&EPA
United States
Environmental Protection
Agency
Oftice of
Toxic Substances
Washington. D.C. 20460
June 1979
Tome Substances
The Toxic Substances
Control Act
Law 94-469
Reporting for the
Chemical Substance
Inventory
Instructions For Reporting
for the Revised Inventory
-------
The Toxic Substances Control Act
Public Law 94-469
Reporting for the Chemical Substances Inventory
Instructions for Reporting
for the Revised Inventory
U.S. Environmental Protection Agency
Office of Toxic Substances
Washington, DC 20460
-------
FOREWORD
The Toxic Substances Control Act's (TSCA) Initial Inventory of
Chemical Substances, published on June 1979, includes chemical
substances reported to EPA by their manufacturers and importers
in accordance with the TSCA inventory reporting regulations.
During the 210-day reporting period that begins June 1, 1979,
processors and users of chemical substances for commercial
purposes and importers of chemical substances as part of mix-
tures or articles for commercial purposes may report substances
that were not included on the Initial Inventory for inclusion
on a Revised Inventory, which will be published sometime in
1980. This booklet provides reporting instructions for the
Revised Inventory.
-------
TABLE OF CONTENTS
Page
INTRODUCTION 1
INVENTORY TIME LINE 3
CHAPTER I. REPORTING FOR THE REVISED INVENTORY 5
A. Who May Report 5
B. What May Be Reported 5
C. When to Report 9
D. How to Determine Whether to Report 9
E. Further Assistance 11
CHAPTER II. HOW TO COMPLETE THE REPORT FORM 15
CHAPTER III. IDENTIFYING CHEMICAL SUBSTANCES 19
A. Reporting the Identity of a Class I
Chemical Substance 19
B. Reporting the Identity of a Class II
Chemical Substance 26
CHAPTER IV. CONFIDENTIALITY 31
APPENDIX 1. INVENTORY REPORTING REGULATIONS 37
APPENDIX 2. SOURCES OF CAS REGISTRY NUMBERS 43
-------
INTRODUCTION
The Environmental Protection Agency (EPA) promulgated the
inventory reporting regulations (40 CFR Part 710) on December
23, 1977 under the authority of section 8 of the Toxic Substances
Control Act (TSCA). These regulations, which appear as Appendix 1
of this booklet, govern the reporting of chemical substances
to create an Inventory of chemical substances manufactured, im-
ported or processed in the United States for a commercial purpose.
The inventory reporting regulations establish a two phase
reporting schedule for compilation of the Inventory. During
a 120-day reporting period in early 1978, manufacturers and
importers reported chemical substances to EPA for inclusion on
an Initial Inventory. Publication of the Initial Inventory marks
the beginning of the second phase, a 210-day reporting period
during which processors and users of chemical substances and
importers of chemical substances as part of mixtures or articles
will have an opportunity to add substances to the Inventory to
ensure compliance with TSCA. The second phase will result in
publication of a Revised Inventory sometime in 1980.
Publication of the Initial Inventory sets into motion the
premanufacture notification provisions of section 5 of TSCA.
Under these provisions a person must notify EPA at least 90 days
before he intends to manufacture or import a chemical substance
that is not included on the Inventory. These provisions take
effect on July 1, 1979, thirty days after publication of the
Initial Inventory, for manufacturers and importers (in bulk) of
chemical substances, and thirty days after publication of the
Revised Inventory for importers of chemical substances as part
of mixtures. The time line on page 3 illustrates the relation-
ship between the Initial and Revised Inventory and premanufacture
notification. Thirty days after publication of the Revised In-
ventory it will become unlawful for any person to use for a
commercial purpose a chemical substance that was manufactured,
imported, or processed in violation of section 5 of TSCA.
Persons should examine carefully the Initial Inventory and
the Trademark and Product Name List before reporting a substance,
in order to determine whether the substance is already included
on the Inventory. Substances that appear on the published Initial
Inventory should not be reported for the Revised Inventory. To
further assist persons in determining whether to report for the
Revised Inventory, EPA will publish one or more supplements to
the Initial Inventory before the Revised Inventory is published.
The supplement(s) will include substances that were omitted from
the Initial Inventory due to late reporting or errors, substances
-I-
-------
reported for the Revised Inventory, and substances that have
completed premanufacture review AND have begun to be manufac-
tured or imported.for commercial purposes.
The Initial Inventory is part of a four volume set. The
Inventory itself is contained in Volume I, and includes two
appendices. Appendix A: Chemical Substance Definitions, identi-
fies further chemical substances whose preferred names alone on
the Inventory do not permit their unambiguous identification.
Appendix B: Confidential Chemical Substance Identities, lists
generic names for substances whose specific chemical identities
were claimed as confidental for purposes of the Inventory. The
other three volumes, entitled User Guide and Indices to the Initial
Inventory, were published for use in conjunction with, but not as
a substitute for, the Initial Inventory. The three indices, the
Substance Name Index (contained in Volumes II and III) and the
Molecular Formula and UVCB* Indices (contained in Volume IV) pro-
vide alternate means for finding substances which are listed on
the Inventory.
In addition to the four volumes, EPA has published a two
volume Trademark and Product Name List, which was compiled from
Voluntary Product Trademark Report Form D's submitted to EPA
during the Initial Inventory reporting period. This list was
compiled solely to assist processors in determining whether to
report for the Revised Inventory. If a processor finds the name
of a product he processes on this list, he does not need to report
it for the Revised Inventory.
*Chemical Substances of Unknown or Variable Composition, Complex
Reaction Products and Biological Materials.
-2-
-------
INVENTORY TIME LINE
June 1, 1979.
30 DAYS
July 1, 1979.
1
210 DAYS
I
Undetermined Date.
December 31, 1979
V
Publication of
Initial Inventory;
Begin reporting
period for Revised
Inventory
. PMN begins for
manufacturers
and importers
of chemical
substances in
"bulk form"
.Supplement(s) to
Initial Inventory
End of reporting
period for Revised
Inventory
Undetermined Date.
30 DAYS
Undetermined Date
I
Publication of
Revised Inventory
• PMN begins for
importers of
chemical sub-
stances as part
of mixtures;
section 15(2)
of TSCA applies
to processors
and users
-3-
-------
Chapter I
REPORTING FOR THE INVENTORY
A. Who May Report
The following persons may report a chemical substance that
is not included on the published Initial Inventory for inclusion
on the Revised Inventory:
(1) a person who has processed or used a chemical
substances (including use in the manufacture of a
mixture or article containing that chemical substances)
for a commercial purpose since January 1, 1975.
OR
2) a person who has imported a chemical substance as part
of a mixture or article for a commercial purpose since
January 1, 1975.
Any person who is permitted to report substances for the
Revised Inventory may either report individually or authorize a
trade association or other agent to report on his behalf.
B. What May Be Reported
To be reportable for the Revised Inventory, a substance must
not be listed on the Initial Inventory and must satisfy all of
the following three criteria:
1) It must be a "chemical substance" as defined by section
710.2(h) of the inventory reporting regulations;
2) It must have been manufactured, imported, or processed
for commercial purposes in the United States since
January 1, 1975; and
3) It must not be excluded from the Inventory by any
provision of section 710.4 of the regulations.
The Toxic Substances Control Act distinguishes three types
of materials: (1) chemical substances, (2) mixtures of chemical
substances, and (3) articles comprised of chemical substances or
mixtures. The Inventory will list only chemical substances. It
will not list mixtures or articles. It wi'll list, however, chem-
ical substances of which mixtures and articles are comprised.
Chemical substance is defined in section 710.2(h) of the regu-
lations as any organic or inorganic substance of a particular
molecular identity, including any combination of such substances
occurring in whole or in part as a result of a chemical reaction
or occurring in nature, and any chemical element or uncombined
radical; except that "chemical substance" does not include:
1) any mixture [710.2(q)]* {31-36}
2) any pesticide when manufactured, processed, or
distributed in commerce for use as a pesticide
[710.2(b)] {37-39},
3) tobacco or any tobacco product, but not including
any derivative products,
•Pertinent citations of the regulations (see Appendix 1) are
given in square brackets, e.g. [710.2(h)]. Pertinent comment
and responses which accompanied the regulations, are cited by
enclosure in braces, e.g. {73}.
- 5 -
-------
4) any source material, special nuclear material, or
byproduct material [710.2(c)],
5) any pistol, firearm, revolver, shells and cartridges,
and
6) any food, food additive, drug, cosmetic or device,
when manufactured, processed, or distributed in
commerce for use as a food, food additive, drug,
cosmetic, or device [710.2 (a)] ' {37, 40-42}.
Chemical substance is defined by chemical composition, by
source or origin, and by excluding those categories of materials
which are not considered substances. The materials identified
in the list above must not be reported for the Inventory.
For a more complete discussion on substances that are re-
portable, you are directed to read Eligibility Criteria For
Inclusion of Chemical Substances on the Inventory found in the
introduction of Volume I of the Initial Inventory.
Excluded Substances
Some materials which are "chemical substances" and which
have been processed for commerical purposes since January 1, 1975,
are excluded from the Inventory, and must not be reported. A
chemical substance is excluded if it is, or has been:
1. Manufactured, imported, or processed solely in small
quantities for research and development [710.4(c) (3) ,
710.2(y)] {29, 43-51}.
o The NOTE appearing at section 710.2(y) of the
regulations states that any chemical substance
that is manufactured, imported or processed in
quantities of less than 1,000 pounds annually
is presumed to be an R&D chemical substance.
Such a chemical substance may be reported for
the Revised Inventory, however, if the person
can certify that the chemical substance was not
imported or processed, solely in "small quantities
for research and development".
2. A Mixture
o Section 710.2(q) defines hydrates and hydrated
'ions' as mixtures. A note to 710.4 (c) indicates
that alloys, inorganic glasses, ceramics, frits,
and cements, including Portland cement, are to
be regarded as mixtures. Certain combinations
of metals, inorganic metal compounds, and inert
supports, which are frequently used for commercial
purposes, including for use as solid phase heter-
ogeneous catalysts, are also considered mixtures
and should not be reported. The components of
these mixtures, insofar as they are known, should
be reported if they are not found on the Initial
Inventory.
3. An impurity [710.2(m)], [710.4(d)(1)] {61}
o By this inclusion, impurities are not reportable,
and, furthermore, no chemical substance which is
reported for the Inventory should be identified
in terms of its impurities, or by its commercial
grades. An impurity is defined as an unintended
component of a substance.
4. A byproduct [710.2(q)J which has no commercial purpose.
NOTE:—A byproduct which has commercial value only to
municipal or private organizations who (i) burn it as
-------
fuel, (ii) dispose of it as a waste, including in a
landfill or for enriching soil, or (iii) extract
component chemical value, may be reported for the
Inventory, but will not be subject to premanufacture
notification under section 5 of TSCA if not included
[710.4(d)(2)] {52-55}.
o Byproducts which have commercial value for reasons
other than those specified in the NOTE are not
excluded from the Inventory [see 710.2(p)].
5. A chemical substance which results from a chemical
reaction that occurs incidental to exposure of another
chemical substance, mixture, or article to
environmental factors such as air, moisture, microbial
organisms, or sunlight [710.4(d)(3)].
o Chemical substances, such as rust on iron, or other
corrosion or degradation products, which form
incidental to environmental exposure are excluded
from the Inventory.
6. A chemical substance which results from a chemical
reaction that occurs incidental to storage of another
chemical substance, mixture, or article [710.4(d) (4)] .
o Degradation products which form incidental to the
storage of a chemical substance, such as the partial
polymerization of a drying oil, are excluded from
the Inventory.
7. A chemical substance which results from a chemical
reaction that occurs upon end use of other chemical
substances, mixtures, or articles such as adhesives,
paints, miscellaneous cleansers or other housekeeping
products, fuels and fuel additives, water softening and
treatment agents, photographic films, batteries,
matches, and safety flares, and which is not itself
manufactured for distribution in commerce or for use as
an intermediate [710 .4(d) (5)].
o Chemical substances that are the components of
curable plastic or rubber molding compounds, inks,
etc., are not excluded from the Inventory by this
provision; only the chemical substances that are
formed upon use of such materials are excluded.
8. A chemical substance which results from a chemical
reaction that occurs upon use of curable plastic or
rubber molding compounds, inks, drying oils, metal
finishing compounds, adhesives, or paints; or other
chemical substances formed during manufacture of an
article destined for the marketplace without further
chemical change of the chemical substances except for
those chemical changes that may occur as described in
section 710.4(d) of the regulations [710.4(d) (6) ] .
o Chemical substances which are the components of
curable plastic or rubber molding compounds, inks,
etc. are not excluded from the Inventory by this
provision; only the chemical substances which are
formed upon the use of such materials are excluded.
9. A chemical substance which results from a chemical
reaction that occurs when (i) a stabilizer, colorant,
odorant, antioxidant, filler, solvent, carrier,
surfacant, plasticizer, corrosion inhibitor, antifoamer
or defoamer, dispersant, precipitation inhibitor,
binder, emulsifier, demulsifier, dewatering agent,
-7-
-------
agglomerating agent, adhesion promoter, flow modifier,
pH neutralizer, sequesterant, coagulant, flocculant,
fire retardant, lubricant, chelating agent, or quality
control reagent functions as intended or (ii) a
chemical substance, solely intended to impart a specific
physico-chemical characteristic, functions as intended
[710.4(d)(7)].
o The substances comprising the various materials
listed above are not excluded from the Inventory;
only the chemical substances unintentionally formed
upon use of such materilas are excluded.
10. A chemical substance which is not intentionally removed
from the equipment in which it was manufactured.
NOTE:—The "equipment in which it was manufactured"
includes the reaction vessel in which the chemical
substance was manufactured and other equipment which
is strictly ancillary to the reaction vessel, and any
other equipment through which the chemical substance
may flow during a continuous flow process, but does
not include tanks or vessels in which the chemical
substance is stored after its manufacture [710.4(d)(8),
710. 2 (n) ] {67-71}.
- 8 -
-------
C. When to Report
The reporting period for the Revised Inventory begins on
June 1, 1979 and ends on December 31, 1979. Persons who begin
processing a chemical substance or importing a chemical substance
as part of a mixture or article FOR THE FIRST TIME after the last
date may report such substance(s) to EPA at the time processing or
importation begins, up to thirty days after publication of the
Revised Inventory.
D. How to Determine Whether to Report
The following suggested procedures are provided to assist
persons who may wish to report a substance for the Revised
Inventory but are unsure whether the substance is included on the
Initial Inventory. Since all reporting is voluntary, you are
under no obligation to follow these procedures, and may use any
suitable method to determine whether you should report.
In general, if a processor has received written certification
from his suppliers that all the component chemical substances in
the product(s) he processes have been reported for the Inventory,
the processor should not be concerned about reporting.
1. If you know the composition of the product:
— Consult the Initial Inventory to determine whether
all the reportable chemical substances comprising the
product are included.
— If all component substances are included on the
Initial Inventory, DO NOT REPORT.
— If one or more component substances are not included
on the Initial Inventory, you should report them for
inclusion on the Revised Inventory by completing a
Form E for each component according to the instructions
provided in Chapter II of this booklet, and submitting
the form to the address provided on it.
2. If you do not know the composition of the product;
— Consult the Trademark and Product Name List to
determine whether the product is included. If the
product is included, DO NOT REPORT.
— If the product is not included in the Trademark and
Product Name List, contact your supplier and ask him
for written certification that all component
substances have been reported for the Inventory.
—'• If your supplier refuses to certify that all
reportable chemical substances comprising the product
have been reported for the Inventory, ask him to
disclose to you the identities of the component
chemical substances.
— If your supplier agrees to disclose to you the
identities of the components, follow part 1 above.
— If your supplier refuses to disclose to you the
identities of the component substances, ask him to
assist you in reporting by following procedure 3 on
page 10.
- 9 -
-------
— If your supplier refuses to assist you in reporting,
submit a letter to EPA providing:
— your company name and address
— the name and address of your supplier
— the name(s) of the product(s) you purchase
— from that supplier
— a signed statement indicating that your supplier
will not certify to you that all reportable
substances comprising the product(s) have been
reported for the Inventory.
— and address this to:
Document Control Officer
Office of Toxic Substances (TS-793)
U.S.E.P.A.
401 M St. S.W.
Washington, D.C. 20460
3. Procedure for Reporting with Supplier Assistance:
Instructions for Reporting Company (i.e., processor/
importer)
— Before completing blocks I-III of the report
form, remove the carbon paper between the
submitting company copy and the acknowledgement
postcard.* (See explanation below.) Enter the
name of your company in Block II. Then, enter
the complete name and address of your supplier,
as the technical contact, in block III.
-- Block I contains the certification statement
which must be signed by an authorized person
of your company.
— In Block IV, check the appropriate box under
the heading "Activity". If you both process
and import the substance and wish to keep that
fact confidential with respect to your supplier,
only check the activity in which you are pri-
marily engaged. You may also claim "Activity"
and/or "Company" as condidential.
--At the bottom of the form, in the space provided
in block IV for supplementary information, print
or type the Product Trade Name.
-- Photocopy the partially completed form for your
records and send the entire form to your supplier.
Remember to write-in your name and address on the
acknowledgement postcard, but do not detach it at
any time.
Instructions for Suppliers (i.e., domestic or foreign
chemical manufacturers):
— Enter the specific chemical identity of the
tradename product indicated by the importer or
processor in block IV. Read carefully the
instructions on how to identify a chemical sub-
stance found in Chapter III of this booklet.
*This report form is designed so that the address entered in
block III will carbon copy onto the attached postcard. Since
this postcard will be returned to that address to verify EPA's
receipt of the form, one should remove the carbon paper between
the submitting company copy and the postcard if the technical
contract address is different from the submitting company address.
On the postcard enter the address to which the card should be
sent. Do not however , detach the postcard from the rest of the
form to insert separately in a typewriter, for example. The
postcard must remain attached to the form.
- 10 -
-------
— If the importer or processor has identified a
product which is an article, mixture, or an
excluded chemical substance, either indicate
that the product contains no reportable sub-
stances or identify the reportable chemical
substance in the product.
— Sign the supplier certification statement
appearing in block I of the form, attesting to
the truth of the statement on the back of the
form. Enter the date you signed the form.
— If you wish to claim the chemical identity or
method of manufacture of the substance
confidential, follow the procedure described in
chapter IV of this booklet, entitled
"Confidentiality." In addition, check the
appropriate box under the heading "Confidentiality
Claims." Suppliers will not have to make
confidentiality claims for "Activity" or "Company"
the processor or importer will have already made
or considered making these claims.
— Retain the last copy, marked "Submitting Company
Copy," and send the remaining form copies to EPA.
E. Further Assistance
If you need further assistance in interpreting the
regulations, finding a substance which may be on the inventory,
or completing the report form, or if you would like to order
additional materials to aid in reporting, contact:
1. EPA's Industry Assistance Office at (800) 424-9065
(Washington, D.C., please call 554-1404). Written
inquiries may be addressed to:
Industry Assistance Office (TS-799)
U.S. Environmental Protection Agency
401 M St., S.W.
Washington, D.C. 20460
2. Your EPA Regional Office. Each Regional Office is
staffed by persons who can respond to your questions
concerning the inventory reporting regulations. The
person to contact in each regional office is identified
on page 13.
- 11 -
-------
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
Regional Offices
NATIONWIDE TOLL-FREE NUMBER: 800-424-9065
*If calling from Washington, D.C: 554-1404
Region I
Mr. Robert Dangel
John F. Kennedy Federal Building
Boston, Massachusetts 02203
617-223-0585
Region II
Mr. William Librizzi
Raritan Depot, Building 209
Edison, New Jersey 08817
201-321-6673
Region III
Mr. Edward Cohen
Curtis Building
6th & Walnut Streets
Philadelphia, PA 19106
215-597-7668
Region IV
Mr. Ralph W. Jennings, Rm. 345
345 Courtland Street, N.E.
Atlanta, Georgia 30308
404-881-3864
Region V
Mr. Karl E. Bremer
230 South Dearborn Street
Chicago, Illinois 60604
312-353-2291
Region IV
Dr. Larry Thomas
First International Building
1201 Elm Street
Dallas, Texas 75270
214-767-2734
Region VII
Mr. William Brinck
324 East llth Street
15th Floor
Kansas City, Missouri 64106
816-374-3036
Region VIII
Mr. Ralph Larsen
1860 Lincoln Street
Denver, Colorado 80295
303-837-3926
Region IX
Mr. Jerry Gavin
215 Freemont Street
San Francisco, California
415-556-3352
Region X
94105
Dr. James Evert
1200 6th Avenue
Seattle, Washington
206-442-1090
98101
- 13 -
-------
IMPORTANT: Bafore completing this lonn. carefully read the Fr*A publication "Reporting for the Chemical
Substance Inventory. Instructions for Reporting for the Revised Inventory."
AGENCY
REPORT
(Section 8(a) and (b) Toxic Substances Control Act 15 DSC 2607)
U.S. ENVIRONMENTAL PROTECTION
CHEMICAL SUBSTANCE INVENTORY
FORM NUMBER
0000000 0
FORM NUMBER
0000000 0
DO NOT REMOVE LABEL
COMPANY NAME/ADDRESS
NAME "KYIS .PiSdce.s.sQHSi.1
AoonEss15i6V7|8i ,Z .Street.
jj ap-5(5,78,91
m.TECHNICAL CONTACT NAME/ADDRESS/PHONE
NAME lA.iS.i iQOilliuiia i i i i i i i i i . i i . i i I
iPjp.qasso.riS.. i .Incu I
I56,7,8j & ,Stre,at . I
, . i . I STATE"! , I
ZIP 156,7,8,91
-|750,-,23fl,-,4532i
I. CERTIFICATION STATEMENT: I hereby certify that (1t I am eligible to teport tor
the Revised Inventory under 40 CHI Pert 710.3(b). and to the ben of my knowledge
•nd beuef. 12) the chemical submnce identilied below <•> is eligible tor inclusion on
the Revised Inventory under 40 Cm 710. and Ib) was not manufactured or imported
in bulk torn, tor a commercial purpose tor the first time after the effective date of pr»-
manutactum notification requirements for manufacturers of chemical substances
and importen of chemical substances In bulk form: (3) ell information emend on this
form is comolets and accurate: and (4) the confidentiality statements on the back of
this form m tme as to that infoimslion for which I have asserted s conMentiafcty
daim. I agnM 10 permit access to. and the copying ol recoids by s duly authorized
representative of the EPA Administrator, in accordance with the Tone Substances
Control Act. to document any information ispffrlerl here.
SIGNATU* a J Oate /
Raymond j. Jchnscff^Vice President
NAME/TITLE (TYPE OR PRINT!
Supplier Signature
IV. CHEMICAL SUBSTANCE IDENTITY / ACTIVITY/CONFIDENTIALITY
CAS REGISTRY
NUMBER
563-45-1
SPECIFIC CHEMICAL NAME
(SEPARATE SYNONYMS WITH A SEMI-COLON)
3-methyl-l-butene: isopropylethylene
ACTIVITY
/ Confidential /
A "am.
IN THE SPACE PROVIDED BELOW. PROVIDE STRUCTURAL
INFORMATION. MOLECULAR FORMULA. AND OTHER
SUPPLEMENTAL INFORMATION TO AID IN THE SPECIFIC
IDENTIFICATION OF THE CHEMICAL SUBSTANCE.
C5H10
D
MOLECULAR FORMULA
See Attached Supplemental Description Sheets
(Write Form Number on all attachments)
H3C-C-C=CH2
H H
Id)
METHOD OF MANUFACTURE IS CONFIDENTIAL
y-7— (Circle applicable information and
ICI mark it CONFIDENTIAL)
CHEMICAL SUBSTANCE IDENTITY IS
CONFIDENTIAL
(1) SUBSTANTIATION:
I I No. of attached substantiation
I I sheets (write form number on
all substantiation sheets)
(2) Proposed Generic Name:
D
(3) I agree to the terms of CONFIDENTIAL
SUBSTANCE IDENTITY STATEMENT on
the back of this form
THE ABOVE IS AN EXAMPLE OF A PROCESSED
CHEMICAL SUBSTANCE FOR WHICH NO
CONFIDENTIALITY CLAIMS HAVE BEEN MADE.
EPA 7710-IE IHEV 2/791
-------
Chapter II
HOW TO COMPLETE THE REPORT FORM
BLOCK I. CERTIFICATION STATEMENT AND SIGNATURE
SIGNATURE: The certification statement must be signed
by a person authorized by the importer or processor to
sign his official documents. If a trade association or
other agent reports on behalf of one or more importers
or processors, a duly authorized official of the trade
association or agent must sign the statement.
DATE: Enter the month, day, and year that the form was
signed.
NAME AND TITLE: Enter the name and title of the person
who signed the certification statement.
SUPPLIER SIGNATURE AND DATE: If an importer or processor
elects to have his supplier (either foreign or domestic)
report the identity of the chemical substance he imports
or processes, a duly authorized official of the supplier
must sign in the space provided, attesting to the truth
of the Certification Statement by Supplier on the back of
the form. Enter the date the certification statement
was signed.
BLOCK II. COMPANY NAME/ADDRESS
GENERAL NOTE: Enter one letter per space. Leave one
blank space between each word.
Reporting individually: Enter the name and address of
the person (company, corporation, or other person as
defined in the inventory reporting regulations) who pro-
cessed or imported the chemical substance identified in
block IV.
Reporting by trade association or other agent: Enter the
complete name and headquarters address of the trade assoc-
iation, or the name and address of the agent.
The following list contains two-letter state abbreviations
which should be used in completing blocks II and III.
- 15 -
-------
BLOCK III. TECHNICAL CONTACT NAME/ADDRESS/PHONE
Enter the name, address, and telephone number (including
area code and extension, if applicable) of the person whom
EPA may contact for clarification of information submitted
on this form. An importer or processor who elects to have
his supplier (either foreign or domestic) report the
identity of the chemical substance must enter the name and
address of this supplier in this block.*
BLOCK IV. CHEMICAL SUBSTANCE IDENTITY/ACTIVITY/CONFIDENTIALITY
CLAIMS
CAS REGISTRY NUMBER: Enter the Chemical Abstracts Service
(CAS) Registry Number if known. Include hyphens. CAS
Registry Number for a great many chemical substances may
be found in the following sources:
— CA Volume, or Collective Chemical Substance Indices
— CA Volume, or•Collective Formula Indices
— CA INDEX GUIDE
— CAS REGISTRY HANDBOOK — Common Names (on microform).
Refer to Appendix 2 or more information on these sources.
SPECIFIC CHEMICAL NAME: Following the instructions presented
in Chapter III enter a specific chemical name for a Class 1
chemical substance or a specific name for a Class 2 chemical
substance. EPA encourages the reporting of synonymous names
for each substance reported. Separate synonyms from the
"specific chemical name" and from one another with
semi-colons. If there is insufficient space, write synonyms
in the supplemental space at the bottom of the form.
OTHER CHEMICAL SUBSTANCE IDENTIFICATION INFORMATION:
Enter in the space provided for supplemental information,
if applicable, other information needed to identify clearly
the reported chemical substance. Refer to Chapter III for
a specification of what information must be submitted when
reporting a Class 1 or Class 2 chemical substance.
ACTIVITY: Enter a check in the appropriate box under the
general heading "Activity" to indicate whether you process
or import the chemical substance. If you both process and
import the substance you may check both boxes.
CONFIDENTIALITY CLAIMS: Enter a check in the appropriate
box(es) to indicate which information is claimed confi-
dential. Trade associations or agents are not permitted
to make any confidentiality claims.
a. By checking the box labeled "Activity" you assert
that the link between your company and the activity,
i.e., the fact that your company imports or processes
the chemical substances identified in Block IV for
commercial purposes, is confidential.
*This report form is designed so that the address entered in
block III will carbon copy onto the attached postcard. Since
this postcard will be returned to that address to verify EPA's
receipt of the form, one should remove the carbon paper between
the submitting company copy and the postcard if the technical
contact address is different from the submitting company address.
On the postcard enter the address to which the card should be
sent. Do not however, detach the postcard from the rest of the
form to insert separately in a typewriter, for example. The
postcard must remain attached to the form.
- 16 -
-------
b. By checking the box labeled "Company" you assert
that the link between your company and the chemi-
cal substance identified in Block IV is confidential.
c. By checking the box labeled "Method of Manufacture
is confidential" you assert that the information
in Block IV which you have designated as relating
to the Method by which the chemical substance re-
ported on the form was manufactured, is confidential.
- 17 -
-------
Chapter III
Identifying Chemical Substances
Which Have No Known CAS Registry Number
All chemical substances which are reported for the Inventory
must be identified clearly. For a substance with a Chemical
Abstracts Service (CAS) Registry Number, reporting the CAS
Registry Number and a specific chemical name usually will ensure
its unambiguous identification for the Inventory. (See Appendix
2 for Sources of CAS Registry Numbers.) To report a chemical
substance which has no known CAS Registry Number, one must
provide chemically descriptive information of the type specified
in this chapter. Such information should be entered in the
appropriate spaces provided in Block IV of the report form.
Supplemental sheets, if needed, should be attached to the form
and bear the identifying Form Number of the specific form to
which they are attached. (The Form Number is the eight digit
number which appears in the upper left-hand corner of each form.)
Class 1 and Class 2 Chemical Substances
The type of chemically descriptive information required to
identify properly a chemical substances depends on whether the
substance is a Class 1 or Class 2 substance.
A Class 1 substance is a chemical substance whose
composition can be represented by a definite chemical structure
diagram. Examples of Class 1 substances are: benzene, sodium
chloride, and dimethylmercury.
A Class 2 substance is a chemical substance whose
composition cannot be represented by a definite chemical
structure diagram. Examples of Class 2 substances are: linseed
oil, chlorinated butyl rubber, and the glycerol monoester of
hydrogenated cottonseed oil acids.
As a special case, polymers which are prepared solely using
Class 1 monomers are considered Class 1 substances. On the other
hand, polymers (for example, alkyd resins) which are prepared
using, in whole or in part. Class 2 monomers are considered Class
2 substances. (For a more complete discussion, see Introduction
of Volume I of the Initial Inventory.)
A. Reporting the Identity of a Class 1 Chemical Substance
The following information must be reported to identify a
Class 1 chemical substance which has no known CAS Registry
Number:
I. a specific chemical name,
II. the molecular formula, and
III. the chemical structure diagram.
Each item of information listed above is important to the
proper identification of a Class 1 chemical substance and is
discussed in detail below. In addition, several examples are
provided which illustrate the type of information needed to
identify and report a Class 1 chemical substance.
1. A Specific Chemical Name
In the space under "Specific Chemical Name" in Block IV of
the form, enter a name that clearly and uniquely identifies the
chemical substance being reported. The name should identify the
positions of attachment of chemical groups or of unsaturation, if
any, by the use of locants. (Locants are numerals or Greek or
Roman letters commonly used in a chemical name to designate the
positions of unsaturated bonds or attachments of chemical groups
in a molecule.) Failure to use locants in naming a substance
- 19 -
-------
that has several isomeric forms will create ambiguity in the
identification of the specific chemical substance being
reported. The following names, as examples, are ambiguous and
should not be used to describe Class 1 compounds: anisidine,
chlorotoluene, nitrosonaphthol, picoline, xylene. Chemical
groups should also be described by terms which are unambiguous
(e.g., "octyl" or "isooctyl" should not be used if "2-ethylhexyl"
is meant). Stereochemical descriptors should be included in the
substance name whenever appropriate.
If the substance is a salt, an ester, or an addition
compound and one or both of the components are polybasic, the
name should clearly specify the ratio of the components (or note
that the ratio is unknown). For example:
Fumaric acid, monosodium salt
Mono(2-ethylhexyl) citrate
Glycerol 1,3-dibenzoate
It is essential that the specific chemical name be
consistent with the other information used to identify the
substance. The name is the first item of information used in
identifying a chemical substance. Any inconsistency among the
name, the molecular formula, and the chemical structure diagram
will necessarily require further clarification on your part
before the chemical substance can be entered on the Inventory.
EPA also encourages you to enter, following the specific
chemical name and separated by semicolons, other common names by
which the chemical substance is identified in the scientific and
technical literature, or in product listings. Do not, however,
enter trademarks, abbreviations, acronyms, or laboratory
designations.
2. The Molecular Formula
There are several possible formats for molecular formulas.
Two important conventions are the Hill convention and the dot-
disconnect convention. The Hill convention lists carbon first,
then hydrogen, and then the rest of the elements in alphabetic
order. The dot-disconnect convention represents salts and
addition compounds as distinct units separated by a dot. In the
case of salts the dot-disconnect format lists acidic hydrogens in
the molecular formula, even though they may have been lost in the
salt formation (for example, silver nitrate is represented as
Ag.HNOg). Since the Hill convention (and dot-disconnect if
appropriate) are used in the Inventory, this is the preferred
format; however, any unambiguous notation is acceptable.
For example, the molecular formula for the sodium salt of
acetic acid (sodium acetate) could be presented as1
C2H-3Na02 (single summation format, Hill
convention)
or
[preferred] C2H402.Na
or
CH3COONa
or
NaC2H302
- 20 -
-------
3. The Chemical Structure Diagram
The chemical structure diagram should be entered in the
space provided within Block IV and should clearly indicate the
identity of the atoms and the nature of the bonds joining in the
atoms. Commonly used functional group abbreviations or shortcuts
are acceptable as long as they are unambiguous. For example:
-Me
-so2-
-Et
-NO,
-Pr
-CO-
-C02H
-CHO
-Ph
Alkyl groups represented by summation-type formulas (e.g., C^H- ~ or
CaH17-) will be assumed to be normal or "straight chain" unless other-
wise designated (e.g., tert-C.Hg-).Carbon atoms in ring systems and
their attached hydrogen atoms need not be explicitly shown. For example:
0
Any ionic charges or stereochemistry should be shown clearly. All known
stereochemical details should be provided. There should also be some
indication whether the stereochemistry shown in the diagram is abso-
lute or merely relative. For example:
Me
Me
=
trans
(i.e., relative)
absolute
(i.e., racemate)
Once again, just as in the case of the chemical substance name, the
ratio of the components for an addition compound or salt should be
indicated clearly if more than one form is at least theoretically
possible. For example:
(H02CCH2)2NCH2CH2N(CH CO H) 2 disodium salt
(H02CCH2)2NCH2CH2N(CH2C02H)2 tetrasodium salt
H N (CH ) NH
£. ^6
dihydrochloride
Class 1 Chemical Substance Identification Examples
The eight examples which follow illustrate the information needed
to identify Class 1 chemical substances properly. Some examples are
introduced by a substance name which is too ambiguous to be used as
a Class 1 substance name. In such cases, the comment points out the
ambiguity. Proper information (name, formula, structure) for the
identification of one possible Class 1 substance is then
presented. (See also the discussion of Class 2 substances where the
ambiguity genuinely exists in the specific name for the chemical
substance).
- 21 -
-------
_N-( isobutoxymethyl)acrylamide:
Comment: This, chemical name unambiguously identifies a
Class 1 substance.
NAME: _N-(isobutoxymethyl)acrylamide
FORMULA: CgH15N02
STRUCTURE: CH2=CH-C-NH-CH,-O-CH,-CH-CH,
II 3
Dixylylethane:
Comment: The name dixylylethane is ambiguous without the
use of locants. This name could either refer to a class 2
substance or could be an ambiguous synonym for a specific
Class 1 substance. The incorporation of locants in the name
can eliminate the ambiguity. A specific Class 1 substance
would be identified as:
NAME: l,l-Di-3,4-xylylethane
OR
1,1-Bls(3,4-dimethylphenyl)ethane
FORMULA: C18H22
STRUCTURE: Me, ^-^ ^Me
cis- and trans-Pipe rylene
Comment: Piperylene, or 1 ,3-Pentadiene, can be found with
CAS Registry Number 504-60-9. This CAS Registry Number,
however, is for the nonstereospecif ic form of the
substance. The cis- and trans-piperylenes , if reported as
individual chemical substances, should clearly distinguish
between the two isomeric forms.
NAME: cis-Plpe rylene
(or cls-l,3-Pentadlene)
NAME: Trans-Pipe rylene
(OR trans-l,3-Pentadiene)
FORMULA: C^Hg
STRUCTURE: Me
/
FORMULA:
H
CH=CH
\
STRUCTURE: Me
H
\
H
CH=CH
- 22 -
-------
D. cis-3-Methyl-A -tetrahydrophthalic anhydride
Comment: While the name 3-Methyl-A --tetrahydrophthalic
anhydride is a systematic or descriptive substance name, the
designation els is ambiguous. Inspection of the structural
diagram for this substance shows three asymmetric carbon
atoms, that is carbon atoms joined to four different atoms
or groups of atoms.
Points of
asymmetry
The stereochemical designation "cis" indicated that two
chemical groups or atoms are located on the same side of a
reference plan through the molecule (in this case, the
cyclohexene ring). It would take two such designations to
uniquely describe the relationship among the three centers.
The following data would be adequate to describe a specific
substance.
NAME: els,cis-3-Methyl-A -tetrahydrophthalic anhydride
or
n
cls-3-Methyl-cis-A -tetrahydrophthalic anhydride
FORMULA: CH0
STRUCTURE:
Me
E. Sodium sebacate
Comment: Sebacic acid is a dibasic acid (i.e., decanedioic
acid). Sodium sebacate could refer to the mono- or disodium
salt. If the designation "sodium sebacate" refers to the
fully neutralized acid, the precise designation "disodium
sebacate" should be used to eliminate the ambiguity. The
proper reporting in that case would be:
NAME: Disodium sebacate
FORMULA: C10H1gOij.2
STRUCTURE: HO C
Na OR
(CF )
l'" 2 8
or
G10Hl6Na2°4
r*r\ u OM-3
disodium salt
or
F. Chromium manganese oxide
Comment: The reporting of mixed metal compounds containing
hydroxyl (-OH), oxy(-O), oxo(=0), or peroxy (-0-0-) groups
- 23 -
-------
presents special problems. Depending upon the nature of the
metals involved, these compounds may be represented as salts
of inorganic oxo acids or as mixed metal oxides with no
attempt to elucidate the structure beyond the basic
elemental composition. The substance CrMnCK can be
represented in three ways — the chromium (2+) salt of
manganic acids, the manganic (2+) salt of chromic acid or as
simple as chromium manganese oxide, i.e., structure
unknown. The reporting of such substance names is
encouraged. (Stock Numbers are Roman numerals added
parenthetically to indicate the state or states of
oxidations.) For example:
Iron(II) oxide PeO
Iron(III) oxide Pe20o
Iron(II,III) oxide PeoO^
The following shows a preferred format for reporting a specific
form of chromium manganese oxide.
NAME: Manganese (II) chromate (VI)
FORMULA: HgCrO^.Mn or MnCrO^
STRUCTURE: O n
II ^^
HO-tr-OH • Mn OR -O-Cr-CTMn2+
Oil
O
G. Maleic acid-phthalic acid-propylene glycol terpolymer
Comment: Synthetic polymers reported for the Inventory
should be identified by name, structure, and formula in
terms of the monomer(s) from which they have been
prepared.
NAME: cis-maleic acid-phthalic acid-propylene glycol
terpolymer
FORMULA: (C^H^O^.CgHgO^.C3Hg02)x
STRUCTURE: S Hv s*
C=C I . CH,CHCH,OH
/ \ 3 2
H02C CO2H CO2H OH
[Note that the structure diagram for maleic acid clearly
shows the els-configuration.]
or
Using specific names and CAS Registry Number:
maleic acid . phthalic acid . propylene glcycol
(110-16-7) (88-99-3) (57-55-6)
H. Disodium salt of polyethylene glycol lauryl ether
monosulfosuccinate
Comment: Polyethylene glycol and polypropylene glycol and
their many derivatives are most conveniently represented on
the basis of a structural repeating unit formula which
simplifies the description of the end groups. The preferred
reporting would include:
NAME: Disodium salt of polyethylene glycol lauryl ether
monsulfosucclnate
- 24 -
-------
FORMULA:
2Na
OR
-------
Reporting the Identity of a Class 2 Chemical Substance
The following information should be reported to identify a
Class 2 chemical substance having no known CAS Registry Number:
I. a specific name, and
II. the method of preparation
Note that the method of preparation refers to the method of
manufacture of the chemical substance being reported and not to
how the substance is being used by the processor. Even though
the processor is reporting the substance, the method of
preparation (manufacture) is necessary for adequate identification
of most Class 2 substances. This information may be held
confidential (refer to Chapter IV of this booklet). In addition,
some Class 2 substances may be represented by a partial or incom-
plete structure diagram, or may be described in terms of their
general chemical composition. Each of these items of information
is discussed below and illustrated by several examples.
I. A Specific Name
A Class 2 chemical substance should be identified by a name,
entered in the space below "Specific Chemical Name" of Block IV,
which is as descriptive of the substance as possible. In some
cases, the name may take the form of a specific chemical name
containing locants, component ratios, and stereochemistry. In
other cases, the best possible name may only identify the
substance as the reaction product of specified reactants.
EPA encourages you to enter, following the specified name
and separated by semicolons, other common names by which the
chemical substance is identified in the scientific and/or
technical literature, or in product listings. Do not however,
enter trademarks, abbreviations, acronyms, or laboratory
designations.
II. The Method of Preparation
In the space provided in Block IV, enter a description of
the final step of the method used to manufacture or produce the
Class 2 chemical substance.
For substances prepared by chemical reaction, the
description should appear in the form of a reaction scheme, for
example:
A + B-»C.
The final reaction scheme should unambiguously identify, by name,
the immediate precursor substance(s), the nature of the reaction,
and the reactants whether or not they are implied by the term
used to describe the nature of the reaction. The precursor
substance(s) and/or the reactants should also be identified by
their respective CAS Registry Number(s), if known. Reaction
description terms should be as specific as possible (e.g.,
acetylation, alkaline hydrolysis, chlorination, diazotization,
epoxidation). General reaction terms should not be used if at
all possible. (e.g., addition, condensation, reaction). The
examples which follow this discussion indicate the appropriate
placement of such information in the reaction scheme.
If a Class 2 chemical substance is produced through several
different final reaction schemes, describe each of these final
reaction schemes. For example, if it is produced by either A +
B—»C or by D + E—*C. Describe C in terms of both of these final
reaction schemes.
- 26 -
-------
For substances produced without chemical reaction, for
example by extraction from a natural source or reaction mass,
specify the source, extraction process and the nature of the
extract.
Other Information
In some cases, a Class 2 chemical substance can be
represented by a partial or incomplete chemical structure
diagram. For example:
A. Hexabromobiphenyl
Br,
x + y = 6
B. Sodium butyl (o-hydroxyphenyl)benzenesulfonate
OH
Comment: butyl (Bu means CHo-CH^-CI^CI
C. Ethoxylated hydrogenated tallow amide
- (straignt chain)
-------
H2S04(7664-93-9)
PREPARATION: Phosphate rock _=».
Consists predominantly of CaHij(POii)2, CaHPO/, and
B. Chlorinated butyl rubber
Comment: Chlorinated butyl rubber is obtained by
chlorination of butyl rubber, which is a copolymer of
isobutylene and isoprene.
NAME: Chlorinated butyl rubber
or
Chlorinated (isobutylene-isoprene copolymer)
PREPARATION: (isobutylene-isoprene) C1SO2C1 (7791-25-5)
x chlorination
9010-85-9
OR
(CH,-C=CH5 /CH2=CH-C=CH,), C1SO2C1 (7791-25-5)
J I V 2 ^ x chlorination*"
CH, CH,
13 ^3
9010-85-9
C. Blown Castor Oil
Comment: Blown castor oil is prepared by reacting
castor oil with air or oxygen at 80-130°C. This
results in oxidation along with some polymerization.
NAME: Blown castor oil
or
Oxidized castor oil
PREPARATION: Castor oil 3» oxidation plus
*8001-79-4 80-130°C some polymerization
D. Linseed oil-phthalic anhydride-glycerol resins
Comment: Linseed oil-phthalic anhydride-glycerol
resins should be reported on the basis of their
monomeric components as with any polymer.
NAME: Linseed oil-phthalic anhydride-glycerol resin
PREPARATION: 0 CH OH
"**• " T 2
Linseed oil + || | "0 + CHOH _
*8001-26-l \^?—(I polymerization
CH2OH
56-81-5
or
Using a specific name and CAS Registry Number for each
reactant:
Linseed oil Phthalic anhydride Glycerol
•8001-26-1 + 85-^-9 + 56-81-5
polymerization
- 28 -
-------
E. C.I. Sulfur Brown 42
Comment: Sulfur dyes are made by heating organic
materials with sulfur and sodium sulfide. The exact
compositions of the resulting dyes are usually unknown.
NAME: sulfurized sodium 2-methyl-3,5-dinitrobenzene-
sulfonate
PREPARATION: fl T Na2S (1313-82-2)
S (7704-34-9)
6274-37-9
P. Anhydrosorbitol monoester of hydrogenated castor oil
acids
Comment: While sorbitol is a well defined substance,
anhydrosorbitol refers to a combination of cyclic
dehydration products and thus is a Class 2 substance.
The monoester might be reported as:
NAME: Anhydrosorbitol monoester of hydrogenated castor
oil acids
PREPARATION:
hydrogenated -— r^, ^ > mono
Anhydrosorbitol + castor oil acids esterification » esters
*61790-39-4
- 29 -
-------
IMPORTANT: Before completing this form, carefully read the EPA publication "Reporting for the Chemical
Substance Inventory. Instructions for Reporting for the Revised Inventory."
AopnMd OMB Fom No
158577011
U.S. ENVIRONMENTAL PROTECTION AGENCY
CHEMICAL SUBSTANCE INVENTORY REPORT
(Section 8(a) and (b) Toxic Substances Control Act 15 USC2607)
ORM NUMBER
0000000 0
FORM NUMBER
0000000 0
DO NOT REMOVE LABEL-. gc:|_
CITY "[EJ.frp.rfl,
II. COMPANY NAME/ADDRESS
, iZ St.TPPfc, I , I ............ I
, I I I I I I I STATE
LTJ.TECHNICAL CONTACT NAME / ADDRESS / PHONE
NAME PEEP, an,ijtji. ,, I
fChiemiicali iGo. i I
P-r234, ,A Street
"IGF/se,A
I
J STATEtftjl
nr ~
I. CERTIFICATION STATEMENT: I hereby certify that (1) I «m eligible to report for
the Reviead Inventory under 40 Cffl Part 71O3(bL and to the best ol my knowtedge
and belief. (2) tha chemical substence identified below <•! u •ligibta for indusion en
tha R*viMd Invwitory under 40 CFR 710. *nd (b) MM not rnanufmcturtd or imported
in bulk form for * comnwrcMl purpoM for th« flr*t tint* atur tfw «fl»cby« dttt of pre-
manuf«cture notification ntquirvrMnta for mflnuftcomn of chtmkal lubnancM
•nd impontn of chemical »ubnancw in bulk form: (3) *H irrfbrmation entered on tt»«
form is comptaie and accuran: and (4> the conMeniiiUty satements on the back of
thii form «* (rue n to that information for which I have mefted • confidential.*?
claim. I agree to permit aecett to. and the copying of. records by • duty autttonxed
represtHitativ* of the EPA Adminntntor. in accordance with the Toxic Substances
Control Act. to document any information tepocttd here.
Raynond J. Johnson, V.P., XYZ Processors
NAME /TITLE (TVP£ OR PRINT)
r SignMuf*
IV. CHEMICAL SUBSTANCE IDENTITY/ACTIVITY/CONFIDENTIALITY
CAS REGISTRY
NUMBER
SPECIFIC CHEMICAL NAME
(SEPARATE SYNONYMS WITH A SEMI-COLON)
Oi
iO
ACTIVITY
/ Confidential /
-------
Chapter IV
CONFIDENTIALITY
Any or all of the information that you submit to EPA
may be claimed as confidential if it relates to trade secrets
or commercial or financial matters that you consider to be
confidential. You must make and substantiate your confidenti-
ality claims before you submit the completed forms to EPA.
If you fail to do so, EPA may disclose the information without
further notice to you.
If you make a claim in the manner specified below, EPA
will disclose the information only to the extent, and by means
of the procedures, set forth in regulations governing EPA's
treatment of confidential business information. These regulations
appearing in Part 2 Subpart B of Title 40 of the code of
Federal Regulations and also in the FEDERAL REGISTER
(41 FR 36906, September 1, 1976; as amended, 43 FR 39997,
September 8, 1978), specify the procedures EPA must follow
in determining disclosure of confidential information. (Contact
EPA's Office of Industry Assistance for a copy of these FEDERAL
REGISTER notices.) Among other things, the regulations require
that EPA notify you in advance of publicly disclosing any
information you have claimed as confidential and substantiated
as specified below.
How to Claim Confidentiality; Activity and Company
You must make confidentiality claims in the spaces provided in
block IV of te form as illustrated on page 30. By checking any
box under the heading "Confidentiality Claims,""you are claiming
as confidential the particular item of information that corre-
sponds to that box. For example, if you wish to claim as
confidential the link between your company and the substance
you are reporting, check the box labeled "Company." If you wish
to claim as confidential the link between your company and the
activity in which your company is engaged with respect to the
chemical substance, i.e., processing or importation, check the
box labeled "Activity."
Confidentiality claims for "Activity" and "Company" are to be
made only by processors or importers completing the form.
Suppliers, assisting in form completion, may not make either
"Activity" or "Company" confidentiality claims.
Making a claim on one form does not effect the status of
information on another form. Therefore, you must make all
applicable confidentiality claims on each form you submit.
Substantiating Confidentiality Claims Other
Than Chemical Substance Identity
By signing the certification statement appearing on the
front of the form you are attesting to the truth of all confi-
dentiality claims you make on the form. This certification
statement includes the following phrase:
I hereby certify that ...(3) the confidentiality
statements on the back of this form are true as to
that information for which I have asserted a confi-
dentiality claim.
The statements which appear on the back of the form are to
substantiate any and all of the claims of confidentiality on the
form except for chemical identity. There are four general
statements, which apply to all information you have claimed as
confidential on the form. Below them are three more statements,
each of which applies to a particular confidentiality claim. For
each claim of confidentiality you make, you must certify, by
signing this form, that all four general statements are true in
addition to the statement which corresponds to the particular
claim you made on the front of the form.
- 31 -
-------
For, example, in order to substantiate that the link between
your company and the reported chemical substance is confidential,
you must attest, by signing the certification statement in Block I,
to the truth of: (1) all four general statements, and (2) the
statement headed "Company", all of which appear on the back of the
form. This example also applies to a claim of confidentiality with
respect to "Activity" (i.e., "process" or "import") and "Method of
Manufacture" (see discussion of the later claim below).
If one or more of the statements is not true for a particular
item of information you wish to claim confidential, you may not
claim that information as confidential. All applicable statements
must be true for each item of information you claim confidential.
Claiming Method of Manufacture Confidential
In many cases, in order to identify a chemical substance
with no known CAS Registry Number and whose composition cannot
be represented by a definite chemical structure diagram (a Class 2
substance), a processor or importer may need to provide a descrip-
tion of the method used to manufacture the substance, in addition
to a specific chemical name for the substance. You may wish to
claim the method of manufacture as confidential even though you
do not consider the specific chemical name you provide for the
substance to be confidential.
If you check the box labeled "Method of Manufacture is
Confidential" under the heading "Confidentiality Claims," EPA will
hold as confidential that information on the form which relates to
the method by which the substance was manufactured. To insure that
EPA maintains the correct information as confidential, circle that
information and indicate that it be held confidential.
If EPA does not consider the specific chemical name for the
substance provided in block IV to be specific enough for inclusion
on the Inventory, EPA will select a more specific name for the
substance. This name may be based, in part, on the method of
manufacture. In such an event, you will be notified of EPA's
selection and given an opportunity to claim the identity of the
substance as confidential.
If you are assisted in reporting by your supplier, your
supplier may claim the method of manufacture as confidential.
Refer to the procedures in Chapter I.
Claiming Chemical Substance Identity As Confidential
If you wish to claim the chemical identity of a particular
chemical substance as confidential for purposes of the Inventory,
check the box in Block IV which is labeled "Chemical Substance
Identity is Confidential."
By claiming the chemical identity of a particular chemical
substance confidential for purposes of the Inventory, you are
asserting that, to the best of your knowledge, the fact that the
chemical substance is manufactured, imported, or processed for a
commercial purpose by anyone is confidential. This claim must be
substantiated in writing, as follows, for each chemical substance
whose identity you claim as confidential:
o In accordance with procedures specified below you must
prepare a letter and attach it to the form on which you
have claimed the chemical identity of a substance as
confidential.
- 32 -
-------
o Your letter must include a cross-reference to the
specifically numbered form. (The form number appears on
the upper left-hand side of the form).
o The letter must be signed by a responsible official with
direct knowledge of the information contained in the
letter.
o Your letter must address each of the following questions
in detail. (To the extent possible, provide factual
information or relevant examples to substantiate your
claim).
1. What harmful effects to your competitive position, if
any, do you think would result from the identity of the
chemical substance appearing on the Inventory? How
could a competitor use such information, given the fact
that the identity of the substance would otherwise
appear on the Inventory of chemical substances with no
link between the substance and your company or
industry? What is the causal relationship between the
disclosure and the harmful effects?
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 been
disclosed through the patent, why should it be treated
as confidential for purposes of the Inventory?
4. Has the identity of the chemical substance been kept
confidential to the extent that your competitors do not
know it is being manufactured, imported or processed
for a commercial purpose by anyone?
5. Is the fact that the chemical substance is being
manufactured, imported or processed for a commercial
purpose publicly available, for example in technical
journals, libraries, or state, local, or federal agency
public files?
6. What measures have you taken to prevent undesired
disclosure of the fact that this chemical substance is
being manufactured, imported or processed for a
commercial purpose?
7. To what extent'has the fact that this chemical
substance is manufactured, imported or processed for a
commercial purpose 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
processing site in any form, either 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 process or import the
substance? ^Not applicable for suppliers completinq
Block IV.)
- 33 -
-------
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.
EPA will regard as confidential any information which you
furnish in response to the above questions provided it is marked
CONFIDENTIAL at the top of each page containing confidential
information and it is not otherwise possessed by EPA. EPA will
not disclose the information without your consent unless
disclosure is ordered by a federal court.
NOTE: In the box provided in Block IV, indicate the number
of pages in the attached letter substantiating the claim.
If a processor or importer is assisted in reporting by his
supplier, the supplier may claim the identity of the substance as
confidential. Refer to the procedures in Chapter II.
Further Information Required on the Form When Identity is
Claimed Confidential
A. Confidential Identity and CAS Registry Number (if known)
Even if you claim the chemical identity of the substance
reported on the form confidential, you must report the specific
identity on the form. Also report the CAS Registry Number if you
know i t.
B. Proposed Generic Chemical Name
If you claim the chemical identity of a substance
confidential, you must furnish EPA with a proposed generic
chemical name which is only as generic as necessary to protect
the confidential chemical identity. EPA will publish a generic
chemical name in an appendix to the Inventory to inform the
public of the type of chemical substance which has been claimed
confidential. You should adhere to the procedures detailed in
the EPA document "Guidelines for Creating Proposed Generic Names
for Confidential Chemical Substances Identities for the TSCA
Inventory," which may be obtained from EPA's Industry Assistance
Office (see Chapter I, page 11). EPA will review your proposed
generic chemical name in accordance with these guidelines and
section 710.7(f) of the Inventory regulations, and may ask you to
submit other proposed names. If you fail to provide a proposed
generic chemical name for your chemical substance, EPA will
consider this a waiver of your claim of confidentiality and will
publish the chemical identity of the substance on the Inventory.
C. Agreement to EPA Disclosure to Bona Fide Manufacturer
If you claim the chemical identity of a substance
confidential, you must agree to the statement appearing on the
back of the form which authorizes EPA to disclose the fact that
the chemical substance is included on the Inventory to a person
with a bona fide intent to manufacture the chemical substance.
In addition, you agree that you have and will make available upon
request, the data specified in section 710.7(e) of the inventory
reporting regulations. If you fail to agree to this statement,
EPA will consider this a waiver of your claim of confidentiality
and will publish the chemical identity of the substance on the
Inventory.
- 34 -
-------
IMPORTANT: Before completing this form, carefuity read the EPA publication "Reporting for th« Chemical
Substance Inventory. Instructions for Reporting for thg Revised Inventory."
Aooroved OUt Form No.
158577011
U.S. ENVIRONMENTAL PROTECTION AGENCY
CHEMICAL SUBSTANCE INVENTORY REPORT
(Section 8(a) and (b) Toxic Substances Control Act 15 USC 2607)
FORM NUMBER
0000000 0
FORM NUMBER
0000000 0
00 NOT REMOVE LABEL BE|_
II. COMPANY NAME/ADDRESS
NAME 1X.Y.Z lPir,o,c,as,so,r,Si ,ln,c,., ,
ADDRESSES, €j 7,8| |Zh , ,St
I
I
J
E,1,m,i,ra,
M,Uch,qU
J STATE"|A,M
j ZIP 15673 91
m.TECHNICAL CONTACT NAME/ADDRESS / PHONE
NAME |A-,B,-, ,QP.1.1.i,HS, ,,,,,,,
ADDBESs'TWl ^1^0063,5,0^,5,, i .IjICi. . ,
156,7,8, ,i .Street
CITY
, , , , , , i , , i , . , I STATED, It
a,l5,6,7,8,9|
PHONE -|50,5,-,234,-,5,4,32i
I. CERTIFICATION STATEMENT: I honby on* But (11 I am •*»«• » ™port to
in. Rimed Inventory under « CFH Part 710.38)1. end to the Da» of my knowledge
and beW. |2) the chemical Irtranc. idnttilM t»krw (.1 i> HifU* for induxn on
tM ««*«d Invxitoy undw 40 CW 710. end (HI w>9 not mmufactmd or inporttd
in bulk torn to • conwmffial P«UPOM to ttw Ant time ifMf tne •ffectiv* d*u of pn>-
nunoracriM* notification nfquinMTwnn to mlmifK&iMn of etwnweil suteuneu
•nd impomn of chemical ubnsnoM in bulk torn: (3) all mtommon •rrand on UM
torn it compkt* and accunm: and (41 the conAdentlality ratMmirrj on the back of
itii. form an> me a« to that intometkxi to which I hav» acwnd a oonno.noaMy
daim. I agrn to permit aeceu to, and the cooyina of. recorde by a duly auflKxned
raixeMnutnm of the EPA Admimsrator. in accordance with the Toxic SubatancM
Contml Act to oocumem any information lepmted hen.
Raymond J. Johnson/Vice President
NAME/TTTI.E (TYPE OR PRINT)
Supplier
IV. CHEMICAL SUBSTANCE IDENTITY/ACTIVITY/CONFIDENTIALITY
CAS REGISTRY
NUMBER
(IF KNOWNI
SPECIFIC CHEMICAL NAME
(SEPARATE SYNONYMS WITH A SEMI-COLON)
2,2.3,3,4.4,5,5,6>6.6-undecaf1uoro-N,N-bis-
(2-hydroxyethyl) hexanamide
ACTIVITY
IN THE SPACE PROVIDED BELOW. PROVIDE STRUCTURAL
INFORMATION. MOLECULAR FORMULA. AND OTHER
SUPPLEMENTAL INFORMATION TO AID IN THE SPECIFIC
IDENTIFICATION OF THE CHEMICAL SUBSTANCE.
WwfUm3
MOLECULAR FORMULA
See Attached Supplemental Description Sheets
(Write Form Number on all attachments)
CH2CH2OH
f////////////
/ Confidential
(0
METHOD OF MANUFACTURE IS CONFIDENTIAL
(Circle applicable information and
mark it CONFIDENTIAL)
CHEMICAL SUBSTANCE IDENTITY IS
CONFIDENTIAL
(1) SUBSTANTIATION:
a No. of attached substantiation
sheets (write form number on
all substantiation sheets)
(21 Proposed Generic Name:
polyf1uoro-N,N-bi s(2-hydroxyethyl
hexanamide
(3) I agree to trie terms of CONFIDENTIAL
SUBSTANCE IDENTITY STATEMENT on
the back of this form
THE ABOVE IS AN EXAMPLE OF A PROCESSOR CLAIMING THE CHEMICAL SUBSTANCE
IDENTITY TO BE CONFIDENTIAL.
EPA 7710-3E (BEV 2/791
-------
APPENDIX 1
Inventory Reporting Regulations
(40 CFR 710)
Part 710 Is established to read as fol-
lows:
Sec.
710.1 Scope and compliance.
710.2 Definitions.
710.3 Applicability; Reporting lor the Ini-
tial and revised Inventory.
710.4 Scope ol the Inventory.
710.5 How to report lor the Inventory.
710.6 Wnen .to report.
710.7 Confidentiality.
710.8 Effective date.
AUTHORITY: Subsection 8(a). Toxic Sub-
stances Control Act (TSCA) (00 Stat. 2003.
(15TJ.S.C. 2607(a»).
§ 710.1 St-ope and compliance.
ia> This Part establishes regulations
governing reporting by certain persons
who manufacture. Import, or process
chemical subsances for commercial pur-
poses under section 8 (a) of the Toxic
Substances Control Act (15 TJ.S.C. 2607
(a >). Section 8'a) authorizes the Admin-
RULES AND REGULATIONS
istrator to require reporting of informa-
tion necessary for administration of the
Act and requires EPA to issue regulations
for the purpose of compiling an inven-
tory of chemical substances manufac-
tured or processed for a commercial pur-
pose, as required by section 8(b) of the
Act. Following an initial reporting pe-
riod. EPA will publish an initial inven-
tory of chemical substances manufac-
tured or imported for commercial pur-
poses. After a supplemental reporting
period, EPA will publish a revised in-
ventory including those additional chem-
ical substances processed or used for
commercial purposes or imported for
commercial purposes as a part of a mix-
ture or article. Further, in accordance
with section 8(b), EPA periodically will
amend the inventory to Include new
chemical substances which are manufac-
tured or Imported for a commercial pur-
pose and reported under section 5 (a) (1)
of the Act. EPA also will revise the cate-
gories of chemical substances and make
other amendments as appropriate.
(b) Section 15(3) of TSCA makes it
unlawful for any person to fail or refuse
to submit information required under
these reporting regulations. In addition,
section 15(3) makes it unlawful for any
person to fail to keep, and permit access
to, records required by these regulations.
Section 16-provides that any person who
violates a provision of section 15 is lia-
ble to the United States for a civil pen-
alty and may be criminally prosecuted.
Pursuant to section 17, the Government
may seek judicial relief to compel sub-
mission of section 8 (a) information and
to otherwise restrain any violation of
section 15.
Nora.—As a matter of traditional Agency
policy, EPA does not Intend to concentrate
Its enforcement efforts on Insignificant cleri-
cal errors In reporting
(c) Each person who reports under
these regulations shall maintain records
that document information reported un-
der these regulations and, In accordance
with the Act, permit access to, and the
copying of such records by EPA officials.
§ 710.2 Definitions.
For the purposes of this Part: (a) The
following terms shall have the meaning
contained in the Federal Food, Drug, and
Cosmetic Act, 21 U.S.C. 321 et seq., and
the regulations issued under such Act:
"cosmetic," "device," "drug," "food," and
"food additive." In addition, the term
"food" includes poultry and poultry prod-
ucts, as defined in the Poultry Products
Inspection Act, 21 TJ.S.C. 453 et seq.:
•meats and meat food products, as defined
in the Federal Meat Inspection Act, 21
U.S.C. 60 et seq.; and eggs and egg prod-
ucts, as denned in the Egg Products In-
spection Act, 21 U.S.C. 1033 et seq.
(b) The term "pesticide" shall have
the meaning contained in the Federal
Insecticide. Fungicide, and Bodenticide
Act, 7 U.S.C. 136 et seq., and the regula-
tions issued thereunder.
(c) The following terms shall have the
meaning contained in the Atomic Energy
Act of 1954. 42 U.S.C. 2014 et seq.. and
the regulations issued thereunder: "by-
64575
product material." "source material,"
and "special nuclear material."
(d) "Act" means the Toxic Substances
Control Act, 15 U.S.C. 2601 et seq.
(e) "Administrator" means the Ad-
ministrator of the UJ3. Environmental
Protection Agency, any employee or au-
thorized representative of the Agency to
whom the Administrator may either
herein or by order delegate his authority
to carry out his functions, or any other
person who shall by operation of law be
authorized to carry out such functions.
(f) An "article" is 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 Ite shape or de-
sign during end use, and (3) which has
either no change of ^n^mi^ai composition
during its end use or only those changes
of composition which have no commercial
purpose separate from that of the article
and that may occur as described in § 710.4
(d) (5); except that fluids and particles
are not considered articles regardless of
shape or design.
(g) "Byproduct" means a chemical
substance produced without separate
commercial intent during the manufac-
ture or processing of "another chemical
substance(s) ormixture(s).
-------
64576
RULES AND REGULATIONS
(k) "EPA" means the U.S. Environ-
mental Protection Agency.
(1) "Importer' means any person who
imports any chemical substance or any
chemical substance as part of a mixture
or article into the customs territory of
the U.S. and includes: (1) The person
primarily liable for the payment of any
duties on the merchandise, or <2) an au-
thorized agent acting on his behalf (as
defined in 19 CFR 1.11).
(m) "Impurity" means a chemical sub-
stance which is unintentionally present
with another chemical substance.
(n) "Intermediate" means any chemi-
cal substance (1) which is intentionally
removed from the equipment in which it
is manufactured, and (2) which either is
consumed in whole or in part in chemi-
cal reaction(s) used for the intentional
manufacture of other chemical sub-
stance(s) or mixture(s), or is intention-
ally present for the purpose of altering
the rate of such chemical reaction (s).
NOTE.—The "equipment in which It was
manufactured" includes the reaction vessel
In which tbe chemical substance was manu-
factured and other equipment which is
strictly ancillary to the reaction vessel, and
any other equipment through which the
rrn*m1'**Ll substance may flow during a con-
tinuous now process, hut does not include
tanks or other vessels in which the chemical
substance is stored after its manufacture.
(o) "Manufacture" means to produce
or manufacture in the United States or
import into the customs territory of the
United States.
(p) "Manufacture or import 'for com-
mercial purposes'" means to manufac-
ture or import:
(1) For distribution in commerce, in-
cluding for test marketing purposes, or
<2) For use by the manufacturer, in-
cluding for use as an intermediate.
(q) "Mixture" means any combina-
tion of two or more chemical substances
if the combination does not occur in
nature and is not, in whole or in part,
the result of a chemical reaction; ex-
cept that "mixture" does include (1)
any combination which occurs, in whole
or in part, as a result of a chemical reac-
tion if the combination could have been
manufactured for commercial purposes
without a chemical reaction at the time
the chemical substances comprising the
combination were combined and if, after
the effective date of premanufacture no-
tification requirements, none of the
chemical substances comprising the
combination is a new chemical sub-
stance, and (2) hydrates of a chemical
substance or hydrated ions formed by
association of a chemical substance with
water.
"United Statfis," when used in the
geographic sense, means all of the States.
territories, and possessions of the United
States.
§ 710.3 Applicability: Reporting for the
initial inventory and revised inven-
tory : \tlio must report; who should
report.
Based on reports from manufacturers
and some importers of chemical sub-
stances, EPA will compile an initial in-
ventory of chemical substances manu-
factured for commercial purposes. Para-
graph (a) of this section identifies who
must report for this initial inventory and
who should report. After publication of
the initial inventory, EPA will compile a
revised inventory of chemical substances
manufactured or processed for a com-
mercial purpose based on reports from
processors of chemical substances, and
from importers of chemical substances
as a part of mixtures or articles. Para-
graph (b) of this section identifies who
may report for this revised inventory.
Paragraph (c) of this section identifies
FEDERAL REGISTER, VOL. 42, NO. 247—FRIDAY, DUCEMBER 23, 1977
- 38 -
-------
the persons not subject to the initial
inventory.
(a) The initial inventory—(1) Domes-
tic manufacturers who must report con-
cerning chemical substances. Any per-
son who manufactured a chemical sub-
stance(s) in the United States for a
commercial purpose during calendar year
197*7 must report concerning:
Revised inventory. (1) During
the reporting period for the revised in-
ventory (J710.6(c)), a person may re-
port concerning a chemical substance
which was not included in the initial
inventory if:
(1) The person has processed or used
the chemical substance (including use in
the manufacture of a mixture or article
containing that chemical substance) for
a commercial purpose since January 1,
1975; or
(ii) The person has imported the
chemical substance as part of a mixture
or article for a commercial purpose since
January 1.1975.
(2) Any person permitted to report un-
der paragraph (b) of this section either
may report individually or. in accordance
with §710.5(f), may authorize a trade
association or other agent to report on
his behalf.
NOTE.—The premanufacture notification
requirements of section 6(a)(l)(A) of the
Act for manufacturers of new chemical sub-
stances and Importers of new chemical sub-
stances in bulk will begin 30 days after the
publication of the initial inventory and will
apply to all chemical substances not included
in the initial inventory. Tbe premanufacture
notification requirements of section 5(a) (1)
(A) will not be applied to importers of
chemical substances as part of a mixture
until 3O days after publication of tbe re-
vised Inventory. In addition, section 16(2)
of the Act as it relates to section 5 Persons not subject to the initial
inventory. Persons who have only pro-
cessed or used a chemical substance for
a commercial purpose are not subject to
the initial inventory requirements.
§ 710.4 Scope of the inventory.
(a) Chemical substances subject to
these regulations. Only chemical sub-
stances which are manufactured, im-
ported, or processed "for a commercial
purpose," as defined in § 710.2, are sub-
ject to these regulations.
< b) Naturally occurring chemical sub-
stances automatically included. Any
chemical substance which is naturally oc-
curring and (1) which is (i) unprocessed
or Any chemical substance which is
manufactured, imported, or processed
solely in small quantities for research
and development, as defined in S 710.2
Any chemical substance not manu-
factured, processed or imported for a
commercial purpose since January 1,
1975.
(d) Chemical substances excluded
from the inventory. The following chem-
ical substances are excluded from the in-
ventory. Although they are considered
to be manufactured or processed for a
commercial purpose for the purpose of
section 8 of the Act, they are not manu-
factured or processed for distribution in
commerce as chemical substances per se
and have no commercial purpose sepa-
rate from the substance, mixture, or ar-
ticle of which they may be a part.
NOTE.—In addition, chemical substances
excluded here will not be subject to pre-
manufacture notification under section 5 of
the Act.
<1) Any impurity.
(2) Any byproduct which has no com-
mercial purpose.
NOTE.—A byproduct which has commercial
value only to municipal or private organiza-
tions wbo (i) burn it as a fuel, (11) dispose of
it as a waste, including in a tatxUUU or for
enriching soil, or (111) extract component
chemical substances which have commercial
value, may be reported for the inventory, but
will not be subject to premanuf acturing no-
tification under section 5 of the Act if not
included.
(3) Any chemical substance, which re-
sults from a chemical reaction that
occurs incidental to exposure of another
chemical substance, mixture, or article to
environmental factors such as air, mois-
ture, microbial organisms, or sunlight.
(4) Any chemical substance which
results from a chemical reaction that
occurs incidental to storage of another
chemical substance, mixture, or article.
(5) Any chemical substance which re-
sults from a chemical reaction that oc-
curs upon end use of other chemical
substances, mxtures, or articles such as
adhesives, paints,' miscellaneous cleans-
ers or ottaer housekeeping products,
fuels and fuel additives, water softening
end treatment agents, photographic,
films, batteries, matches, and safety
flares, and which is not itself manu-
factured for distribution in commerce
or for use as an intermediate.
<6) Any chemical substance which re-
sults from a chemical reaction that oc-
curs upon use of curable plastic or rub-
ber molding compounds, inks, drying
oils, metal finishing compounds, ad-
hesives, or paints; or other chemical
FEDERAL REGISTER, VOL. 42, NO. 247—FRIDAY, DECEMBER 23, 1977
- 39 -
-------
64578
RULES AND REGULATIONS
substances formed during manufacture
of an article destined for the market-
place without further chemical change
of the chemical substance except for
those chemical changes that may occur
as described elsewhere in this § 710.4
-------
RULES AND REGULATIONS
6-1579
Trad? associations or other agents.
d) A trade association or other agent
may report on behalf of any person who
is not required to report for the initial
inventory under §710.3 Either an X-ray diffraction pat-
tern fin the case of inorganic sub-
stances) or a mass spectrum (in the case
of most other substances) of the particu-
lar chemical substance,
(v) A sample of the substance in its
purest form, if requested, and
(vi) Any additional or alternative
spectra, or other data that may be re-
quired to resolve uncertainities with re-
spect to the identity of the chemical sub-
stance.
(3) (i) Upon receipt of the informa-
tion specified in paragraph (g) (2) of this
section, EPA may require the submitter
who asserted the confidentiality claim
for a specific chemical substance within
the generic name to submit to EPA:
(A) Either an X-ray diffraction pat-
tern or a mass or alternative spectrum
for the substance,
(B) An elemental analysis of the sub-
stance,
(C) A sample of the substance in its
purest form, if requested, and
(D) Any additional spectral or other
data that may be required to resolve un-
FEDERAL REGISTER, VOL. 4Z, NO. 247—FRIDAY, DECEMBER 23, 1977
- 41 -
-------
&4580 RULES AND REGULATIONS
certainties with respect to the identity
of the substance.
(ii) Failure to submit any of the in-
formation required by EPA under this
pargraph (g) (3) will be construed as a
waiver of the submitter's confidentiality
claim, and EPA will place the specific
chemical identity on the inventory with-
out further notice to the submitter.
(4) EPA will compare the information
submitted by the proposed manufacturer
under paragraph (g) (2) of this section
with the information submitted under
paragraph (g) (3) of this section.
(5) If
-------
APPENDIX 2
SOURCES OF CAS REGISTRY NUMBERS
Chemical Abstracts Service (CAS) has assigned a unique
Registry Number to each of over four million chemical substances
and mixtures. Finding the CAS Registry Number for a substance
will greatly simplify its reporting for the Inventory. With its
CAS Registry Number, the substance may be identified simply by
entering the number and a specific chemical name. Without the
CAS Registry Number, the chemical substance must be identified by
detailed chemical information of the type specified in Chapter 3
of this booklet.
The format of a CAS Registry Number is AAAAA-BB-C, where A,
B, and C are numbers from 0-9. The first five digits may include
leading zeroes which are often omitted. For example, the number
00106-72-9 would be represented as 106-72-9, omitting the first
two zeroes.
CAS Publications
The Chemical Abstracts Service offers a number of documents
which are useful sources of CAS Registry Numbers. These are:
1. The CA (Volume or Collective) Chemical Substance
Indices,
2. The CA (Volume or Collective) Formula Indices,
3. The CA INDEX GUIDE, and
V. The CA REGISTRY HANDBOOK — Common Names (on
microform).
The first three sources are commonly found in major academic
libraries; the fourth is commercially available from the Chemical
Abstracts Service, located in Columbus, Ohio.
CAS Registry Numbers may be found in these publications by
searching lists of trivial or common names, systematic CA Index
Names, or molecular formulas. These sources cover the full range
of substances reported in the scientific and technical
literature.
The first three sources are published by CAS in conjunction
with the publication of Chemical Abstracts. Chemical Abstracts
is a weekly journal comprised of abstracts and index entries for
recent publications relevant to chemistry and chemical
engineering. CAS compiles comprehensive volume indices every six
months. The CA Volume Chemical Substance Index relates the CA
Index Names of substances, along with their CAS Registry Numbers,
to CA Abstracts Numbers of publications, abstracted in the
volume, in which the substances were mentioned.
CAS also publishes the CAS REGISTRY HANDBOOK — Number
Section, a comprehensive listing of substances registered in the
CAS Chemical Registry System. The Handbook lists, in ascending
CAS Registry Number order, the CA Index Name and molecular
formula for each CAS Registry Number. The Handbook is not
intended to be a source of CAS Registry Numbers. It may be used,
however, to confirm a chemical substance identity, a CA Index
Name, or molecular formula linked to a particular CAS Registry
Number. It cannot be emphasized too strongly that CAS
registrations are highly specific. Different postional isomers,
sterochemical isomers, and salt forms have distinct CAS Registry
Numbers. For example, there are four (4) registry numbers for
xylenes, one for each of the three isomers, and one for an-
umlifferentlated combination of thwse isomers. THE REGISTRY
- 43 -
-------
HANDBOOK — Number Section, with its inclusion of the usually
systematic CA Index Names, will help to validate a CAS Registry
Number that might have been obtained from a search using a non-
chemically descriptive substance name.
Other Sources
CAS Registry Numbers may also be found in computer-based
information retrieval systems. Three on-line information systems
that include CAS Registry Numbers are the NIH/EPA Chemical
Substructure Search System, the National Library of Medicine's
CHEMLINE file, and Lockheed's CHEMNAME file. Many academic and
public libraries are equipped with facilities for searching these
computer-based files.
IMPORTANT: In reporting the identity of chemical substances
for the Inventory, care must be taken to ensure, first, that the
proper CAS Registry Number has been selected, and second that the
chemical name is as specific as possible. The substance name
should uniquely identify the substance and should include such
information as positions of chemical substitutent groups, salt
forms and ratios, and sterochemistry as appropriate. Any
inconsistency between the structure associated with a particular
CAS Registry Number and the name supplied will prevent the
substance from being added to the Inventory until clarifying
information is provided. Also, the fact that a CAS Registry
Number exists for a chemical does not mean it is necessarily a
reportable chemical substance. For example, many numbers refer
to mixtures, which may not be reported for the Inventory.
- 44 -
------- |