United States
        Environmental Protection
        Agency
             September 1979
        Toxic Substances
&EPA
THE TOXIC
SUBSTANCES
CONTROL ACT:

The Initial Chemical
Substance Inventory
and Reporting for its
Revised Edition
      INITIAL CHEMl

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Foreword
This handbook has been prepared by the U.S. Environmental
Protection Agency's Industry Assistance Office established under
the Toxic Substances Control Act of 1976 (TSCA) (Public Law
94-469).

The contents, in a non-technical manner, include information on:
  • The Initial Chemical Substance Inventory: What It Is, How To
    Read It, and Its Availability
  • The Trademark and Product Name List: What It Is and Its
    Purpose
  • The Master Inventory File: What It Is
  • Revised Inventory Reporting: Who It Concerns and When,
    Also How To Report, If Necessary
  • Report Form E:  How To Complete It
  • Future Publication of the Inventory: When and Why
  • Premanufacture Notification: Briefly, What It Is and When and
    Who It Concerns

This is an informal document. Persons are directed to the May 15,
1979 and December 23,1977 Federal Register, as well as the June
1979 Instruction Booklet for official Revised Inventory reporting
directions.
For further TSCA information or copies of the publications
referenced:
  • Call Toll Free: 800-424-9065
    (in Washington, D.C.: 554-1404)
  • or, Write: Industry Assistance Office (TS-799)
             Office of Toxic Substances
             U.S. EPA
             401 "M" Street, S.W
             Washington, D.C. 20460

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s>EPA
THE TOXIC
SUBSTANCES
CONTROL ACT:

The Initial Chemical
Substance Inventory
and Reporting for its
Revised Edition
    JAN. 1, 1977
       JUNE 1-DEC. 31, 1979

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TOXIC SUBSTANCES CONTROL ACT
        (EFFECTIVE JAN. 1, 1977)

       TSCA + I!  EPA
r

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On January 1,1977, when the Toxic Substances Control Act
became effective ... an unprecedented strategy was launched to
protect our public health and environment from chemical harm.
This law, often referred to as TSCA, gives the U.S. Environmental
Protection Agency broad authority to monitor the entire life cycle
of chemical substances—their product development, testing,
manufacturing, processing, distribution, use, and disposal.
Due to TSCA's unprecedented "cradle to grave" authority over
chemical substances—a major delineation had to first be made.
Those chemicals already existing in U.S. commerce had to be
listed or inventoried; once this listing was in place, then all
chemicals not included on the Inventory would be considered
"new"—and subject to premanufacture notification review, by
EPA under TSCA, prior to being manufactured or imported for a
commercial purpose.

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JAN. 1, 1977
     JUNE 1-DEC. 31, 1979
           =INVENTORY REPORTING
                 (2 PHASES)
            (MANUFACTURERS & IMPORTERS REPORTED)
  JUNE 1,1979=
           JUNE 1979
    10
    17
    24
         M
11
18
25
12
19

26
         W
13
20

27
14
21
28
                           8
15
22
29
16

23
30

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Never before had an inventory of chemical substances in U.S.
commerce been compiled—or even attempted. The Agency's
toxic substances program, working since the law's outset, has
come a long way in achieving this enormous collection. This
presentation addresses the progress of the Inventory—its initial
publication on June 1,1979; as well as, the work that still
remains—the Revised Inventory reporting period which continues
through December 31,1979 to supplement the first listing.
On December 23,1977, TSCA Inventory reporting regulations
appeared in the Federal Register. The regulations set up a 2-phase
reporting period. The first phase, now over, called for chemical
manufacturers and importers to report chemicals they
manufactured, or imported, for a commercial purpose since
January 1,1975. For over one year EPA compiled these submitted
reports ... which,  in turn, led to the June 1,1979 release of the
Initial Chemical Substance Inventory.
June 1,1979 ... is an important date. It sets three major TSCA
activities into motion ...

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JUNE 1,1979...
        1. PUBLICATION DATE OF INITIAL INVENTORY;
        2. SECOND REPORTING PHASE BEGINS
          FOR REVISED INVENTORY;
        3. ESTABLISHES JULY 1, 1979 AS THE
          DATE MANUFACTURERS OF NEW
          CHEMICALS & IMPORTERS OF NEW
          CHEMICALS (IN BULK) FOR
          COMMERCIAL PURPOSES BECOME
          SUBJECT TO PMN.

                            oEPA   Toxic Substances
                                 Control Act
                                 Chemical Substance
                                 Inventory
                                 Initial Inventory
                                 Volume I
         • LISTS NEARLY 44,000 CHEMICAL
         SUBSTANCES DISTRIBUTED FOR
         COMMERCIAL PURPOSES IN U.S.

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  • It is the Inventory release date of the existing chemical
substances submitted to EPA by manufacturers and importers
during the first reporting period.
  • It triggered the second reporting phase of 210 days—through
December 31,1979—during which processors (those who buy,
use, or distribute chemicals from manufacturers or importers) are
to review for completion the list of chemicals reported to EPA by
their suppliers and add any chemicals not there, which have been
processed for a commercial purpose.
  • And third, it established July 1,1979—that is, 30 days after the
Inventory's publication—as the date premanufacture notification
review must begin for manufacturers of a new chemical and
importers of new chemicals in bulk not on the Initial Inventory
listing.
                    THE INITIAL
    CHEMICAL SUBSTANCES INVENTORY:
                    WHAT IT IS
                        AND
                 HOW TO READ IT.
Nearly 44,000 chemical substances are listed on the Initial
Inventory. The actual chemical substance listings, and three
different access guides to them, are contained in a four volume
set. Do not look for mixtures and articles on the Inventory; only
the chemical substances contained in them are listed.

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8
       VOLUME I - ACTUAL LIST OF CHEMICAL
                  SUBSTANCES (+ 2 APPENDICES)
          51-64-9
            BENZENEETHANAMINE,a-METHYL-, (SJ- C9H,3N


          51-66-1
             ACETAMIDE, /V-(4-METHOXYPHENYU- C9H,,NO2
          51-74-1
             \H IMIDAZOLE-4-ETHANAMINE, PHOSPHATE (1:2)
   INVENTORY LISTING (VOLUME I)
                   O
   APPENDIX A: CHEMICAL SUBSTANCE DEFINITIONS
                 (ALSO IN VOLUME I)
                       APPENDIX B
          CONFIDENTIAL CHEMICAL SUBSTANCE
                        IDENTITIES

       10005
        POLYMER OF ETHYL ACRYLATE.
          (2- a-METHYLACRYLOXYACETAMIDO)
          ETHYLHETEROMONOCYCLE, AND METHYL
          METHACRYLATE.

       10107
        COPPER* COMPLEX OF SODIUM SALT OF
          33'-DIHYDROXY-4-(6-AIMILINO-1-HYDROXY-3-SULFONATO
          -2-NAPHTHYLAZO) 4'(1-HYDROXYDISUBSTITUTED
          -2-NAPHTHYLAZO) BIPHENYL

       10152
        ALKENYLDIAMINE. POLYMER WITH CHOLROMETHYL-
          OXIRANE AND OXIRANE


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Volume I contains the actual Inventory list of chemical
substances, plus two appendices. For each chemical a preferred
name, reported to EPA by manufacturers and importers, is
given—along with its unique Chemical Abstract Service, or CAS,
Registry Number. The chemicals are listed by their CAS Registry
Number in ascending order. If you know the CAS Registry
Number for a substance go directly to Volume I to locate it; you
do not need to consult any of the access guides in the other
volumes.
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
substance. Therefore when you find a dagger next to a CAS
Registry Number of a substance on the Inventory—then turn to
Appendix A. Here these substances are by CAS Registry Number,
in ascending order. For each a supplemental definition or
description phrase is provided.
Appendix B in Volume I lists generic names for substances on the
Inventory whose specific chemical identities are confidential. If
you intend to manufacture or import a chemical substance not
included on the Inventory by a specific chemical name, and you
believe, if falls within one of the generic names listed in Appendix
B, you may ask EPA whether the specific chemical is included on
the Inventory or not. EPA will let you know whether the specific
chemical identity is listed or not after you have established a
bona fide intent to manufacture or import it—in accordance with
Sec. 710.7(g) of the December 23,1977 Inventory regulations.

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10
         ACCESS GUIDES TO THE INVENTORY
           SUBSTANCE NAME INDEX
                        •USE IF YOU DON'T KNOW
                         CAS REGISTRY NUMBER
                        •PREFERRED NAMES AND
                         SYNONYMS LISTED
                         ALPHABETICALLY
          SUBSTANCE NAME INDEX

          ABADOL [96-50-4] C3H4N2S
          ABADOLE [96-50-4] C3H4N4N2S
          ABASIN [7766-7] C9H15BrlM2O3
          ABATE [3383-96-8] Ci6H2oO6P2S3
     PREFERRED NAME
     OR SYNONYM
                                I
MOLECULAR FORMULA
               CAS REGISTRY NO.

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                                                        11
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 actual Inventory.
Volumes II and III comprise the Substance Name Index. 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.

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12
                     CONTAINS THE MOLECULAR
                     FORMULA AND UVCB
                     INDICES
              MOLECULAR FORMULA INDEX
           BENZENE, (CHLOROMETHYL) DODECYL-I28061-21-4J

          C19H,,NO,
           GLYCINE, N-K2-HYDROXY-5-NONYLPHENYL) METHYLJ-N
               METHYL MONOSODIUM SALT [5696808-2]
           BENZENE, 1-DODECYL4-METHYL-/704-476/
           - . TRIDECYL-/723-02-4/
   U VCB  STANDS FOR SUBSTANCES OF



     U NKNOWN OR

     VARIABLE COMPOSITION,

     COMPLEX REACTION PRODUCTS. OR
              •
                                     •
     BIOLOGICAL MATERIALS

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                                                        13
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.
Substances of unknown or variable composition, complex
reaction products, or biological materials are included in the
UVCB Index—the second portion of Volume IV. These substances
lack an accepted molecular formula representation and therefore,
have been grouped into subsets of closely related substances.

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14
      TUNG OIL
        ASPHALT
         POLYMER WITH COPALS, FORMALDEHYDE, GLYCEROL,
            LINSEED OIL, PHENOL, ROSIN AND TUNG OIL 168355-77-1*
         POLYMER WITH LINSEED OIL AND TUNG OIL 1688443-12-9*]
        CASHEW
          NUTSHELL LIO.. POLYMER WITH DI-ET SULFATE AND
            TUNG OIL 169011-97-8*]


        MORE SPECIFIC
        SUBSET HEADING
                      CAS REGISTRY NO
 ENERAL SUBSET
HEADING
                                            Toxic Substances
                                            Control Act
                                            Trademarks and Product Names
                                            Reported in Conjunction with
                                            the Chemical Substance
                                            Initial Inventory

                                            Trademarks and
                                            Product Names Section
       TRADEMARK & PRODUCT NAME LIST
          NOT OFFICIAL PART OF INVENTORY
        • SOLELY TO HELP PROCESSORS DETERMINE
         WHETHER TO REPORT

        • ONE TIME PUBLICATION

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                                                   15
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 actual  Inventory.
    THE TRADEMARK AND PRODUCT LIST:
                    WHAT IT IS
                        AND
                   ITS PURPOSE
In addition to the four volume Inventory, EPA, at the same time,
has published a 2-volume Trademark and Product Name List. It is
not part of the Initial Inventory. It was compiled solely to help
processors determine whether or not they need to report for the
second Revised Inventory phase. It is a one time publication.

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16
     TRADEMARK & PRODUCT NAME REPORTERS
       MANUFACTURERS

       IMPORTERS


       PROCESSORS
      ALSO HAD TO REPORT
      CHEMICAL COMPONENTS
      DURING INITIAL
      REPORTING PERIOD

 HAVE TO VERIFY CHEMICAL
 COMPONENTS ON INITIAL
 INVENTORY OR REPORT THEM
 FOR REVISED INVENTORY
            ALL TRADEMARK & PRODUCT NAME REPORTING
            WAS VOLUNTARY
                            FOR USE DURING REVISED
                            INVENTORY REPORTING PERIOD
                            BY PROCESSORS — WHO DO
                            NOT KNOW A SUBSTANCE BY ITS
                            SPECIFIC CHEMICAL NAME.
          TRADEMARKS AND PRODUCT NAME LIST
  1. TRADEMARKS & PRODUCT
           NAMES
   AMERGY 5400 PLUS
   AMERIBOND (ALL
   PRODUCTS)
DREW CHEMICAL
 COMPANY

AMERICAN CAN
 COMPANY
   AMERICAN           AMOCO OIL
   AVIATION GASOLINE 80/87  COMPANY
             2. REPORTING COMPANY NAMES
C.E. CAST INDUSTRIAL PRODUCTS
   4401 CREEKSIDE AVENUE
     TOLEDO OH 43612

 #480 PEARL PARTING
 ARCO LITE 100 THROUGH 999
 ARCO LUBE
 ARCO PART 50 THROUGH 100
 ARCO PASTE 100 THROUGH 999

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                                                        17
During the initial 1978 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 during this
time—if they too certified, that they would be responsible for
verifying that the component chemical substances were reported
for the Inventory.
All reporters of this information understood that the sole purpose
for this information was to compile this listing. Subsequently, the
two resulting volumes are to be used by processors, who only
know the trademark or product name of the chemicals they buy
from their suppliers.
This list is divided into two sections. In the Trademark & 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.

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18
                                                            AEPA      Toxic Substances
                                                                      Control Act
                                                                      Chemical Substance
                                                                      Inventory

                                                                      Initial Inventory

                                                                      Volume I

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                                                       19
Refer to the section most feasible for you. If a trademark or
product name is found listed you do not have to report—and you
can be assured of the respective chemical components appearing
on the actual Initial Inventory. One note—if you were a processor
who reported a trademark or product name between January 1
and May 1,1978 to EPA—you must go to the Inventory to verify
that your supplier actually reported the chemical components. If
not, it is your responsibility to do so during the second 210-day
reporting phase.
             INVENTORY AVAILABILITY
Due to 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. The Inventory is also available in microfiche and
magnetic tape. Inventory ordering and availability information
appears in the May 15,1979 Federal Register.

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20
                    REFERENCE INVENTORY COPIES
                                          GPO REGIONAL
                                        DEPOSITORY LIBRARIES
                            EPA REGIONAL ft STATE
                           ENVIRONMENTAL OFFICES
                   TO ORDER CALL
                       TOLL FREE:
                   800-424-9065
                   (554-1404 IN WASHINGTON D.C.)

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                                                     21
If you need to search the Inventory listing for only a few chemical
substances, you don't need to order or purchase one. EPA has
placed reference copies of the Inventory in the libraries of all
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 entitled, "Directory of TSCA Local Resource Centers:
Initial Inventory." This booklet and the May 15,1979 Federal
Register can be ordered by calling the toll free number shown.
        THE MASTER INVENTORY FILE-
           A THIRD SOURCE TO CHECK

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22
              MASTER  INVENTORY FILE
          NOT A LIST FOR PUBLIC DISTRIBUTION
                 CALL 800-424-9065
                 (554-1404 IN WASHINGTON, D.C.)
                 FOR INQUIRIES..
  REASONS SUBSTANCE NOT ON PRINTED
  INVENTORY BUT MAY BE ON THE
  MASTER INVENTORY FILE:
         • REPORTED TOO LATE FOR INCLUSION ON
          PRINTED VERSION;
         •SPECIFIC CHEMICAL IDENTITIES CLAIMED
          CONFIDENTIAL NOT ON INVENTORY;
         • INADEQUATE IDENTIFICATION OF SUBSTANCES;
         •AMBIGUITY ABOUT SUBSTANCES REPORTED
          BY COLOUR INDEX NAME;
         • PROBLEMS WITH PRODUCTS OF REACTIONS
          INVOLVING TRADE NAME MATERIALS;
         • AMBIGUOUS CONFIDENTIALITY CLAIMS.

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                                                        23
If you do not find the chemical substance you process or use on
the Initial Inventory, that does not mean it has not been reported.
It could be on EPA's Master Inventory File. The Master Inventory
File is not a list for public release. A phone inquiry to EPA's
Industry Assistance toll free number is the way you determine
whether a substance is on the Master Inventory or not.
There are several reasons why the printed Initial Inventory is
incomplete . . . and is continuously being added to ...

  • Some substances were reported too late to be included in the
printed Inventory—they are in the Master Inventory File;
  • The published Initial Inventory contains only nonconfidential
information—confidential chemical identities can be searched for
on the Master Inventory File;
  • Some reported substances were inadequately identified—as
the Agency resolves these identity problems, the chemicals are
added to the Master Inventory;
  • There is some ambiguity about substances reported by
Colour Index Name;
  • There have been a few problems with substances reported as
products of reactions involving trade name materials;
  • And finally, there are a number of ambiguous confidentiality
claims—as these problems are resolved the specific or generic
substance names will be entered on the Master Inventory.

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24

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                                                     25
First check the printed Initial Inventory for your substance. If it is
not there and you know the specific chemical identity you can go
ahead and report it to EPA on the proper Form E. Or you can
search one step further, and ask Industry Assistance to check the
Master Inventory File. You will be notified whether the substance
is there or not. If you are told it isn't—you should submit it during
the Revised Inventory report period.
      REVISED INVENTORY REPORTING
             WHO, WHEN, AND HOW
If you have processed or used a chemical substance for a
commercial purpose since January 1,1975—or, you have
imported a chemical substance as part of a mixture or article
since that same date ... and cannot find it listed on the printed
Initial Inventory or the Trademark & Product Name List. .. then
you are eligible to report the substance to EPA during the second
reporting phase.

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26
      SECOND PHASE REPORTING
     FOR THE REVISED INVENTORY
     JUNE 1979
DECEMBER 1979









31

























                  no DAYS
     IF A LETTER IS NOT OBTAINABLE
     ASK YOUR SUPPLIER TO:
         • DISCLOSE THE COMPONENT
           CHEMICAL IDENTITIES IN THE
           TRADEMARK PRODUCT SO
           YOU CAN REPORT;
           OR, ASSIST YOU IN REPORTING
           THE SUBSTANCE BY SHARING IN
           THE REPORT FORM COMPLETION.

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                                                        27
Second phase report submissions are to be sent to EPA from
June 1 through December 31,1979. These submissions will go
onto the Revised Chemical Substance Inventory, which EPA will
publish in 1980.
Before you finally determine to complete a report form yourself
even after searching and not finding a substance on the printed
Inventory or the Trademark List, EPA suggests you ask your
supplier—domestic or foreign—to provide you a letter certifying
that all reportable chemical substances in the product have been
reported for the Inventory. They may be listed but weren't found
by you.  If this letter is supplied to you, you would not report. EPA
suggests and encourages that this correspondence of report
verification take place between supplier and processor, if
possible, but it is not required. The purpose of determining
whether or not to report during this second phase reporting—as it
was during the first—is to achieve the most thorough list of
chemical substances manufactured, imported  or processed for
commercial purposes in the United States possible. Cooperation
among industry members is recommended to achieve this.
If a letter confirming that the chemical substances were reported
is not obtainable, then either—ask your supplier to disclose the
identities of the component substances in the trademarked
product, so you can report any substance eligible for the Revised
Inventory:—or, ask him to assist you in reporting the appropriate
chemical substances. The procedure for joint processor/supplier
reporting is outlined in the instruction booklet, "Reporting for the
Chemical Substance Inventory" published in June 1979 and
available from EPA.

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28
                IF YOU ARE UNSUCCESSFUL IN THESE
                AVENUES AND STILL ONLY KNOW THE
                PRODUCT TRADENAME, WRITE EPA:
                   • PROVIDE SUPPLIER NAME & ADDRESS
                   • PROVIDE TRADEMARK OR TRADE
                    PRODUCT NAME
                   • EXPLAIN YOU'RE UNABLE TO DETERMINE
                    WHETHER TO REPORT OR NOT

              SEND LETTER TO:
                              Document Control Officer
                              Ann IMS. Office of Tonic
                               Subitancei ITS-7931
                              U.S. Environmental Protection Agency
                              401 "M" St.. S W
                              Washington. D.C. 30009
                                     REPORT FORM E

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                                                        29
If you are unsuccessful in any of these avenues and still only
know the product tradename, you are encouraged to write the
Agency. Provide the name and address of the supplier, the name
of the trademarked product, and state that you have been unable
to determine whether or not to report for the Revised Inventory.
EPA will attempt to obtain the information from the supplier.
If you, as a processor, choose to report—or if you designate an
agent or trade association to do so for you—an official EPA
Chemical Substance Inventory Report Form E must be used.
For reporting you will need:
  • The June 1979 instruction booklet, "Reporting for the
Chemical Substance Inventory";
  • The May 15,1979 Federal Register, which spells out who and
what is reportable during this second reporting phase; and
  • Report Form E.

These materials will be mailed to you by calling the Industry
Assistance toll free number: 800-424-9065; in Washington, D.C.
call 554-1404.

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30
                                                        TRADE AS8OC/AGENT

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                                                       31
   REPORT FORM E-HOW TO COMPLETE IT
Form E consists of 4 information blocks. If you—as a processor or
importer of a chemical in a mixture or article—choose to report
individually, enter in the top left-hand block, Block II, the name
and address of your company. Be sure to leave a space between
each word and to use 2-letter state abbreviations. If you are
jointly reporting with your supplier—domestic or foreign—your
name still goes in Block II. If a trade association or other agent is
completing the form for you, their name and headquarters
address is to be entered into Block II.
In Block III—underneath Block II—enter the name, address, and
phone number of the person EPA can contact if it is necessary to
clarify information on the form. If you are reporting with your
foreign or domestic supplier enter their name. If a trade
association or agent is filling out the form for you, either your
name or theirs can be put here—the determination should be
based on the most qualified information source on the substance
being reported.

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32
                  • IF POSTCARD ADDRESS IS TO
                   BE DIFFERENT THAN BLOCK III-
                   REMOVE CARBON IN FRONT OF
                   CARD BEFORE COMPLETING
                   BLOCK III ON THE FORM.

                  • DO NOT DETACH THE POSTCARD
                   AT ANY TIME.

                  • WRITE-IN APPROPRIATE
                   ADDRESS ON POSTCARD
                                                     PROCESSOR/IMPORTER OR
                                                     TRADE ASSOCIATION/
                                                     AGENT SIGNS HERE
                                                     SUPPLIER, IF YOU ARE
                                                     JOINTLY REPORTING.
                                                     SIGNS HERE
                                           BLOCK IV FOR...
                                              • CHEMICAL SUBSTANCE IDENTITY

                                              • ACTIVITY

                                              • CONFIDENTIALITY CLAIMS

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                                                          33
Block III is designed so that the address entered there will carbon
copy onto the attached card, which will be sent back to the person
who wants verification that EPA has received the form. Therefore,
if this name differs from the technical contact—make certain the
carbon in front of the postcard is removed before filling out block
III. On the postcard write in the address you want EPA to send it
back to—but do not detach the postcard at any time.
Block I—in the top right-hand corner—contains the certification
statement. It should be signed by someone authorized by
you—the processor or importer. If a trade association or agent
reports for you, they must have an authorized officer sign this
statement. If you are jointly reporting with your supplier, an
authorized processor or importer's signature still must be
entered. The supplier will eventually sign beneath your signature.
Block IV is for chemical substance identity, activity, and
confidentiality. If you are jointly reporting with your
supplier—there are only a few things for you to do in Block IV.

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34
                             ACTIVITY • CONFIDENTIALITY
                        1C CHEMICAL  NAME

                      SrNONYMS WITH A SEMI COLON'
                        OVIOE STRUCTURAL

                     ULA. AND OTHER

                   O AID IN  THE SPECIFIC

                  ICAL SUBSTANCE
                   METHOD OF MANUFACTURE IS CONFIDENTIAL
                   (Orel* Ippbcjol* alternation and
                   mart it CONFIDENTIAL)
                                                                  CHEMICAL SUBST
                                                                  CONFIDENTIAL
                                                                        ID SUBSTANTIATION
                       nption  Sh««tj
                       itachmentsj
                                                                Confictantxl
                                                                  Ownit
                                                                     J

                                          Ic)
                                          Id)
METHOD OF MANUFACTURE IS CONFIDENTIAL
'C.rcle 3ppltcabl0 information and
mark it CONFIDENTIAL)

CHEMICAL SUBSTANCE IDENTITY IS
CONFIDENTIAL


       It] SUBSTANTIATION
            ~| No o< anactod lubnantianon
       I	I sheets Iwnte form number on
               all substantiation sheets)
       (21 Proposed Genenc Name
                                                                           TRADEMARK  OR
                                                                           PRODUCT  NAME

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                                                       35
In the "Activity" Block, check whether you process or import the
substance to be identified by your supplier in Block IV. Check both
process and import, if appropriate.
In the "Confidential Claims" Block—check "Activity," if you want
the link between your company and the fact that you import or
process the substance—claimed confidential. Check the
"Company" Box, if you want the link between the reported
substance and your company—claimed confidential.
Now go down to the bottom of the form and write the trademark
or product name of the substance—you are asking your supplier
to specifically identify. At this point, processors jointly reporting
—are to send the Form E to their supplier for completion.

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36
       PROCESSORS/IMPORTERS JOINTLY

         REPORTING WITH SUPPLIERS
     DO...

    1 MAKE A PHOTOCOPY
     FOR YOUR FILES

    •PUT YOUR ADDRESS
     ON THE RETURN
     POSTCARD
DONT...

• DETACH ANY FORM COPIES

* DETACH THE POSTCARD
 ON THE BACK
        JOINT COMPLETION OF FORM E
                                            •.**•'
                                    U.S ENVIRONMENTAL
                                    PROTECTION
                                    AGENCY
    PROCESSOR/
    IMPORTER
    SUPPLIER
                  SEARCH THESE SOURCES FOR
                  CAS REGISTRY NUMBERS:

                    (1) CA VOLUME, OR COLLECTIVE
                       CHEMICAL SUBSTANCE INDICES

                    (2) CA VOLUME, OR COLLECTIVE
                       FORMULA INDICES

                    (3) CA INDEX GUIDE

                    (4) CAS REGISTRY HANDBOOK-
                       COMMON NAMES (ON
                       MICROFORM)

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                                                         37
Do not detach any of the form copies—but do make a photocopy
of it for your files, before sending it to your supplier. Also, do not
detach the postcard on the back, but you can enter your name
and address on the receipt verification postcard —which EPA will
then send back to you.
Processors—sending a Form E to their supplier—will not see it
again. Suppliers, after entering the chemical identity information
in Block IV, are to send the completed form directly to EPA.
For processors and importers, filling out all of Block IV, as well as,
for suppliers completing this portion of the form—enter the
Chemical Abstract Service, or CAS, Registry Number, if you know
it. Include hyphens. If you don't know the CAS Registry Number
for a substance, try consulting one of the following sources. The
first three sources are found in most major academic libraries;
the fourth is commercially available from the Chemical Abstract
Service in Columbus, Ohio. If you can't locate a CAS Registry
Number, leave this block blank.

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38
   'ENTER A  SPECIFIC CHEMICAL  NAME
    (WHETHER  IT IS A CLASS  1  OR 2 SUBSTANCE)
     iv CHEMICAL SUBSTANCE iDE'jT'n ACTIVITY  CONFIDENTIA
     5 I CAS REGISTRY
        NUMBER
   SPECIFIC CHEMICAL NAME

|S€»A«ATI SrNON>US WITH A SfMI JHONI
                  L-me.tVvfl-'L-
      IN THE SPACF PROVIDED BELOW PROVIDE STRUCTURAL

      INFORMATION MOLECULAR FORMULA AND O'HEH

      SUPPLEMENTAL INFORMATION TO AID IN THE SPECIFIC

      IDENTIFICATION OF THE CHEMICAL SUBSTANCE
             VOUCULA0 'ORMJLA
                                                         3
                              METHOD OF MANUFACTURE IS CONFIDENTIAL
                                I >pcl>CJtx« info'miroo jrwj
                              ITU it.I CONFIDENTIAL!


                              CHEMICAL SUBSTANCE IDENTITY IS
                              CONFIDENTIAL
               • ALSO WRITE-IN SYNONYMS IF KNOWN..
                                                 • SEPARATE SYNONYMS
                                                  FROM THE SPECIFIC
                                                  CHEMICAL NAME
                                                  AND ONE ANOTHER
                                                  BY SEMICOLONS.
                                                 • USE THE SUPPLEMENTAL
                                                   SPACE AT THE BOTTOM
                                                   OF THE FORM IF YOU
                                                   NEED MORE SPACE
                                                   FOR SYNONYMS.
                                      1 SUBSTANCE:
        IN THE SPACE PROVIDED BELOW PROVIDE STRUCTURAL

        INFORMATION MOLECULAR FORMULA AND OTHER

        SUPPLEMENTAL INFORMATION TO AID IN  THE SPECIFIC

        IDENTIFICATION OF THE CHEMICAL SUBSTANCE

               C5H10
            SM Attached Supplemental Description Sheets
              (Write Form Number on all attachments)
                          •PROVIDE A MOLECULAR FORMULA
                          • PROVIDE A STRUCTURAL DIAGRAM
                                                             ••^•••M

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                                                       39
Next enter a specific name for the chemical substance you are
reporting—whether it is a Class 1 or a Class 2 substance. A Class 1
substance is one whose composition can be represented by a
definite chemical structure diagram. A Class 2 substance is one
whose composition cannot be represented in this way.
Also in this space EPA encourages you to enter synonyms—after
the specific name entry. Separate synonyms from one another,
and from the specific chemical name, by semi-colons. If you need
more space for synonyms, use the supplemental space at the
bottom of the form.
For a Class 1 substance provide a molecular formula and a
chemical structure diagram on the form.

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40
      CLASS 2 SUBSTANCE:
                                      • PROVIDE THE METHOD BY
                                       /WHICH THE CHEMICAL SUBSTANC
                                       IS MANUFACTURED-NOT HOW TH
                                       SUBSTANCE IS USED BY THE
                                       PROCESSOR.
                                      •PROCESSORS/IMPORTERS ARE
                                        TO CHECK THE APPROPRIATE
                                         ACTIVITY" BOX(ES) BEFORE
                                         ENDING TO SUPPLIER.
          METHOD OF MANUFACTURE IS CONFIDEN
          ICrcla applicable information and
           art it CONFIDENTIAL)
          HEMICAL SUBSTANCE IDENTITY IS
         CONFIDENTIAL
                 METHOD OF MANUf ACTVKE IS CONFIDENTIAL
                 1C.re* •pvKttM ****
                 m«
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                                                         41
For a Class 2 substance, in this space on the form, provide the
method of preparation. This refers to the method of manufacture
of the chemical substance—not how the substance is being used
by the processor.
In the "Activity" Box check whether you process or import the
substance. Check both if appropriate. A supplier completing this
Block IV portion of the form will not have to do this—the
processor will have already placed the right check here.
Enter a check in the box or boxes, to flag which information you
want to claim confidential. As a processor, importer, or supplier
completing this portion of the form—you  may claim any
information you want confidential. As a trade association or agent
filling it out—you are not allowed to make any confidential
claims.

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42
                                                      • PROCESSORS/IMPORTERS ARE TO
                                                        CHECK THE APPROPRIATE ACTIVITY
                                                        OR COMPANY CONFIDENTIAL
                                                        CLAIM BOXES BEFORE SENDING
                                                        TO SUPPLIER.
                                                                ;;
                                                                 ,/  UITNOO O* *.•*•*!•-• is CO
                                                                 -Jfr K^I.«PK«MM.-W«.M
                                                                 •  •Mfc40>«f>OIMTtAU

                                                                     -,u .   |»T*«| 3m* p. -,
                                                                   1 c&*(. :.!••• •

                                                                        ' S>_ •'.•*•.'**. s

                                                                           | "M, B» «"»C>»I **.'•« •' - »«••*
                                                                         - . !*- »-  S.-»
                                                                       ', *V**. « Pl>' «' :.**'|%H*< if I'
                                                                ','.         ••                '•'•


                                                               S6«
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                                                         43
By checking the box—within the Confidentiality Block—labeled
"Activity," you are saying that you want the link between your
company and the fact that you import or process the substance in
Block IV for commerical purposes—claimed confidential. By
checking the box labeled "Company"—you assert that the link
between your company and the Block IV substance is
confidential. Neither of these  confidential claim boxes are to be
checked by suppliers—the processors or importer, you are
reporting with, will have already made the  appropriate entries
here.
To claim the method of manufacture confidential, check the
appropriate box. Also, circle the applicable information and label
it confidential—as shown.
To claim the chemical identity of a substance confidential, check
the appropriate box. By claiming chemical identity confidential,
you are claiming that, the fact that anyone manufactures, imports,
or processes this chemical for a commercial purpose—is
confidential information. A written substantiation for this claim is
needed—the points to cover are in the instruction booklet.
Indicate the number of pages of this substantiation on the form.
Each must be cross-referenced with the form number on it. A
proposed generic name must also be given for the substance
identity being claimed confidential.

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44

    DETACH LAST COPY..
                                   SEND TO:

                            U.S. ENVIRONMENTAL
                            PROTECTION AGENCY
                            OFFICE OF TOXIC SUBSTANCES
                            P.O. BOX 02201
                            COLUMBUS, OHIO 43202
            FUTURE PUBLICATION
                       OF THE
               \  INVENTORY
        \
         1979
       Toxic Subilanc«»
       Control Ad
       Ch«mlc»l Sub«t.nc*
       Inventory

        SUPPLEMENT
          TO
       INITIAL INVENTORY
CONTENTS:

• SUBSTANCES, REPORTED FOR, BUT FOR
   SOME REASON WERE NOT PRINTED
       ON INITIAL INVENTORY

• NEW CHEMICAL SUBSTANCES WHICH
   HAVE ALREADY GONE THROUGH
   PMN AND HAVE BEGUN TO BE
   MANUFACTURED OR IMPORTED

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                                                    45
Detach the last form copy—marked "Submitting Company
Copy"—and send the remaining copies to EPA. Remember, this
fourth copy is to be torn off by the supplier's completing Block IV
for their processor or importer.  Be sure not to detach the postcard
on the back. EPA, when it gets your report Form E, will mail this
card back to you as confirmation of receipt.
  FUTURE PUBLICATION OF THE INVENTORY
EPA will publish a supplement to the Initial Inventory in 1979. This
supplement will include some of the substances not on the Initial
Inventory for reasons mentioned earlier. The supplement will also
include substances—which have begun to be manufactured or
imported for a commercial purpose for the first time since July 1,
1979, and have been reviewed by EPA's premanufacture
notification system.

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46
       1980
      Toxic Sobtttnctt
      Control Act
      Chamlcal Sub*l»nc«
      Inventory

      REVISED INVENTORY
    miimniMiiflTTiiiiiiTTTiiiii
CONTENTS:
• CHEMICAL SUBSTANCES REPORTED
 JUNE 1-DEC. 31, 1979

• CHEMICAL SUBSTANCES ON THE
 INITIAL INVENTORY

• CHEMICAL SUBSTANCES ON THE
 1979 INITIAL INVENTORY SUPPLEMENT
                        • A CHEMICAL SUBSTANCE
                         NOT ON THE INVENTORY...

                        • MAKES IT NEW
                                AND
                        • SUBJECT TO PREMANUFACTURE
                         NOTIFICATION REQUIREMENTS

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                                                  47
The Revised Inventory will be published in 1980—and will list the
substances reported between June 1 and December 31,1979, in
addition to the substances on the Initial Inventory and its 1979
supplement.
     PREMANUFACTURE NOTIFICATION
               BRIEFLY, WHAT IT IS
                         &
        WHEN AND WHO IT CONCERNS
Premanufacture notification review—authorized under Section 5
of TSCA—is the EPA process to which "new" chemical substances
are subject. New chemical substances are those not on the
Inventory. Implementation of premanufacture notification is
staggered—due to the two phase reporting method used for the
Inventory collection.

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48
                          F NEW CHEMICAL
                                ANCES
                        SUBJECT TO PMN
                        BEGINNING
                        JULY 1,1979
                         JANUARY 10, 1979 - PROPOSED
                        PREMANUFACTURE NOTIFICATION
                        REGULATIONS PUBLISHED IN THE
                             FEDERAL REGISTER
                     MAY 15,1979 - INTERIM PREMANUFACTURE
                       NOTIFICATION PROCEDURES PUBLISHED
                           IN THE FEDERAL REGISTER

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                                                         49
Manufacturers of new chemical substances, and importers of new
chemical substances in bulk form—that is, substances not listed
on the Initial or Master Inventory—became subject to
premanufacture notification requirements on July 1,1979.
Proposed premanufacture notification regulations were published
in the January 10,1979 Federal Register. The number and nature
of comments received on these proposed rules delayed EPA from
publishing final  regulations by July 1,1979.
Therefore, interim premanufacture notification procedures
appeared in the May 15,1979 Federal Register. Manufacturers and
importers of new chemical substances are to follow these,
beginning July 1, until the final rules are released and become
effective.

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50

                  • UPON RELEASE OF THE REVISED
                   INVENTORY IN 1980...

                  • PROCESSORS CANNOT KNOWINGLY USE FOR
                   A COMMERCIAL PURPOSE A CHEMICAL
                   SUBSTANCE IN VIOLATION OF TSCA'S
                   SECTION 5 (PMN REQUIREMENTS).
CALENDAR

7
14
21
28
1
8
15
22
29
2
9
16
23
30
3
10
17
24

4
11
18
25

5
12
19
26

6
13
20
27

                              IMPORTERS OF NEW
                              CHEMICAL SUBSTANCES
                              IN MIXTURES...
                              BECOME SUBJECT TO
                              PMN 30 DAYS AFTER
                              THE REVISED INVENTORY
                              IS PUBLISHED IN 1980.

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                                                      51
After the release of the Revised Inventory in 1980, it will be
unlawful for processors to knowingly use "new" substances
which have not passed through premanufacture notification. Note
that processors, themselves, are not subject to premanufacture
notification—but they cannot knowingly use for a commercial
purpose a substance manufactured in violation of TSCA's
Section 5.
And finally, importers of new chemical substances in mixtures
become subject to premanufacture notification requirements 30
days after the 1980 Revised Inventory's publication. Importers of
new chemical substances in articles are not now covered under
the Section 5 premanufacture notification procedure. EPA has not
yet made a final decision on this situation.
SOURCE FOR INFORMATION AND MATERIALS

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52
                                  AVAILABLE FROM...
                                  INDUSTRY ASSISTANCE OFFICE
                                          CALL TOLL FREE
                                          800-424-9065
                                          (554-1404 IN WASHINGTON. D.C.)
                                          OR
                                          WRITE
                                          INDUSTRY ASSISTANCE OFFICE (TS 799)
                                          U.S. ENVIRONMENTAL PROTECTION AGENCY
                                          401 M ST., S.W.
                                          WASHINGTON, D.C. 20460

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                                                         53
To obtain a copy of any of the Federal Registers referenced in this
presentation, the Revised Inventory Report Form E and
instruction booklet the locator directory for reference copies of
the Initial Inventory, to check the Master Inventory File, and any
other information you need on TSCA—call our Industry
Assistance Office toll free number or write to the address shown.
EPA is committed to using the Toxic Substances Control Act-
fully. The ongoing task of inventorying all existing chemicals and
developing an unprecedented review procedure for all new
ones—is complex and enormous. To achieve it, industry,
government, and the public must work together. The ultimate
rewards of health and environmental protection are for all of us.

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