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 ------- 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 ------- 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 ------- 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) ------- 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) ------- 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) ------- 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) ------- 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 ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 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 - ------- 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 ------- 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. ------- 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. ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 24 U. S. GOVERNMENT PRINTING OFFICE : 1979 0 299-312 ------- |