United States
Environmental Protection
Agency
Pesticides And
Toxic Substances
(TS 793)
EPA 560'7-90-006
August 1990
Instructions For Reporting For
The Partial Updating Of The
TSCA Chemical Inventory
Data Base
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Instructions for Reporting for the Partial Updating
of the TSCA Chemical Inventory Data Base
U.S. Environmental Protection Agency
Office of Toxic Substances
Washington, DC 20460
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NEW IN 1990
The 1990 reporting instructions incorporate the following changes
from 1986 instructions:
Companies report using a revised reporting form, which is
readable by optical character recognition scanners. Note,
however, that the information to be reported has not changed
from 1986 requirements.
Companies may now report using floppy diskettes, as well as
computer tape. In addition, the electronic reporting format
has changed, and there is no minimum number of chemical
substances required for reporting electronically.
A 1990 Supplement to the TSCA Inventory has been published,
and the computer tape version of the Inventory has been
updated.
An appendix to the instructions lists chemical substances
regulated under sections 4, 5(a)(2), 5(b)(4), or 6 of TSCA.
This list has been updated to include recent regulatory
actions.
Addresses and telephone numbers for contacting the Agency have
been updated.
Information requirements when requesting a search of the
Master Inventory File have been reduced.
Chemical substances whose identities are confidential may now
be reported on the same reporting form (or diskette/tape) as
non-confidential chemical substances.
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INSTRUCTIONS FOR REPORTING FOR THE PARTIAL UPDATING
OF THE TSCA CHEMICAL INVENTORY DATA BASE
(INVENTORY UPDATE RULE)
I. INTRODUCTION
The Environmental Protection Agency (EPA) in 1986 promulgated
a rule for the partial updating of the TSCA Chemical Inventory data
base, often referred to as the Inventory Update Rule. The rule
requires manufacturers and importers of selected chemical
substances included on the TSCA Chemical Substance Inventory to
report current data on the production volume, plant site, and site-
limited status of these substances. The rule was promulgated under
the authority of section 8(a) of the Toxic Substances Control Act
(TSCA), and is codified in Subpart B of Part 710 of Title 40 of the
Code of Federal Regulations (40 CFR Part 710). A technical
amendment to the rule, affecting only the reporting form and type
of magnetic media for electronic reporting, was published in the
Federal Register in August 1990.
Reporting under the Inventory Update Rule takes place at four
year intervals which began in 1986. These instructions pertain to
reporting during 1990.
This booklet provides detailed instructions and examples to
assist manufacturers and importers in reporting under the Inventory
Update Rule. These instructions, however, are not a substitute for
the rule. Manufacturers and importers of chemical substances
should carefully review the Inventory Update Rule to determine
whether they are subject to its reporting requirements and what
information is to be reported.
Persons reporting under the Inventory Update Rule should have
a thorough understanding of the scope and organization of the TSCA
Chemical Substance Inventory and of the criteria used to determine
whether a substance belongs on the Inventory. Information on the
scope and organization of the Inventory can be found in the
introductory pages of the 1985 edition of the Inventory and in the
1990 Supplement to the Inventory. Subpart A of 40 CFR Part 710
prescribes criteria for inclusion of a substance on the Inventory.
See section V below for instructions on how to obtain copies
of the Inventory and of TSCA regulations.
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II. DETERMINING THE SUBSTANCES FOR WHICH YOU MUST REPORT
To ascertain your reporting obligations, you must make two
determinations for each chemical substance that you manufacture in
the United States or import into the United States:
A) Is the substance reportable under the Inventory Update
Rule?
B) Are you a manufacturer or importer who is required to
report that substance?
A. Reportable substances.
To be reportable under the Inventory Update Rule, a chemical
substance must meet two requirements:
1) The substance must be on the TSCA Chemical Substance
Inventory as of August 25, 1990; and
2) The substance must not be of a type exempt from reporting
under the Inventory Update Rule.
1. Inventory substances. The TSCA Chemical Substance
Inventory is a list of chemical substances in commerce in the
United States. The Inventory was originally compiled from reports
submitted by manufacturers, importers and processors in 1978 and
1979. New chemical substances are added to the Inventory when
companies who have submitted Premanufacture Notifications (PMNs)
or Polymer Exemption Applications to EPA under section 5 of TSCA
notify the Agency that manufacture or import of the chemical
substance has commenced.
EPA keeps a Master Inventory File, which is the authoritative
list all the eligible chemical substances which have been reported
to EPA for inclusion in the Inventory. EPA also makes available
a public version of the Inventory, both in printed and computer-
readable form. This public version does not contain the specific
identities of chemical substances whose identities are confidential
business information (CBI). However, the printed version does
contain generic chemical names for these CBI chemical substances.
The public version of the Inventory has been updated several times.
The most complete edition of the printed Inventory was published
in 1985, and a 1990 supplement to the 1985 edition is now
available. The computer-readable version is current as of December
1988. See section V, below, for information on obtaining copies
of the public version of the Inventory.
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2. How to determine whether a chemical substance is listed
on the Inventory. Many companies have already determined that
the substances they manufacture or import are on the Inventory.
You may have been able to make such a determination if:
you have located the substance in a previous edition of
the public Inventory;
you reported the substance to EPA under the Inventory
reporting rule in 1978 or 1979 or as an Inventory
correction;
in response to a PMN, Test Market Exemption Application,
bona fide request, or other communication the Agency has
informed you that the substance is on the Inventory; or
you have submitted a Notice of Commencement of
manufacture or import for a PMN substance.
If you do not already know whether a substance you manufacture
or import is on the Inventory, you should consult a copy of the
latest public version of the Inventory (see section V, below, for
instructions on how to obtain a copy). The printed Inventory
provides detailed information on the organization of the Inventory
and on how substances are named and listed.
Several commercial databases have incorporated the public
version of the Inventory (which does not include substances with
confidential identities) and indicate whether a given chemical
substance is included on the Inventory. EPA can guarantee neither
the currency nor the accuracy of the information on these
databases; however, there is no penalty for reporting a substance
which is not required to be reported.
If at this point you know that your substances are on the
Inventory, you may proceed to section II.A.2. to determine whether
they are of a type exempt from reporting under the Inventory Update
Rule.
If aftar having checked the above sources you are still
uncertain as to whether a chemical substance is listed on the
Inventory, you should write EPA at the following address:
Document Processing Center (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Room E-105
ATTN: Inventory Update Rule Bonafide
Your letter is a request that EPA search the Master Inventory
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File, including confidential substances, to determine whether the
substance is listed. You must substantiate the fact that you are
actually manufacturing or importing the substance in question by
providing the following information:
(1) company identification, address, and telephone number;
(2) the specific chemical identity of the substance,
preferably a Chemical Abstracts Service Preferred or
Index Name, a Chemical Abstracts Service Registry Number
(if available), and a structural diagram (if available);
(3) a statement signed by a company officer that your company
is manufacturing and/or importing the chemical substance
for commercial purposes;
(4) a statement signed by a company officer that your company
is requesting this search pursuant to the Inventory
Update Rule; and
(5) an elemental analysis of the substance.
You may claim information in your letter as confidential by
circling or bracketing the text to be protected and marking
"CONFIDENTIAL" on each page containing confidential information.
Failure to so mark this information may result in EPA making the
information available to the public without further notice to you.
Note that this procedure is similar but not identical to EPA's
bona fide procedure codified in 40 CFR §710.7(g) and §720.25(b).
If you need a search of the Master Inventory File to determine
whether you are required to file a Premanufacture Notification, you
must follow the procedures codified in those sections.
If you are an importer and cannot provide all of the required
information because your foreign manufacturer/supplier is
maintaining it is confidential, the manufacturer/supplier can send
the information directly to EPA.
Because searches of the Master Inventory File require a
considerable amount of time to process you are urged to request
such a search only if your search of the public version of the
Inventory,- commercial databases, and your company's records fails
to resolve your question. Moreover, if your request is not
received prior to October 25, 1990, EPA cannot guarantee that you
will receive a response in time for you to complete the reporting
form before the end of the reporting period.
3. Excluded substances. Four categories of substances,
though included on the Inventory, are largely excluded from
reporting under the Inventory Update Rule. These categories are
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polymers, inorganic substances, microorganisms, and naturally
occurring substances. Refer to section 710.26 of the Inventory
Update Rule and to the preamble of the June 12, 1986 Federal
Register notice (51 FR 21438) announcing the rule for precise
definitions of these categories.
The Inventory Update Rule definition of polymer is
sufficiently broad to include virtually all those substances that
are generally considered polymers. These include polysaccharides
such as agar and gums, and all classes of proteins, enzymatic or
structural. However, substances which result from hydrolysis,
depolymerization, or chemical modification of polymers such that
the final products are no longer polymeric (e.g., a mixture of
amino acids which is the result of hydrolysis of a polypeptide)
are not considered to be polymers, and must be reported if not
otherwise excluded. For reporting purposes, salts of polymers are
also considered to be polymers.
a. Determining whether a substance is excluded. To assist
identification of excluded substances, most of these substances
are labelled in the printed and computer-readable versions of the
Inventory with an "XU" flag. However, due to difficulties in
developing a computer algorithm for identifying all such substances
in the Inventory, EPA was not able to flag all excluded substances.
For example, inorganic substances and biopolymers found in the UVCB
Index section of the public Inventory (chemical substances of
unknown or variable composition, complex reaction products, and
biological materials) are frequently not labelled with an XU flag.
If a substance does not bear an XU flag and section 710.26 of
the Inventory Update Rule does not provide sufficient guidance to
determine whether the substance is excluded, you may request
assistance from EPA (see section VI, below, for inquiries). In
addition, the following substances, though not flagged with the XU
designation, nonetheless qualify as inorganic substances:
Name CAS Number
Carbon black 1333-86-4
Carbon 7440-44-0
Graphite 7782-42-5
Charcoal 16291-96-6
b. When an excluded substance must still be reported. With
the exception of naturally occurring substances, a chemical
substance which falls into one of the excluded categories must
still be reported if it is the subject of a rule proposed or
promulgated under section 4, 5(a)(2), 5(b)(4), or 6 of TSCA, of an
order issued under section 5(e) or 5(f), or of relief which has
been granted under a civil action under section 5 or 7. A list of
all substances which fall into one of these categories is contained
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in an appendix at the back of these instructions.
B. Determining whether vou are a manufacturer or importer who is
required to report a substance.
Even if you manufacture or import a substance reportable under
the Inventory Update Rule you may be exempt from the reporting
requirements for that substance. Questions relevant to whether you
must report include:
1. Did you manufacture or import 10,000 pounds (4,540
kilograms) or more of the reportable substance at any
single site during the corporate fiscal year immediately
preceding the reporting period?
2. Do you qualify as a small manufacturer with respect to
the substance?
3. Did you manufacture or import the reportable substance
under circumstances which do not require reporting?
1. Manufacture or import of 10.000 pounds or more.
a. Manufacturers and Importers. Reporting for the Inventory
Update Rule is done by individual site of manufacture or by the
organizational site which controls importation. For the purposes
of the following discussion, manufacturers and importers are
treated separately.
Manufacturers. A manufacturer is defined in 40 CFR §710.3(o).
Note that a manufacturer creates a substance through a chemical
reaction. Processors, formulators, and distributors do not qualify
as manufacturers so long as they do not create the substance
through a chemical reaction.
Importers. The site of importation is defined in section
710.28 (c) of the Inventory Update Rule as the site of the operating
unit which is directly responsible for importing the substance and
which controls the import transaction. In some cases this may be
the site of your headquarters, in others a specific plant site or
a broker.
Importers under TSCA are defined in 40 CFR §704.3 and
§710.2(1). Although for a given substance that your company is
importing at a given site more than one person may meet the
criteria in sections 704.3 and 710.2(1), only one should report.
b. Meeting the 10.000 pound annual production volume threshold.
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Reporting is required for a chemical substance only if you
manufactured or imported 10,000 pounds (4,540 kilograms) or more
of the substance at any single site during the corporate fiscal
year immediately preceding the reporting period (see section
III.B., below, for more information about fiscal year). Moreover,
if during the year you manufactured 10,000 Ibs. or more of the
substance at some sites and less than 10,000 Ibs. at other sites,
you need report the substance only for those sites at which you
manufactured or imported 10,000 Ibs. or more.
Companies that both manufacture and import the same substance.
Such companies should add the manufacturing and importation volume
at each site (see above to determine site of importation) to
determine whether the 10,000 pound threshold has been met. For
example, if you manufacture 5,000 pounds of a reportable substance
and import 6,000 pounds, you should report.
Substances in a mixture. Although mixtures (defined in 40
CFR §710.2(q)) are not reportable, the chemical substances of which
a mixture is comprised are reportable. If you manufacture the
substances as part of a mixture, you must determine for each
substance in the mixture whether the production volume was over
10,000 pounds. Similarly, if you import a mixture you must
determine for each substance in the mixture whether its importation
volume was 10,000 pounds or more. Note that a person who creates
a mixture by combining existing substances without a chemical
reaction is not a manufacturer of those substances and therefore
does not report under the Inventory Update Rule.
Recordkeepinq requirement. Even if you manufacture/import
less than 10,000 pounds of a reportable substance at a site, you
must maintain records documenting that fact (see section IV.G.
below).
2. Small Manufacturers. (For the purposes of the following
discussion, the term "manufacturers" refers to both manufacturers
and importers.) Small manufacturers are usually exempt from
reporting under the Inventory Update Rule (but see below for a
discussion of when small manufacturers are not exempt). You
qualify as a small manufacturer if you meet either one of the
following tests:
1) If your total annual sales, combined with those of your
parent company, domestic or foreign (if any), do not
exceed $4 million, regardless of annual production volume
you qualify as a small manufacturer.
2) if your total annual sales, combined with those of your
parent company, domestic or foreign (if any), are between
$4 million and $40 million, you qualify as a small
manufacturer with respect to a particular substance for
those plant sites at which the annual production volume
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of the substance does not exceed 100,000 Ibs. If the
annual production volume of the substance at any of your
sites is over 100,000 Ibs., you are required to report
only for those sites. Note that it is possible to
qualify as a small manufacturer with respect to some
substances and not others, or some plant sites and not
others.
See 40 CFR §704.3 for a more complete discussion of the small
manufacturer exemption.
When a small manufacturer must still report. Even if you
qualify as a small manufacturer you must still report if you
produced 10,000 Ibs. or more of a reportable substance which is
the subject of (1) a rule proposed or promulgated under section 4,
5(b)(4), or 6 of TSCA, (2) an order under section 5(e), or (3)
relief granted under a civil action under section 5 or 7. A list
of all substances which fall into one of these categories is
contained in the appendix.
3. Additional reporting exemptions. Persons who manufacture
or import reportable substances under the following circumstances
are not required to report for those substances under the Inventory
Update Rule:
a. The chemical substance is manufactured or imported solely
in small quantities for research and development. NOTE:
The preamble of the technical amendment to the rule makes
a call for comments on this exemption.
b. The chemical substance is imported as part of an article.
c. The chemical substance is manufactured as an impurity,
byproduct, or non-isolated intermediate, or in a manner
incidental to another operation or upon end use of
another substance or mixture, as described in 40 CFR
§720.30(g) and (h) (see 48 Fed. Reg. 21746, May 13,
1983).
d. All the information required by the Inventory Update Rule
was reported to EPA pursuant to a rule under section 8 (a)
of TSCA between August 25, 1989 and August 24, 1990.
Articles. An article is defined in 40 CFR §710.2 (f) as "a
manufactured item (1) which is formed to a specific shape or design
during manufacture, (2) which has end use function(s) dependent in
whole or in part upon its shape or design during end use, and (3)
which has either no change of chemical composition during its end
use or only those changes resulting in compositions which have no
commercial purpose separate from that of the article and that may
occur as described in section 710.4(d)(5), except that fluids and
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particles are not considered articles regardless of shape or
design."
EPA considers imported items as articles if they are
manufactured in a specific shape or design for a particular end
use application, and this design is maintained as an essential
feature in the finished product. Thus, materials such as metal or
plastic sheets, wire, coated fabric, rolled carpet, sheets of
plywood and other similar materials will be viewed as articles by
EPA, even if, for example, subsequent to import they are rolled or
drawn thinner, cut, printed, laminated, or thermoformed, so long
as they meet the above criteria. Substances which are part of such
articles are not subject to reporting under the Inventory Update
Rule.
If an item is manufactured in a particular shape for the
purpose of shipping convenience and the shape has no function in
the end use, it would not be considered an article. Thus, chemical
substances which are part of items such as metal ingots, billets,
and blooms are subject to reporting under the Inventory Update
Rule.
Duplicative reporting unnecessary. If between August 25, 1989
and August 24, 1990 you submitted the information required by the
Inventory Update Rule in response to another rule promulgated under
section 8(a) of TSCA (e.g. the Preliminary Assessment Information
Rule, 40 CFR §712, Subpart B, or the Comprehensive Assessment
Information Rule, 40 CFR §704, Subpart D) , you are not required to
report under the Inventory Update Rule for the same substance
during 1990.
C. DecisionmakincT flow chart.
The following flow chart summarizes the questions which must
be answered to determine your reporting obligations for a
particular substance. (For simplicity's sake, not all reporting
exemptions are included in the flow chart.)
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REPORTING OBLIGATIONS FLOW CHART
Is this substance listed
on the TSCA Chemical Inventory
NO
YES
Is this substance a
polymer, inorganic substance,
microorganism, or
naturally occurring?
NO
YES
Is the substance
subject to a
special regulatory
action under TSCA?
YES
Did you manufacture or import
10,000 Ibs. or more per year
at a single site?
NO
YES
Are you a small manufacturer
for this substance?
NO
YES
Is the substance
subject to a
special regulatory
action under TSCA?
YES
Did you manufacture or import
the chemical substance under circumstances
for which reporting is not required?
YES
You need not
report
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D. Manufacture or importation of chemical substances subject to
TSCA but not included on the Inventory.
When checking the chemical substances you manufacture or
import against the TSCA Chemical Substances Inventory you may
discover that you are manufacturing or importing substances which
are not on the Inventory but which should have been reported to
EPA and never were. Such manufacture or importation is in
violation of section 15 of TSCA and could subject you to
administrative or criminal penalties.
If you find that you have or may have manufactured or imported
chemical substances in violation of TSCA, you should contact the
Agency at the following address:
Director, Compliance Division
Office of Compliance Monitoring (EN-342)
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Attn: Document Control Officer
Information in your letter may be claimed as confidential by
circling or bracketing the text to be protected and marking the
page, "CONFIDENTIAL." Failure to so mark this information may
result in EPA making the information available to the public
without further notice to you.
Significant reductions in penalties are given for persons
voluntarily disclosing violations. Note, however, that continued
manufacture or importation of such chemical substances remains
illegal even after you have contacted the Agency, until the
requirements of TSCA have been met.
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III. WHEN YOU MUST REPORT
The Inventory Update Rule establishes reporting periods
every four years. The first reporting period was during 1986; the
second is during 1990. A reporting period serves two functions:
A) It is a 120-day period during which reports for the
Inventory Update Rule must be filed.
B) It is used to determine the applicable fiscal year for
calculating annual production volume.
A. You must report during the 120-dav reporting period.
The next reporting period begins August 25, 1990 and ends
December 23, 1990. All submissions must be postmarked no later
than December 23. If you are required to report (see section II.,
above), failure to file your report during this period is a
violation of section 15 of TSCA.
Persons requesting searches of the Master Inventory File (see
section II.A.I. above) must make their requests at least 60 days
prior to the close of the reporting period. If you have made your
request in time you will be allowed 15 business days from the date
of receipt of EPA's answer or until the end of the reporting
period, whichever is later, to submit the report for the substance
which was searched. Any other reports received after the end of
the reporting period will be considered late and will be subject
to enforcement action.
The next reporting period after 1990 will be August 25, 1994
to December 23, 1994; subsequent reporting will occur at four-year
intervals, beginning on August 25. Each reporting period lasts 120
days. EPA will publish reminder notices before these reporting
periods begin.
B. Determine annual production using the reporting period as a
reference point.
To determine whether you manufactured or imported 10,000 Ibs.
or more of a reportable substance at a site, you must determine
your total manufacture/import volume for your last corporate fiscal
year which ends prior to August 25, 1990. For example, someone
whose fiscal year is the calendar year would determine manufacture
or import volume for the period January 1, 1989 - December 31,
1989, while someone whose fiscal year is July 1 to June 30 would
determine manufacture or import volume for the period July 1, 1989
to June 30, 1990.
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Note that even though you may be exempt from reporting a
chemical substance during one reporting period because you
manufactured or imported less than 10,000 Ibs. during the
applicable fiscal year, you may be required to report it during
the next reporting period if during the next applicable fiscal year
the production volume increases to 10,000 Ibs. or more.
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IV. HOW TO REPORT
A. Form of submission.
Information reported for the Inventory Update Rule must be
submitted either on Form U or by magnetic media (see subsection
C., below). Separate forms are required for each plant site.
For the 1990 reporting period, Form U has been made readable
by Optical Character Recognition (OCR) technology. OCR is an
electronic data entry means that will help ensure that the
information submitted for the IUR will be correctly and quickly
entered into the data base. In OCR, a light beam is passed over
the paper, and the information on the page is 'recognized1 as text.
This process requires that the text be typed (or written very
clearly, in capital letters), so that the machine can properly
recognize the characters on the form. The form itself is printed
in a red 'drop-out1 color that the OCR machine cannot see.
B. Confidentiality.
Information submitted to EPA under the Inventory Update Rule
may be claimed as confidential business information (CBI), by
checking the appropriate "CBI" boxes on Form U.
You may assert a CBI claim for the specific identity of a
chemical substance only if EPA treats that substance identity as
confidential on the Inventory as of the time your report is
submitted (i.e., the substance is not on the public Inventory).
Both confidential and non-confidential substances may be reported
on the same form, and confidential substances may be included in
computer tape and floppy diskette submissions (this is a change
from the 1986 reporting instructions).
If you are manufacturing or importing a chemical substance
which is currently listed on the Inventory as confidential you are
encouraged not to assert confidentiality claims if circumstances
are now such that confidentiality is no longer necessary. If you
report a previously confidential substance as non-confidential (see
subsection C, below, for specific instructions) that substance will
subsequently be listed on the Inventory as non-confidential.
No CBI claim for chemical identity will be accepted unless
accompanied by a separate written substantiation for each chemical
substance claimed as CBI, with detailed answers to the eleven
questions prescribed in section 710.38 of the Inventory Update
Rule, and repeated below. The answers must be complete and
specific to the chemical substance in question. The substantiation
must be dated and signed by an officer of the company. If the
required substantiation does not accompany your Form U, EPA may
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make the chemical identities reported on the form available to the
public without further notice to you.
Information in a substantiation may itself be claimed as CBI
by circling or bracketing the text you wish to claim as
confidential and marking the page "CONFIDENTIAL." Failure to so
mark this information may result in EPA making the information
available to the public without further notice to you.
The eleven questions to be answered in the substantiation are:
(1) What harmful effects to your competitive position, if
any, do you think would result from the identity of the chemical
substance being disclosed in connection with reporting under this
subpart?
(2) How long should confidential treatment be given? Until
a specific date, the occurrence of a specific event, or
permanently? Why?
(3) Has the chemical substance been patented? If so, have
you granted licenses to others with respect to the patent as it
applies to the chemical substance? If the chemical substance has
been patented and therefore disclosed through the patent, why
should it be treated as confidential?
(4) Has the identity of the chemical substance been kept
confidential to the extent that your competitors do not know it is
being manufactured or imported for a commercial purpose by anyone?
(5) Is the fact that the chemical substance is being
manufactured or imported for a commercial purpose publicly
available, for example in technical journals, libraries, or State,
local, or Federal agency public files?
(6) What measures have you taken to prevent undesired
disclosure of the fact that this chemical substance is being
manufactured or imported for a commercial purpose?
(7) To what extent has the fact that this chemical substance
is manufactured or imported for commercial purposes been revealed
to others? What precautions have been taken regarding these
disclosures? Have there been public disclosures or disclosures to
competitors?
(8) Does this particular chemical substance leave the site
of manufacture in any form, as product, effluent, emission, etc.?
If so, what measures have you taken to guard against discovery of
its identity?
(9) If the chemical substance leaves the site in a product
that is available to the public or your competitors, can the
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substance be identified by analysis of the product?
(10) For what purpose do you manufacture or import the
substance?
(11) Has EPA, another Federal agency, or any Federal court
made any pertinent confidentiality determinations regarding this
chemical substance? If so, please attach copies of such
determinations.
C. Completing Form U.
1. Report only using original copies of Form U.
Each copy of Form U bears an individual report number, and is
readable by optical character recognition (OCR) technology- Do not
report on a photocopy of Form U, because it will not have a unique
report number and will not be OCR-readable. See section V, below,
for obtaining copies of Form U.
2. Certification Statement.
a. Signature. The certification statement must be signed by
an officer of the company or a person with managerial
responsibility for the plant site reporting. This statement
certifies to the truth and accuracy of the information reported
and of the confidentiality claims made on the form (see the back
of Form U for details) . Note that by certifying the truth and
accuracy of the information on the form, you acknowledge that any
knowingly false or misleading statement may be punishable by fine
or imprisonment or both under applicable law. Sign in black pen
to ensure that the form bears a legible signature which can be
archived.
b. Date. Enter the month, day, and year that the form was
signed.
c. Name and Title. Enter the name and title of the person
who signed the certification statement.
3. Technical Contact and Company Information.
a. Technical Contact Name. Enter the name of the person whom
EPA may contact for clarification of the information submitted on
Form U. The technical contact need not be located at the site for
which information is reported, but should be located in the U.S.
If you wish to identify more than one person as a technical
contact, please include the extra name(s) in a separate cover
letter.
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b. Company Name. Address I. Address II. Use these three
lines to enter the company name and street address of the technical
contact. Post office box numbers are acceptable if also
accompanied by a street address.
c. CBI. Checking this box asserts a confidentiality claim
for the link between your company and the chemical substances
reported on the form. Checking other CBI boxes on the form will
not protect this link. If there are some substances whose
connection to your company you do not require to be kept as
confidential, report those substances on a separate form on which
the CBI box in Block II is not checked.
4. Plant Site Information.
Reporting under the Inventory Update Rule is done by
individual site. Therefore all the substances reported on one form
must be manufactured/imported at the same site. Enter the name and
street address of that site and its Dun & Bradstreet number here.
a. Dun & Bradstreet Number. Dun & Bradstreet gives separate
numbers to plant sites and parent companies; make sure that the
number you provide EPA belongs to the individual plant site for
which you are reporting. If the plant site does not have a Dun &
Bradstreet number, a Dun & Bradstreet number assignment can be
requested from your local office of Dun & Bradstreet. Dun &
Bradstreet does not charge for this service, and does not require
that you disclose sensitive financial information in order to get
a number.
b. Address. A street address, including Zip code, must be
reported. Post office box numbers are not acceptable. If the site
does not have a street address, please provide what descriptive
site information you have, including the Zip code.
See block G, below, concerning CBI claims for the link between
plant site identity and individual substances.
5. Chemical Substance Identity/Activity/Confidentiality.
a. Line Number. This part of the form is divided into ten
lines to allow reporting of up to ten chemical substances per form.
If the chemical identity will not fit on one line, you may use more
than one line to report a single chemical substance.
-------
- 18 -
SAMPLE FORM*
(Chemical Substance Information Only)
CHEMICAL SUBSTANCE IDENTITY/ACTIVITY/CONFIDENTIALITY ^
A. a Identifying Number
1
29735
H.SDecme Chemical Name
ID CODE
C. (Setback of form)
D.M1^ CBI
E. umn»d CBI 1
a n|
Production volume
F. In Pound! CBI
11.000 1 Ixl
_, Plant Chemical
G. C8I CBI
1— Nanthalenamine . 4— f ( 2-bromo— 4.6— dlnitro— nhenvllaznl— N— ethvl—
A. B. Identifying Number
2
52-8500145 1
H. Specific Chemical Name
C. (Sea tuck of form)
cn
P.1*?? CBI
_ Slta
E. Umttad CBI
cn n
Production volume
F. In Poundt CBI
24.000 1 1
. Plant Ctwnfcal
U CBI C8I
D H
1.2-Ethanediaminc. N-ethvl-N1 .N'-dimcthvl- 1
A. B. Identifying Number
3
1 33649773
H. Specific Chemical Name
ID CODE
C. (SMbeckol lorm)
O.'ffff CB.
_ Site
E.Umtod CBI
Production VokinM
F. In Poumta CBI
1 43.000 1 Ixt
„ Plant ClMmlul
G. CBI CBI
H D
1 1 .3— Prooanediaminium. N.N.N.N' .N1 .— nenta— methvl— N'— T3— f (tetramethvlnonvl^oxvlnroDvll—
A. a Identifying Number
4
i i
H. Specific Chemical Name
_ ID CODE
C. (Sea back ol form)
o.'syr CB.
CD D
Slta
E. Umttad CBI
n n
_ Production volume
F. In Pound! CBI
[ |
_ Plant Chemical
°-Q a
1 dichloride 1
A. a Identifying Number
5j
1 53437422
H. Specific Chemical Name
_ ID CODE
C. ISea back of form)
IX«ff CB.
E.Umted CBI
1 1 D
F. mPoundiUm* CBI
20,000 1 1
„ Plant Charnfcal
G CBI CBI
'B n
Benzenamine , 4-heptvl-N-phenvl
A. a Identifying Number
6
P-85-131 I
H. Specific Chemical Name
_ DCOOE
C. ISeibeekol form)
O-'SKfl CBI
E. Limited CBI
1 1 D
F. PraftpSmd»U™ CBI
67.000 1 Ixl
Q.W ""a-1
Ely 1
IA 1
2-Naphthalenecarboxvlic acid, 3-hvdroxv-4-f (2-methoxv-4-nitroDhenvl)azol-
A. a Identifying Number
7
T-85-35
H. Specific Chemical Name
_ ID CODE
C. (Seebjckof loon)
O.'ffyi CBI
|M| D
E.ujjjjtod CBI
_ Production Volume
F. In Pound! CBI
1 170,000 I I
_ Plant Chamleal
Gn a
Benzenamine, 4-heptyl-N-phenyl 1
A. a Identifying Number
8
5165-81-1
H. Specific Chemical Name
_ DCOOE
C. (SeibKkof form)
D."^ CBI
on n
EQB|
2-Naohth-o-ansidine . 4 ' -chloro-3-hvdroxv-5 ' -methvl-
A. a Identifying Number
9
14679997/21
H. Specific Chemical Nam*
C. (Seebeckot (omi)
D.*SW CB.
E. LMted CBI 1
Methacrylic acid, 2-ethvlbutvl ester
A. . a Identifying Number
10
H. Specific Chemical Name
_ DCOOE
C IS*, beck of term)
1 1
D.'ffff! CB.
i i n
E. Limit*) CBI
czi n
1
_ Production Volume
F. In Pound! CBI
1 93.000 Ixl
_ Plant Chemical
G. CBI CBI
D D
_ Production volume
F. In Pound! CBI
120.000 i n
_ Plant Chemical
G. CBI CBI
n n
1
Production volume
F. In Pound! CBI
1 1
_ Plant Chemical
G. CBI CBI
D D
-I
The substances on this sample form are listed as confidential
only for purposes of illustration.
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- 19 -
_b. CAS Registry or other Identifying Number (block B) . Every
chemical substance reported on Form U must be accompanied by its
Chemical Abstracts Service (CAS) Registry Number (see line 8 of
sample form) or other identifying number. The printed edition of
the Inventory contains detailed instructions on how to locate the
CAS Registry Number for a substance listed therein. When you
report a CAS Registry Number, please verify that the number you are
reporting is the correct number for your substance.
You may be unable to find a CAS Registry Number in the public
Inventory either because the substance is listed as confidential
(in which case the specific identity is not present and the
chemical substance has an Accession Number rather than a CAS
Registry Number) or because the substance was not on the Inventory
as of the date of printing. If this is the case you may use one
of the following identifying numbers:
(1) EPA Accession Number;
(2) Original Inventory Report Form Number;
(3) Premanufacture Notice Number;
(4) Bona Fide Document Control Number; or
(5) Test Market Exemption Application Number.
Use one of the above identifying numbers only if you cannot locate
the CAS Registry Number for a substance or you are uncertain
whether the CAS Registry Number you have located is correct. The
CAS Registry number is the preferred identifier for chemical
substances reported.
(1) EPA Accession Number. (See line 1 of sample form.) If
the identity of a chemical substance on the Inventory is
confidential, the printed Inventory lists an Accession Number for
that substance and uses a generic name rather than a specific
identity. You may use an Accession Number as an identifying number
only if EPA has communicated the appropriate Accession Number to
you, e.g., following your report for the original Inventory in 1978
or 1979, or following commencement of manufacture or import of a
substance for which you filed a premanufacture notification.
Because a generic name can pertain to more than one substance, if
you use a generic chemical identity in the printed Inventory to
determine what the Accession Number is you may possibly report for
the wrong substance. An Accession Number may not be used for a
non-confidential chemical substance. A typical Accession Number
would be "29735".
(2) Original Inventory Report Number. In 1978 and 1979,
submissions for the Initial and Revised TSCA Chemical Substance
Inventories were filed on one of four forms, "A", "B", "C", or "E".
You may use an original Inventory report form number as an
identifying number. A typical Original Inventory Report Number
would be "32345678".
-------
- 20 -
Since both "A" and "B" forms allowed reporting of several
chemical substances, EPA needs to know the line number on the
original "A" or "B" form that the substance occupied. If you use
an original Inventory report number from an "A" or "B" form (these
form numbers begin with "1M or "2") you must therefore include the
original line number for that chemical substance, separated from
the form number by a slash. For example, if a chemical substance
had been reported on line number 3 of form 12345678, report the
identification number as "12345678/3" (see line 9 on sample form).
If you originally reported on a "C" or "E" form (form numbers
beginning with "3" or "5") , do not include a slash or a line number
(see line 3 on sample form).
If you submitted a correction to an original Inventory report,
use the number of the form on which you submitted the correction.
(3) Premanufacture Notification Number. (See line 6 of
sample form.) If you filed a Premanufacture Notification (PMN)
for a substance which is now reportable under the Inventory Update
Rule, and that PMN was assigned a PMN number, you may use that as
an identifying number. A typical PMN number would be "P-85-243".
Please be aware that a chemical substance which has a PMN
number is not automatically reportable under the Inventory Update
Rule; a PMN substance is included on the Inventory only if a Notice
of Commencement was received for the substance.
(4) Bona Fide Request Control Number. (See line 2 of
sample form.) If you filed a Bona Fide Intent to Manufacture or
Import a chemical substance which is now reportable under the
Inventory Update Rule (see 40 CFR §710.7(g) or §720.25(b)), you
may use the document control number assigned that submission by
EPA as an identifying number. A typical Bona Fide document control
number would be "52-8500287".
The fact that you filed a Bona Fide for a substance does not
necessarily mean that the substance is on the Inventory and
reportable; you must have independent confirmation that the
substance is on the Inventory (e.g. in a communication from EPA).
(5) Test Market Exemption Application Number. (See line
7 of sample form.) If you filed a Test Market Exemption
Application (TMEA) for a substance which is now reportable under
the Inventory Update Rule, the number assigned by EPA to that
application may be used as an identifying number. A typical TMEA
number would be "T-85-27". You should use a TMEA number only if
you know that the chemical substance is on the Inventory (e.g. the
Agency told you so when you submitted the TMEA).
-------
- 21 -
Procedures for obtaining CAS Registry Numbers and Accession
Numbers from EPA when you previously reported the substance to the
Agency. If by one of the methods discussed in section II.A.,
above, you were able to determine that the substances you
manufacture are on the Inventory, you should already have
identifying numbers for them. If you do not know any of the above
identifying numbers for a substance you are unlikely to be certain
that the substance is on the Inventory. If this is the case you
should reread section II.A. Following the procedures in that
section should enable you to find an identifying number.
There may be some manufacturers or importers who reported for
the Inventory in 1978 or 1979 but no longer have the original
report forms. In this case you must request an identifying number
from EPA. Send a letter to the following address:
Document Processing Center (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Room E-105
ATTN: Inventory Update Rule
The letter must include the specific identity of the chemical
substance, must be signed by an officer of the company, and must
designate a technical contact (include name, title, address, and
telephone number). The structure of the substance, if available,
should also be provided. Note that this procedure can be used only
when you have previously reported the substance to the Agency; if
you need EPA to tell you whether the substance is on the Inventory
you must follow the procedures in section II.A.1., above.
Information on this letter may itself be claimed as
confidential by circling or bracketing the text to be protected
and marking the page "CONFIDENTIAL." Failure to so mark this
information may result in EPA making the information available to
the public without further notice to you.
EPA will release information in response to these letters only
to the company which originally submitted the information. If
company ownership has changed or the technical contact authorized
to receive confidential information has changed since you reported
the substance to EPA during 1978 - 1980, you must include a
notarized letter by an officer of the current surviving chemical
company certifying to the change and designating the new technical
contact.
EPA will send to the technical contact a CAS Registry Number
(if the substance is listed as non-confidential on the Inventory)
or an Accession Number (if the substance is confidential) .
-------
- 22 -
EPA will release CAS Registry Numbers or Accession Numbers in
response to these letters only for substances which are reportable
under the Inventory Update Rule. Your letter must be received by
November 12, 1990; otherwise the Agency cannot guarantee a response
in time for you to meet your reporting obligations.
c. A. B. C. F. P. or T Codes (block C) . Indicate in this
block the type of identifying number contained in block B, as
follows:
If the number you are Type this code
reporting in block B is a(n) in block C
Accession Number A
Bona Fide Number B
CAS Registry Number C
Original Inventory Report Number F
Premanufacture Notice (PMN) Number P
Test Market Exemption Application
(THEA) Number T
d. Specific Chemical Name (block H) . Enter the specific
chemical identity of the chemical substance you are reporting.
Chemical Abstracts Index or Preferred Names should be used if
available. For non-confidential substances, these names can be
found in either the printed or the computer-readable version of
the public Inventory. If such names are not available, you must
use nomenclature which completely and accurately describes the
chemical substance. If you need more than one line to type the
chemical name, continue the name in block H on the line below;
leave the rest of the blocks on the second line blank.
Trade names may not be used except where a trade name
describes a reactant which is part of the identity of a chemical
substance you are reporting, and your supplier will not disclose
to you the specific identity of the trade name reactant. Report
all such chemical substances on a separate form, entering the
specific identities of reactants where you know them and the trade
names where you do not. You must also submit along with Form U a
letter certifying that your supplier will not disclose to you the
specific identity of the trade name reactant and identifying the
supplier of each trade name reactant reported.
Information in this letter may be claimed as confidential by
circling or bracketing the text to be protected and marking the
-------
- 23 -
page, "CONFIDENTIAL." Failure to so mark this information may
result in EPA making the information available to the public
without further notice to you.
If you are an importer whose foreign supplier will not reveal
to you the identity of the substance you are reporting, follow the
procedures in subsection H., below.
If you are claiming the chemical identity as confidential,
check the Chemical CBI box in block G.
e. Activity; Manufacture or Import (block D) . If you
manufacture the substance, enter "M" in the space next to the CBI
box; enter "I" if you import the substance. If you both
manufacture and import the substance at the same site, use two
lines to report, one for each activity. Check the CBI box if you
wish to claim the nature of the activity (i.e., manufacture vs.
importation) as confidential for the substance. Claiming activity
as CBI does not protect the link between your company and the
substance; that will not be protected unless you check the CBI box
next to Company Name.
f. Site Limited (block El . If you manufacture the chemical
substance at the plant site identified in Block III and do not
distribute the chemical substance or any mixture containing that
substance outside the plant site for commercial purposes, enter "X"
in the space next to the CBI box. Otherwise leave the space blank.
(Note: an imported chemical substance cannot be reported as site-
limited.) If you wish to claim this information as confidential
for the substance, check the CBI box. You may claim the fact that
a substance is not site-limited as confidential, if appropriate.
g. Production Volume (block F). Enter your annual
manufacture volume or importing volume, in pounds, for the fiscal
year preceding the reporting period. If you both manufacture and
import a particular substance, report the manufacture and import
volumes separately, on two lines. The quantity should be reported
to at least two significant figures, and should be accurate to the
extent known or reasonably ascertainable by you (if the figure
reported is within ±10% of the actual value, it is acceptable for
purposes of the rule) . Production volumes must be reported in
numeric format ("2 million" is not acceptable). Abbreviations such
as M or K are not acceptable, and scientific notation may be used
only if the number would not otherwise fit in the box provided.
(Volumes reported in other than numeric format cannot be read by
the Agency's automated equipment.) If you wish to claim this
information as confidential for this substance, check the CBI box.
h. Plant site and Chemical CBI Claims (block G).
(1) Plant site CBI claim. If it is confidential as to which
of your plant sites manufactures/imports the substance, check the
-------
- 24 -
"Plant CBI11 box. Note that you may claim this connection as CBI
for some chemical substances while not making that claim for
others.
*
(2) Chemical identity CBI claim. The identity of a substance
which is listed as confidential on the TSCA Inventory may be
claimed as confidential by checking this box. EPA will not honor
a chemical identity CBI claim for a substance which is listed on
the non-confidential Inventory. Note that checking this box does
not protect the link between your company and the substance; it
only asserts a CBI claim for the specific identity of the
substance. If you wish to claim company identity as CBI, check the
CBI box next to Company Name.
D. Reporting by computer tape or floppy diskette.
1. General.
In 1986 submitters were offered the option of submitting
reports on computer tape. In 1990 the option has expanded to
include floppy diskettes. Two restrictions which were applicable
in 1986 no longer apply: 1) there is no longer a minimum number
of chemical substances required before you can report
electronically; and 2) substances whose specific identities are
confidential may now be reported electronically.
2. Copies of Form U required.
The tape or floppy diskette must be accompanied by a separate
copy of Form U for each plant site reported. On the written form
complete only the technical contact and company information
described on page 17. The remainder for the form should not be
filled in. In its place include a statement that the required
information is being submitted on tape or diskette, plus
tape/diskette identifier information (this should match the
information on the label affixed to the tape/diskette).
3. Tape/diskette formats and physical characteristics.
See document entitled Inventory Update Magnetic Media
Instructions (available from EPA; see page 30).
4. Information on individual chemical substances.
See instructions for completing Block IV in section C.,
above.
E. Sending forms and tapes or floppy diskettes to EPA.
Send the original form, along with any accompanying tapes or
floppy diskettes, to the following address:
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- 25 -
Document Processing Center (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Room E-105
ATTN: Inventory Update Rule
If you wish acknowledgement from EPA of receipt of your forms
and tapes/floppies, you must include a cover letter listing the
enclosed form numbers, as well as any tape reel numbers or diskette
identifiers, along with a request for acknowledgement.
F. Correcting errors in submissions for the original Inventory.
In reporting under the Inventory Update Rule you may find
that an error was made when you reported for the original Inventory
in 1978 or 1979. If that error falls into one of the following
categories:
1. the chemical identity originally reported was incomplete
or inaccurate;
2. an isolated intermediate occurring during the
manufacture of a substance previously reported for the
Inventory was not then recognized; or
3. EPA informed your company of a reporting error and
requested a correction from you, to which you did not
respond;
you should file an Inventory Correction, following the procedures
outlined in the Federal Register notice of July 29, 1980 (45 FR
50544). Be sure to reference the original Inventory report form
and line number (if appropriate) when you file a correction.
For copies of the Federal Register notice or further
assistance with an Inventory Correction, you may contact:
Document Processing Center (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Room E-105
ATTN: Inventory Update Rule
Telephone: 202-382-3527
Inventory Correction requests should be filed with your
copies of Form U. Note that Form U should report the chemical
substance you are actually manufacturing or importing and should
-------
- 26 -
reference the number of the correction form you submit.
The act of correcting errors in submissions to the Original
Inventory does not grant to the person making the correction
immunity from enforcement action for any possible violations of
the Original Inventory Reporting Rule.
G. Recordkeepinq requirements.
Persons subject to the Inventory Update Rule are required to
maintain records that document the information contained in their
submissions. These records must be kept for four years after the
end of the applicable reporting period. As long as the records are
maintained in a manner consistent with normal business practice,
you may determine their exact format. Required records include
those that show the production volume, plant site, and site-
limited status of each substance reported. If a substance is not
reported because its site-specific annual production is less than
10,000 pounds, only the site-specific production records for that
substance need to be kept. Persons who qualify as exempt small
manufacturers need to keep records only for those chemical
substances which they are required to report; however, in claiming
an exemption they bear the burden of documenting that they qualify
for the exemption.
H. Special instructions for importers and foreign suppliers.
This section applies to importers who do not know the
specific chemical identity of a substance because the foreign
supplier chooses to keep it confidential. If you are such an
importer, you are still responsible for ensuring that the
information is submitted to EPA. You may accomplish this by having
your foreign supplier complete some of the information on Form U,
as follows:
1. Include a cover letter with your submission, stating
the following: "The identifying numbers and specific
chemical identities for the substances on this form and
the technical contact will be submitted by our foreign
supplier."
2. Use a separate Form U for each foreign supplier who does
not inform you of the identity of the chemical
substances you are importing. Do not report by computer
tape or floppy diskette. Do not use the same report
form for substances whose specific identities you do
know.
3. Make a photocopy of a blank Form U before entering any
information on the form.
4. On the original copy, sign the certification statement,
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- 27 -
enter the technical contact and company information and
plant site information, and complete blocks D, E, F, and
G for each chemical substance. In block B, instead of
entering the identifying number, enter the trade name
or other designation by which you know each chemical
substance. Leave block C blank. Check the "Chemical
CBI" box in block H only if you wish to claim the
identities of the chemicals identified on the form as
confidential (you must answer the substantiation
questions in subsection B., above). Your foreign
supplier is responsible for his own CBI claim. Send
this copy to EPA.
5. On the photocopy of the blank form, enter only the plant
site information. Send this copy to your foreign
supplier.
6. The foreign supplier should enter technical contact-
company information on his copy (the technical contact
here should be the foreign supplier), complete blocks
B and C, and enter the appropriate specific chemical
identities in block H. Make sure that your supplier
understands which chemical identities belong with each
line number on Form U. If the foreign supplier wishes
to claim the chemical identities as confidential, the
supplier should check the "Confidential" box in column
d and submit a substantiation as described in subsection
B., above. The supplier should include with Form U a
letter stating that this information is being submitted
by a foreign supplier on behalf of an importer.
Information in the letter may be claimed as confidential
by circling or bracketing the text to be protected and
marking the page, "CONFIDENTIAL." Failure to so mark
this information may result in EPA making the
information available to the public without further
notice to the supplier. The supplier should then send
the form and letter to EPA.
Note that it is your responsibility to ensure that your
foreign supplier understands how to complete his copy of Form U
(including any relevant CBI claims) and that the supplier sends
the information to EPA by the end of the reporting period. If the
supplier fails to submit the information, your company may be found
to be in violation of TSCA.
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- 28 -
V. OBTAINING COPIES OF DOCUMENTS CITED IN THESE INSTRUCTIONS
A. Obtaining copies of TSCA regulations.
Copies of TSCA regulations can be obtained by contacting:
Environmental Assistance Division (TS-799)
Office of Toxic Substances
Environmental Protection Agency
Rm. E-543B
401 M St., SW.
Washington, D.C. 20460
(202) 554-1404
TDD: (202) 554-0551
B. Obtaining copies of the Inventory.
1. Obtaining copies of the printed editions of the
Inventory. Non-confidential Inventory listing can be found in TSCA
Chemical Substance Inventory; 1985 Edition. a complete version
of the non-confidential Inventory current as of July 1985, and in
TSCA Chemical Substance Inventory; 1990 Supplement, a supplement
to the 1985 edition current as of February 1, 1990. Copies may be
purchased from:
Superintendent of Documents
Government Printing Office
Washington, D.C. 20402
Order Desk: (202) 783-3238
The price for the 1985 edition is $161.00 in the U.S. and
Canada, $201.25 elsewhere; the price for the 1990 supplement is
$15.00 in the U.S., and $18.75 outside the U.S. GPO will also
accept orders by telephone; MasterCard and Visa are accepted.
Refer to stock number 055-000-00254-1 for the 1985 edition, and
055-000-00361-1 for the 1990 supplement. Please allow 4-6 weeks
for delivery (longer outside the U.S.).
2. Obtaining the Inventory in computer-readable form. The
Inventory is available in the form of three computer tapes. The
first tape lists the chemical substances by their Chemical
Abstracts Service (CAS) Registry Numbers, Index or Preferred
chemical names, and where appropriate, molecular formulas. An
alphabetical listing of chemical synonyms for the substances is
also included, as are "XU" flags for substances exempt from
reporting under the Inventory Update Rule (see section II.B.2.a.,
above). The listed synonyms include only those reported to EPA
for these substances (in contrast to the printed Inventory, which
also includes synonyms derived from CAS files). The tape contains
neither generic names nor Accession Numbers for substances with
confidential identities.
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- 29 -
The second tape contains plant site names and addresses and
Manufacturer Identification Numbers. The third tape contains
submitter identity information and production and import statistics
(from 1977 only). No confidential information appears on any of
these tapes. Copies of the documentation for the computer tapes
are included with the tapes. Each of the three tapes may be
ordered separately.
Ordering information for these tapes may be obtained by
contacting:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650
C. Obtaining copies of Form U.
Copies of Form U may be obtained from:
Document Processing Center (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Room E-105
ATTN: Inventory Update Rule
Telephone: (703) 534-1050
-------
- 30 -
VI. REQUESTING ASSISTANCE IN REPORTING
Should you need information on or assistance in the following
areas:
o determining your reporting obligations;
o the mechanics of completing Form U;
o reporting by computer tape or floppy diskette; or
o determining the status of forms/tapes/floppies you have
submitted to EPA;
you may write to or call the following address:
Document Processing Center (TS-790)
Office of Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Room E-105
ATTN: Inventory Update Rule
Telephone: 202-382-3591
-------
APPENDIX
CHEMICAL SUBSTANCES SUBJECT TO
PROPOSED OR FINAL TSCA RULES OR ORDERS
Following is a list of CAS Registry Numbers (for non-confidential
chemical substances) or Accession Numbers (for confidential
substances) of substances which are subject to proposed or final
rules or orders under TSCA sections 4, 5(a)(2), 5(b)(4), 5(e), 6,
and 7, as of February 1990 (see sections 710.26 and 710.29 of the
rule and pages 6 and 8 in these reporting instructions). If after
consulting this list you are uncertain as to the regulatory status
of a chemical substance, contact EPA at the address given on page
30 of these reporting instructions).
CAB
9O-OO-O
51-79-6
54-11-5
K*gul*
Ond«r TSCA
SactlonCmi
CAS
TSCA
89-63-4
92-B2-4
92-66-O
62-44-2
62-53-3
67-63-O
92-86-4
94-58-6
94-75-7
7O-3O-4
71-55-6
72-2O-8
72-57-1
74-87-3
74-93-1
75-38-7
75-44-5
75-56-9
94-82-6
95-48-7
95-50-1
95-51-2
95-B4-S
95-63-6
95-69-2
95-7O-5
95-76-1
95-77-2
95-8O-7
95-82-9
95-83-O
95-94-3
95-95-4
4/5(a)(2)
96-23-1
96-29-7
96-37-7
97-O2-9
97-63-2
98-82-8
98-86-2
98-87-3
98-95-3
99-09-2
99-28-5
99-29-6
4/S<*)<2)
99-3O-9
99-56-9
1OO-O1-6
100-O2-7
1O1-5S-3
101-77-9
103-85-5
1O4-76-7
1O6-4O-1
S(a)(2)
4
4
1O6-44-S
1O6-46-7
1O6-47-8
tequli
Under
MCA
5(a)(2)
4
4
1O8-31-6
108-39-4
1O8-42-9
122-O9-8
122-6O-1
123-31-9
-------
Appendix, Page 2
Dn<2)
4
4
5(2)
5<2)
4
4
4
5(a)(2)
29091-20-1
29761-21-5
32534-S1-9
2113-57-7
2136-89-2
2238-07-5
5<
>(2)
4
4
32536-52-O
34621-99-3
363S5-01-8
5<
s<«
a><2
2)
2425-79-8
2426-O8-6
2432-99-7
4
4
B(a)(2)
37853-59-1
37853-61-5
38954-75-5
2461-18-9
2528-36-1
2577-72-2
39156-41-7
41137-6 O-4
42389-3O-O
2687-25-4
2716-10-1
2716-12-3
47758-37-2
51160-97-5
51363-64-6
3O83-2S-8
3132-64-7
3236-71-3
S(a)(2)
5(a)<2)
5<«0
3288-58-2
3389-71-7
3531-19-9
5(a)(2)
52277-33-5
5S2O5-38-4
568O3-37-3
58965-66-5
6O466-61-7
61167-6O-O
5<2)
4
4
*<•)
3618-72-2
3648-2O-2
3663-23-8
3689-24-5
3772-94-9
4016-11-9
4O16-14-2
4162-45-2
417O-3O-3
62654-17-5
65879-44-9
65992-66-7
66422-95-5
67801-06-3
68O15-98-5
68239-8O-5
68239-82-7
68239-83-8
4
4
5
-------
Appendix, Page 3
CAS
Xaoulatad
Ondar TSCA
Saeticn<«>
Aocaaalon
Baoulatad
Undar TSCA
Accaaalon
Kaqulatad
Undar TSCA
Saofeionfal
116671-32-0
118270-87-4
119275-S3-S
119438-11-8
12B3O4-11-2
125*97-20-8
AoeaMlon
3O3O9
38585
41259
42741
43313
43993
44292
49435
49457
50567
52381
52676
53215
53862
55904
5<«O
Und«r TSCA
8*crtlon<«>
5(a)(2)
S(a)
5(a)(2)
S(a)(2)
5(a)(2)
S(a)(2)
S(a)(2)
S(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
5(a)(2)
»(a)(2)
56236
57397
58834
59531
59622
60787
62283
62625
62705
65599
66387
66616
67993
681O1
71546
72414
72S5O
72721
76972
77511
77668
77759
77873
779»7
5(a)(2)
5(a)(2)
5(a)(2)
B(a)(2)
5(a)(2)
5(a)(2)
B(a)(2)
5(a)(2)
5(a)(2)
5>
5
5(*>
5(a)
5(a)
5(a)
5(a)
5(a)
B(a)
------- |