical sundries
0714
0718 Sponge and foam rubber
goods
-------
PRODUCT TYPE:
Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
SOURCE
RT, p. 297
EPST, 7,
p. 843
EPST 2,
p. 737
RT, p. 306
EPST 2,
p. 737
KT, p. 335
FUNCTION
APPLICATION
7. Footwear and shoe products
A. Soles and heels
8. Toys and sporting goods
A. Golf balls
Nitrile rubber
1. Mechanical goods
A. Gaskets
B. Oil seals
C. Oil hose
D. Belting
E. Oil well parts
F. Fuel cell liners
G. Fuel hose
H. Tank liners
Neoprene rubber
1 . Automotive
A. Window gaskets
USE AS DESCRIBED USING EPA
Function
Code | Name
DESCRIPTORS
Application
Code | Name
0716
1682
0710
Rubber heels and soles
Sporting and athletic
goods
Mechanical rubber goods
0710
075
Rubber & plastic hose
and belting
075
0710
0710
075
0710
< 0710
1 283
B. Motor mounts
C. Wire jackets
D. Shock absorber covers
E. Blown sponge for door gaskets
Motor vehicles and
equipment
283
283
283
f0718
Sponge & foam rubber
goods
1 283
F. Molded seals
/ 283
\ 0710
G. Belts
< 075
\ 283
1. V-belts
2. Transmission
2. Aviation
A. Mountings
B. Wire and cable gaskets
280
{ 280
Aircraft and parts
I 0710
C. Deirers
D. Seals
280
( 280
\ 0710
o
Ul
N>
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Code
Application
Name
EPST 2j
p. 728
RT, p. 335
O
EPST 2,
p. 728
5. Railroad
A. Track mounting
B. Car body mounting
C. Air brake hose
D. Flexible car connectors
Construction
A. Building seals
B. Concrete-highway joist seals
C. Bridge pads and mounts
D. Soil-pipe gaskets
E. High rise window wall seals
F. Roof coatings
5. Food-related products
A. Creamery hose
B. Jar rings
C. Can closures
6. Medical
A. Closures for drug ampules
7. Textiles
A. Gloves
8. Mechanical goods
A. Belts
1. Conveyor
2. Escalator hand rails
B. Hose
1. Fire
2. Dredging
3. Garden
4. Industrial
5. Gasoline curb pump
6. Oil delivery
7. Oil suction
8. Air
286 Railroad car & equipment
286
(286
(075 Rubber and plastic
hose and belting
286
0710 Mechanical rubber goods
0710
0310 Bridges, tunnels and
elevated highways
0710
0710
1801 Barn and roof paints
/ 0710
I 1493 Food processing equip-
ment
0714 Rubber druggist and
medical sundries
0711 Rubber apparel
075
075
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Code |
Function
Name
Code
Application
Name
EPST 2,
p. 728
RT,
pp. 346-347
EPST 6^,
pp. 449
RT, pp. 316
-317
C, Molded goods
9. Wire and cable jackets
Chlorosulfonated polyethylene rubber
1. Tires and tire-related products
A. White sidewalls
2. Automotive
A. Spark plug boots
B. Primary and ignition wire coatings
C. Power steering hose liners and jackets
3. Construction
A. Curtain wall gaskets
4. Textiles
A. Tarpaulins
B. Rain wear
C. Boat covers
D. Radomes
E. Inflatable structures
F. Insulating blankets
G. Fabric conveyor belts
5. Wire and Gable sheetlinings
A. Control cable
B. Mine trailing cable
C. Service drop wire
D. Motor lead wire
E. Telephone handset cords
F. Appliance cords
G. Weatherproof wire
0710 Mechanical rubber goods
0655 Miscellaneous fabri-
cated wire products
076 Tires and inner tubes
(0655
(283
Motor vehicles and
equipment
(283
\075 Rubber and plastic
hose and belting
0710 Mechanical rubber goods
0713 Rubber coated fabrics
0711 Rubber apparel
0713
0713
0710
0713
075
0655
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
o
ui
EPST 6,
p. 449
RT, pp.
346-347
EPST 6^
p. 449
RT, pp.
346-348
EPST 6^
p. 449
RT, pp.
346-347
EPST_4_,
pp. 732
&766
RT, pp.
364-366
ESPT _U
p. 441
6. Food and food-related products
A. Food industry conveyor belts
7. Electrical accessories
A. Cable connectors
B. Sockets
C. Line hose
D. Insulating hoods
8. Floor tile
9. Hose
A. Garden
B. High pressure steam
C. Discharge
D. Industrial water hose covers
E. Line hose
Polysulfide rubber
1. Dental impression material
2. Electronic embedding material
3. Rollers for paints and inks
4. Hose liners (solvent-resistant)
5. Gaskets
6. Gas meter diaphragms
7. Acid-resistant rubber-sulfur cements
1493 Food process equipment
075 Rubber and plastic
hose and belting
0710 Mechanical rubber goods
0710
075
0710
0715
075
Rubber floor and wall
coverings
112 Medical and dental
instrument supplies
143 Electronic components
and accessories
0710
075
0710
0710
F009 Adhesives
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code \
Name
Application
Code
Name
RT, p. 369
O
l
Ul
EPST 12.,
pp.552
& 545
Silicone rubber
1. Automotive
A. Spark plug boots
B. Ignition cable jacket
C. Seals and sealants
1. Transmission
2. Engine
3. Windshield
D. Hose
E. Maintenance applications
F. Shock absorber fluid
2. Aerospace
A. Seals
1. Airframe opening (doors, windows, etc.)
2. Aerodynamic balance and control surface seals
3. Lubricating system
4. Hydraulic system
5. Gaskets & 0-rings
6. Firewall bulkhead
B. Hot air ducts
C. Dust shields
D. Limit switch boots
E. Jet engine starter hose
F. Airframe and spacecraft body sealants
G. Insulation
1. Aircraft & missile wire
2. Missile external and base heating
H. AN connector inserts
283
Motor vehicles and
equipment
Miscellaneous fabri-
283 cated wire products
0710 Mechanical rubber goods
283
0655
075
m
283
Rubber & plastic hose
and belting
0710
280 Aircraft and parts
075
0710
2ftO
281 Guided missiles and
space vehicles & parts
281
280
-------
1MCDUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code
Name
RT, p. 369
EPST .12,
P- 552
O RT, p. 370
Ul
EPST .U,
p. 545
RT, p. 370
3. Appliances
A. Seals, gaskets, and insulation
1. Oven doors
2. Washers-dryers
3. Steam irons
4. Frying pans
5. Coffee makers
6. Air conditioners
4. Sponge
5. Electronic
A. Capacitor bushings
B. Rubber-coated glass sleeving
C. Rubber tubing
D. Television corona shields
E. Television receiver high-voltage circuits
F. Potting, impregnation and encapsulation
Wire and cable jackets
A. Apparatus lead wire
B. Appliance & fixture wire
C. Defroster harness wire
D. Electronic hook-up wire
E. Nuclear power cable
F. Naval vessel wire
1481 Household eletrrical
and electronic appli-
aaces
0710 Mechanical rubber goods
1484 Refrigeration, air con-
ditioning and heating
equipment
0768 Sponge and foam
rubber goods
1431 Electronic capacitors
143 Electronic components
and accessories
143
1430 Cathode ray television
picture tubes
1436 Semiconductors and re-
lated solid state
devices
143
0655 Miscellaneous fab-
ricated wire products
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
5T 12,
546
T 12,
550
p. 370
T 12,
544-552
APPLICATION — Code |
7 . Medical
A. Tubing
B. Surgical implants
1. Artificial heart valves
2. Artificial arteries
AS DESCRIBED USING EPA DESCRIPTORS
ctlon Application
Name Code | Name
112 Medical and dental
instruments and
supplies
3. Encapsulation of electronic heart-beat stimulators
C. Prosthetic devices
D. Dental impressions
E. Research applications
F. Pharmaceutical stoppers
G. Bouncing putty for rehabilitative therapy
8. Construction
A. Sealants
1. Suspended window walls
2. Expansion joints
3. Glazing
4. Truck & house trailers
5. Silos and grain cribs
6. Radomes
B. Weatherproof coatings
1. Roof
2. Wall
3. Deck
9. Food and food -related products
A. Conveyor belts
0710 Mechanical rubber goods
1801 Barn and roof paints
1802 Exterior house paints
1802
075 Rubber and plastic
hose and belting
1493 Food processing equip-
ment
n
i
Ul
00
p-
RT,
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Name
Application
Code
Name
O
I
V/l
vO
10. Molds
A. Jewelry
B. Furniture
11. Toys
A. Bouncing putty
12. Household repairs
13. Gas masks
A. Decorating leather & viny]
B. Sculpture
C. Paint
Fluorocarbon rubber
1. Seals
A. 0-rings
B. Gaskets
C. Extrusions
D. Cross-sectional configurations
2. Hose
A. Rubber-lined
B. Rubber-covered
C. Fabric-reinforced
3. Rolls
A. Paper processing
B. Film processing
C. Fabric processing
4. Textiles
A. Clothing
0710 Mechanical rubber goods
1681 Games, toys, and
children's vehicles
04001 Dwelling cleaning and
maintenance
0710
1690 Art supplies
0710
075 Rubber and plastic
hose and belting
0710
0711 Rubber apparel
-------
PRODUCT TYPE: Rubber Processing Chemicals
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
RT, p. 433
5. Food and food-related products
A. Food processing
B. Carbonated beverage handling
6. Medical
Pharmaceutical handling
7. Valve & pump linings
8. Protective overlay for flammable substances
9. Sponge
O
O
1493 Food process machinery
149 Special industry
machinery
0710 Mechanical rubber goods
0710
0718 Sponge and foam
rubber products
-------
PRODUCT TYPE: Trade Sales Paints
SOURCES: Chemical Economics Handbook. SRI International,
Menlo Park, California, pp. 592.5500 A-E.
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
U.S. Department of Commerce, Bureau of the Census,
1967 Census of Manufactures, Numerical List of
Manufactured Products, U.S. Government Printing
Office, 1968.
*
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code
Name
Application
Code
Name
CEH
SRI Staff
1967 Census
Anti-
fearning
agents
CEH
SRI Staff
1967 Census
Anti-
skinning
agents
* When EPA
on a page
.pplication
only code
/246
1160
Foam inhibitors
Defoamers
1. Exterior paints
A. All purpose water-based paints
B. Masonry water-based paints
C. Other exterior water-based paints
Interior paints
A. Flat water-based paints
B. Semigloss water-based paints
C. All purpose water-based paints
D. Other interior water-based paints
1810
1811
1810
088
Antiskinning agent
1. Exterior solvent-based paints
A. Oil and alkyd vehicle house paints
B. Sash, trim & trellis enamels
C. Porch & deck enamels
D. Undercoaters & primers
E. Barn & roof paints
F. Marine paints & enamels
G. Metallic paints
H. Traffic paints
I. Automotive & machinery — refinishing paints
J. Automotive & machinery — primers
& undercoaters
.s listed more than once
repeated.
1802
1802
1802
1802
1801
1803
1804
1806
1800
1800
All purpose water
emulsion paints &
tinting bases
Masonry water emulsion
paints & tinting bases
1840 Interior water emul-
sion wall & trim
paints
Exterior house paint
Barn & roof paints
Marine paints & enam-
els, except industrial
Metallic paints
Traffic paints
Automotive & machinery
refinish paints and
enamels
-------
PRODUCT TYPE: Sales Trade Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
CEH Driers
SRI Staff
1967 Census
APPLICATION Code |
K. Oleoresinous varnish
L. Stains (including shingle & shake)
M. Other exterior oil paints
2. Interior solvent-based paints
A. Flat wall paints
B. Gloss & quick dry enamels
C. Semigloss enamels
D. Primers & undercoaters
E. Other interior oil paints
F. Varnishes, except shellac
G. Shellac varnish
H. Interior oil & alkyd stains
I. Aerosol paints
AS DESCRIBED USING EPA DESCRIPTORS
ction Application
Name Code | Name
1807 Varnishes (exterior)
1805 Stains (exterior)
1802 Exterior house paints
1830 Interior oil base wall
& trim paints
1830
1830
1830
1830
1832 Varnishes (interior)
1832
1831 Stains (interior)
183 Interior oil base
paint products
196 Driers
1. Exterior solvent-based paints
A. Oil and alkyd vehicle house paints
B. Sash, trim & trellis enamels
C. Porch & deck enamels
D. Primers & undercoaters
E. Barn & roof paints
F. Marine paints & enamels
G. Metallic paints
H. Traffic paints
I. Automotive & machinery — refinishing paints
J. Automotive & machinery — primers and undercoaters
1802
1802
1802
1802
1801 Barn & roof paints
1803 Marine paints & enam-
els, except industrial
1804 Metallic paints
1806 Traffic paints
1800 Automotive & machinery
refinish paints &
enamels
1800
n
i
N)
-------
PRODUCT TYPE: Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
SOURCE
CEH
SRI Staff
FUNCTION
Pigments :
Colored
& black
APPLICATION
K. Oleoresinous varnish
L. Stains (including shingle & shake)
M. Other exterior oil paints
2. Exterior water-based paint
A. Acrylic/alkyd all purpose paint
3. Interior solvent-based paint
A. Flat wall paints
B. Gloss & quick dry enamels
C. Semigloss enamels
D. Primers & under coaters
E. Other interior oil paints
F. Varnishes, except shellac
G. Interior oil & alkyd stains
H. Aerosol paints
1. All trade sales paints except
varnishes and other clear finishes
USE AS DESCRIBED USING EPA
Function
Code | Name Code
1807
1805
1802
1810
1830
1830
1830
1830
1830
1832
1831
183
1411 Pigments
1800
1801
1802
1803
1804
1805
1806
181
1830
1831
184
185
DESCRIPTORS
Application
1 Name
Varnishes (exterior)
Stains (exterior)
Exterior house paints
All purpose water emul-
sion paints & tinting
bases
Interior oil base
wall & trim paints
Varnishes (interior)
Stains (interior)
Interior oil base
paint products
Automotive & machinery
refinish paints &
enamels
Barn & roof paints
Marine paints & enam-
els, except industrial
Metallic paints
Traffic paints
Exterior water base
paint products
Interior water base
paint products
Lacquers
o
I
o\
LO
-------
PRODUCT TYPE: Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code [
Name
Code |
Application
Name
SRI Staff
Pigments:
Corrosion
inhibitors
CEH
SRI Staff
1967 Censu
Pigments:
Extenders
(non-opaque
O
I
144 Corrosion inhibitors
1. Metallic paints
2. Automotive & machinery — refinishing paints
3. Automotive and machinery — lacquers
4. Automotive & machinery — primers and
undercoaters
233
Extenders
Exterior paints
A. Oil and alkyd house paints
B. Porch & deck enamels
C. Primers & undercoaters
D. Barn & roof paints
E. Traffic paints
F. Automotive & machinery — refinishing paints
G. Automotive & machinery — primers & undercoaters
H. All purpose water-based paints
I. Masonry water-based paints
J. Other exterior water-based paints
2. Interior paints
A. Flat wall paints
B. Gloss & quick dry enamels
C. Semigloss enamels
D. Primers & undercoaters
E. Flat water-based paints
F. Semigloss water-based paints
G. All purpose water-based paints
H. Other water-based paints
1804
1800
1850
1800
1802
1802
1802
1801
1806
1800
1800
1810
1811
1810
1830
1830
1830
1830
1840
1840
1840
1840
Metallic paints
Automotive & machinery
refinish paints &
enamels
Automotive original
& refinish lacquers
Exterior house paints
Barn and roof paints
Traffic paints
All purpose water
emulsion paints &
tinting bases
Masonry water emulsion
paints & tinting bases
Interior oil base wall
and trim paints
Interior water emulsion
wall & trim paints
-------
PRODUCT TYPE: Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code|
Name
Application
Code [
Name
CEH
Pigments:
White
(opaque)
O
I
1411 Pigments
1. Exterior paints
A. Oil & alkyd vehicle house paints
B. Sash, trim & trellis enamels
C. Porch & deck enamels
D. Primers & undercoaters
E. Barn & roof paints
F. Marine paints & enamels
G. Metallic paints
H. Traffic paints
I. Automotive & machinery — refinishing paints
J. Automotive and machinery — primers & undercoaters
K. Other exterior oil paints
L. All purpose water-based paints
M. Masonry water-based paints
N. Other exterior water-based paints
2. Interior paints
A. Flat wall paints
B. Gloss & quick dry enamels
C. Semigloss enamels
D. Primers & undercoaters
E. Other interior oil paints
F. Aerosol paints
G. Flat water-based paints
H. Semigloss water-based paints
I. All purpose water-based paints
J. Other water-bsed paints
1802
1802
1802
1802
1801
1803
1804
1806
1800
1800
1802
1810
1811
1810
Exterior house paints
Barn & roof paints
Marine paints & enam-
els, except industrial
Metallic paints
Traffic paints
Automotive & machinery
refinish paints &
enamels
All purpose water
emulsion paints &
tinting bases
Masonry water emulsion
paints & tinting bases
1830 Interior oil base
wall & trim paints
1830
1830
1830
1830
183 Interior oil base paint
products
1840 Interior water emul-
sion wall & trim
paints
1840
1840
1840
-------
PRODUCT TYPE:
Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code |
Name
Application
Code |
Name
CEH
SRI Staff
1967 Censu;
Preserv-
atives &
mildew-
cides
O
|2570 Mildew preventives
(339 Preservatives
1. Exterior oil & alkyd vehicle house paints
2. Exterior all purpose water-based paints
A. Acrylic emulsion type
B. Acrylic-alkyd light tint type
C. PVAc emulsion type
3. Exterior masonry water-based paints
A. Acrylic white types
B. Vinyl acetate copolymer
It. Other exterior water-based paints
A. Acrylic emulsion type primer
B. PVAc type primer
5. Interior flat water-based paints
A. Acrylic flat wall paint
B. Vinyl acetate copolymer flat white paint
C. Vinyl-acrylic flat paint
6. Interior semigloss water-based paints
A. Acrylic latex gloss white enamel
B. Acrylic emulsion semigloss paint
C. PVAc white semigloss enamel
7. Interior all purpose water emulsion paints
8. Interior water-based paints including pastes & semi pastes
A. Acrylic white type
B. Vinyl acetate copolymer white type
1802 Exterior house paints
1810 All purpose water
emulsion paints &
tinting bases
Masonry water emulsion
paints & tinting bases
1811
1810
1840 Interior water emul-
sion wall & trim paints
1840
1840
1840
-------
PRODUCT TYPE: Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
SOURCE
_ -- --
SRI Staff
1967 Censu
CEH
CEH
SRI Staff
1967 Censu!
FUNCTION
Propellants
Resin binde
(film-form-
ing agents)
Solvents
APPLICATION
Aerosol paints
s
All trade sales paints
All trade sales paints (including water-
based)
1. Exterior paints
A. Oil and alkyd vehicle house paints
B. Sash, trim & trellis enamels
C. Porch & deck enamels
D. Primers & undercoaters
E. Barn & roof paints
F. Marine paints & enamels
G. Metallic paints
H. Traffic paints
USE AS DESCRIBED USING EPA
Function
DESCRIPTORS
Application
Code | Name Code I Name
014 Aerosol propellants
183
|104 Binders
(140 Coating agents
180
181
183
184
185
384 Solvents
1802
1802
1802
1802
1801
1803
1804
1806
I. Automotive & machinery — refinishing paints 1800
Interior oil base
paint products
Exterior oil base
paint products
Exterior water-base
paint products
Interior water-base
paint products
Lacquers
Exterior house paints
Marine paints & enam-
els, except industrial
Metallic paints
Traffic paints
Automotive & machinery
refinish paints &
enamels
J. Automotive & machinery — primers & undercoaters 1800
K. Oleoresinous varnish
1807
Varnishes (exterior)
n
i
-------
PRODUCT TYPE: Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY
USE AS DESCRIBED USING EPA DESCRIPTORS
SOURCE
FUNCTION
APPLICATION
Function
Code [
Name
Application
Code [ Name
n
oo
L. Stains (including shingle & shake)
M. Other exterior oil paints
N. All purpose water-based paints
0. Masonry water-based paints
P. Other exterior water-based paints
2. Interior paints
A. Flat wall paints
B. Gloss & quick dry enamels
C. Semigloss enamels
D. Primers & undercoaters
E. Other interior oil paints
F. Varnishes, except shellac
G. Shellac varnish
H. Interior oil & alkyd stains
I. Aerosol paints
J. Flat water-based paints
L. All purpose water-based paints
M. Other water-based paints
3. Lacquers
A. Automotive & machinery — lacquers
B. Other trade sales lacquers
1805
1802
1810
1811
1810
1830
1830
1830
1830
1830
1832
1832
1831
183
1840
1840
1840
1850
1851
1852
1853
Stains (exterior)
Exterior house paints
All purpose water
emulsion paints &
tinting bases
Masonry water emulsion
paints & tinting bases
Interior oil base wall
& trim paints
Varnishes (interior)
Stains (interior)
Interior oil base
paint products
Interior water emul-
sion wall & trim paints
Automotive original &
refinish lacquers
Fabricated metal
lacquers
Paper and paperboard
lacquers
Wood lacquers
-------
PRODUCT TYPE: Trade Sales Paints
USE AS NORMALLY DESCRIBED IN THE INDUSTRY USE
SOURCE FUNCTION
CEH Surfactants
SRI Staff £,
1967 Census dispersing
agents
CEH Thickeners
SRI Staff
1967 Census
Fun
APPLICATION Code |
AS DESCRIBED USING EPA DESCRIPTORS
ction Application.
Name Code 1 Name
( J93 Surfactants
( 3931 Dispersants
1. Exterior paints
A. All purpose water-based paints
B. Masonry water-based paints
C. Other exterior water-based paints
2. Interior water-based paints
A. Flat water-based paints
B. Semigloss water-based paints
C. All purpose water-based paints
D.. Other interior water-based paints
1810 All purpose water
emulsion paints &
tinting bases
1811 Masonry water emulsion
paints & tinting bases
1810
1840 Interior water emul-
sion wall & trim paints
401 Thickeners
1. Exterior paints
A. All purpose water-based paints
B. Masonry water-based paints
C. Other exterior water-based paints
2. Interior paints
A. Flat water-based paints
B. Semigloss water-based paints
C. All purpose water-based paints
D. Other interior water-based paints
1810
1811
1810
1840
o
vd
-------
APPENDIX D
INSTRUCTIONS FOR REPORTING CHEMICAL USES
D-l
-------
INSTRUCTIONS FOR REPORTING CHEMICAL USES
1.0 INTRODUCTION
This section provides specific instructions for using
this manual in reporting chemical use information.
2.0 INSTRUCTIONS FOR REPORTING CHEMICAL USES
2.1 DEFINITION OF CHEMICAL USE
For purposes of reporting'within this classification
system, the concept of "use" has been divided into two components/
i.e., function and application. In this classification system,
"function" and "application" are defined as follows:
• Function; what a chemical is used ajs—an action or
process which the chemical itself performs. Function
terms denote classes of substances which perform a
common action or process, e.g., "adhesives", "slime
preventives".
• Application i what a chemical is used in~a chemical
process, product or activity in which the chemical
is employed, e.g., "petroleum distillation" (chemical
process), "leather gloves" (product), "cleaning and
maintenance" (activity).
For example, a chemical may function as. a soil release
agent for application to yarns and fabrics. Do not report as a
use a subsequent production or formulation operation which results
in a product that does not contain the chemical being reported.
For example, if acrylonitrile functions as a polymerization
monomer, and the resulting polyacrylonitrile is used in the
formulation of coatings for yarns and fabrics, report the function
of acrylonitrile as a monomer and the application as finished
D-3
-1-
-------
yarns and fabrics. For each chemical use reported, you will need
to provide one function and one application, as described below.
Please note that each unique combination of a function
and an application constitutes a distinct use, different from
other uses which may have as a component the same function or
application, but not both.
2.2 INSTRUCTIONS FOR REPORTING FUNCTION
In order to report the function component of a chemical
use, you will need List I, which contains function terms in a
hierarchical classification, and the alphabetical index to List I.
2.2.1 Step 1: Using the Index to Locate the Appropriate
Function"
First, turn to the index to List I and look for a term
(or terms) that, to your knowledge, most nearly corresponds to the
function of the chemical in the use you are reporting. In searching
the index, bear in mind that entries are listed in direct, rather
than in inverted form. For example, the term "Cyclic Chemicals"
is listed as such, and not as "Chemicals, Cyclic".
Entries in the index to List I are of two types: valid
terms, which are to be used for reporting functions, and cross-
references to valid terms. All valid terms in the index are
followed by a three or four character code which identifies the
location of the term in the hierarchical structure of List I.
Cross-references are of two types: "see" and "see also", e.g.,
Cleansing agents
See: Cleaners 136
D-4
-2-
-------
Coloring agents
See also: Stains 337
The "see" cross-reference refers a user from a synonym to the
valid term which is preferred for reporting purposes. The "see
also" cross-reference refers a user from one valid term to
another valid term denoting a related function. The purpose of
the "see also" cross-reference is to alert the user to related
terms which may describe the function more appropriately.
2.2.2 Step 2; Locating the Selected Function Term in the
Hierarchical List
Having selected a valid function term, look up its co'»le*
in List I. Keep in mind that List I is arranged hierarchically,
so that, for example, 1490, 1491, and 1492 follow 149. In List I,
a definition is supplied for each function term. In addition,
seme terms have scope notes indicating the limits of a term's
usage within the classification. Read the definition and scope
note for the term you have chosen, as well as for other terms in
the hierarchy (if any). (Occasionally you will be referred from
a "see" cross-reference in the index to a valid term with a defini-
tion, but no hierarchical relationships.) In this way, you can
judge whether the term you selected initially is the most specific
and most appropriate function for the chemical use being reported.
Turn back to the index and begin the selection process again, if
you fael you have not located the proper function term.
*While most codes contain only numbers, a few contain letters as
well. The sequence is zero to 9, followed by A to Z.
D-5
-3-
-------
You may locate valid functions that are near-synonyms
but that are employed specifically by different industries. A
typical example of this situation is the term class "surfactants",
which includes the subcategories, "wetting agents" and "detergents'
A given surfactant substance may be variously described as a
surfactant, wetting agent or detergent, depending on the industry
in which it is used. In such instances, report the term which is
consistent with terminology in the industry for which use is being
reported.
2.2.3 Step 3; Reporting Function
When you have selected from List I the most appropriate
valid function term, locate the line shown below:
Term Code Term Name
List I. FUNCTION [ ] [ ] [ ] [ ]
Write the code of the term you have chosen in the designated boxes,
and then write the term name on the line following the coding boxes.
Always write the code beginning in the leftmost box, even if the
code for the term you have selected has only three characters.
A completed function entry is shown below.
Term Code Term Name
List I. FUNCTION [3_] [8_] [6_] [ ] STABILIZERS
If you could not find an appropriate term 'in List I which
fits the function concept you have in mind, even though you have
searched the index, you may supply an appropriate term in the
D-6
-4-
-------
following manner. List I contains the term class "315 OTHER".
Use this term class to report a new function, as follows:
Term Code Term Name
List I. FUNCTION [3_J [1_J [5J [ ] OTHER - (NEW TERM)
When you add a new term as described, you must/ in addition,
provide a definition of the new term being reported. Before
adding new terms, however, examine the existing terms carefully
for applicability.
2.3 INSTRUCTIONS FOR REPORTING APPLICATION
In order to report the application component of a chemical
use, you need List II, which contains application terms in a
hierarchical classification, and the alphabetical index to List
II..
2.3.1 Step 1; Using the Index to Locate the Appropriate
Aggiication"
First, turn to the index to List II and look for the
most appropriate application term (or terms) that, to your know-
ledge, combines with the function you have just selected, as
described above, to denote the use you are reporting. The index
to List II is similar to the index to List I in format and contains
valid application terms and codes, synonyms with "see" cross-
references, and "see also" cross-references.
If you cannot find an appropriate term in the List II
index, return to the List I index and look for the application
there. (See the special situation rule explained in Section 2.5
below.)
D-7
-5-
-------
If you are reporting on Agricultural Chemicals or
Chemical Intermediates, please see Section 2.6 for specific
instructions on how to proceed.
2.3.2 Step 2: Locating the Selected Application Term in the
Hierarchical List
Having selected a valid application term in the index,
look up its code*- in List II. Keep in mind that List II is
arranged hierarchically in three levels of specificity from most
general to most specific, e.g.,
012 CHOP PRODUCTION
012a CASH GRAIN PRODUCTION
01200 CORN PRODUCTION
01201 RICE PRODUCTION
Read any scope notes, and examine the other terms in the hierarchy.
Select the most specific appropriate application term which you are
able to locate in List II.
2.3.3 Step 3: Reporting Application
When you have chosen an application term, locate the line
shown below:
List II. APPLICATION [ ][ ][ ][ ][ ]
Write the cede of the term you have chosen in the designated boxes,
and then write the term name on the line following the coding boxes
Always write the code beginning in the leftmost box, even if the
code for the term you have selected has fewer than five characters.
"While most codes contain only numbers, a few contain letters
as well. The sequence is zero to 9 followed by A to Z.
D-8
-6-
-------
A completed application entry is shown below.
List II. APPLICATION [2J [OJ [OJ ] ] [_J PETROLEUM BLENDING
AND COMPOUNDING
If you could not find an appropriate application term in
List II (or in List I, as explained in Section 2.5), you may
supply an application term in the following manner.
List II contains the term class "MISCELLANEOUS PRODUCTS
AND SERVICES 16". Use this term class to report a new application
as follows:
LIST II. APPLICATION [1_] [ 6J [ ] [ ] [ ] MISCELLANEOUS -
(NEW TERM)
Before adding new terms, however, examine the existing terms care-
fully for applicability.
2.4 ADDITIONAL GUIDELINES FOR REPORTING USES
2.4.1 Choosing the Most Specific Term Available
If you are seeking a term which is more specific than
the most specific applicable term given in Lists I and II, use
the more general term as given. For example, in reporting a
chemical used as a binder for grinding wheels, you would look up
the term "BINDERS" in the index to List I and would enter this
term for function. You might then look for the term "grinding
wheels" in the index to List II. However, the closest appropriate
term in List II is "ABRASIVE PRODUCTS", and this is the term
vou should select.
D-9
-7-
-------
If, on the other hand, you do not know the specific
application of a chemical, you may also report a more general
application. For example, in the term grouping:
212 NONCSLLULOSIC ORGANIC FIBERS
2120 ACRYLIC AND MODACRYLIC FIBERS
2121 POLYAMIDE FIBERS
2122 POLYESTER FIBERS
2133 POLYOLEFIN FIBERS
If you do not know the specific type of fiber in which a chemical
is used, you may report "212 NONCELLULOSIC ORGANIC FIBERS."
2.4.2 Repeating a Function With Different Applications
If a single function has more than one application (List
II), repeat the same function (List I) as many times as necessary
to cover each application reported. Each unique combination of a
function and an application constitutes a distinct use, different
from other uses which may have as a component the same function
or application, but not both. For example, sodium silicate, when
functioning as a binder, has applications in both paperboard
container manufacture and iron and steel foundry product manu-
facture . This information would be coded as follows:
Term Code Term Name
List I. FUNCTION [LJ [0_J [4_] [ ] BINDERS
List II. APPLICATION [1 ][9 ][3 ][ ][ ] PAPERSOARD
CONTAINERS AND BOXES
Term Code Term Name
List I. FUNCTION [1 ][0 ][4 ][ ] BINDERS
List II. APPLICATION [2J [2J [2_] [ ] [ ] IRON AND STEEL
FOUNDRY PRODUCTS
D-10
-8-
-------
2.4.3 Repeating an Application With Different Functions
If the chemical functions in more than one way in the
same application, repeat the same application as many times as
necessary to cover each function reported. For example, a
particular chemical may function as both a solvent and a reaction
medium in the same application.
2.4.4 Choosing the Most Appropriate Function/Application
Combination(s)
While you are encouraged to report as many unique
function/application combinations as necessary to cover all uses
of the chemical known to you, please report only those combinations
which most closely correspond to the specific conditions of use
for the reported chemical. In other words, if you discover two
function terms which both come close to the function of the
chemical in the use you are reporting, choose the one you believe
to be most appropriate. Do not report both.
2.5 SPECIAL SITUATION RULE FOR USING A DOUBLE FUNCTION
In certain cases, a chemical may have as its application
not a process, product or activity (which is the way this clas-
sification system defines application), but rather another
function. For example, the chemical toluene may function as a
solvent in the formulation of an adhesive. According to this
classification system, both "solvent" and "adhesive" are
considered functions. (The adhesive may later be used to
laminate materials such as fabrics, plastics and wood, and as
such would have a valid application in the context of the system.)
D-ll
-9-
-------
In this case, you would select two terms from List I
and use them to report both function and application. Code the
List .1 code and term as usual on the List I coding line. Code
the List I code and term being used, in this instance, to describe
application, on the List II coding line, placing a letter F in
the leftmost box, as follows:
Term Code Term Name
List I. FUNCTION [3_J [8_J [4_] [ ] SOLVENTS
List II. APPLICATION [F ][0 ][0 ][9 ][ ] ADHESIVES
2.6 SPECIAL REPORTING INSTRUCTIONS FOR AGRICULTURAL CHEMICALS
AND CHEMICAL INTERMEDIATES
2.6.1 Agricultural Chemical Reporting
In the List II term class, "AGRICULTURE, FORESTRY AND
FISHING", crop-related applications such as fertilization, weed
control and soil preparation are not included. (These are
described in terms of functions in the classification system, e.g.
fertilizers, herbicides, soil conditioners.) Instead, you should
report the application of a given chemical to a given crop or
crops. For example, a fertilizer (List I) for cotton crops
should be associated with the List II term, "COTTON PRODUCTION".
2.6.2 Chemical Intermediate Reporting
In the context of this classification system, a chemical
intermediate is defined as a chemical compound that is formed
in the sequence of chemical reactions between a starting material
and a product. This definition excludes chemical compounds which
are mixed with other compounds to make a formulated product
D-12
-10-
-------
without undergoing a chemical change. For example, nitrobenzene
used in the manufacture of aniline would be considered a chemical
intermediate. On the other hand, nitrobenzene used as an
ingredient of shoe polishes would not be considered an inter-
mediate .
In reporting on a chemical intermediate which is used to
make more than one chemical substance of the same type (e.g.,
cyclic chemicals), report only one use. If the chemical inter-
mediate is used to make more than one type of chemical substance
(e.g., acyclic chemicals and reagent and high purity grade
chemicals), report as many uses as appropriate.
D-13
-11-
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APPENDIX E
FUNCTION TERMS DEFINED AS
CONTAINING TWO OR MORE FUNCTIONS
E-l
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Code No. Function Term
006 Acidulants
007 Activators
020 Analytical and product
testing agents
049 Antifogging agents
108 Bloom inhibitors
136 Cleaners
145 Coupling agents
151 Curing agents
180 Desiccants
184 Developers
191 Disintegrating agents
197 Drilling mud conditioners
200 Dust control agents
209 Eluting agents
213 Etching agents
224 Feed supplements
232 Finishing agents
(textile technology)
235 Fixatives
241 Flour treating agents
2452 Melting fluxes
247 Food conditioners
249 Formulation aids
251 Fuel additives
255 Functional fluids
268 Hormones
287 Latex compounding
agents
Code No. Function Term
299 Metal treating agents
300 Microbiocides
307 Nucleating agents
323 Papermaking agents
324 Papermaking aids
330 Pickling agents
334 Plastics compounding agents
335 Polymerization additives
339 Preservatives
354 Resists
356 Rubber compounding agents
363 Scavengers
365 Scouring agents
379 Softeners
380 Soil conditioners
387 Stains
389 Stiffening agents
392 Surface finishing agents
399 Textile conditioners
400 Texturizers
401 Thickeners
403 Toners
404 Tonics
414 Water repellents
417 Well treating agents
425 Peptizing agents
E-3
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APPENDIX F
SIGNIFICANCE OF THE ASSUMPTIONS
F-l
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The six assumptions used in t-he preceding assessment of sorting
errors are generally biased toward acceptability of the system. The
rationale for this generalization follows.
A. Use of Ten Groups
Use of 10 rather than 15 groups biases the analysis toward lower
probabilities of an erroneous assignment of priority to a use
category, because the broader the point spread in a group, the lower
the probability that a one-point error will cause a shift from one group
to another.
B. Use of Even-Sized Scoring Groups
This neither obviously favors nor disfavors the acceptability of
use categories. If the interval sizes were larger for high-priority
groups than for low-priority groups, the probability of erroneous
decisions would be reduced. However, broader categories would tend
to be less useful, due to the rise in the number of use categories
that they would tend to contain. Moreover, although the probability
that errors would be made decreases as the groups are enlarged, the
probability that an error would be important would rise by an equal
amount.
C. Even Distribution of Use Categories
If most of the use categories fell in the vicinity of the cut-off
point, the percent of regulatory errors would rise relative to what
this assumption would predict. Conversely, were they clustered away
from this point, the probability of error would fall. Hence, the
assumption neither greatly favors nor disfavors the concept of use as a
surrogate for exposure.
F-3
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D. Restriction of Analysis to One-Point Errors
Multiple errors in the same directions would make the system
look worse; hence, this assumption biases the analysis in favor of the
concept of use as a surrogate for exposure. Multiple errors in varied
directions would tend to offset each other and would have correspond-
ingly less effect. (Although the probability of multiple errors could
be developed using a complex computer program, it would be costly to
do so.)
E. Independence
If the errors in the estimation of the ten values needed for the
scoring procedure were not independent, the errors that occurred would
tend to be multiple, and hence, when they occurred, would be more
serious. They would not necessarily be more frequent.
F. High Threshold
In the absence of a bias toward overestimation of the score to be
assigned to the components of the scoring methodology, only very
high scores can be obtained with a low incidence of errors. In
contrast, numerous combinations of compensating multiple errors can
give scores in the middle of the range of possible values. This
problem is greatest for the score of 25, the midpoint in the range
of possible scores.
F-4
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
560/13 - 79 - 007
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
An Analysis of the EPA Chemical Use Classification
System and the OTS Exposure Estimation Methodology
5. REPORT DATE
June 1979
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Jeffrey Allport, Sharon Casey, Janet Hardy,
Buford Holt, and Kirtland McCaleb
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
SRI International
333 Ravenswood Avenue
Menlo Park, California 94025
10. PROGRAM ELEMENT NO.
2 LS 8-12
11. CONTRACT/GRANT NO.
Contract No. 68-01-4109
Research Request No. 4
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Toxic Substances
Environmental Protection Agency
Washington, B.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Work under this Research Request was directly monitored by the
Office of Programs Integration and Information/OTS/EPA
16. ABSTRACT
This report contains separate evaluations of the EPA Chemical Use Classification
System and the OTS Exposure Estimation Methodology developed by EPA/OTS and
another contractor.
The Use Classification System describes uses of chemicals in terms of two components,
function and application. The results of a three-part study of the systems led to
the conclusion that the system provides neither adequate application terms nor
satisfactory instructions to assure that the available terms will be used in
essentially the same way by the various users.
The Exposure Estimation Methodology was analyzed by statistical and systems analysis
methods and found to be seriously lacking. The overall scores produced by this
scoring system are probably not usefully related to exposures which would occur due
to a particular chemical use.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATi Field/Group
Chemical Industry
Descriptions
Evaluation
Methodology
Exposure (General)
Estimating
Paints
Rubber
Use Classification Systen
Exposure Estimation
Methodology
Chemical Uses
07/01
14/07
14/07
14/00
06/19
14/07
11/03
11/11
13. DISTRIBUTION STATEMEN1
Release Unlimited
19. SECURITY CLASS (ThisReport)
Not classified
21. NO. OF PAGES
185
20. SECURITY CLASS (This page)
Not classified
22. PRICE
EPA Form 2220-1 (9-73)
4 U. S. GOVERNMENT PRINTING OFFICE ; 1979—299-975
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