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.
                               14

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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
                                15

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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.
                               16

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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.


                              17

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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.
                               18

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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.
                              19

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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.
                               20

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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.


                              21

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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.
                               22

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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.
                               23

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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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