United States
Environmental Protection
Agency
Off ice of Toxic
Substances TS-799
Washington, DC 20460
July 1979
Toxic Substances
SEPA The Toxic Substances
Control Act
Questions and Answers
to Help Persons Report
for the Revised Inventory
of Chemical Substances
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The Toxic Substances Control Act
Public Law 94-469
Questions and Answers to Help Persons
Report for the Revised Inventory
of Chemical Substances
Prepared by the Industry Assistance Office
July 1979
U.S. Environmental Protection Agency
Office of Toxic Substances
Washington, D.C. 20460
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INDEX
QUESTIONS PAGE
I INTRODUCTION i
II DESCRIPTION OF THE TSCA ii
INITIAL INVENTORY OF
CHEMICAL SUBSTANCES
III HOW TO ORDER THE INITIAL INVENTORY iii
IV WHERE TO FIND HELP iv
V QUESTIONS AND ANSWERS
1 INITIAL INVENTORY 1-8 1
2 REVISED INVENTORY 9-15 4
3 MASTER INVENTORY FILE 16-21 6
4 INVENTORY AVAILABILITY 22 26 8
5 USING THE INITIAL INVENTORY 27 10
6 TRADEMARK AND PRODUCT 28 30 12
NAME LIST
7 HOW TO REPORT 31 33 13
8 CHEMICAL SUBSTANCES 34 46 14
REPORTABLE FOR THE
REVISED INVENTORY AND
MISCELLANEOUS REPORTING
QUESTIONS
9 TRADEMARK PRODUCTS AND 47-54 17
SUPPLIER-PROCESSOR
RELATIONSHIPS
10 IMPORTING MIXTURES 55 - 60 19
AND ARTICLES
11 PREMANUFACTURE NOTIFICATION 61-64 21
12 CONFIDENTIALITY 65-71 23
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I. INTRODUCTION
The Toxic Substances Control Act of 1976 (P. L. 94-469)
requires the U.S. Environmental Protection Agency (EPA) to
compile an inventory of chemical substances which have been
manufactured or processed in the U.S. for commerical purposes
since January 1, 1975. Inventory reporting regulations were
published in the Federal Register on December 23, 1977, and
supplemented on March 6, 1978 and April 17, 1978. These
regulations required most persons who manufactured or imported
in bulk a chemical substance in the U.S. for a commercial
purpose during calendar year 1977 to report for the Inventory.
In addition, persons who manufactured and imported a chemical
substance for a commercial purpose since January 1, 1975,
were permitted to report to ensure that the Inventory would
be complete. Based on reports from manufacturers and importers
EPA published the Toxic Substances Control Act Initial
Chemical Substance Inventory on June 1, 1979.
The Inventory reporting regulations established a two-
phase reporting schedule designed to prevent duplicate
reporting. The second phase, which began on June 1, 1979
and ends on December 31, 1979, provides an opportunity for
processors and users of chemicals for a commercial purpose
and importers of chemical substances as part of mixtures and
articles to report chemical substances which were not included
on the Initial Inventory. (From here on we will use "processor
to cover all these people.) These reports will supplement
the Initial Inventory. EPA expects to publish a Revised
Inventory in 1980. A notice discussing Revised Inventory
reporting procedures was published in the May 15, 1979
Federal Register.
This Booklet* contains information to help reporters
for the Revised Inventory.
*This Booklet has been prepared by the Industry Assistance
Office within EPA's Office of Toxic Substances. It is an
informal document, and persons are directed to the May 15, 1979
Federal Register Notice for official reporting instructions.
Additional information concerning reporting for the Inventory
is in the December 23, 1977 Federal Register.
(i)
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II. Description of the Initial Inventory
of Chemical Substances
June 1, 1979
Printed Volumes
Volume
Volume I
(720 pages
including 2
appendices)
Appendix A
Appendix B
Volume II
(802 pages)
Volume III
(800 pages)
Volume IV
(712 pages)
Title
Toxic Substances Control
Act Initial Chemical
Substance Inventory
Chemical Substance
Definitions
Confidential Chemical
Substance Identities
Substance Name Index
Substance Name Index
Contents
Over 44,000 chemical substances
identified by preferred
name and unique Chemical
Abstracts Service (CAS)
Registry Number
Further identifies chemical
substances whose preferred
names alone on the Inventory
do not completely identify
them.
Lists generic names for
substances whose specific
chemical identities were
claimed confidential when
reported for the Inventory.
Volume II and Volume III
contain preferred names
and synonyms of chemicals.
Molecular Formula and
UVCB Indices
Lists substances by
molecular formula; also
includes chemical substances of
Unknown or Variable
CompositionT Complex Reaction
Products, and B_iological
Materials.
Trademarks and Product Names Reported in Conjunction with the Initial
Chemical Substance Inventory.
Section I
(573 pages)
Section II
(1761 pages)
Reporting Company Section
Trademarks and Product
Names Section
Alphabetical list of
reporting companies with
product names grouped
under each company.
Alphabetical list of trade-
mark or product name; name
of company opposite each
product.
(ii)
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III. HOW TO ORDER THE INITIAL INVENTORY
PRINTED INITIAL INVENTORY
Free Copy Policy:
The Initial Inventory is available through the
Industry Assistance Office. One set will be given free
of charge to each company or major geographically-separated
division of a chemical company.
Order Additional Copies From:
Superintendent of Documents
Government Printing Office (GPO)
Washington, D.C. 20402
To Order by Telephone from GPO:
Call (202) 783-3238
(Visa or Master Charge accepted)
Order Information:
• 4 Volume Inventory GPO No. 055-007-00004-7 $34.50
• 2 Volume Trademarks GPO No. 055-007-00003-9 19.50
Total Weight of six volumes is 26 Ibs. $54.00
Mailed from Laurel, Maryland, 4th Class Book
Rate. Allow 3 weeks for delivery.
MICROFICHE
Is available free from the Industry Assistance Office. ,It
contains everything that is in the printed volumes. Companies
may obtain as many copies of microfiche as they require.
MAGNETIC TAPES
Are available only from National Technical Information Service.
By mail: Send $125 check or money order
By phone: (703) 557-4650 with NTIS charge card or American Express:
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Order number PB 295 108
EBC DIG Code
Nine Track, Odd Parity
Density 800 or 1600 Bits
Standard 1/2 in width
Note: Magnetic Tape Does Not include Appendix A or Appendix
B of Volume I. To obtain Appendices containing
information about generic names for confidential substance
identities or the definitions prepared for certain substances,
call the Industry Assistance toll-free number.
(iii)
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IV. WHERE TO FIND HELP
For any assistance you may need to report for the
Revised Inventory, you may call:
(800) 424-9065
In Washington, D.C., call 554-1404
Written inquiries may be addressed to:
Industry Assistance Office (TS-799)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Each EPA Regional Office is staffed by people who will
respond to your questions concerning Inventory reporting.
The Regional Toxic Substance Coordinator, the person to
contact in each Regional office, is identified on the
following page, as well as the telephone number and the
mailing address of the Regional Office.
(iv)
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TO OBTAIN ADDITIONAL INFORMATION PROM EPA REGIONAL OFFICES CONCERNING
THE REVISED INVENTORY REPORTING PROCEDURES, CALL THE FOLLOWING PERSONS:
Robert Dangel
EPA Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
(617) 223-0585
FTS: 8-223-0585
Michael Bonchonsky
EPA Region II
26 Federal Plaza
New York, New York 10007
(212) 264-1925
FTS: 8-264-1925
Edward Cohen
EPA Region III
Curtis Building
6th & Walnut Street
Philadelphia, PA 19106
(215) 597-7668
FTS: 8-597-7668
Ralph Jennings
EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30308
(404) 881-3864
FTS: 8-257-3864
Paul Meriage
EPA Region V
230 South Dearborn Street
Room 1165
Chicago, Illinois 60604
(312) 353-2291
FTS: 8-886-6003
Larry Thomas
EPA Region VI
First International Building
1201 Elm Street
Dallas, Texas 75207
(214) 767-2734
FTS: 8-729-2734
Wolfgang Brandner
EPA Region VII
324 East llth Street
Kansas City, Missouri 64106
(816) 374-3036
FTS: 8-758-3036
Stephen Farrow
EPA Region VIII
1860 Lincoln Street
Denver, Colorado 80295
(303) 837-3926
FTS: 8-327-3926
Kirby Narcisse
EPA Region IX
215 Fremont Street
San Francisco, California 94105
(415) 556-3352
FTS: 8-556-3352/1406
James Everts
EPA Region X
1200 6th Avenue
Seattle, Washington 98101
(206) 442-1090
FTS: 8-399-5562
299-312 0
79
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1. INITIAL INVENTORY
1. WHAT IS THE INITIAL INVENTORY?
The Initial Inventory, published on June 1, 1979, is
a list of over 44,000 chemical substances manufactured
or imported for commercial purposes in the United States
since January 1, 1975. (Note: Under the Toxic Substances
Control Act (TSCA), the term "manufacture" also includes the term
"import". For the sake of brevity, when the term "manufacture"
is used in this document it is intended to include "import.")
2. WHAT TSCA COMPLIANCE REQUIREMENTS ARE SET IN MOTION BY
THE JUNE 1, 1979 PUBLICATION OF THE CHEMICAL SUBSTANCE
INITIAL INVENTORY?
The June 1, 1979 publication of the Initial Inventory
kicked off two important TSCA actions:
(1) It started the revised inventory reporting period
(June 1, 1979) for processors who buy, use, blend, or
distribute chemicals not listed on the Initial Inventory.
This period ends December 31, 1979.
(2) It established for manufacturers and importers (in bulk)
of new chemical substances, July 1, 1979 as the effective
date for Premanufacture Notification (PMN) requirements.
3. WHY IS THE DATE OF JUNE 1, 1979 CONSIDERED THE
PUBLICATION DATE OF THE INITIAL INVENTORY?
EPA needed to establish a specific date for the Initial
Inventory because other TSCA actions would be triggered
by the date. (1) The Act requires premanufacture notification
to begin 30 days after this publication date and (2) the date
starts the 210 day revised reporting period.
Easily identifiable time frames for each of these TSCA
actions are set in motion with the June 1 publication
date: (1) July 1 premanufacture notification begins;
(2) processor reporting begins June 1 and ends
December 31, 1979.
4. WHAT IS AN ACCURATE DESCRIPTION OF THE CONTENTS, SIZE
AND COST OF THE INITIAL INVENTORY?
The Initial Inventory is listed in the first volume. The
next three volumes provide cross reference by synonym and
molecular structure to the chemicals in Volume I. The last
two volumes contain trademark and product names. The six
volumes weigh 26 pounds and can be purchased from the
Government Printing Office for $54, including postage.
See the official description of the Initial Inventory in
the front of this Booklet.
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5. IS ANY OF THE INFORMATION THAT EPA COLLECTED EXCLUDED
FROM PUBLICATION IN THE INITIAL INVENTORY?
Yes. Where a person claimed the fact that the
specific identity of a chemical substance manufactured
for a commercial purpose was confidential, the specific
name is not published.
Additionally, certain information that was submitted
during the Initial Inventory reporting period was not
published. This includes plant site data and production
volume. The Inventory does not show what firms produce
any given chemical.
6. WHEN WAS THE INFORMATION COLLECTED FOR THE INITIAL
INVENTORY?
Chemical manufacturers and importers reported to EPA
from January 1 through May 1, 1978, the chemical
substances they manufactured for commercial purposes
in the U. S. since January 1, 1975. For chemical substances
manufactured or imported in bulk for the first time
after May 1, 1978, manufacturers and importers were
required to report to EPA as soon as that manufacture
or importation began. The published Inventory contains
the majority of the chemicals reported to EPA by mid-
December 1978, the printing cutoff date.
7. I CANNOT FIND THE CHEMICAL SUBSTANCE I PURCHASE ON THE
INITIAL INVENTORY. IS THE INITIAL INVENTORY INCOMPLETE?
The printed Inventory does not list all chemical substances
that were reported for the Initial Inventory and are
considered to be included on it. There are several
reasons for this:
d. Some substances were reported too late to be
included in the Printed Inventory. They are,
however, included in the Master Inventory File.
b. The published Initial Inventory contains only
nonconfidential information. Confidential
chemical identities are included on the published
Inventory under the category "chemical substances
with confidential identities." EPA has published
generic names for some of these substances in
Appendix B of the Initial Inventory. The remainder
will be published in the future as generic names
are agreed upon. Because they are confidential
their specific identities are not available to
the public.
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c. Some reported substances were inadequately
identified.
d. Some substances were reported by Colour Index names
which were insufficient to identity the specific
substances.
e. Some substances were reported as products of
reactions involving trade name materials.
f. Some substances were reported with ambiguous
confidentiality claims.
MOST OF THE ABOVE CHEMICALS WILL BE ADDED TO THE
PUBLISHED INVENTORY IN SUPPLEMENTS.
8. WHY IS THERE AN INITIAL INVENTORY AND A REVISED INVENTORY?
TSCA required EPA to establish and maintain an inventory
of chemical substances manufactured, processed or imported
for commercial purposes (other than those used solely for
research and development purposes). The Initial Inventory
was published as a first step toward getting the base of
existing chemicals. The Initial Inventory contains most
but not all of the chemicals manufactured, processed, or
imported for commercial purposes in the United States since
January 1, 1975. It is possible that some chemicals
eligible for the Inventory were not reported by manufacturers
and importers for the Initial Inventory.
Thus, a Revised reporting period for processors was permitted,
A Revised Inventory will be published in 1980/ which will
include the chemicals omitted from the Initial Inventory
(see question 7) and those chemicals reported by processors.
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2. REVISED INVENTORY
9. WHO MAY REPORT FOR THE REVISED INVENTORY?
(1) Processors and users of chemical substances,
(2) Importers of chemical substances which are a part of
mixtures or articles.
10. WHAT IS A PROCESSOR OR USER?
Processor and user are terms used synonymously for purposes
of Revised Inventory Reporting. Processors and users are
persons who prepare for distribution in commerce or for use
as an intermediate, chemical substances that have already
been manufactured. This includes persons who grind, pulverize,
blend or repackage a chemical substance for commercial
purposes or who blend purchased chemical substances to
make mixtures or solutions, or use them in articles which have
a commercial purpose.
11. IS THERE ANYONE WHO MUST REPORT FOR THE REVISED INVENTORY?
Yes. Some processors filed a Voluntary Trademark
Report Form (Form D) for the Initial Inventory. They
certified that if the substances contained in the trademark
products were not included on the Initial Inventory, they,
as processors, would report the substances for the Revised
Inventory.
If, after looking through the Initial Inventory, those
processors do not find 'the components of their trademark
products, then they must report them for the Revised
Inventory.
12. WHERE DO I FIND REVISED INVENTORY REPORTING PROCEDURES?
Revised Inventory reporting procedures are discussed
in the May 15, Federal Register (44 FR 28558). A policy
statement concerning Revised Inventory Reporting appeared
in the Federal Register on October 24, 1978 (44 FR 49688).
After you have determined that you should report you may
request the booklet, "Reporting for the Chemical Substance
Inventory," together with Form E, from the Industry Assistance
Office. This booklet provides step-by-step procedures for
reporting for the Revised Inventory.
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13. WHAT WILL BE IN THE REVISED INVENTORY WHEN IT IS PUBLISHED?
The Revised Inventory will include:
(a) substances appearing on the Initial Inventory
(b) substances reported for, but not processed in
time for, the published Initial Inventory
(c) substances reported by processors during the
second reporting phase
(d) new substances that have completed Premanufacture
Notification review and are being manufactured or
imported for commercial purposes.
14. WHEN WILL THE REVISED INVENTORY BE PUBLISHED?
Sometime in 1980.
15. WILL THERE BE A SUPPLEMENT TO THE INITIAL INVENTORY
PUBLISHED BEFORE THE REVISED INVENTORY COMES OUT IN
1980?
Yes. In the next few months, EPA plans to publish a
supplement to the Initial Inventory. This supplement
will include substances reported for Initial Inventory
which do not appear on it because identity clarifications
were necessary. In addition substances which were reported
too late to be included in the Initial Inventory as well as
substances that have completed premanufacture notification
and have begun to be manufactured or imported will appear
on the supplement.
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3. MASTER INVENTORY FILE
16. WHAT DOES THE MASTER INVENTORY FILE CONTAIN?
The Master Inventory File is the complete file of
chemical substances reported by manufacturers, importers
and processors. It contains:
All of the substances listed in the
printed portion of the Initial Inventory
of over 44,000 chemicals;.
About 2500 confidential chemicals, some of
which appear in the printed version under
generic names.
Chemical substances that were reported too
late to appear on the Initial Inventory.
(They will appear in a supplement.)
Chemical substances of questionable chemical
identity reported on Form C for the Initial
Inventory and which are still to be defined.
Substances reported by processors using Form E
(These will appear in the Revised Inventory.)
Chemicals which complete Premanufacture
Notification review and which are manufactured
or imported for commercial purposes, (that is,
the person who submitted the approved premanu-
facture notification notice has filed notice
with EPA that manufacturing or importing has
begun.)
17. IS THE INITIAL INVENTORY PART OF OR SEPARATE FROM THE
MASTER INVENTORY FILE?
There is only one inventory, the Master Inventory File
which is maintained by EPA. This Master Inventory File
contains all chemical substances which have been properly
reported to EPA. The printed INITIAL INVENTORY is the
major portion of the MASTER INVENTORY File and contains
items which had been fully processed for correct nomen-
clatures and generic terms by the end of 1978. It
therefore does not cdntarin some items that were not
fully processed and/or were reported too late for
inclusion.
- 6 -
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18. WILL THE MASTER INVENTORY FILE EVER BE PUBLISHED?
No. It is not a list for public release. It contains
confidential business information which EPA may not
publish.
19. IS THE MASTER INVENTORY FILE COMPLETE NOW? WILL IT
EVER BE COMPLETE?
The Master Inventory File is complete at any one instant.
However, it is continuously being increased. As processors
report new items and as chemicals complete PMN review
and after EPA has been notified that commercial
production has begun, they will be added to the Master
Inventory File.
20. I RECEIVED SIX VOLUMES WHEN I ASKED FOR THE INITIAL
INVENTORY. DID I GET THE MASTER INVENTORY FILE BY
MISTAKE?
No. You received the Initial Inventory in Volume I.
In addition you received three volumes of user indices plus
two volumes of Trademarks and Product Name listings.
All six volumes will assist you in determining whether
certain chemicals were reported.
21. ARE THERE ANY CHEMICAL SUBSTANCES THAT ARE NOT AND
SHOULD NOT BE ON THE MASTER INVENTORY FILE.
Yes. Certain substances are excluded from the
Inventory by TSCA, such as: mixtures, tobacco
products, nuclear materials, and substances used solely
as pesticides, foods, food additives, drugs, cosmetics,
and devices.
299-312 0 79
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4. INVENTORY AVAILABILITY
22. HOW MANY FREE COPIES OF THE PRINTED INITIAL INVENTORY
CAN A COMPANY RECEIVE FROM EPA?
Because of the high cost of printing and distribution, EPA
is providing only one free copy of the Initial Inventory,
in printed form, to each requesting company. The Divisions
of large corporations in different geographical locations
can also each be provided one free copy.
23. IS IT POSSIBLE TO PURCHASE ADDITIONAL COPIES OF THE
PRINTED INITIAL INVENTORY?
You may purchase the printed volumes from the
Superintendent of Documents, Government Printing Office,
Washington, D.C. 20402. Or you may telephone the GPO
Order Desk (202-783-3238) if you have a Visa or Master
Charge Card.
Order: 4 Volume Inventory: GPO No. 005-007-00004-7
$34.50
2 Volume Trademarks and Product Names
GPO No. 055-007-00003-9 $19.50
Total for 6 volumes is $54.00 which includes
4th class book rate postage. Allow 3 weeks
for delivery.
24. IS THE INVENTORY AVAILABLE IN MICROFICHE AND MAGNETIC
TAPE?
Microfiche is available free of charge from the Industry
Assistance Office.
Magnetic Tape is available from: NTIS SALES DESK:
703-557-4650
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Order: PB 295 108 $125.00 check or money order;
$200.00 overseas
Documentation describing computer information may be
needed before ordering the magnetic tape. Call the
Industry Assistance Office for documentation.
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25. IS IT POSSIBLE TO HAVE ACCESS TO THE INITIAL INVENTORY
WITHOUT OBTAINING A PERSONAL COPY?
If you need to search the Initial Inventory for only
a few chemical substances, you don't need to order or
purchase one. EPA has placed over 300 reference
Inventory sets in libraries of most large cities,
Government Printing Office Regional Depository Libraries,
State Environmental Offices, and EPA Regional Offices.
The location of these reference copies can be found in
an EPA booklet entiled, "Directory of TSCA Local
Resource Centers: Initial Inventory." This booklet
and the May 15, 1979 Federal Register may be ordered
by calling the toll-free number in the Industry Assistance
Office.
26. I AM THE PRESIDENT OF A SMALL CHEMICAL COMPANY. I
RECEIVED THE CANDIDATE LIST AND I AM ON THE INDUSTRY
ASSISTANCE OFFICE MAILING LIST. WHY HAVEN'T I RECEIVED
MY COPY OF THE INITIAL INVENTORY?
If you did not call or write to the Industry Assistance
Office to reserve your copy of the Initial Inventory,
you will not receive one. EPA published an order blank
in the Federal Register of October 24, 1978, for persons to
reserve the Initial Inventory (43 FR 49687). You may
call the Industry Assistance Office to obtain a copy
if your firm has not already ordered or received one.
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5. USING THE INITIAL INVENTORY
27. HOW DO I FIND A CHEMICAL SUBSTANCE ON THE INVENTORY?
If you have access to the Initial Inventory, refer to
the Introduction to Volume I which contains a complete
description of the Initial Inventory and instructions
for using it.
After you have read through the Introduction to Volume I
and after you have reviewed the answers in this
booklet, if you still have questions, you may call
the Industry Assistance Office on its toll-free line
number for help.
(1) If you know the CAS REGISTRY NUMBER for a substance
go directly to Volume 1 to locate it.
Volume I contains the actual Inventory list of chemical
substances, plus two appendices. For each chemical,
reported to EPA by manufacturers and importers, a
preferred name is given -- along with its unique Chemical
Abstract Service (CAS) Registry Number. The chemicals
are listed by their CAS Registry Number in ascending order.
Appendix A, also in Volume I, contains definitions of
chemical substances designed to assist in locating those
substances not identifiable by preferred name alone.
Some chemical substances listed on the Inventory are
marked by a dagger symbol. This dagger indicates that
their preferred names are not specific enough to permit
an unambiguous identification of the substances and that
there is a definition for the substance in Appendix A.
Appendix B in Volume 1 lists generic names for substances
on the Inventory whose specific chemical identities are
confidential.
(2) If you don't know the CAS Registry Number, the
remaining three volumes provide alternate routes
for locating the desired chemical substances in
Volume I, the inventory.
10
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(3) If you know the preferred name or synonym, use
volumes II and III.
Volumes II and III are the substance name indices.
In these two volumes preferred names and various
synonyms are listed alphabetically.
The substance name is the heading. The CAS Registry
Number is adjacent to it in brackets. Where it
applies, the molecular formula appears. Once a
substance is found go back to Volume I to verify
its actual listing in the Inventory.
(4) If you know the molecular formula, use volume IV.
Volume IV contains the molecular formula and UVCB
indices. If you know the molecular formula, go to
this portion of Volume IV. The molecular formula
is the heading. The substance name, or names are
arranged in alphabetical order below the heading.
A long dash replaces the heading parent when it
is repeated. The CAS Registry number is enclosed
in brackets. When the desired substance is found,
then go back to Volume I to verify its listing on
the actual Inventory.
(5) If the substance you are looking for is a UVCB
(Unknown or Variable Composition, Complex Reaction
Products, or Biological Materials) go to the UVCB
Index in the second portion of Volume IV.
The UVCB substances lack an accepted molecular
formula representation and, therefore, have been
grouped into subsets of closely related substances.
The most general subset headings are placed
alphabetically at the left margin of the hierarchy.
More specific subset headings are placed below these
headings. The CAS Registry Number is enclosed in
brackets. When your search is complete, go back to
Volume I, the Inventory.
11
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6. TRADEMARK AND PRODUCT NAME SECTION
28. HOW DO I FIND THE CHEMICAL SUBSTANCE I BUY FROM MY
SUPPLIER IF I ONLY KNOW IT BY THE TRADEMARK NAME?
Use the two volume Trademark and Product Name Section.
They were compiled solely to help processors who only know
the trademark or product name of the chemicals they buy
from their suppliers to determine whether they need to
report for the Revised Inventory. If the trademark is
listed, processors will not find the specific ingredient
listed, but will know that the substances are considered
to be in the Inventory. These Trademark and Product Name
Sections will not be republished.
During the initial reporting period, manufacturers and
importers were permitted to voluntarily report their
trademark and product names to EPA if they could
certify that all component chemical substances had been
reported for the Initial Inventory. EPA also permitted
processors to report for the Trademark Sections if they
certified that they would be responsible for verifying
that the component chemical substances were reported for
the Inventory.
29. HOW DO I USE THE TRADEMARK AND PRODUCT NAME Sections?
This Section is divided into two books. In the Trademark
and Product Name Section the names are listed alphabetically,
and the name of the reporting company is listed opposite
each trademark or product name.
In the Reporting Company Section, all trademarks or
product names are grouped with the reporting company.
Refer to the section you prefer. If a trademark or
product name is listed you do not have to report the
components of the products for the Inventory. The
chemical components of the trademark or product name are
considered to be on the Inventory.
30. I KNOW THE CHEMICAL SUBSTANCE THAT IS IN THE TRADEMARKED
PRODUCT I BUY, YET I CAN'T FIND IT ON THE INVENTORY.
THE TRADEMARK IS LISTED IN THE TRADEMARK BOOK. MUST I
REPORT THE CHEMICAL SUBSTANCE FOR THE REVISED INVENTORY?
No. Persons who reported trademarks had to certify that
the chemical substances contained in the trademarked
product either had been reported or would be reported by
them for the Inventory. You may report if you want to.
If you have reason to believe the supplier has not reported
the substance you buy, you should report it.
12
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7. HOW TO REPORT
31. WHAT IS THE FORMAT OF THE REVISED INVENTORY FORM E?
The Revised Inventory Reporting Form E consists of four
information blocks and is similar to the Initial Reporting
Form C. Form E should be used for all processor reporting,
32. CAN I REPORT CHEMICAL SUBSTANCES TO EPA IN A LETTER
RATHER THAN ON AN OFFICIAL FORM? CAN I PHOTOCOPY THE
OFFICIAL FORMS AND SUBMIT THEM TO EPA?
No. Only the official EPA Chemical Substances Inventory
Report Form E may be used. EPA will not accept chemical
substances reported in letters or on duplicates of the
official report forms because EPA has established a
procedure to acknowledge receipt of reports, using a
prenumbered acknowledgement card attached to each form.
33. WHERE DO I GET A REPORTING FORM? IS THERE AN INSTRUCTION
BOOK FOR THE REVISED INVENTORY?
Request both it and Reporting Form E from the
Industry Assistance Office toll-free number,
800-424-9065, or in Washington, D.C. 554-1404.
13
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8. CHEMICAL SUBSTANCES REPORTABLE FOR THE
REVISED INVENTORY
AND MISCELLANEOUS REPORTING QUESTIONS
34. WHAT IS A "REPORTABLE CHEMICAL SUBSTANCE"?
A Chemical substance is eligible for inclusion on
the Revised Inventory if:
(1) it was not included on the Initial
Inventory, and;
(2) it is not exempted or excluded from
reporting for the TSCA Chemical
Substance Inventory, and;
(3) it was processed or used, imported
as part of a mixture, or imported
as part of an article between
January 1, 1975 and December 31, 1979.
(Note: reporters must certify on
Form E that to the best of their
knowledge the chemical substance was
not manufactured or imported in bulk
form FOR THE FIRST TIME after effective
date for premanufacture notification
requirements, July 1, 1979.)
35. I MIX SEVERAL CHEMICAL SUBSTANCES TOGETHER BUT NO
CHEMICAL REACTION OCCURS DURING THE PROCESS. SHOULD
I REPORT ANY OF THE SUBSTANCES FOR THE REVISED
INVENTORY?
The mixture is not reportable. The components which
comprise the mixture should be reported only if they
are not found on the Initial Inventory.
36. I BUY SEVERAL CHEMICAL SUBSTANCES, INCLUDING A RESIN,
THAT I USE IN THE PRODUCTION OF PLASTIC SHEETING.
SHOULD I REPORT THE PLASTIC SHEETING FOR THE INVENTORY?
THE RESIN? BOTH?
The plastic sheeting is an article and it is therefore
not a reportable substance. The chemical substances
that comprise the article should be reported,
including the resin, if they are not found on the
Initial Inventory.
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37. I AM A MANUFACTURER AND I INADVERTENTLY FAILED TO REPORT
FOR THE INITIAL INVENTORY. WHAT CAN I DO?
EPA recognized that clerical errors would occur in reporting
for the Inventory. If a manufacturer inadvertently failed to
report for the Initial Inventory and can establish "good
cause" he may report on Form A, B, or C at the time he
discovers his error. He should send his report with an
accompanying letter explaining his reasons for failure to
report to Dr. Marilyn C. Bracken, Deputy Assistant Administrator
for Program Integration and Information, (TS-793) EPA, 401
M St., SW, Washington, D.C. 20460.
38. I STOPPED MANUFACTURING A CHEMICAL SUBSTANCE IN 1974.
HOWEVER, IT WAS PROCESSED BY SOMEONE ELSE IN 1977.
CAN I, AS A MANUFACTURER, REPORT IT FOR THE REVISED
INVENTORY?
No. Manufacturers are not permitted to report for
the Revised Inventory. However, the person who
processed the chemical substance during 1977 may
report it for the Revised Inventory.
39. I IMPORTED A BULK CHEMICAL SUBSTANCE DURING 1977.
CAN I REPORT IT FOR THE REVISED INVENTORY?
No. Importers of bulk chemical substances are
considered the same as manufacturers and are not
permitted to report for the Revised Inventory.
However, a processor or user of the substance could
report it.
40. I PURCHASED A CHEMICAL SUBSTANCE IN OCTOBER 1974
AND HAVE NOT USED IT. I AM NOW BLENDING IT INTO A
MIXTURE. THE CHEMICAL SUBSTANCE DOES NOT APPEAR
ON THE INITIAL INVENTORY. SHOULD I REPORT IT?
Yes. You may report any substance you process between
January 1, 1975 and 30 days after the Revised Inventory
is published in 1980.
41. I PROCESS REPORTABLE CHEMICAL SUBSTANCES A AND B, WITHOUT
A CHEMICAL REACTION, INTO A MIXTURE A + B. I PURCHASE
CHEMICAL A FROM A DOMESTIC FIRM AND I IMPORT CHEMICAL B
IN BULK.
You are both a processor and an importer of a chemical
substance.
You are an importer with respect to B. Therefore, you
cannot report B for the Revised Inventory. You should
have reported chemical B for the Initial Inventory. A
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processor of B could report it. If chemical A does not
appear on the Inventory, you may report it or authorize a
trade association to report it for the Revised Inventory.
Mixtures are excluded from the Inventory, so you will
not report A + B.
42. I REPORTED A CHEMICAL SUBSTANCE FOR THE INVENTORY BUT
I CAN'T FIND IT LISTED. DOES THIS MEAN I HAVE TO
REPORT FOR THE REVISED INVENTORY?
No. If your reported chemical substance is not on
the published Inventory, call EPA's Industry Assistance
Office (toll free: 800-424-9065, in Washington, D.C.
554-1404) to verify that the substance is included
in the Master Inventory File. Be prepared to specify
the number of the form on which it was reported.
43. I AM A PROCESSOR OF CHEMICALS. WHY SHOULD I HAVE TO
REPORT FOR A MANUFACTURER WHO NEGLECTED TO REPORT FOR
THE INITIAL INVENTORY?
You don't have to, but it is in your own best interest to
do so. If the substance does not appear on the Revised
Inventory you will not be able to knowingly use it for a
commercial purpose.
44. I REPRESENT A CLIENT WHO PROCESSES CHEMICAL SUBSTANCES.
MY CLIENT'S CUSTOMERS ARE REQUESTING CERTIFICATION THAT
HE HAS COMPLIED WITH THE INVENTORY REPORTING REGULATIONS.
HE HAS ASKED ME, AS HIS LEGAL COUNSEL, TO ADVISE HIM.
There is no requirement for such certification; however,
EPA understands that many people within the industry are
supplying guarantees that they have complied with TSCA.
45. CAN A PROCESSOR AUTHORIZE A TRADE ASSOCIATION OR OTHER
AGENT TO REPORT HIS REPORTABLE CHEMICAL SUBSTANCE?
Yes. A trade association or other agent may report on behalf
of a processor. The processor must certify, though, to the
trade association or agent, that he has processed the
chemical substance since January 1, 1975.
46. DO I HAVE TO BE A MEMBER OF THE TRADE ASSOCIATION THAT
I AUTHORIZE TO REPORT FOR THE INVENTORY ON MY BEHALF?
The Trade Association can report on behalf of nonmembers
if it chooses to do so.
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9. TRADEMARK PRODUCTS AND SUPPLIER-PROCESSOR RELATIONSHIPS
47. WILL THERE BE A VOLUNTARY TRADEMARK REPORTING FORM
FOR THE REVISED INVENTORY?
No. Voluntary Trademark reporting will not occur
during the Revised Inventory reporting period. EPA
does not intend to update the Trademark List.
48. A PRODUCT WHICH I PURCHASE IS LISTED ON THE TRADEMARKS
& PRODUCT NAMES LIST. DO I HAVE TO DETERMINE IF THE
COMPONENT CHEMICAL SUBSTANCES HAVE BEEN REPORTED FOR
THE INVENTORY?
No. According to the reporting procedures, persons
who submitted the trademarks certified that the
ingredients had been reported for the Inventory.
49. I PURCHASED A TRADEMARKED PRODUCT OF UNKNOWN COMPOSITION
FROM MY SUPPLIER. THE TRADEMARK IS NOT LISTED ON THE
PRODUCT TRADEMARK LIST. HOW CAN I BE SURE THAT THE
COMPONENTS OF THE TRADEMARKED PRODUCT HAVE BEEN REPORTED?
You can ask your supplier to provide you with a letter
certifying that all reportable chemical substances
comprising the trademarked product have been reported.
Alternatively, you can request that your supplier identify
the component chemical substances, so that you can check
their inclusion on the Initial Inventory.
50. MY SUPPLIER WILL NOT CERTIFY THAT HE HAS REPORTED THE
CHEMICAL SUBSTANCES COMPRISING HIS TRADEMARKED PRODUCT
WHICH IS NOT ON THE TRADEMARK LIST. HE REFUSES TO REVEAL
THE IDENTITY OF THE COMPONENTS OF HIS PRODUCT. WHAT
SHOULD I DO?
It is permissible for your supplier to jointly report with you
for the Revised Inventory. If your supplier will agree to
this reporting procedure, you should obtain a Report Form E
from EPA, completing information Blocks I through III and then
send the form directly to the supplier, who should complete
the form and send it to the Agency for inclusion on the
Revised Inventory. This voluntary procedure is recommended
by EPA and outlined in the June 1979 instruction booklet,
"Reporting for the Chemical Substance Inventory."
If your supplier will not agree to the joint reporting
procedure, write a letter to EPA: (1) provide the name
and address of the supplier, (2) the name of the trademarked
product, and (3) state that your supplier will not help you
report the specific chemical identity. EPA will attempt to get
the information from the supplier. Send your letter to:
Document Control Officer, Attn: IMS, Office of Toxic Substances
(TS-793), US Environmental Protection Agency, 401 M Street, S.W.,
Washington, D. C. 20460.
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51. AS A SUPPLIER, AM I REQUIRED TO DISCLOSE THE CHEMICAL
IDENTITY OF MY TRADEMARKED PRODUCT TO MY CUSTOMER SO THAT
THE CUSTOMER CAN DETERMINE WHETHER ALL COMPONENT CHEMICALS
WERE REPORTED FOR THE INITIAL INVENTORY?
No. The supplier is not required to inform his customer
of the chemical identity of a trademarked product. He
should, however, inform his customer that the chemical
substances have been reported.
52. WHAT INFORMATION DO I NEED TO DIVULGE TO MY CUSTOMERS
CONCERNING THE CONTENT OF MY MIXTURE?
You do not need to divulge anything. You should advise
your customers that all components have been reported
so they are not concerned about the use of the mixture.
53. I USE A TRADEMARKED PRODUCT. I CONTACTED MY SUPPLIER
BY PHONE AND ASKED FOR THE CAS NUMBERS OF ALL THE
INGREDIENTS TO CHECK THEM AGAINST THE INITIAL INVENTORY.
HE REFUSED TO GIVE ME THE CAS NUMBERS OR IDENTITY OF ANY OF
THE INGREDIENTS, BUT ASSURED ME THAT ALL THE INGREDIENTS
HAD BEEN REPORTED FOR THE INITIAL INVENTORY. IS THIS
ASSURANCE FROM MY SUPPLIERS SATISFACTORY?
Absolutely. There is no requirement that any supplier
furnish ingredient names or CAS numbers. For your own
satisfaction you may wish to have the supplier's
assurance in a letter.
54. WHEN I REPORTED FOR THE INITIAL INVENTORY I DIDN'T KNOW
THE SPECIFIC CHEMICAL COMPOSITION OF A TRADE NAME MATERIAL
I USE TO MANUFACTURE ANOTHER CHEMICAL. THEREFORE, I
REPORTED THE TRADE NAME MATERIAL TO EPA AND DESCRIBED THE
PROCESS I USED TO MAKE MY CHEMICAL. IS MY SPECIFIC CHEMICAL
ON THE INVENTORY?
You reported properly. If you received an acknowledgement
card from EPA, you may be assured that your chemical is on
the Inventory. If you did not receive an acknowledgement
card, call the Industry Assistance Office.
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10. IMPORTING MIXTURES AND ARTICLES
55. WHAT SHOULD AN IMPORTER OF A CHEMICAL SUBSTANCE (AS
PART OF A MIXTURE OR AN ARTICLE) DO IF HIS SUPPLIER
WILL NOT DIVULGE TO THE IMPORTER THE CHEMICAL
IDENTITIES OF THE COMPONENT CHEMICAL SUBSTANCES?
The foreign supplier and the American importer may
jointly report. The American importer should remove
the carbon paper between the submitting company copy
and the acknowledgement post card before completing
blocks I through III of Form E. Then enter the name
and address of the foreign supplier in block III as
the technical contact. Do not detach the post card;
it must remain ^attached to the form. The importer
should print his company name and address on the post
card so he will receive EPA1^ acknowledgement card.
In the space provided in block IV for supplementary
information the importer should print, "PRODUCT NAME"
and underneath this, he should place the name of the
product. The importer should photocopy the partially
completed form for his records and send the entire
form to his foreign supplier, along with the EPA booklet,
"Reporting for the Revised Inventory," which details the
procedures to be followed when reporting for the Inventory.
If the importer has identified a product which is an
article, mixture, or an excluded chemical substance,
the foreign supplier should either indicate that the product
contains no reportable chemical substances or identify
the reportable chemical substance in the product.
The supplier should 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 the form is signed.
If the chemical identity or method of manufacture of
the substance is claimed confidential, follow the
procedure described in chapter IV of the instruction
booklet, entitled "Confidentiality." In addition,
check the appropriate box under the heading "Confiden-
tiality Claims.:
Retain the last copy, marked "Submitting Company Copy,"
and send the remainder to the EPA address indicated on
Report Form E.
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56. ARE PROCESSORS OF IMPORTED ARTICLES REQUIRED TO REPORT
THE CHEMICALS CONTAINED IN ARTICLES FOR THE REVISED
INVENTORY?
They are not required to report, but they are encouraged
to, if necessary.
57. ARE EPOXY COATED TIN PLATES AND SHEETS CONSIDERED TO
BE ARTICLES? THE PLATES ARE OF A SPECIFIC DESIGN.
Yes.
58. IS IT TRUE THAT IF MY COMPANY IMPORTS THROUGH A
DISTRIBUTOR (WHO PAYS THE DUTIES) AND THE SUBSTANCE
DOES NOT APPEAR ON THE INITIAL INVENTORY, MY COMPANY
MAY THEN REPORT IT?
If the substance is part of a mixture or article, you may
report it for the Revised Inventory.
59. I IMPORT MIXTURES WHICH CONTAIN REPORTABLE CHEMICAL
SUBSTANCES. SHOULD I REPORT FOR THE REVISED INVENTORY?
You should only report if the substances contained in
the mixtures are not included on the Initial Inventory.
60. I IMPORT ARTICLES WHICH CONTAIN REPORTABLE CHEMICAL
SUBSTANCES. SHOULD I REPORT THESE SUBSTANCES FOR THE
REVISED INVENTORY?
You may report any of the chemical substances which
comprise the articles that are not included on the
Initial Inventory.
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11. PREMANUFACTURE NOTIFICATION
61. THIRTY DAYS AFTER INITIAL INVENTORY PUBLICATION (JULY 1, 1979),
MANUFACTURERS AND IMPORTERS IN BULK OF UNLISTED CHEMICAL
SUBSTANCES BECAME SUBJECT TO PREMANUFACTURE NOTIFICATION
REQUIREMENTS. DO ADDITIONAL PEOPLE BECOME SUBJECT TO
PREMANUFACTURE NOTIFICATION AFTER THE REVISED INVENTORY
IS PUBLISHED IN 1980?
When the Revised Inventory is published, two TSCA
compliance activities begin:
(1) It will become unlawful for any person to use for
commercial purpose a chemical substance which that
person had reason to know was manufactured, imported
or processed in violation of section 5.
(2) Thirty (30) days after the Revised inventory is
published, premanufacture notification requirements
will apply to importers of new chemical substances
which are part of mixtures.
62. I REPORTED A CHEMICAL SUBSTANCE FOR THE INVENTORY.
I DON'T KNOW IF EPA RECEIVED THE REPORT. MY CHEMICAL
IS NOT ON THE INITIAL INVENTORY. DO I HAVE TO COMPLY
WITH PREMANUFACTURE NOTIFICATION REQUIREMENTS?
No. You should have received an acknowledgement card
indicating that the report has been received. If you
did, the substance is in the Master Inventory File. If you did
not receive the card, call the Industry Assistance Office
to request verification that the substance has been
included in the Master Inventory File.
63. I REPORTED CHEMICAL SUBSTANCES FOR THE INVENTORY BY
COLOUR INDEX NAMES. THEY DON'T APPEAR ON THE INVENTORY
DO I HAVE TO COMPLY WITH PREMANUFACTURE NOTIFICATION
REQUIREMENTS?
No. If you received a report acknowledgment card, the
report is still in process. In processing these Colour
Index name reports EPA found many cases in which
insufficient identity information was provided. EPA
is clarifying the identity ambiguities concerning
substances reported this way. You should have received
a letter covering this.
A separate printed addendum to the Initial Inventory lists
the reported Colour Index names. The Master Inventory File lists
the reported Colour Index names. The addendum is
available from the IAO. It is not on the computer
readable tape, but anyone requesting the computer tape
will receive the printed Colour Index listing of names.
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64. IF A SUBSTANCE I WANT TO MANUFACTURE OR IMPORT IN BULK
FOR THE FIRST TIME IS DESCRIBED BY ONE OF THE LISTED COLOUR
INDEX NAMES, IS IT CONSIDERED TO BE LISTED ON THE INVENTORY,
OR MUST I SUBMIT PREMANUFACTURE NOTICE?
You should first call EPA's Industry Assistance Office to
determine whether the particular substance is listed in
the Master Inventory File. If it is, you may manufacture
it without going through premanufacture notification. If
it is not in the Master Inventory File, you would be subject
to Section 5.
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12. CONFIDENTIALITY
65. WILL EPA ALLOW ANY OF THE INFORMATION SUBMITTED
ON FORM E TO BE CLAIMED CONFIDENTIAL?
You may claim all, or only portions of the information you
submit to EPA as confidential. This information must relate
to trade secrets, commercial or financial matters. Form E
provides blocks to check confidentiality claims for activity,
whether the substance is imported or processed, company name,
method of manufacture, and chemical substance identity.
66. WHAT INFORMATION AM I PROTECTING WHEN I CHECK THE BOX
CLAIMING THE COMPANY CONFIDENTIAL?
If you check the box labeled "company" under the heading
"confidentiality claims," you are claiming as confidential
the link between your company and the substance you are
reporting.
67. I PLAN TO AUTHORIZE A TRADE ASSOCIATION TO REPORT FOR ME.
ARE THERE SPECIAL PROCEDURES REQUIRED FOR ASSOCIATIONS TO
CLAIM CONFIDENTIALITY?
A trade association cannot make confidential claims for any
information reported for the Inventory.
68. WHAT DOES IT MEAN WHEN I CHECK THE BOX MARKED "ACTIVITY"?
If you check the box labeled "activity" under the heading
"confidentiality claims," you are claiming 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 importing.
69. WHAT DOES IT MEAN WHEN I CHECK THE BOX LABELED "METHOD OF
MANUFACTURE"?
By checking this box, you are claiming confidential the
information on Form E relating to the way the substance is
made. To ensure that EPA maintains the correct information
confidential, circle it and label it "confidential"
on the form.
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70. HOW DO I ASSERT A CONFIDENTIALITY CLAIM FOR CHEMICAL
IDENTITY?
First, you must report the specific identity on Form E
and the CAS Registry Number if you know it. Then you
must furnish EPA with a proposed generic chemical name.
Check the box claiming the chemical identity confidential.
By doing this, you are claiming as confidential the Fact
that there is someone who imports or processes that
specific chemical for a commercial purpose. You must
substantiate this claim by writing a letter, signed by
a responsible official with detailed knowledge of the
letter's contents, and attach it to the Form E. It is
important to cross-reference each page of the substantia-
tion letter with the Form E serial number which appears
in the upper left hand corner. Answer each of the eleven
questions in the instruction booklet in as much detail
as possible.
71. IS THERE ANY INFORMATION AVAILABLE ABOUT HOW TO PROPOSE A
GENERIC NAME?
Review the EPA document, "Guidelines for Creating Proposed
Generic Names for Confidential Chemical Substances Identities
for the TSCA Inventory," which is available through the
Industry Assistance Office. You should propose a name
that is only as generic as necessary to protect the
confidential chemical identity. EPA will review your
proposed generic name and may ask you to submit other
proposed names.
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U. S. GOVERNMENT PRINTING OFFICE : 1979 0 299-312
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