United States
Environmental Protection
Agency
Prevention, Pesticides, And
Toxic Substances
(7407)
EPA 749-K-94-001
June 1994
Instructions For Reporting For The
1994 Partial Updating Of The
TSCA Chemical Inventory
Data Base
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Instructions for Reporting
for the 1994 Partial Updating of the
TSCA Chemical Inventory Data Base
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
Washington, DC 20460
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HIGHLIGHTS OF THE 1994 IUR COLLECTION
o The reporting period is from August 25, 1994 to December 23, 1994.
o There are no substantive changes in the information required for the 1994 IUR
reporting as compared to the 1990 collection.
o Manufacturers of TSCA Inventory chemical substances manufactured solely for
export, which are not otherwise exempt from reporting, have an obligation to
comply with all IUR reporting requirements.
o An appendix to the instructions, Appendix A, lists chemical substances which:
are subject to a rule, proposed or promulgated under TSCA sections 4, 5(a)(2),
5(b)(4), and 6; are subject to an order issued under section 5(e) and 5(f); or are
the subject of relief that has been granted under a civil action under sections
5 or 7 of the Act. This list has been updated to include recent regulatory
actions. All subjects on this list are subject to IUR reporting.
o A current version of the non-confidential TSCA Inventory has been prepared in
diskette and computer tape formats. The printed and electronic versions of the
Inventory are available from the National Technical Information Service. (1-800-
553-NTIS)
o The revised 1994 IUR reporting forms (Form U) are readable by optical
recognition scanners and each reporting form has a unique identifying report
number. Use only original 1994 Form U's obtained from the Agency. You may
not use photocopies.
o Companies may report to EPA using PC diskettes. Computer tapes are not
acceptable. There is no minimum number of chemical substances required for
electronic reporting. Information on any chemical with a confidential identity
may be included on a diskette submission.
o Appendix B contains instructions for computer diskette submissions.
o Mailing addresses and telephone numbers for contacting the Agency have been
updated.
o For questions concerning IUR reporting or to request additional forms, contact
the TSCA Hotline, Monday through Friday, 8:30 am to 5:00 pm, East Coast
time at (202) 554-1404.
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Table of Contents
I. INTRODUCTION 1
II. DETERMINING THE SUBSTANCES FOR WHICH YOU MUST REPORT .... 2
A. Reportable substances 2
1. Inventory substances 2
2. How to determine whether a chemical substance is listed
on the Inventory 3
3. Excluded substances 5
a. Determining whether a substance is excluded 5
b. When an excluded substance must still be reported . 6
B. Determining whether you are a manufacturer or importer who is
required to report a substance 6
1. Manufacture or import of 10,000 pounds or more 6
a. Manufacturers and Importers 6
b. Meeting the 10,000 pound annual production
volume threshold 7
2. Small Manufacturers 7
3. Additional reporting exemptions 8
C. Decision making flow chart 9
D. Manufacture or importation of chemical substances subject to
TSCA but not included on the Inventory 11
III. WHEN YOU MUST REPORT 12
A. You must report during the 120-day reporting period 12
B. Determine annual production using the reporting period as a
reference point 12
IV. HOW TO REPORT 13
A. Form of submission 13
B. Confidentiality 13
C. Completing Form U 15
1. Report only using original copies of Form U 15
2. Certification Statement 15
a. Signature 15
b. Date 15
c. Name and Title 15
3. Technical Contact and Company Information 15
a. Technical Contact Name 15
b. Company Name, Address Line I, Address Line II,
Telephone Number 15
c. CBI 15
4. Plant Site Information 16
a. Dun & Bradstreet Number 16
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b. Address 16
5. Chemical Substance Identity/Activity/Confidentiality 16
a. Line Number 16
b. CAS Registry or Other Identifying Number 16
(1) EPA Accession Number 19
(2) Original Inventory Report Number 19
(3) Premanufacture Notice Number 19
(4) Bona Fide Request Control Number 20
(5) Test Market Exemption Application Number . . 20
c. A, B, C, F, P, or T Codes 21
d. Specific Chemical Name 21
e. Activity: Manufacture or Import 22
f. Site Limited 22
g. Production Volume 23
h. Plant site and Chemical CBI Claims 23
(1) Plant site CBI claim 23
(2) Chemical identity CBI claim 23
D. Reporting by diskette 23
1. General 23
2. Copies of Form U required 23
3. Diskette formats and physical characteristics 23
4. Information on individual chemical substances 24
E. Sending forms and diskettes to EPA 24
F. Correcting errors in submissions for the original Inventory 24
G. Recordkeeping requirements 25
H. Special instructions for importers and foreign suppliers 25
V. OBTAINING COPIES OF DOCUMENTS CITED IN THESE
INSTRUCTIONS 27
A. Obtaining copies of TSCA regulations 27
B. Obtaining copies of the Public Inventory 27
1. Obtaining copies of the printed editions of the Public
Inventory 27
2. Obtaining the Public Inventory in computer-readable form . 27
C. Obtaining copies of Form U 28
VI. REQUESTING ASSISTANCE IN REPORTING 29
Appendix A - Chemical Substances Subject to Proposed or Final TSCA Rules
or Orders A-1
Appendix B Instructions for Submitting IUR Reports on Magnetic Media ... B-1
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INSTRUCTIONS FOR REPORTING FOR THE PARTIAL UPDATING
OF THE TSCA CHEMICAL INVENTORY DATA BASE
(INVENTORY UPDATE RULE)
I. INTRODUCTION
The Environmental Protection Agency (EPA) in 1986 promulgated a rule, often
referred to as the Inventory Update Rule, for the partial updating of the TSCA
Chemical Inventory data base. The rule requires manufacturers and importers of
selected chemical substances included on the TSCA Chemical Substance Inventory
to report current data on the production volume, plant site, and site-limited status of
these substances. The rule was promulgated under the authority of section 8(a) of
the Toxic Substances Control Act (TSCA), and is codified in Subpart B of Part 710 of
Title 40 of the Code of Federal Regulations (40 CFR Part 710).
Reporting under the Inventory Update Rule takes place at four-year intervals
which began in 1986. These instructions pertain to reporting during 1994.
This booklet provides detailed instructions and examples to assist
manufacturers and importers in reporting under the Inventory Update Rule. These
instructions, however, are not a substitute for the rule. Manufacturers and importers
of chemical substances should carefully review the Inventory Update Rule to
determine whether they are subject to its reporting requirements and what information
is to be reported.
Persons reporting under the Inventory Update Rule should have a thorough
understanding of the scope and organization of the TSCA Chemical Substance
Inventory and of the criteria used to determine whether a substance belongs on the
Inventory. Information on the scope and organization of the Inventory can be found
in the introductory pages of the 1985 edition of the Inventory and in the 1990
Supplement to the Inventory. Subpart A of 40 CFR Part 710 prescribes criteria for
inclusion of a substance on the Inventory.
See Section V (page 27) for instructions on how to obtain copies of the
Inventory and of TSCA regulations.
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II. DETERMINING THE SUBSTANCES FOR WHICH YOU MUST REPORT
To ascertain your reporting obligations, you must make two determinations for
each chemical substance that you manufacture in the United States or import into the
United States:
1) Is the substance reportable under the Inventory Update Rule?
2) Are you a manufacturer, importer, or exporter who is required to report
that substance?
A. Reportable substances.
To be reportable under the Inventory Update Rule, a chemical substance must
meet two requirements:
1) The substance must be on the TSCA Chemical Substance Inventory as
of August 25, 1994; and
^
2) The substance must not be of a type exempt from reporting under the
Inventory Update Rule.
1. Inventory substances. The TSCA Chemical Substance Inventory is a list
of chemical substances distributed in commerce in the United States. The Inventory
was originally compiled from reports submitted by manufacturers, importers and
certain processors in 1978 and 1979. New chemical substances are added to the
Inventory when companies who have submitted Premanufacture Notifications (PMNs)
or Polymer Exemption Applications to EPA under section 5 of TSCA notify the Agency
that manufacture or import of the chemical substance has commenced.
EPA keeps a Master Inventory File, which is the authoritative list of all the eligible
chemical substances which have been reported to EPA for inclusion in the Inventory.
EPA also makes available both in printed and computer-readable form a public version
of the Inventory, referred to as the Public Inventory. The Public Inventory does not
contain the specific identities of chemical substances whose identities have been
claimed as confidential business information (CBI). The printed version of the Public
Inventory does contain generic chemical names for these CBI chemical substances.
However, the computer-readable version does not. The Public Inventory has been
updated several times both in print and computer-readable form. The most complete
edition of the printed version of the Public Inventory was published in 1985, and a
1990 supplement to the 1985 edition is also available. The computer-readable
version of the Public Inventory is being updated biannually. Additionally, EPA will also
be making available to the public a PC readable version before the commencement of
the reporting period, as referenced in the Federal Register announcement for the
IUR1994 Page 2
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reporting period. See Section V of these instructions (page 27) for information on
obtaining copies of the Public Inventory.
2. How to determine whether a chemical substance is listed on the
Inventory. Many companies have already determined that the substances they
manufacture or import are on the Inventory. You may have been able to make such
a determination if:
1) you have located the substance in the Public Inventory;
2) you reported the substance to EPA under the Inventory reporting rule in
1978 or 1979 or as an Inventory correction;
3) in response to a PMN, Test Market Exemption Application, bona fide
request, or other communication the Agency has informed you that the
substance is on the Inventory; or
4) you have submitted a Notice of Commencement of manufacture or
import for a PMN substance.
If you do not already know whether a substance you manufacture or import is
on the Inventory, you should consult a copy of the latest public version of the
Inventory (see Section V, below, for instructions on how to obtain a copy). The
Public Inventory provides detailed information on the organization of the Inventory and
on how substances are named and listed.
Several commercial databases have incorporated the public version of the
Inventory (which does not include substances with confidential identities) and indicate
whether a given chemical substance is included on the Inventory. EPA can guarantee
neither the currency nor the accuracy of the information on these databases; however,
there is no penalty for reporting a substance which is not required to be reported.
If at this point you know that your substance is on the Inventory, you may
proceed to Section 11. A. 2. (page 3) to determine whether it is of a type exempt from
reporting under the Inventory Update Rule.
If after having checked the above sources you are still uncertain as to whether
a chemical substance is listed on the Inventory, you should write to EPA at the
following address:
OPPT Document Control Officer
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
401 M Street, S.W.
Washington, DC 20460
ATTN: Inventory Update Rule/Bonafide
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Your letter should request that EPA search the Master Inventory File, including
confidential substances, to determine whether the substance is listed. You must
substantiate the fact that you are actually manufacturing or importing the substance
in question by providing the following information:
1) company identification, address, and telephone number;
2) the specific chemical identity of the substance, preferably a Chemical
Abstracts Service Preferred or Index Name, a Chemical Abstracts Service
Registry Number (if available), and a structural diagram (if available);
3) a statement signed by a company officer that your company is
manufacturing and/or importing the chemical substance for commercial
purposes;
4) a statement signed by a company officer that your company is
requesting this search pursuant to the Inventory Update Rule; and
5) an elemental analysis of the substance.
You may claim information in your letter as confidential by circling or bracketing
the text to be protected and marking "CONFIDENTIAL" on each page containing
confidential information. Failure to so mark this information may result in EPA making
the information available to the public without further notice to you.
Note that this procedure is similar but not identical to EPA's bona fide
procedure codified in 40 CFR §710.7(g) and §720.25(b). If you intend to. but do not
currently manufacture or import a substance for commercial purposes and need a
search of the Master Inventory File, you must follow the procedures codified in those
sections.
EPA's response will inform the manufacturer or importer whether the chemical
substance is on the Inventory and whether the substance is subject to reporting under
the Inventory Update Rule.
If the chemical substance is found on the confidential Inventory, EPA will notify
the person(s) who originfHy reported the substance that another person has requested
information pursuant to the Inventory Update Rule procedures, and therefore was told
that the chemical substance is on the Inventory and that it is subject to reporting.
t
If you are an importer and cannot provide all of the required information
because your foreign manufacturer/supplier is maintaining it as confidential, the
manufacturer/supplier can send the information directly to EPA. Be advised that it is
the obligation of the importer to insure that the foreign manufacturer complies with
the requirements of the IUR.
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Because searches of the Master Inventory File require a considerable amount
of time to process, you are urged to request such a search only if your search of the
public version of the Inventory, commercial databases, and your company's records
fails to resolve your question. Moreover, if your request is not received prior to
October 25, 1994, EPA cannot guarantee that you will receive a response in time for
you to complete the reporting form before the end of the reporting period.
3. Excluded substances. Four categories of substances, though included
on the Inventory, are largely excluded from reporting under the Inventory Update Rule.
These categories are polymers, inorganic substances, microorganisms, and naturally
occurring substances. Refer to section 710.26 of the Inventory Update Rule and to
the preamble of the Federal Register notice announcing the rule (51 FR 21438) for
precise definitions of these categories.
The Inventory Update Rule definition of polymer is sufficiently broad to include
virtually all those substances that are generally considered polymers. These include
polysaccharides such as agar and gums, and all classes of proteins, enzymatic or
structural. However, substances which result from hydrolysis, depolymerization, or
chemical modification of polymers such that the final products are no longer polymeric
(e.g., a mixture of amino acids which is the result of hydrolysis of a polypeptide) are
not considered to be polymers, and must be reported if not otherwise excluded. For
reporting purposes, salts of polymers are also considered to be polymers.
a. Determining whether a substance is excluded. To assist in identification
of excluded substances, most of these substances are 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.
A few of the polymerization gases which are not considered to be polymers
might have been incorrectly flagged because of the inclusion of the word "polymer"
in the chemical name. These substances are nevertheless reportable under the IUR.
Submitters are advised to utilize the flag only as a guide: submitters will be
responsible for verifying exemptions. If a substance does not bear an XU flag and
section 710.26 of the Inventory Update Rule does not provide sufficient guidance to
determine whether the substance is excluded, you may request assistance from EPA
(see Section VI, below, for inquiries). In addition, the following substances, though
not flagged with the XU designation, nonetheless belong to a category excluded from
Inventory Update Rule reporting:
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Name CAS Registry Number
Carbon black 1333-86-4
Carbon 7440-44-0
Graphite 7782-42-5
Charcoal 16291-96-6
b. When an excluded substance must still be reported. With the exception
of naturally occurring substances, a chemical substance which falls into one of the
excluded categories must still be reported if it is the subject of a rule proposed or
promulgated under section 4, 5(a)(2), 5(b)(4), or 6 of TSCA, of an order issued under
section 5(e) or 5(f), or of relief which has been granted under a civil action under
section 5 or 7. A list of all substances which fall into one of these categories is
contained in Appendix A at the back of these instructions. However, if you are unable
to determine whether the specific chemical substance you manufacture falls within
one of the generic chemical names listed in the appendix, you may ask EPA whether
the specific substance is reportable by following the procedures outlined on page 3
of this manual.
B. Determining whether you are a manufacturer or importer who is required to
report a substance.
Even if you manufacture or import a substance reportable under the Inventory
Update Rule you may be exempt from the reporting requirements for that substance.
Questions relevant to whether you must report include:
1) Did you manufacture or import 10,000 pounds (4,540 kilograms) or
more of the reportable substance at any single site during the corporate
fiscal year immediately preceding the reporting period?
2) Do you qualify as a small manufacturer with respect to the substance?
3) Did you manufacture or import the reportable substance under
circumstances which do not require reporting?
1. Manufacture or import of 10.000 pounds or more.
a. Manufacturers and Importers. Reporting for the Inventory Update Rule
is done by individual site of manufacture or by the organizational site which controls
importation. For the purposes of the following discussion, manufacturers and
importers are treated separately.
Manufacturers. A manufacturer is defined at 40 CFR §704.3. The word
"manufacture" is defined at 40 CFR section 710.2{o) and also at 40 CFR section
704.3.
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Importers. The site of importation is defined in section 710.28(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.
Exporters. A manufacturer of an IUR reportable chemical substance
manufactured solely for export is required to report and otherwise comply with all IUR
requirements applicable to manufacturers of all IUR reportable chemicals.
b. Meeting the 10.000 pound annual production volume threshold.
Reporting is required for a chemical substance only if you manufactured or
imported 10,000 pounds (4,540 kilograms) or more of the substance at any single site
you owned or controlled during the corporate fiscal year immediately preceding the
reporting period (see Section III.B., below, for more information about fiscal year).
Moreover, if during the year you manufactured 10,000 Ibs. or more of the substance
at some sites and less than 10,000 Ibs. at other sites, you need to report the
substance only for those sites at which you manufactured or imported 10,000 Ibs. or
more.
Companies that both manufacture and import the same substance. Such
companies should add the manufacturing and importation volume at each site (see
above to determine site of importation) to determine whether the 10,000 pound
threshold has been met. For example, if you manufacture 5,000 pounds of a
reportable substance and import 6,000 pounds, you should report.
Substances in a mixture. Although mixtures as defined in 40 CFR §710.2(q)
are not reportable, the chemical substances of which a mixture is comprised are
reportable. If you manufacture the substances as part of a mixture, you must
determine for each substance in the mixture whether the production volume was over
10,000 pounds. Similarly, if you import a mixture you must determine for each
substance in the mixture whether its importation volume was 10,000 pounds or more.
Note that a person who creates a mixture by combining existing substances without
a chemical reaction is not a manufacturer of those substances and therefore does not
report those substances under the Inventory Update Rule.
Recordkeepina requirement. Even if you manufacture/import less than 10,000
pounds of a reportable substance at a site, you must maintain records documenting
that fact (see Section IV.G. below, page 25).
2. Small Manufacturers. (For the purposes of the following discussion, the
term "manufacturers" refers to both manufacturers and importers.) Small
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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.
or
2) If your total annual sales, combined with those of your parent company,
domestic or foreign (if any), are less than $40 million, you qualify as a
small manufacturer with respect to a particular substance for those plant
sites at which the annual production volume of the substance does not
exceed 100,000 Ibs. If the annual production volume of the substance
at any of your sites is over 100,000 Ibs., you are required to report only
for those sites. Note that it is possible to qualify as a small
manufacturer with respect to some substances and not others, or some
plant sites and not others.
See 40 CFR §704.3 for a more complete discussion of the small manufacturer
exemption.
When a small manufacturer must still report. Even if you qualify as a small
manufacturer you must still report if you produced 10,000 Ibs. or more of a reportable
substance which is the subject of (1) a rule proposed or promulgated under section
4, 5(b)(4), or 6 of TSCA, (2) an order under section 5(e), or (3) relief granted under
a civil action under section 5 or 7. A list of all substances which fall into one of these
categories is contained in Appendix A.
3. Additional reporting exemptions. Persons who manufacture or import
reportable substances under the following circumstances are not required to report for
those substances under the Inventory Update Rule:
1) The chemical substance is manufactured or imported solely in small
quantities for research and development.
2) The chemical substance is imported as part of an article.
3) The chemical substance is manufactured as an impurity, byproduct, or
non-isolated intermediate, or in a manner incidental to another operation
or upon end use of another substance or mixture, as described in 40 CFR
§720.30(g) and (h) (see 48 Fed. Reg. 21746, May 13, 1983).
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4) All the information required by the Inventory Update Rule was reported
to EPA pursuant to a rule under section 8(a) of TSCA between August
25, 1993 and August 24, 1994.
Articles. An article is defined in 40 CFR §710.2(f) as "a manufactured item (1)
which is formed to a specific shape or design during manufacture, (2) which has end
use function (s) dependent in whole or in part upon its shape or design during end use,
and (3) which has either no change of chemical composition during its end use or only
those changes resulting in compositions which have no commercial purpose separate
from that of the article and that may occur as described in section 710.4(d)(5), except
that fluids and particles are not considered articles regardless of shape or design."
EPA considers imported items as articles if they are manufactured in a specific
shape or design for a particular end use application, and this design is maintained as
an essential feature in the finished product. Thus, materials such as metal or plastic
sheets, wire, coated fabric, rolled carpet, sheets of plywood and other similar
materials will be viewed as articles by EPA, even if, for example, subsequent to import
they are rolled or drawn thinner, cut, printed, laminated, or thermoformed, so long as
they meet the above criteria. Substances which are part of such articles are not
subject to reporting under the Inventory Update Rule.
If an item is manufactured in a particular shape for the purpose of shipping
convenience and the shape has no function in the end use, it would not be considered
an article. Thus, chemical substances which are part of items such as metal ingots,
billets, and blooms are subject to reporting under the Inventory Update Rule.
Duplicative reporting unnecessary. If between August 25, 1993 and August
24, 1994 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 1994.
C. Decision making flow chart.
The following flow chart summarizes the questions which must be answered
to determine your reporting obligations for a particular substance. (For simplicity's
sake, not all reporting exemptions are included in the flow chart.)
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Is this substance listed on the
TSCA Chemical Inventory?
NO
YES
Is this substance a polymer,, inorganic
substance, microorganism,
or naturally occurring?
NO
1TTYES
Is this substance subject to a special
regulatory action under TSCA?
NO
YES
Did yon manufacture or import
10,000 Ibs. or more per year
at a single site?
YES
Are you a small manufacturer
of this substance?
NO
\ YES
Is this substance subject to a special
regulatory action under TSCA?
YES
Did yon manufacture or impart the chemical
substance under circumstances for which
reporting is not required?
NO
You must report.
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.
Note that hydrates are not listed on the Inventory. You are required to report
the CAS Registry number of the corresponding anhydrous form. Adjust the reported
production volume to exclude water.
If you are manufacturing or importing a substance which was previously on the
Inventory but which has subsequently been delisted, then you are in violation and
must follow the directions below.
If you find that you have or may have manufactured or imported chemical
substances in violation of TSCA, you should contact the Agency at the following
address:
Director
Toxics and Pesticides Enforcement Division
Office of Regulatory Enforcement (2245)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Information in your letter may be claimed as confidential by circling or
bracketing the text to be protected and marking the page, "CONFIDENTIAL." Failure
to so mark this information may result in EPA making the information available to the
public without further notice to you.
Significant reductions in penalties are given for persons voluntarily disclosing
violations. Note, however, that continued manufacture or importation of such
chemical substances remains illegal even after you have contacted the Agency, until
the requirements of TSCA have been met.
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III. WHEN YOU MUST REPORT
The Inventory Update Rule establishes reporting periods every four years. The
first reporting period was during 1986; the second was during 1990; the third period
is during 1994. A reporting period serves two functions:
1) It is a 120-day period during which reports for the Inventory Update Rule
must be filed.
2) It is used to determine the applicable fiscal year for calculating annual
production volume.
A. You must report during the 120-day reporting period.
The next reporting period begins August 25, 1994 and ends December 23,
1994. All submissions must be postmarked no later than December 23, 1994. If you
are required to report (see Section II., page 2), failure to file your report during this
period is a violation of section 15 of TSCA.
Persons requesting searches of the Master Inventory File (see Section H.A.2.,
page 2, 3) must make their requests at least 60 days prior to the close of the
reporting period. If you have made your request in time you will be allowed 15
business days from the date of receipt of EPA's answer or until the end of the
reporting period, whichever is later, to submit the report for the substance which was
searched. Any other reports received after the end of the reporting period will be
considered late and will be subject to enforcement action.
B. Determine annual production using the reporting period as a reference point.
To determine whether you manufactured or imported 10,000 Ibs. or more of
a reportable substance at a site, you must determine your total manufacture/import
volume for your last corporate fiscal year which ends prior to August 25, 1994. For
example, someone whose fiscal year is the calendar year would determine
manufacture or import volume for the period January 1, 1993 - December 31,1993,
while someone whose fiscal year is July 1 to June 30 would determine manufacture
or import volume for the period July 1, 1993 to June 30, 1994.
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 electronic means (see subsections C., page 15 and D. page 23).
Separate forms are required for each plant site.
For the 1994 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 'recognized' 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. You may only use an original form for
reporting.
B. Confidentiality.
Information submitted to EPA under the Inventory Update Rule may be claimed
as confidential business information (CBI) by checking the appropriate "CBI" boxes on
Form U. Claims of confidentiality will not be accepted and honored if they are not
asserted at the time information is submitted to EPA or submitted in a manner
inconsistent with the rule and reporting instructions.
You may assert a CBI claim for the specific identity of a chemical substance only
if EPA treats that substance identity as confidential on the Inventory at the time your
report is submitted (i.e., the substance is not on the Public Inventory). Both
confidential and non-confidential substances may be reported on the same form, and
confidential substances may be included in diskette submissions.
If you are manufacturing or importing a chemical substance which is currently
listed on the Inventory as confidential you are encouraged not to assert confidentiality
claims if circumstances are now such that confidentiality is no longer necessary. If
you report a previously confidential substance as non-confidential (see subsection C,
below, for specific instructions) that substance will subsequently be listed on the
Inventory as non-confidential.
No CBI claim for chemical identity will be accepted unless accompanied by a
separate written substantiation for each chemical substance claimed as CBI, with
detailed answers to the eleven questions prescribed in section 710.38 of the
Inventory Update Rule, and repeated below. The answers must be complete and
specific to the chemical substance in question. The substantiation must be dated and
signed by an officer of the company. If the required substantiation does not
accompany your Form U, EPA may make the chemical identities reported on the form
available to the public without further notice to you.
IUR 1994 Page 13
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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 undeslred disclosure of the
fact that this chemical substance is being manufactured or imported for a commercial
purpose?
7) To what extent has the fact that this chemical substance is manufactured
or imported for commercial purposes been revealed to others? What precautions have
been taken regarding these disclosures? Have there been public disclosures or
disclosures to competitors?
8) Does this particular chemical substance leave the site of manufacture In
any form, as product, effluent, emission, etc.? If so, what measures have you taken
to guard against discovery of Its identity?
9) If the chemical substance leaves the site in a product that is available to
the public or your competitors, can the substance be Identified by analysis of the product?
10) For what purpose do you manufacture or Import the substance?
IUR1994 Page 14
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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 (page 27) for obtaining copies of Form U.
2. Certification Statement.
a. Signature. The certification statement must be signed by an officer of
the company. This statement certifies to the truth and accuracy of the Information
reported and of the confidentiality claims made on the form (see the back of Form U
for details). Note that by certifying the truth and accuracy of the information on the
form, you acknowledge that any knowingly false or misleading statement may be
punishable by fine or Imprisonment or both under applicable law. Sign in black ink to
ensure that the form bears a legible signature which can be microfiched or otherwise
archived.
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.
b. Qpmpany Name. Address Line I. Address Line II. Telephone Number. Use
this block to enter the company name and street address. Please use standard
addressing techniques as established by the U.S. Postal Service. Post office box
numbers are only acceptable if also accompanied by a street address. If a post office
box Is listed, It should be listed after the street address on Address Line II. The
telephone number listed should be that of the technical contact.
c. CBI. Checking the CBI box In this block asserts a confidentiality claim for
the link between your company and all the chemical substances reported on the form.
IUR1994 Page 15
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Checking other CBI boxes on the form will not protect this link. If there are some
substances whose connection to your company you do not require to be kept as
confidential, report those substances on a separate form on which the CBI box in the
Company block is not checked.
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, street address, and Dun & Bradstreet number of the site here.
The plant site name should be listed as a concatenation of the company name and
plant site name (e.g., Acme Intl-Madison Pit). (See sample form on page 18)
a. Dun & Bradstreet Number. Dun & Bradstreet gives separate numbers to
plant sites and parent companies; make sure that the number you provide EPA
belongs to the individual plant site for which you are reporting. If the plant site does
not have a Dun & Bradstreet number, a Dun & Bradstreet number assignment can be
requested from your local office of Dun & Bradstreet. Dun & Bradstreet does not
charge for this service, and does not require that you disclose sensitive financial
information in order to get a number. Do not report the headquarters Dun and
Bradstreet number unless the reporting site corresponds to that number.
b. Address. A street address, including Zip code, must be reported. Post
office box numbers are not acceptable. If the site does not have a street address,
please provide what descriptive site information you have, including the Zip code.
See Block G, below, concerning CBI claims for the link between plant site identity
and individual substances.
5. Chemical Substance Identitv/Activitv/Confidentialitv.
a. Line Number (block A). This part of the form is divided into ten lines to
allow reporting of up to ten chemicals per form. Each line should represent one
chemical. If the chemical identity will not fit on one line, rather than using a second
line, you should truncate the name with the use of an ellipsis (...) indicating an
omission of letters or words, (e.g., utilize the available space and if you can not
include the complete name, end it with a series of full stops or period dots.)
b. CAS Registry or Other Identifying Number. Every chemical substance
reported on Form U must be accompanied by its Chemical Abstracts Service (CAS)
Registry Number (see lines 1, 8, and 10 of sample form) or other identifying number.
The printed edition of the Inventory contains detailed instructions on how to locate
the CAS Registry Number for a substance listed therein. When you report a CAS
Registry Number, please verify that the number you are reporting is the correct
number for your substance.
IUR 1994 Page 16
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You may be unable to find a CAS Registry Number in the Public Inventory either
because the substance is listed as confidential (in which case the specific identity is
not present and the chemical substance has an Accession Number rather than a CAS
Registry Number) or because the substance was not on the Inventory as of the date
of printing. If this is the case you may use one of the following acceptable identifying
numbers:
1) EPA Accession Number;
2) Original Inventory Report Form Number;
3) Premanufacture Notice Number;
4) Bona Fide Document Control Number; or
5) Test Market Exemption Application Number.
Use one of the above identifying numbers only if you cannot locate the CAS Registry
Number for a substance or you are uncertain whether the CAS Registry Number you
have located is correct. The CAS Registry number is the preferred identifier for
chemical substances reported.
IUR 1994 Page 17
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SAMPLE 1994 IUR FORM
U
United Suia*
Environmental Protection Agency
Wa»hinoton. DC 2O4OO
Partial Updating of TSCA Inventory Data Base
Production and SHe Report
(Saotkm Bit) Tmde Sulxtonoai Control Act IS USC 20O7)
«n trw btcfc * tftto f»w *»MU»«n*oimet v !• ttta MwmMfan Iv wHdi I h*M •
REPORT NUMBER
CHEMICAL SUBSTANCE IDEITOTY/ACTIVITY/CONFIDENTIALITY
""••• *?•.•."•...; .>.
C^BBu *---•- -Y«—ILj . "^ . . >JI «k •• »«^Li^i.1--:-.-tgfapjr.j-v4^g»rfBM*-...^v:r"| •' • WTunt •• "• '--jga;••:?•?:«•
: 29735 H--..1 A I'- .,] I M I-1 Lp-J J: t:j:j 11 ronn ;-:fT|--"-i":rx}
1-Hapthalenamliie,~ i>i-::'t.(2-broiiio-4,6—dloltro—phenyl)agdg—W-ethYll~
. • t-\ 2^.000
1,2-£thanediamlna. H-cchyl-K ,Nf-
:-::-«r-------ft-'"W^H5'»
• . . . . _ ..
^ffi ;' :F4j;OOQ j^x't
*
:-: 33649773/001
. 1.3-Prononedlamlnlum. K.N.N.M',-penta-metbyl-M'-[3-[ttecra
ij'J 20,000
t:i 53437422/001
5 •:>! "
Benzenomine, A~hpR|fcy^—N—
: 6 Z,PQO._..._J'-
A
•
:: P-85-0131
6 •'•*; ~
-• 2-NaphChalen«carboxvlic *cld. 3-hydrpxy-4-r(2-methoxy- -i
;;; t-as-ooss ., ,. . .. ,.
": BenzeaamiDc, 4-heptyl-H-pho.nyl
I70JMO
.. -a. 1af.~,.&seit*~! ::•
"'
A; ' ; •, M.
_
8
:--_ 1 8236-1 S-2
•• '-' ••"••••• "r::»i
•" Eehanethlol. 2-ftriethoxvallvl)-
9 1-55
::n::::^>
! Methncrvllc acid. 2-ethvlbutvl ester
« />
1U
::, Fhoaphonic acid, dilsooctxJ
The substances on this sample form are listed as confidential
only for purposes of illustration.
IUR 1994
Page 18
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(1) EPA Accession Number. (See line 2 of sample form.) If the identity of
a chemical substance on the Inventory is confidential, the printed Inventory lists an
Accession Number for that substance and uses a generic name rather than a specific
identity. You may use an Accession Number as an identifying number oniyjf EPA has
communicated the appropriate Accession Number to you, e.g., following your report
for the original Inventory in 1978 or 1979, or following commencement of
manufacture or import of a substance for which you filed a premanufacture notice.
If you find a generic chemical identity in the printed Inventory which you think belongs
to your substance, and report using the Accession Number which pertains to that
substance, you may possibly report for the wrong substance. An Accession Number
may not be used for a non-confidential chemical substance. A typical Accession
Number would be "29735".
(2) Original Inventory Report Number. In 1978 and 1979, submissions for
the Initial and Revised TSCA Chemical Substance Inventories were filed on one of four
forms, "A", "B", "C", or "E". You may use that original Inventory report form number
as an identifying number. A typical Original Inventory Report Number would be
"12345678".
Since both "A" and "B" forms allowed reporting of several chemical substances
on a single form, EPA needs to know the line number on the original "A" or "B" form
that the substance occupied. If you use an original Inventory report number from an
"A" or "B" form (these form numbers begin with "1" or "2") you must therefore
include the original line number for that chemical substance, separated from the form
number by a slash. For example, if a chemical substance has been reported on line
number 3 of form 12345678, report the identification number as "12345678/003";
(see line 9 on sample form). Add leading zeroes to make the line number three digits
long, e.g. # "001", "012", or "123". If you originally reported on a "C" or "E" form
(form numbers beginning with "3" or "5"), include a slash and line number-of 001
(see lines 4 and 5 on sample form).
If you submitted a correction to an original Inventory report, use the number of
the form on which you submitted the correction. Be sure to add a line number (001),
as above.
(3) Premanufacture Notice Number. (See line 6 of sample form.) If you filed
a Premanufacture Notice (PMN) for a substance which is now reportable under the
Inventory Update Rule and that PMN was assigned a PMN number, you may use that
as an identifying number. A typical PMN number would be "P-85-0243" or "P-83-
0001 A". The four digit block of numbers must be right justified with leading zeros
as needed. The eighth space is reserved for an optional alpha character suffix (A, B,
etc.) and should be used only if one has been assigned by EPA. Please be sure to
include the dashes in the correct locations.
Please be aware that a chemical substance which has a PMN number is not
automatically reportable under the Inventory Update Rule. A PMN substance is
IUR1994 Page 19
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reportable under the IUR only if it is included on the Inventory. A PMN substance is
included on the Inventory only if a Notice of Commencement was received by EPA for
the substance.
(4) Bona Fide Request Control Number. (See line 3 of sample form, page 18)
If you filed a Bona Fide Intent to Manufacture or Import a chemical substance which
is now reportable under the Inventory Update Rule (see 40 CFR §710.7(g) or
§720.25(b)), you may use the document control number assigned to that submission
by EPA as an identifying number. A typical Bona Fide document control number
would be "528500287".
The fact that you filed a Bona Fide for a substance does not necessarily mean
that the substance is on the Inventory and reportable; you must have independent
confirmation that the substance is on the Inventory (most likely in a communication
from EPA).
(5) Test Market Exemption Application Number. (See line 7 of sample form.)
If you filed a Test Market Exemption Application (TMEA) for a substance which is now
reportable under the Inventory Update Rule, the number assigned by EPA to that
application may be used as an identifying number. A typical TMEA number would be
"T-85-0243" or "T-83-0001A". The four digit block of numbers must be right
justified with leading zeros as needed. The eighth space is reserved for an optional
alpha character suffix (A, B, etc.) and should be used only if one has been assigned
by EPA. Please be sure to include the dashes in the correct locations. You should use
a TMEA number only if you know that the chemical substance is on the Inventory.
Procedures for obtaining CAS Registry Numbers and Accession Numbers from
EPA when you previously reported the substance to the Agency. If by one of the
methods discussed in Section II.A. (page 2), you were able to determine that the
substances you manufacture are on the Inventory, you should already have identifying
numbers for them. If you do not know any of the above identifying numbers for a
substance you are unlikely to be certain that the substance is on the Inventory. If this
is the case you should reread Section 11. A. Following the procedures in that section
should enable you to find an identifying number.
There may be some manufacturers or importers who reported for the Inventory
in 1978 or 1979 but no longer have the original report forms. In this case you may
request an identifying number from EPA. Send a letter to the following address:
OPPT Document Control Officer
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
IUR 1994 Page 20
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The letter must include the specific identity of the chemical substance, must
be signed by an officer of the company, and must designate a technical contact
(include name, title, address, and telephone number). The structure of the substance,
if available, should also be provided. Note that this procedure can be used only when
you have previously reported the substance to the Agency; if you need EPA to tell you
whether the substance is on the Inventory you must follow the procedures in Section
M.A.2. (page 3).
Information on this letter may itself be claimed as confidential by circling or
bracketing the text to be protected and marking the page "CONFIDENTIAL." Failure
to so mark this information may result in EPA making the information available to the
public without further notice to you.
EPA will release information in response to these letters only to the company
which originally submitted the information. If company ownership has changed or the
technical contact authorized to receive confidential information has changed since you
reported the substance to EPA during 1978 - 1980, you must include a notarized
letter by an officer of the current surviving chemical company certifying to the change
and designating the new technical contact.
EPA will send to the technical contact a CAS Registry Number (if the substance
is listed as non-confidential on the Inventory) or an Accession Number (if the
substance is confidential).
EPA will release CAS Registry Numbers or Accession Numbers in response to
these letters only for substances which are reportable under the Inventory Update
Rule. Your letter must be received by November 12, 1994; 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 column the type of
identifying number you entered in column B, as follows:
If the number you are Type this code
reporting in block B is a(n) in block C
Accession Number A
Bona Fide Number B
CAS Registry Number C
Original Inventory Report Number F
Premanufacture Notice (PMN) Number P
Test Market Exemption Application
(TMEA) Number T
d. Specific Chemical Name (block H). Enter the specific chemical identity
of the chemical substance you are reporting. Chemical Abstracts Index or Preferred
Names should be used if available. For non-confidential substances, these names can
IUR1994 Page 21
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be found in either the printed or the computer-readable version of the Public Inventory.
If such names are not available, you must use nomenclature which completely and
accurately describes the chemical substance.
If the chemical identity will not fit on one line, you should truncate the name
at the end of the line with the use of an ellipsis (...) indicating an omission of letters
or words. Each line should represent one chemical. (See line 4 of sample form, page
18) Do not continue the chemical identity to the next line.
Trade names may not be used except where a trade name describes a reactant
which is part of the identity of a chemical substance you are reporting and your
supplier will not disclose to you the specific identity of the trade name reactant.
Report all such chemical substances on a separate form, entering the specific
identities of reactants where you know them and the trade names where you do not.
You must also submit along with Form U a letter certifying that your supplier will not
disclose to you the specific identity of the trade name reactant and identifying the
supplier of each trade name reactant reported.
Information in this letter may be claimed as confidential by circling or bracketing
the text to be protected and marking the page, "CONFIDENTIAL." Failure to so mark
this information may result in EPA making the information available to the public
without further notice to you.
If you are an importer whose foreign supplier will not reveal to you the identity
of the substance you are reporting, follow the procedures in subsection H. (page 25).
If you are claiming the chemical identity as confidential, check the Chemical CBI
box in block G.
e. Activity: Manufacture or Import (block D). If you manufacture the
substance, enter "M" in the Activity box; enter "I" if you import the substance. If you
both manufacture and import the substance at the same site, use two lines to report,
one for each activity. Check the CBI box if you wish to claim the nature of the
activity (i.e., manufacture vs. importation) as confidential for the substance. Claiming
activity as CBI does not protect the link between your company and the substance;
that will not be protected unless you check the CBI box next to Company Name.
f. Site Limited (block E). If you manufacture the chemical substance at the
plant site identified and do not distribute the chemical substance or any mixture
containing that substance outside the plant site for commercial purposes, enter "X"
in the space next to the CBI box. Otherwise leave the space blank. (Note: an
imported chemical substance cannot be reported as site-limited.) If you wish to claim
this information as confidential for the substance, check the CBI box. You may claim
the fact that a substance is not site limited as confidential, if appropriate.
IUR 1994 Page 22
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Q. Production Volume (block R. Enter your annual manufacture volume or
importing volume, in pounds, for the fiscal year preceding the reporting period. If you
both manufacture and import a particular substance, report the manufacture and
import volumes separately, on two lines. The quantity should be reported to at least
two significant figures, and should be accurate to the extent known or reasonably
ascertainable by you (if the figure reported is within ±10% of the actual value, it is
acceptable for purposes of the rule). Production volumes must be reported in numeric
format ("2 million" or "Ex10" are not acceptable): Abbreviations such as M or K are
also not acceptable. (Volumes reported in other than numeric format cannot be read
by the Agency's automated equipment.) If you wish to claim this information as
confidential for this substance, check the CBI box.
h. Plant site and Chemical CB) Claims (block G).
(1) Plant site CBI claim. If you wish to claim the site of manufacture/import
as confidential, check the "Plant CBI" box. Note that you may claim this connection
as CBI for some chemical substances on the form while not making that claim for
others.
(2) Chemical identity CBI claim. The identity of a substance which is listed
as confidential on the TSCA Inventory may be claimed as confidential by checking this
box. EPA wBI 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 on the upper portion of the form.
D, Reporting by diskette.
1, General. In 1986 submitters were offered the option of submitting
reports on computer tape. For the 1990 collection, the option was expanded to
include diskettes. In this 1994 reporting period magnetic media submissions are again
encouraged; however, only diskettes will be accepted.
2. Copies of Form U required. All diskettes 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 in subsections IV.C.3.
and 4., on pages 15 and 16. The remainder of the form should not be filled in. In its
place include a statement that the required information is being submitted on diskette,
plus diskette identifier information (this should match the information on the label
affixed to the diskette).
3. Diskette formats and physical characteristics.
See Appendix B for instructions on providing submissions on diskette.
IUR1994 Page 23
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4. Information on individual chemical substances.
See Appendix B and instructions for completing the Chemical Substance Block
in Section C.r above.
E. Sending forms and diskettes to EPA.
Send the original form, along with any accompanying diskettes, to the
following address:
OPPT Document Control Officer
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
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:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Telephone: (202) 554-1404
IUR1994 Page 24
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Inventory Correction requests should be submitted to EPA with your copies
of Form U. Note that your Form U should report the chemical substance you are
actually manufacturing or importing. The correction should be explained in a cover
letter by specifically referencing the number of the correction form, the Form U
number, and the Form U report line number.
The act of correcting errors in submissions to the Original Inventory does not
grant to the person making the correction immunity from enforcement action for any
possible violations of the Original Inventory Reporting Rule.
G. Recordkeepina 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 effective date of the applicable reporting period. As
long as the records are maintained in a manner consistent with normal business
practice, you may determine their exact format. Required records include those that
show the production volume, plant site, and site-limited status of each substance
reported. If a substance is not reported because its site-specific annual production is
less than 10,000 pounds, only the site-specific production records for that substance
need to be kept. Persons who qualify as exempt small manufacturers need to keep
records only for those chemical substances which they are required to report;
however, in claiming an exemption they bear the burden of documenting that they
qualify for the exemption.
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 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.
IUR1994 Page 25
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4) On the original copy, sign the certification statement, enter the
technical contact, and complete blocks D, E, F and G for each chemical
substance. In block B, instead of entering the identifying number, enter
the trade name or other designation by which you know each chemical
substance. Leave column C blank. Check the "Chemical CBI" box in
block H only if you wish to claim the identities of the chemicals
identified on the form as confidential (you must answer the
substantiation questions described in subsection B., page 13). Your
foreign supplier is responsible for his own CBI claim. Send this copy to
EPA.
5) On the photocopy of the blank form, enter only the plant site
information. Send this copy to your foreign supplier.
6) The foreign supplier should enter technical contact-company
information on his copy (the technical contact here should be the
foreign supplier), complete blocks B and C and enter the appropriate
specific chemical identities in block H. Make sure that your supplier
understands which chemical identities belong with each line number on
Form U. If the foreign supplier wishes to claim the chemical identities
as confidential, the supplier should check the "Confidential" box in
block G and submit a substantiation as described in subsection B.,
above. The supplier should include with Form U a letter stating that
this information is being submitted by a foreign supplier on behalf of
the importer, who should be identified. Information in the letter may
be claimed as confidential by circling or bracketing the text to be
protected and marking the page, "CONFIDENTIAL." Failure to so mark
this information may result in EPA making the information available to
the public without further notice to the supplier. The supplier should
then send the form and letter to EPA.
Note that it is your responsibility to ensure that your foreign supplier
understands how to complete his copy of Form U (including any relevant CBI claims)
and that the supplier sends the information to EPA by the end of the reporting period.
If the supplier fails to submit the information, your company may be subject to an
enforcement action.
IUR 1994 Page 26
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V. OBTAINING COPIES OF DOCUMENTS CITED IN THESE INSTRUCTIONS
A. Obtaining copies of TSCA regulations.
Copies of TSCA regulations can be obtained by contacting:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Telephone: (202) 554-1404
B. Obtaining copies of the Public Inventory.
1. Obtaining copies of the printed edition of the Public Inventory. Non-
confidential Inventory listing can be found in the TSCA Chemical Substance Inventory:
1985 Edition, a complete version of the Public (non-confidential) Inventory current
as of July 1985, and in the TSCA Chemical Substance Inventory: 1990 Supplement.
a supplement to the 1985 edition current as of February 1, 1990. This printed
version contains the CAS Registry Number, Preferred CA Index Name, molecular
formula, and if applicable, the substance definition and appropriate EPA flags
(including the "XU" flag for substances exempt from reporting under the Inventory
Update Rule) for non-confidential substances. For chemical substances whose
chemical identity has been claimed as confidential, generic chemical names and EPA
accession numbers are listed. Copies may be purchased from:
Superintendent of Documents
Government Printing Office
Washington, D.C. 20402
Order Desk: (202) 783-3238
The price for the 1985 edition is $161.00 in the U.S. and Canada, $201.25
elsewhere; the price for the 1990 supplement is $15.00 in the U.S., and $18.75
outside the U.S. if ordering by mail use the above address. GPO will also take orders
by telephone; MasterCard and Visa are accepted. Refer to stock number 055-000-
00254-1 for the 1985 edition, and 055-000-00254-1 for the 1990 supplement.
Please allow 4-6 weeks for delivery (longer outside the U.S.).
2. Obtaining the Public Inventory in computer-readable form. The Public
Inventory is available in the form of computer tapes or PC diskettes. Both can be
obtained from the National Technical Information Service (1-800-553-NTIS). The
computer tape version consists of two tapes. The first tape, the Inventory Preferred
Name File, is sorted by CAS Registry Number. It contains the CAS Registry Number,
Preferred CA Index Name, molecular formula, and if applicable, the substance
definition and appropriate EPA flags (including the "XU" flag for substances exempt
IUR1994 Page 27
-------
from reporting under the Inventory Update Rule) for non-confidential substances. The
second tape, the Inventory Synonym Name file, contains the same data elements as
the first tape but differs in two ways. First, it is sorted by chemical name, not CAS
Registry Number. Second, in addition to the Preferred CA Index names, this file is
expanded by the inclusion of valid names (synonyms) as supplied to EPA by Inventory
submitters. In contrast to the printed version of the Public Inventory which includes
CAS derived synonyms, the synonyms listed on this tape are only those reported to
EPA by Inventory submitters.
The PC diskette version is a set of diskettes containing the information on
both computer tapes merged together with duplicate information removed. It is in
CAS Registry Number order.
The tapes and diskettes only contain information on chemical substances
which have not had confidentiality claims made on the chemical identity. They do not
reference in any way chemicals on the TSCA Inventory claimed as confidential.
Ordering information for these products may be obtained by contacting:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650 or (800) 553-NTIS
C. Obtaining copies of Form U.
Copies of Form U may be obtained from:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Telephone: (202) 554-1404
IUR1994 Page 28
-------
VI. REQUESTING ASSISTANCE IN REPORTING
Should you need information on or assistance in the following areas:
1) determining your reporting obligations;
2) the mechanics of completing Form U;
3) entering data onto computer diskette for submission; or
4) determining the status of forms/diskettes you have submitted to EPA,
you may write to or call the following address:
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 554-1404
IUR1994 Page 29
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Page 30
IUR 1994
-------
Appendix A
Chemical Substances Subject to
Proposed or Final TSCA Rules or Orders
Following is a list of CAS Registry Numbers (for non-confidential chemical substances)
or Accession Numbers (for confidential substances) of substances which are subject
to proposed or final rules or orders under TSCA sections 4, 5(a)(2), 5(b)(4), 5(e), 5(f),
6, and 7, as of April 1994 (see sections 710.26 and 710.29 of the rule and pages 6
and 8 in these reporting instructions). All chemical substances appearing on this list
are subject to IUR reporting. The usual exclusions for polymers, inorganic substances,
microorganisms, or small businesses do not apply for substances on this list. The
exclusion for naturally occurring substances is still valid, as referenced on page 6 of
this instruction manual. If after consulting the list you are uncertain as to the
regulatory status of a chemical substance, contact EPA at the address given on page
29 of these reporting instructions.
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
51-79-6 5(a)(2)
54-11-5 4
57-10-3 4
60-29-7 4
62-44-2 4
62-53-3 4
67-63-0 4
67-64-1 4
70-30-4 4
71-36-3 4
71-55-6 4
72-20-8 4
72-57-1 4
74-87-3 4
74-93-1 4
74-95-3 4
74-97-5 4
75-00-3 4
75-02-5 4
75-05-8 4
75-09-2 4
75-12-7 4
75-15-0 4
75-25-2 4
75-34-3 4
75-35-4 4
75-38-7 4
75-44-5 4
75-56-9 4
75-70-7 4
75-87-6 4
75-88-7 5(a)(2)
76-01-7 5(a)(2)
76-01-7 4
78-33-1 4
78-59-1 4
78-83-1 4
78-87-5 4
78-93-3 4
79-10-7 4
79-19-6 4
79-22-1 4
79-31-2 4
79-34-5 4
IUR 1994
A-1
-------
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
79-94-7 4
79-95-8 4
80-05-7 4
81-07-2 4
82-68-8 4
84-65-1 4
84-66-2 4
84-74-2 4
85-22-3 5(a)(2)
85-22-3 4
85-44-9 4
85-68-7 4
85-69-8 4
87-10-5 4
87-61-6 4
87-63-8 5(a)(2)
87-65-0 4
87-84-3 4
88-74-4 4
89-61-2 4
89-64-5 4
89-69-0 4
92-04-6 4
92-52-4 4
92-66-0 5(a){2)
92-86-4 5(a)(2)
94-58-6 4
94-74-6 4
94-75-7 4
94-81-5 4
94-82-6 4
95-48-7 4
95-49-8 4
95-50-1 4
95-51-2 4
95-54-5 4
95-56-7 4
95-57-8 4
95-69-2 5(a){2)
95-76-1 4
95-77-2 4
95-80-7 4
95-88-5 4
95-94-3 4
95-95-4 4
96-23-1 4
96-29-7 4
96-37-7 4
97-02-9 4
97-50-7 4
97-63-2 4
98-56-6 4
98-82-8 4
98-86-2 4
98-87-3 4
98-95-3 4
99-28-5 4
99-30-9 4
99-54-7 4
100-01-6 4
100-02-7 4
100-21-0 4
100-40-3 4
101-55-3 4
101-90-6 4
103-65-1 4
103-85-5 4
104-76-7 4
106-37-6 4
106-44-5 4
106-46-7 4
106-47-8 4
106-50-3 4
106-51-4 4
106-90-1 4
106-91-2 4
106-92-3 4
107-04-0 5(a)(2)
107-10-8 4
107-12-0 4
IUR 1994
A 2
-------
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
107-13-1 4
108-10-1 4
108-31-6 4
108-39-4 4
108-45-2 4
108-60-1 4
108-67-8 4
108-70-3 4
108-86-1 4
108-90-7 4
108-94-1 4
108-95-2 4
109-06-8 4
109-77-3 4
109-99-9 4
110-75-8 4
110-80-5 4
110-82-7 4
111-11-5 4
111-40-0 4
111-54-6 '. 4
111-91-1 4
112-34-5 4
112-35-6 4
112-50-5 4
112-90-3 4
115-86-6 4
116-14-3 4
116-15-4 4
117-18-0 4
117-81-7 4
118-75-2 4
118-79-6 4
120-36-5 4
120-58-1 4
120-80-9 4
120-82-1 4
120-83-2 4
121-69-7 4
122-09-8 4
122-60-1 4
123-30-8 4
123-31-9 4
123-33-1 4
123-54-6 5(a)(2)
123-63-7 4
123-86-4 4
124-17-4 4
126-72-7 5(a)(2)/6
126-73-8 4
126-80-7 4
126-98-7 4
128-39-2 4
131-11-3 4
131-89-5 4
134-32-7 4
140-66-9 4
141-78-6 4
141-79-7 4
143-22-6 4
143-33-9 4
149-30-4 4
149-57-5 4
306-83-2 5{a)(2)
320-72-9 4
328-84-7 4
348-51-6 4
350-30-1 4
353-50-4 4
354-33-6 5(a)(2)
420-46-2 5(a)(2)
428-59-1 5(a){2)
428-59-1 4
431-89-0 5(a)(2)
488-47-1 4
494-03-1 4
506-68-3 4
541-70-8 4
541-73-1 4
542-76-7 4
IUR 1994
A3
-------
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
556-52-5 4
556-67-2 4
576-24-9 4
576-26-1 4
583-78-8 4
585-07-9 5(a)(2)
591-08-2 4
591-78-6 5(a)(2)
598-31-2 4
606-20-2 4
608-71-9 4
608-93-5 4
615-58-7 4
615-67-8 4
616-23-9 4
622-86-6 5(a)(2)
626-39-1 4
628-63-7 4
636-21-5 4
640-19-7 4
646-06-0 4
680-31-9 5(a)(2)
757-58-4 4
765-34-4 4
811-97-2 5(a)(2)
822-06-0 4
827-94-1 4
872-50-4 4
930-37-0 4
933-75-5 4
1129-42-6 5(a)(2)
1163-19-5 4
1241-94-7 4
1309-64-4 4
1330-78-5 4
1332-21-4 6
1336-36-3 6
1345-04-6 4
1464-53-5 4
1511-62-2 5(a)(2)
1634-04-4 4
1649-08-7 5(a)(2)
1675-54-3 4
1705-60-8 5(a)(2)
1717-00-6 5(a)(2)
1737-93-5 5(a)(2)
1940-42-7 4
2052-07-5 5(a)(2)
2113-57-7 5(a)(2)
2136-89-2 4
2210-79-9 4
2224-15-9 4
2238-07-5 4
2421-27-4 5(a)(2)
2425-01-6 4
2425-79-8 4
2426-08-6 4
2432-99-7 5(a)(2)
2461-15-6 4
2461-18-9 4
2516-92-9 5(e)
2528-36-1 4
2530-83-8 4
2577-72-2 4
2615-25-0 5(a)(2)
2716-10-1 5(a){2)
2716-12-3 5(a)(2)
2837-89-0 5(a)(2)
2897-60-1 4
3072-84-2 4
3083-25-8 5(a)(2)
3089-19-8 5(a)(2)
3101-60-8 4
3132-64-7 5(a)(2)
3165-93-3 5(a){2)
3188-83-8 4
3194-55-6 4
3288-58-2 4
3319-31-1 4
3389-71-7 5{a)(2)
IUR 1994
A-4
-------
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
3568-29-4 4
3618-72-2 4
3648-20-2 4
3689-24-5 4
3772-94-9 4
4016-11-9 4
4016-14-2 4
4162-45-2 4
4170-30-3 4
4694-91-1 5(a)(2)
5026-74-4 4
5216-25-1 4
5255-75-4 4
5344-82-1 4
5493-45-8 4
5958-25-8 5(a)(2)
6178-32-1 4
6196-98-1 5(a)(2)
6304-39-8 5(a)(2)
6422-86-2 4
6752-33-6 5(a){2)
7027-11-4 5(a)(2)
7195-45-1 4
7328-97-4 4
7422-52-8 4
7440-36-0 4
7665-72-7 4
7779-31-9 5(a)(2)
7789-99-3 5(a){2)
7803-55-6 4
9030-09-5 5(a)(2)
10333-53-6 5(a)(2)
10588-01-9 6
12027-96-2 5(a)(2)
12036-37-2 5(a)(2)
12056-51-8 5(a){2)
13236-02-7 4
13561-08-5 4
13654-09-6 5(a)(2)
14228-73-0 4
15827-56-2 5(a)(2)
15965-99-8 4
16245-77-5 4
16245-97-9 4
16532-79-9 4
17557-23-2 4
17963-04-1 4
18241-31-1 5(e)
19201-36-6 5(a)(2)
19721-22-3 5(a)(2)
20166-73-8 5(a)(2)
20217-01-0 4
20830-81-3 4
21160-95-2 5(a){2)
21807-69-2 5(a)(2)
21850-44-2 4
22421-59-6 4
25155-23-1 4
25327-89-3 4
25550-98-5 4
26447-14-3 4
26761-45-5 4
26967-76-0 4
27193-86-8 4
27554-26-3 4
27610-48-6 5(e)
27753-52-2 5(a)(2)
27858-07-7 5(a)(2)
27970-79-2 5(e)
28108-99-8 4
28109-00-4 4
28554-31-6 5(a)(2)
29091-20-1 5(a)(2)
29305-12-2 5(a)(2)
29570-58-9 5(a)(2)
29761-21-5 4
30486-37-4 5(a)(2)
32534-81-9 4
32536-52-0 4
32568-89-1 4
IUR 1994
A-5
-------
CAS
Registry
Number
Regulated Under
TSCA
Section (si
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
34415-31-1 5(a)(2)
34621-99-3 5(a)(2)
35243-89-1 4
36355-01-8 5(a)(2)
37853-59-1 4
37853-61-5 4
38304-52-8 4
38954-75-5 4
41137-60-4 5(a)(2)
41240-76-0 5(a)(2)
42404-50-2 5(a)(2)
42594-17-2 5(a)(2)
47758-37-2 5(a)(2)
51160-97-5 5(a)(2)
52277-33-5 5(a)(2)
52495-71-3 5(a)(2)
54208-63-8 4
54398-08-2 5(a)(2)
54423-67-5 5(a)(2)
55205-38-4 4
56803-37-3 4
58965-66-5 5(e)
59789-51-4 5(a)(2)
60466-61-7 5{a)(2)
60501-41-9 4
61167-58-6 5(a)(2)
61167-60-0 5(a)(2)
61578-04-9 4
62435-71-6 5(e)
65652-41-7 4
65992-66-7 5(a)(2)
67786-03-2 4
68081-84-5 4
68134-06-5 4
68134-07-6 4
68490-66-4 5(a)(2)
68515-42-4 4
68515-47-9 4
68515-48-0 4
68515-49-1 4
68515-50-4 4
68515-51-5 4
68517-02-2 4
68609-96-1 4
68609-97-2 4
68959-23-9 4
68987-80-4 4
69155-42-6 4
70693-06-0 4
71033-08-4 4
71526-07-3 5(a)(2)
71808-64-5 4
72319-24-5 4
74398-71-3 4
75150-13-9 4
75405-06-0 5(a)(2)
75980-60-8 5(a)(2)
79771-08-7 5(a)(2)
79771-09-8 5(a)(2)
80584-91-4 5(f)/6(a)
80584-92-5 5(f)/6(a)
81517-07-9 5(e)
84268-08-6 5(a)(2)
84583-67-5 5(e)
84583-77-7 5(e)
84852-15-3 4
85029-61-4 5(a)(2)
85137-09-3 5(a)(2)
85204-21-3 5(f)/6(a)
85412-54-0 5(a)(2)
85712-26-1 5(a)(2)
85712-27-2 5(a)(2)
86178-38-3 5(a)(2)
87320-05-6 5(a)(2)
87676-07-1 5(a)(2)
89800-10-2 5(a)(2)
90884-29-0 5(a)(2)
92484-07-6 5(a)(2)
93589-69-6 5(a)(2)
94108-97-1 5(a)(2)
IUR 1994
A-6
-------
CAS
Registry
Number
Regulated Under
TSCA
Section (si
CAS
Registry
Number
Regulated Under
TSCA
Section (s)
94148-67-1 5(a)(2)
95732-35-7 5(a)(2)
95823-36-2 5(e)
96478-09-0 5(a)(2)
96549-95-0 5(a)(2)
96915-49-0 5(a)(2)
96915-50-3 5(a)(2)
100545-50-4 5(a)(2)
101646-62-2 5(a)(2)
101646-63-3 5(a)(2)
102093-68-5 5(a)(2)
103192-58-1 5(a)(2)
103458-56-6 5(a)(2)
103490-06-8 5(a)(2)
103490-08-0 5(a)(2)
103697-96-7 5(a)(2)
104503-68-6 5(a)(2)
104983-85-9 5(a)(2)
105658-30-8 5(a)(2)
106143-20-8 5(a)(2)
106158-22-9 5(a)(2)
106246-33-7 5 (a) (2)
106569-82-8 5(e)
109578-44-1 5(e)
110843-97-5 5(a)(2)
116671-32-0 5(a)(2)
118270-87-4 5(a)(2)
119438-11-8 5(a)(2)
121144-97-6 5(a)(2)
121255-03-6 5(a)(2)
121733-80-0 5(a)(2)
122035-71-6 5(a)(2)
124993-63-1 5(a)(2)
125304-11-2 5(a)(2)
125630-94-6 5(a)(2)
125904-10-1 5(a)(2)
125904-11-2 5(a)(2)
125997-20-8 5(a)(2)
126505-35-9 5(a)(2)
129733-59-1 5{a)(2)
130097-33-5 5(a)(2)
130169-66-3 5(a)(2)
130353-62-7 5(a)(2)
130728-76-6 5(a)(2)
131298-44-7 5(a)(2)
132739-31-2 5(e)
133911-74-7 5(a)(2)
133911-76-9 5(a)(2)
134083-75-3 5(a)(2)
134818-69-2 5(a)(2)
136210-32-7 5(a)(2)
136504-96-6 5(a)(2)
137873-52-0 5(a)(2)
138859-29-7 5(a)(2)
139018-98-7 5(a)(2)
141686-56-8 5(a)(2)
142828-65-7 5(a)(2)
144761-93-3 5(a)(2)
145556-04-3 5(a){2)
146987-99-7 5(a)(2)
147129-86-0 5(a)(2)
147170-47-6 5(a)(2)
148373-01-7 5(a)(2)
148993-99-1 5(a)(2)
151686-36-1 5(e)
151717-27-0 5(a)(2)
152007-82-4 5(a)(2)
153454-44-5 5(a)(2)
153590-17-1 5(a)(2)
154397-82-7 5(e)
Accession
Number
Regulated
Under TSCA
Section (s)
30309 5(a)(2)
32178 5(a)(2)
38585 5(a)(2)
39168 5(a)(2)
IUR1994
A 7
-------
Accession
Number
Regulated Under
TSCA
Section (s)
Accession
Number
Regulated Under
TSCA
Section (s)
41259 5(a)(2)
42741 5(a)(2)
43313 5(a)(2)
43993 5(a)(2)
44292 5(a)(2)
45002 5(a)(2)
49435 5(a)(2)
49457 5(a)(2)
50567 5(a)(2)
52381 5(a)(2)
52676 5(a)(2)
53215 5(a)(2)
53862 5(a)(2)
55904 5(a)(2)
56236 5(a)(2)
57397 5{a)(2)
58834 5{a)(2)
59531 5(a)(2)
59622 5(a)(2)
60425 5(a)(2)
60787 5(a)(2)
62283 5(a)(2)
62625 5(a)(2)
62705 5(f)/6(a)
64621 5(a)(2)
65328 5(a)(2)
65599 5(a)(2)
66116 5(a)(2)
66387 5(a)(2)
66503 5(a)(2)
66616 5(a)(2)
66898 5(e)
67993 5(a)(2)
68101 5
-------
Accession
Number
Regulated Under
TSCA
Section (si
Accession
Number
Regulated Under
TSCA
Section (s)
105578 5(a)(2)
106720 5(a)(2)
106877 5(a)(2)
107450 5(a)(2)
108260 5(a)(2)
108635 5(a)(2)
108737 5(e)
108851 5(a)(2)
109525 5(a)(2)
110828 5(a)(2)
111423 5(a)(2)
112233 5(a)(2)
112277 5(a)(2)
112380 5(a)(2)
112766 5(a)(2)
113236 5(a)(2)
113372 5(a)(2)
113736 5(a)(2)
114024 5(a)(2)
115209 5(a)(2)
115538 5(a)(2)
115981 5(a)(2)
116439 5(a)(2)
116531 5(e)
116917 5(e)
117090 5(a)(2)
118526 5(a)(2)
119450 5(a)(2)
119585 5(a)(2)
120208 5(a){2)
120866 5(a)(2)
121585 5(a)(2)
121621 5(a)(2)
121972 5(a)(2)
122395 5(a)(2)
122464 5(a)(2)
122704 5(a)(2)
122908 5(a)(2)
123116 5(a){2)
123296 5(a)(2)
123401 5(a)(2)
123650 5(a)(2)
123785 5(a)(2)
123898 5(a)(2)
123912 5(a)(2)
124540 5(a)(2)
124595 5(a)(2)
124722 5(a)(2)
125292 5{a)(2)
125792 5(a)(2)
125883 5(a)(2)
126002 5(a)(2)
126615 5(a)(2)
126784 5(a)(2)
127992 5(a)(2)
128155 5(a)(2)
128520 5(a)(2)
129147 5(a)(2)
129487 5(a)(2)
129750 5(a)(2)
129829 5(a)(2)
130291 5(e)
130428 5(a){2)
131125 5(a)(2)
131943 5(a)(2)
132537 5(a)(2)
132651 5(e)
132811 5(a)(2)
133201 5(a)(2)
133256 5(a)(2)
133336 5(a)(2)
134077 5(aM2)
136722 5(a)(2)
137361 5(a)(2)
138217 5(a)(2)
140502 5(a)(2)
143636 5(a)(2)
144231 5(a)(2)
149872 5(e)
149907 5(a)(2)
IUR 1994
A 9
-------
Accession Regulated Under Regulated Under
Number TSCA Accession TSCA
Section (s) Number Section (s)
151032 5(a)(2)
151690 5(a)(2)
154473 5(e)
156424 5(a)(2)
156526 5(a)(2)
158715 5(a)(2)
159003 5(a)(2)
166768 5(a){2)
167227 5(a)(2)
167910 5{a)(2)
168822 5(a)(2)
168935 5(a)(2)
170059 5(a)(2)
170219 5(a)(2)
171063 5(a)(2)
173014 5(a)(2)
173296 5(a)(2)
173310 5(a)(2)
173343 5(a)(2)
174324 5(a)(2)
174722 5(a)(2)
176875 5(a)(2)
178097 5(a)(2)
179090 5(a)(2)
179578 5(a)(2)
IUR1994 A-10
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Appendix B
Instructions for Submitting IUR Reports on Magnetic Media
EPA is encouraging ail 1994 IUR submitters to file their IUR reports in an
electronically readable format. Magnetic media submissions are preferred because
handling and archiving are more efficient and there is less likelihood of transcription
error than with paper copies.
These instructions are furnished for two purposes: to allow companies to
determine whether they are able to comply with the general instructions for magnetic
media submissions, and to provide the responsible computer professionals the
technical specifications they need to actually prepare the IUR electronic reports.
GENERAL INSTRUCTIONS
An electronic IUR submission is produced by a plant site or company mailing
to EPA two flat ASCII files which report the appropriate production information from
each plant site. All such submissions must be on diskette. Instructions in this
appendix describe who can report by such files, how to prepare the reporting packet,
specifications for the preparation of the files, and a detailed description of their
contents. Finally, instructions for mailing the submission are included.
Minimal Magnetic Media Reporting Restrictions in 1994
In the 1986 reporting cycle, no form U's containing chemicals with claims for
confidentiality could be submitted via magnetic media; however, this restriction is no
longer valid. Magnetic Form U reports may include chemicals with claims for
confidentiality; a report with a variety of confidentiality claims on one submission is
also acceptable.
There is also no longer a minimum or maximum number of chemicals to qualify
for electronic reporting; any number is acceptable. However, there is a maximum of
999 chemicals from one plant site.
There are only two magnetic media restrictions remaining:
1) Importers who are unaware of the chemical identity of the substance
which they are importing must report via hard copy; no magnetic media
reporting is permitted. In this case, the foreign supplier must have a
hard copy of the Form U to provide the identity information to the EPA.
2) Any chemical with production volume exceeding 999,999,999,999 Ibs.
must be reported on hard copy.
IUR 1994 B'1
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No magnetic tapes will be accepted in this reporting cycle. Only diskettes can
be processed in 1994.
Hard CODV Form Still Required
Persons who file via magnetic media are still required to fill in the top portion
of the hard copy Form U report with the certification statement and signature,
technical contact and company name, and plant site information in accordance with
subsection IV.D.2. (page 23) of the instruction manual. Any accompanying
information, e.g., substantiation claim for CBI claims on chemical ID or Form C's for
Inventory corrections, would also be attached as hard copy pages. Only the chemical
substance identity/activity/production volume/confidentiality information can be
furnished on the magnetic media.
Note also that no corrections for any previously submitted reporting may be
made on magnetic media, for 1994 or any earlier reporting cycle. Corrections must
always be provided to EPA as hard copy.
TECHNICAL INFORMATION
Types of Acceptable Media
In this cycle, magnetic tapes will not be accepted. Only ASCII diskette
submissions from IBM and compatible personal computers are permissible. The
person preparing the submission should check file contents via the TYPE command
in DOS to ensure that the files are in ASCII format.
DISKETTE SUBMISSION TECHNICAL SPECIFICATIONS:
DOS formatted: 2.3 or higher
Double Density or High Density
3.5" or 5.25" diskette dimensions
ASCII text only (no word processing, data bases, or spread sheet files in native
format)
One Form U Number per Site
The Form U number on the top right of the form uniquely identifies the plant
site. For 1994 reporting, the EPA will assign Form U numbers starting from
61100000. Numbers lower than 61100000 are unacceptable for 1994 reports.
Each plant site must use a different Form U number. All plant sites must
submit a minimum of one hard copy Form U with the top portion filled out. Every line
IUR1994 B-2
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of the electronic file(s) will contain the Form U number which corresponds to the top
of the Form U filled out for that site.
A single Form U will generally suffice for any single plant site if magnetic
reporting is anticipated for every substance. This differs from hard copy reporting,
where only ten chemicals are reportable per form. There is an upper limit of 999
chemicals from one site, corresponding to one Form U number, if a diskette is used
to convey the chemical information. For example, plant site A could report on 135
chemicals using one Form U number and filling out only the top portion of only one
Form U. In the unlikely event that more than 999 chemicals are reportable from one
plant site, a second Form U will be required.
Data File Formats
For each plant site, two ASCII data files will be prepared. The first data file is
a chemical name file (N is the record type and the first character in each line). The
second data file is a submitter production file (D is the record type and the first
character in each line). These files together will correspond to the chemical identifi-
cation/activity/confidentiality block of the Form U (Blocks A. through H.).
The chemical name file and the submitter production file must be submitted as
two separate files, rather than as alternating records in one consolidated file.
The file format layouts for reporting are in Exhibits B-1 and B-2. There should
be no deviations from these file formats. Use the designated constants and do not
use any delimiters. Where blanks or spaces are acceptable, be sure to maintain the
specified column positions by spacing over to the desired starting point.
Samples of valid electronic reporting are provided in Exhibit B-3. The first field
in each file consists of the record type, either D or N, followed by a two digit number
denoting the number of record occurrences for the substance (always "00" for the D
file, see N file layout for more information on this number in the N file). Next is the
Form U number for the site, followed by a "line" number. The line numbers start with
'001' and each substance is assigned a sequential line number by the submitter. For
example, in a valid submitter production file the first six lines might begin with these
characters in the first fourteen columns:
D0061100012001...
D0061100012002...
D0061100012003...
D0061100012004.. .
D0061100012005.. .
D0061100012006...
IUR 1994
B-3
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There can be up to 999 lines, e.g., chemicals, reported per one plant site using
one Form U number.
Submitters should not mix reporting from several sites in one file. Each site
should submit two ASCII files, one for chemical names and one for submitter
production data. Both of the files will start with identical digits in the columns 4-14.
Both of the files will have the same number of lines (except where chemical names
are very long. See below for additional details on handling long names).
Companies may, however, submit the pairs of plant site files from multiple plant
sites on one diskette, e.g., Company A might submit a single diskette with twenty
four files, which consist of twelve chemical name files and twelve submitter
production files, corresponding to twelve plant sites.
File Naming Conventions
Submitters should name diskette files using the Form U number, e.g. for
Company A's plant site in Hometown, KY, the chemical name file might be
61100012.NAM and the submitter production file might be 61100012.SUB. Use of
this convention will provide consistency.
IUR1994 B-4
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Exhibit B-1
Chemical Name File Format
Column Column Type
Start End11
Definition/Requirements
1. Record Type
1
1 CH Constant value of "N" to indicate that
the record contains a chemical name.
Mandatory.
Sequence
Number
NU Refers to the number of 135 byte
segments for the chemical name.
Values range from "01" to "99". The
first segment would be "01", the
second segment of the chemical name
would be "02", etc. Mandatory.
3. Form Number
11 CH Left justified. Corresponds to the Form
U number on the submitter production
file and the Form U for the plant site.
Mandatory.
4. Line Number
12
14 NU Right justified; zero filled. Corresponds
to the line number on the submitter
production file. (Exhibit b-2)
Mandatory. Example: "003".
5. Chemical Name 15
149 CH 135 byte segments of the chemical
name for the substance being reported.
Mandatory.
End of Chemical Name Record Layout.
NU = Numeric; CH = Alphanumeric Character
IUR 1994
B-5
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Chemical Name File Instructions (File N)
There is only one record format in this file. No blanks or spaces, other than
those in the chemical name or at the end of the chemical name, will be included.
Each record begins with the upper case "N" character in column 1 (field #1 =
Record Type).
The sequence number in columns 2 3 (field # 2 = Sequence Number) is
always right justified and zero filled, e.g. 01, 02. For names shorter than 135 bytes,
the sequence number will always be "01" and the Form U and line number
combination (fields # 3 and 4) will occur only once per file.
If the chemical name (field # 5 = Chemical Name) is longer than 135 bytes, the
sequence number in columns 2-3 will reflect the multiple occurrence, as follows. In
this case, the Form U and line number combination (fields # 3 - 4, or cols. 4-14) may
occur more than once per file.
Example of a long chemical name record for Form U 61100012, line 005:
First segment of the chemical name will start with
NpJ.61100012005Methyl... (sequence number of "01")
Second segment of the chemical name for the same substance will begin with
N0261100012005benzyl... (sequence number of "02")
The line number in columns 12 14 (field #4 = Line Number) is always right
justified and zero filled, e.g., "005".
IUR 1994 B - 6
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Exhibit B-2
Submitter Production File Format
Field Name
Column Column Type
Start End
Definition/Requirements
1. Record Type
1
1 CH Constant value of "D" to indicate that the record
contains submitter production data, such as
chemical identification numbers, activity, pro-
duction volumes, and CBI claims. Mandatory.
2. Sequence Number
NU Sequence number for a "0" record type is
always "00". Mandatory.
3. Form Number
11 CH Left justified. Corresponds to Form U number
on plant site form. Mandatory.
4. Line Number
12
14 NU Right justified; zero filled. Each substance is
assigned a unique line number. Allowed values
from "001" through "999". Mandatory.
CAS Registry
Number
15
23 NU Right justified; zero filled. Example:
000050000. Blank if unknown.
6. EPA Accession
Number
24
32 NU Right justified; zero filled. Example: 000055555.
Blank if not used.
Original Inventory
Number
33
40 NU Right justified; zero filled. Only to be used if
neither field 5 or 6 is filled in. Corresponds to
form A, B, C or E. Example: 33000001. Blank if
not used.
8. Original Inventory
Line Number
41
43 NU Right justified; zero filled. Values from "001" to
"999". Only to be used if field 7 is also filled in.
If form C was used for reporting, this field
always contains "001". Blank if not used.
PMN Number
44
51 NU Left justified; no hyphens. Format is
PYYNNNNA, where P is a constant, YY indicates
year, NNNN is a four digit zero filled sequence
number and A is an optional suffix. Example:
P860023. Blank if not used.
10. Bona Fide Number
52
60 NU Left justified; no hyphens. Format is
52YYNNNNN, where "52" is a constant, YY in-
dicates year, and NNNNN is a five digit
sequence number. Example: 528800011.
Blank if not used.
11. TMEA Number
61
68 CH Left justified; no hyphens. Format is
TYYNNNNA, where T is a constant, YY
indicates year, NNNN is a four digit zero filled
sequence number and A is an optional suffix.
Example: T850023B. Blank if not used.
IUR 1994
B-7
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Field Name Column
Start
1 2. Activity 69
13. CBI Activity 70
14. Site Limited 71
15. CBI Site Limited 72
16. CBI Plant Site 73
17. Production Volume 74
1 8. CBI Production 86
Volume
1 9. CBI Chemical 87
Identity
Column Type Definition/Requirements
End
69 CH "M" for Manufacture, or "I" for Import. Create a
second line if a chemical is both manufactured
and imported at same plant site. Mandatory.
70 CH "Y" for YES, or "N" for NO to indicate a CBI
claim for the activity. Mandatory.
71 CH "X" if the chemical is consumed in entirety on
site, BLANK if not. Mandatory.
72 CH "Y" for YES, or "N" for NO to indicate a CBI
claim for the SITE LIMITED status in filed #14.
Mandatory.
73 CH "Y" for YES, or "N" for NO to indicate a CBI
claim for the PLANT SITE name and address.
Mandatory.
85 NU Right justified, with leading zeros, no commas or
decimals. Report volume in pounds. No
scientific notation. Mandatory.
86 CH "Y" for YES, or "N" for NO to indicate a CBI
claim for the PRODUCTION VOLUME value in
field 17. Mandatory.
87 CH "Y" for YES, or "N" for NO to indicate a CBI
claim for the chemical identity, which is a
combination of the identifier and the chemical
name. Mandatory.
End of Submitter Production Record Layout.
NU = Numeric; CH = Alphanumeric Character
IUR 1994
B-8
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Submitter Production File Instructions (File D)
There is only one record format in this file. Each record begins with an upper
case "D" in column 1 (Field #1 = Record Type), followed by the constant "00" in
columns 2 3 (Field #2 = Sequence Number). Fields #1 through #4 ("DOO" or
Record type/Sequence number, Form U number, Form U 'line') are mandatory on each
line. The same Form U number (Field #3) and Line number (Field #4) combination can
occur only once per file.
In reporting a chemical identifier in fields #5 through #11 or columns 15 - 68,
several options are available. The submitter is expected to fill out only one chemical
identifier (either field #5, #6, #7 and #8, #9, #10 or #11) and leave the remaining
fields blank. See Section III.C.5.b. and c. (page 16) of the manual for guidance.
Other than within the chemical identifier area (fields #5-11, columns 15 - 68),
blanks or spaces are acceptable only in the column for Site Limited (field #14; col.
71). All numeric values must be zero filled and right justified. All alphabetic
characters must be upper case. Entries in fields #12, #13 and #15 through #19,
columns 69 - 70 and 72 - 87, are mandatory; no blanks or spaces are allowed.
IUR1994 B-9
-------
Exhibit 3: Example of Valid IUR Diskette Reporting Files
PRODUCTION FILE 61100012.SUB: (Column Positions specified for ease in interpretation)
1 2 3 4 5 6,7 8
12345678901234567890123456789012345678901234567890123456789012345678B012345678901234567
File Begins Here:
D0061100012001000050000
D0061100012002010010670
D0061100012003000050011
D0061100012004000050011
D0061100012005000067641
D0061100012006
D0061100012007028118107
000105553
MN NN000000333000NN
MNXYN000000033000YN
MN NN000987444000NN
IN NN000008008888NN
MN NN000000123435NN
IY NN000088770000YY
MN NN000004440000NN
CHEMICAL NAME FILE 61100012.NAM: (Column Positions specified for ease in interpretation)
123456789
1
0..
File Begins Here:
N0161100012001Formaldehyde
N01611000120021,4-Piperazinediethanesulfonic acid, monosodium salt
N0161100012003Guanidine, monohydrochloride
N01611000120042-Propanone
N01611000120052-Propanone
N0161100012006Naphthalene, 1,3,5-trisubstituted, alkali salt
N01611000120071H-Benzimidazolium, 5,6-dichloro-2-[3-(5,6-dichloro-l,3-diethyl-l,3-dihydro-2H-benzimi...2
N0261100012007ylidene)-1-propenyl-]-l-ethyl-3-...
IUR 1994
B- 10
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MAILING INSTRUCTIONS
If the diskette contains CBI, it should be physically labeled indicating that it
"Contains TSCA CBI". It should be identified with the company name and, if
appropriate, the plant site. Read-only tab protection should be applied. If more than
one diskette is submitted by a company, the labels should also indicate the number
and the total number, e.g., disk 1 of 2, disk 2 of 2.
Diskettes should be placed in a durable mailing container, as damaged diskettes
will be returned to the submitter without further attempt by EPA to recover data. It
is advisable to send a backup diskette, in case of damage to the primary diskette.
All feasible precautions in mailing magnetic media containing CBI should be
adopted by the submitter for its protection, such as double wrapped envelopes,
registered mail, etc., just as one would apply to the hard copy submission. The
signed Form U should also be included in the same mailing packet.
Cover letters accompanying any magnetic media submission should refer to the
CBI status of the submissions, and should list plant site, Form U numbers and the
corresponding file names. Number of records (chemicals) per file may also be
specified. A technical contact name for data processing matters, if different from the
contact on the form, should be identified in the cover letter.
Questions about the magnetic media submission instructions should be
addressed to:
•
TSCA Hotline
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7408)
401 M Street, S.W.
Washington, DC 20460
Attn: Inventory Update Rule
Telephone: (202) 554-1404
IUR1994 e-11
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