United States
Environmental Protection
Agency
Office of
Toxic Substances
Washington, D.C. 20460
MaY 1979
Toxic Substances
svEPA Reporting for the
Chemical Substance
Inventory
The Toxic Substances
Control Act
Public Law 94-469
Instructions For Reporting
for the Revised Inventory
-------
The Toxic Substances Control Act
Public Law 94-469
Instructions for Reporting for
The Revised Inventory
June 1979
U.S. Environmental Protection Agency
Office of Toxic Substances
Washington, DC 20460
-------
FOREWORD
The Toxic Substances Control Act (TSCA) Initial Inventory
of Chemical Substances, published in May 1979, includes chemical
substances reported to EPA by their manufacturers and importers
in accordance with the TSCA inventory reporting regulations.
During the 210-day reporting period that begins June 1, 1979,
processors and users of chemical substances for commercial
purposes and importers of chemical substances as part of mixtures
or articles for commercial purposes may report substances that
were not included on the Initial Inventory for inclusion on a
Revised Inventory, which will be published sometime in 1980.
This booklet provides instructions for the Revised Inventory.
-------
Table of Contents
Page
Introduction 1
Inventory Time Line 3
Chapter I. Reporting for the Revised Inventory. 5
. . . . A. Who May Report 5
. . . . B. What May Be Reported 5
. . . . C. When to Report 9
. . . . D. How to Determine Whether to Report . 9
. . . . E. Further Assistance 11
Chapter II. How to Complete the Report Form. . 15
Chapter III. Identifying Chemical Substances. . 19
. ... A. Reporting the Identity of a Class I
. . . . . Chemical Substance 19
. . . . B. Reporting the Identity of a Class II
. . . . Chemical Substance 26
Chapter IV. Confidentiality 31
Appendix 1. Inventory Reporting Regulations. . 37
Appendix 2. Sources of CAS Registry Numbers. . 43
-------
INTRODUCTION
The Environmental Protection Agency (EPA) promulgated the
inventory reporting regulations (40 CFR Part 710) on December 23,
1977 under the authority of section 8 of the Toxic Substances
Control Act (TSCA). These regulations, which appear as Appendix
I of this booklet, govern the reporting of chemical substances to
create an Inventory of chemical substances manufactured, imported
or processed in the United States for a commercial purpose.
The inventory reporting regulations establish a two phase
reporting schedule for compilation of the Inventory. During a
120-day reporting period in early 1978, manufacturers and
importers reported chemical substances to EPA for inclusion on an
Initial Inventory. Publication of the Initial Inventory marks
the beginning of the second phase, a 210-day reporting period
during which processors and users of chemical substances and
importers of chemical substances as part of mixtures or articles
will have an opportunity to add substances to the Inventory to
ensure compliance with TSCA. The second phase will result in
publication of a Revised Inventory sometime in 1980.
Publication of the Inventory sets into motion the
premanufacture notification provisions of section 5 of TSCA.
Under these provisions a person must notify EPA at least 90 days
before he intends to manufacture or import a chemical substance
that is not included on the Inventory. These provisions take
effect thirty days after publication of the Initial Inventory for
manufacturers and importers (in bulk) of chemical substances, and
thirty days after publication of the Revised Inventory for
importers of chemical substances as part of mixtures. The time-
line on page 3 illustrates the relationship between the Initial
and Revised Inventory and premanufacture notification. Thirty
days after publication of the Revised Inventory it will become
unlawful for any person to use for a commercial purpose a
chemical substance that was manufactured, imported, or processed
in violation of section 5 of TSCA.
Persons should examine carefully the Initial Inventory and
the Trademark and Product Name List before reporting a substance,
in order to determine whether the substance is already included
on the Inventory. SUBSTANCES THAT APPEAR ON THE INITIAL
INVENTORY SHOULD NOT BE REPORTED FOR THE REVISED INVENTORY. To
further assist persons in determining whether to report for the
Revised Inventory, EPA will publish one or more supplements to
the Initial Inventory before the Revised Inventory is
published. The supplement(s) will include substances that were
omitted from the Initial Inventory due to late reporting or
errors, substances reported for the Revised Inventory, and
substances that have completed premanufacture review AND have
begun to be manufactured or imported for commercial purposes.
The Initial Inventory is part of a four volume set. The
Inventory itself is contained in Volume I, and includes two
appendices. Appendix A: Chemical Substance Definitions,
identifies further chemical substances whose preferred names
alone on the Inventory do not permit their unambiguous
identification. Appendix B: Confidential Chemical Substance
Identities, lists generic names for substances whose specific
chemical identities were claimed as confidential for purposes of
the Inventory. The other three volumes, entitled User Guide and
Indices to the Initial Inventory, were published for use in
conjunction with, but not as a substitute for, the Initial
Inventory. The three indices, the Substance Name Index
(contained in Volumes II and III) and the Molecular Formula and
- 1 -
-------
UVCB* Indices (contained in Volume IV) provide alternate means
for finding substances which are listed on the Inventory.
In addition to the four volumes, EPA has published a two
volume Trademark and Product Name List, which was compiled from
Voluntary Product Trademark Report Form D's submitted to EPA
during the Initial Inventory reporting period. This list was
compiled solely to assist processors in determining whether to
report for the Revised Inventory. If a processor finds the name
of a product he processes on this list, he does not need to
report the components for the Revised Inventory.
~Chemical Substances °f.Unknown or \fariable Composition, Complex
Reaction Products and Ji10logical Materials.
- 2 -
-------
INVENTORY TIME LINE
June 1st
i
u
I
30 days
Publication
of Initial
Inventory;
Begin reporting
period for
Revised Inventory
July 1st
210 days-
December 31st
Supplement(s) to
Initial Inventory-
undetermined—
PMN begins
for manufac-
turers and
Importers of
chemical sub-
stances in
"bulk form"
End of
reporting
period for
Revised
Inventory
¦30 days
Publication
of Revised
Inventory
PMN begins for
Importers of
chemical
substances as
part of mixtures;
section 15(2) of
TSCA applies to
processors and
users
-------
Chapter I
REPORTING FOR THE INVENTORY
A. Who Hay Report
The following persons may report a chemical substance THAT
IS NOT INCLUDED ON THE INITIAL INVENTORY for inclusion on the
Revised Inventory:
(1) a person who has processed or used a chemical
substances (including use in the manufacture of a
mixture or article containing that chemical substances)
for a commercial purpose since January 1, 197 5.
OR
2) a person who has imported a chemical substance as part
of a mixture or article for a commercial purpose since
January 1, 1975.
Any person who is permitted to report substances for the
Revised Inventory may either report individually or authorize a
trade association or other agent to report on his behalf.
B. What May Be Reported
To be reportable for the Revised inventory, a substance must
not be listed on the Initial Inventory and must satisfy all of
the following three criteria:
1) It must be a "chemical substance" as defined by section
710.2(h) of the inventory reporting regulations;
2) It must have been manufactured, imported, or processed
for commercial purposes in the United States since
January 1, 1975; and
3) It must not be excluded from the Inventory by any
provision of section 710.4 of the regulations.
Definition of "Chemical Substances"
The Toxic Substances Control Act distingishes three types of
materials: (1) Chemical substances, (2) mixtures of chemical
substances, and (3) articles comprised of chemical substances
and/or mixtures. The Inventory will list only chemical
substances. It will not list mixtures or articles. It will
list, however, chemical substances of which mixtures and articles
are comprised.
"Chemical substance" is defined in section 710.2(h) of the
regulations by chemical composition, by source or origin, and by
identification of certain categories of materials which are not
considered "chemical substances":
"Chemical substance" means any organic or inorganic
substance of a particular molecular identity, including
any combination of such substances occurring in whole
or in part as a result of a chemical reaction or
occurring in nature, and any chemical element or
uncombined radical; except that "chemical substance"
does not include [710.2(h)]:
- 5 -
-------
1) any mixture [710.2(q)] * {31-36},
2) any pesticide when manufactured, processed, or
distributed in commerce for use as a pesticide
[710.2(b)] {37-393},
3) tobacco or any tobacco product, but not including
any derivative products,
4) any source material, special nuclear material, or
byproduct material [710.2(c)],
5) any pistol, firearm, revolver, shells and
cartridges, and
6) any food, food additive, drug, cosmetic or device,
when manufactured, processed, or distributed in
commerce for use as a food, food additive, drug,
cosmetic, or device [710.2(a)] {37, 40-42}.
Materials identified in the list above must not be
reported for the Inventory.
For a more complete discussion on substances that are
reportable, you are directed to read Eligibility Criteria For
Inclusion of Chemical Substances on the Inventory" found in the
introduction of Volume I of the Initial Inventory.
Excluded Substances
Some materials which are "chemical substances" and which
have been processed for commercial purposes since January 1,
1975, are excluded from the Inventory, and must not be
reported.
been:
1.
A chemical substance is excluded if it is, or has
Manufactured, imported, or processed solely in small
quantities for research and development [710,4(c)]
(3),[ 710.2(y)] {29, 43-51}.
o The NOTE appearing at section 710.2(y) of the
regulations states that any chemical substance that
is manufactured, imported or processed in
quantitities of less than 1,000 pounds annually is
presumed to be an R&D chemical substance. Such a
chemical substance may be reported for the Revised
inventory, however, if the person can certify that
the chemical substance was not imported or
processed, solely in "small quantities for research
and development."
2. A Mixture
o Section 710.2(q) defines hydrates and hydrated
•ions' as mixtures. A note to 710.4(c) indicates
that alloys, inorganic glasses, ceramics, frits, and
cements, including Portland cement, are to be
regarded as mixtures. Certain combinations of
metals, inorganic metal compounds, and inert
supports, which are frequently used for commercial
purposes, including for use as solid phase
heterogeneous catalysts, are also mixtures and must
not be reported. The components of these mixtures,
insofar as they are known, should be reported if
they are not found on the Initial Inventory.
~Pertinent citations of the regulations are given in square
brackets, e.g. l'iu.2(h J. Pertinent comment and responses whioh
are part of the regulations, are cited by enclosure i^braces
e.g. {73}.
- 6 -
-------
An impurity [710.2(m)], [710.4(d) (1)1
{61}
o By this inclusion, impurities are not reportable,
and, furthermore, no chemical substance which is
reported for the Inventory should be identified in
terms of its impurities, or by its commercial
grades. An impurity is defined as an unintended
component of a substance or mixture.
A byproduct [710.2(q)| which has no commercial purpose.
NOTE:—A byproduct which has commercial value only to
municipal or private organizations who (i) burn it as
fuel, < ii5 dispose of it as a waste, including in a
landfill or for enriching soil, or (iii) extract
component chemical value, may be reported for the
Inventory, but will not be subject to premanufacture
notification under section 5 of TSCA if not included
[710.4(d) (2)] {52-55}.
o Byproducts which have commercial value for reasons
other than those specified in the NOTE are not
excluded from the Inventory [see 710.2(p)].
A chemical substance which results from a chemical
reaction that occurs incidental to exposure of another
chemical substance, mixture, or article to
environmental factors such as air, moisture, microbial
organisms, or sunlight [710.4(d) (3)1.
o Chemical substances, such as rust on iron, or other
corrosion or degradation products, which form
incidental to environmental exposure are excluded
from the Inventory.
A chemical substance which results from a chemical
reaction that occurs incidental to storage of another
chemical substance, mixture, or article [710.4(d) (4)].
o Degradation products which form incidental to the
storage of a chemical substance, such as the partial
polymerization of a drying oil, are excluded from
the Inventory.
A chemical substance which results from a chemical
reaction that occurs upor. end use of other chenical
substances, mixtures, or -articles such as adhasives,
paints, miscellaneajs cleansers or other housekeeping
products, fuels and fuel additives, water scftening -and
treatment agents, photographic films, batteries,
matches, and safety flares, and which is not itself
manufactured for distribution in commerce or for use as
an intermediate [710.4(d) (5)],
o Chemical substances that are the components of
curable plastic or rubber molding compounds, inks,
etc., are not excluded from the Inventory by this
provision; only the chemical substances that are
formed upon use of such materials are excluded.
ft chemical substance which results from a chemical
reaction that occurs upon use of curable plastic ac
rjbber molding compounds, inks, drying oils, metal
finishing compounds, adhesives, or paints; or other
chemical substances formed during manufacture of an
article destined for the marketplace without further
chemical change of the chemical substances except for
those chemical changes that may occur as described in
section 710.4(d) of the regulations [710.4(d) (6)1.
-------
o Chemical substances which are the components of
curable plastic or rubber molding compounds, inks,
etc. are not excluded from the Inventory by this
provision; only the chemical substances which are
formed upon the use of such materials are excluded.
9. A chemical substance which results from a chemical
reaction that occurs when (i) a stabilizer, colorant,
odorant, antioxidant, filler, solvent, carrier,
surfacant, plasticizer, corrosion inhibitor, antifoamer
or defoamer, dispersant, precipitation inhibitor,
binder, emulsifier, demulsifier, dewatering agent,
agglomerating agent, adhesion promoter, flow modifier,
pH neutralizer, sequesterant, coagulant, flocculant,
fire retardant, lubricant, chelating agent, or quality
control reagent functions as intended to impart a
specific physico-chemical characteristic, functions as
intended [710.4(d) (7)].
o The substances comprising the various materials
listed above are not excluded from the Inventory;
only the chemical substances unintentionally formed
upon use of such materials are excluded.
10. A chemical substance which is not intentionally removed
from the equipment in which it was manufactured.
NOTE:—The "equipment in which it was manufactured"
includes the reaction vessel in which the chemical
substance was manufactured and other equipment which is
strictly ancillary to the reaction vessel, and any
other equipment through which the chemical substance
may flow during a continuous flow process, but does not
include tanks or vessels in which the chemical
substance is stored after its manufacture [710.4(d)
(8), 710.2(n)] {67-71}.
- 8 -
-------
C. When to Report
The reporting period for the Revised Inventory will begin on
June 1, 1979 and will end on December 31, 1979. Persons who
begin processing a chemical substance or importing a chemical
substance as part of a mixture or article FOR THE FIRST TIME
after the last date may report such substance(s) to EPA at the
time processing or importation begins, up to thirty days after
publication of the Revised Inventory.
D. How to Determine Whether to Report
The following suggested procedures are provided to assist
persons who may wish to report a substance for the Revised
Inventory but are unsure whether the substance is included on the
Initial Inventory. Since all reporting is voluntary, you are
under no obligation to follow these procedures, and may use any
suitable method to determine whether you should report.
In general, if a processor has received written
certification from his supplier that all the component chemical
substances in the product(s) he processes have been reported for
the Inventory, the processor should not be concerned about
reporting.
1. If you know the composition of the product:
— Consult the Initial Inventory to determine whether
all the reportable chemical substances comprising
the product are included.
— If all component substances are included on the
Initial Inventory, DO NOT REPORT.
— If one or more component substances are not included
on the Initial Inventory, you should report them for
inclusion on the Revised Inventory by completing a
form for each component according to the
instructions provided in chaper II of this booklet,
and submitting the form to the address provided on
it.
2. If you do not know the composition of the product;
— Consult the Trademark and Product Name List to
determine whether the product is included. If the
product is included, DO NOT REPORT.
— If the product is not included in the Trademark and
Product Name List, contact your supplier and ask him
for written certification that all component
substances have been reported for the Inventory.
— If your supplier refuses to certify that all
reportable chemical substances comprising the
product have been reported for the Inventory, ask
him to disclose to you the identities of the
component chemical substances.
— If your supplier agrees to disclose to you the
identities of the components, follow part 1 above.
- 9 -
-------
— If your supplier refuses to disclose to you the
identities of the component substances, ask him to
assist you in reporting by following procedure 3 on
paqe 10.
-- If your supplier refuses to assist you in reporting,
submit a letter to EPA providing:
-- your company name and address
— the name and address of your supplier
-- the name(s) of the product(s) you purchase from
that supplier
-- a signed statement indicating that your supplier
will not certify to you that all reportable
substances comprising the product(s) have been
reported for the Inventory.
-- and address this to:
Document Control Officer
Office of Toxic Substances (TS-793)
U.S.E.P.A.
401 M St. S.W.
Washington, D.C. 20460
3. Supplier Assisted Reporting Procedure -
Instructions for Reporting Company:
— Before completing blocks I-III of the report
form, remove the carbon paper between the
submitting company copy and the acknowledgement
postcard.* (See explanation below.) Then, enter
the complete name and address of your supplier as
the technical contact in block II.
— In the space provided in block IV for
supplementary information, print or type Product
Name, and add the name of the product.
— Photocopy the partially completed form for your
records and send the entire form to your
supplier.
Instructions for Suppliers:
— Enter the specific chemical identity of the
product indicated by the importer or processor in
block IV. Read carefully the instructions on how
to identify a chemical substance found in Chapter
III of this booklet.
-- If the importer or processor has identified a
product which is an article, mixture, or an
excluded chemical substance, either indicate that
the product contains no reportable substances or
*This report form is designed
block II will carbon copy onto = + *- Z ^ dress entered in
postcard will be returned to thah postcard* Since this
of the form, one should remove ?h.«KSS verify epa's receipt
submitting company copy and the nostcarn") between the
address is different from the technical contact
postcard enter the address to which the^ard^ho f^eSS* °n the
not however, detach the postcard fu should be sent, do
"insert separately in a ?nr ! °f the fo™ to
must remain attached to the form ' examPle. The postcard
- 10 -
-------
identify the reportable chemical substance in the
product.
— Sign the supplier certification statement
appearing in block I of the form, attesting to
the truth of the statement on the back of the
form. Enter the data you signed the form.
— If you wish to claim the chemical identity or
method of manufacture of the substance
confidential, follow the procedure described in
chapter IV of this booklet, entitled
"Confidentiality." In addition, check the
appropriate box under the heading
"Confidentiality Claims."
Retain the last copy, marked "Submitting Company
Copy," and send the remainder to EPA.
E. Further Assistance
If you need further assistance in interpreting the
regulations, finding a substance which may be on the inventory,
or completing the report form, or if you would like to order
additional materials to aid in reporting, contact:
1. EPA's Industry Assistance Office at (800) 424-9065
(Washington, D.C., please call 554-1404). Written
inquiries may be addressed to:
Industry Assistance Office (TS-799)
U.S. Environmental Protection Agency
401 M St., S.W.
Washington, D.C. 20460
2. Your EPA Regional Office. Each Regional Office is
staffed by persons who can respond to your questions
concerning the inventory reporting regulations. The
person to contact in each regional office is identified
on page 13.
- 11 -
-------
NATIONWIDE TOLL-FREE NUMBER: 800-424-9065
~If calling from Washington, D.C: 554-1404
Region I
Mr. Robert Dangel
John F. Kennedy Federal Building
Boston, Massachusetts 02203
617-223-0585
Region II
Mr. William Librizzi
Raritan Depot, Building 209
Edison, New Jersey 08817
201-321-6673
Region III
Mr. Edward Cohen
Curtis Building
6th & Walnut Streets
Philadelphia, PA 19106
215-597-7668
Region IV
Mr. Ralph W. Jennings, Rm. 34 5
345 Courtland Street, N.E.
Atlanta, Georgia 30308
404-881-3864
Region V
Mr. Karl E. Bremer
230 South Dearborn Street
Chicago, Illinois 60604
312-353-2291
Region IV
Dr. Larry Thomas
First International Building
1201 Elm Street
Dallas, Texas 7527 0
214-767-2734
Region VII
Mr. William Brinck
324 East 11th Street
15th Floor
Kansas City, Missouri 64106
816-374-3036
Region VIII
Mr. Ralph Larsen
1860 Lincoln Street
Denver, Colorado 80295
303-837-3926
Region IX
Mr. Jerry Gavin
215 Freemont Street
San Francisco, California 94105
415-556-3352
Region X
Dr. James Evert
1200 6th Avenue
Seattle, Washington 98101
206-442-1090
- 13 -
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
CHEMICAL SUBSTANCE INVENTORY REPORT
(Section 8(a) and (b) Toxic Substances Control Act 15 USC 26071
FORM NUMBER
00000005
FORM NUMBER
00000005
DO NOT REMOVE LABEL
. COMPANY NAME/ADDRESS
name!
^rmppg;R"|5£7fti 1'\ t I I I I I I I 1 I * I J
Mil
CtTY*t2£UUk^L
. ^ i i i i 1 t i ' t i m t 1 1 1 ! I 1 1 1.1-1 1 V j 1 j
I M I ' ' 1 1 1
<
Q
CL
UJ
O
UJ
cc
<
CL
UJ
1 1 ) 1 t I 1 1 \\
-T&iJ
slAwtf>7m
I I I I I I t 1 state
IE. TECHNICAL CONTACT NAME/ADDflESS/PHONE
NAME IVPrj PPAA-r^Pfti i i i i i i i i i i i i i i i. i l i i..
£nnpFcJX.VZ.^PrftCAsepr6,.. Xnc...
~till!
IViJS. z.
,"ITY1^-Inli^r^' ' 1 ' 1 ' ' 1 1
t i i I I 1
I I I I i
uJ
III:
.,11-
i ¦ IfiTATE&LJ
,.ot36789l
m . ceFUif-iCATiON f.TAl t MF.NT i hmepy eio* {&\ is eligible tot inclusion on me in.eMOfy unOftf
40 Cf H 710 ana (h) was riof manufactured or imported >n Du'k lo'ffi
for a commercial purpose (or the fusi time alter ihe elective date
ol pre'tianulaciure notitn.aiion requirements lo* manufacturers ol
chemical substances and importers ol chemical substances tr\ t>utfc
form (3) all information entered on this form is complete and
accurals, and (4) the conficjeniianty statements on tr>e Dae* of this
lorm are true as lo thai information toi wh>c.h ) asseaed a
conlidenliahty claim I agree In permit access to. ana the copying
ol. records by a du'y authorized representative of ihe EPA Admin-
istrator, in accordance with the Tome Substances Control Act, to
• document any information reported here
Cu^f-A Q
Tl # "
t/'M
Raymond J. Johnson/Vice President
NAMETITLE (TYPE or PRINT)
rT5fl5.-23A.-A.53 21
EZ. CHEMICAL SUBSTANCE
CAS
REGISTRY
number
(IF KNOWN)
563-45-L
IDENTITY/ACTIVITY/CONFIDENTIALITY
SPECIFIC CHEMICAL NAME
(SEPARATE SYNONYMS WITH A SEMI-COLON)
3-methyl-l-butene; Isopropylethylene
IN THE SPACE PROVIDED BELOW, PROVIDE STRUCTURAL
INFORMATION, MOLECULAR FORMULA, AND OTHER
SUPPLEMENTAL INFORMATION TO AID IN THE SPECIFIC
IDENTIFICATION OF THE CHEMICAL SUBSTANCE:
C5 H10
MOLECULAR FORMULA
I ! See Attached Supplemental Description Sheets
J 1 1
-------
Chapter II
HOW TO COMPLETE THE REPORT FORM
BLOCK I. COMPANY NAME/ADDRESS
¦ GENERAL NOTE: Enter one letter per space. Leave one blank
space between each word.
Reporting Individually: Enter the name and address of the
person (company, corporation, or other person as defined In
the Inventory reporting regulations) who processed or
imported the chemical substance identified in block IV.
Reporting by trade association or other agent: Enter the
complete name and headquarters address of the trade
association, or the name and address of the agent.
The following list contains two-letter state abbreviations
which should be used in completing blocks I and II.
TWO-LETTER STATE ABBREVIATIONS
Alabama
AL
Montana
MT
Alaska
AK
Nebraska
NE
Arizona
AZ
Nevada
NV
Arkansas
AK
New Hampshire
NH
California
CA
New Jersey
NJ
Canal Zone
CZ
New Mexico
NM
Colorado
CO
New York
NY
Connecticut
CT
North Carolina
NC
Delaware
DE
North Dakota
ND
District of Columbia
DC
Ohio
OH
Florida
FL
Oklahoma
OK
Georgia
GA
Oregon
OR
Guam
GU
Pennsylvania
PA
Hawaii
HI
Puerto Rico
PR
Idaho
ID
Rhode Island
RI
Illinois
IL
South Carolina
SC
Indiana
IN
South Dakota
8D
Iowa
IA
Tennessee
Tib
Kansas
K£
Texas
TX
Kentucky
KY
Utah
UT
Louisiana
LA
Vermont
VT
Maine
ME
Virginia
VA
Maryland
MD
Virgin Islands
VI
Massachusetts
Ma
Washington
WA
Michigan
MI
West Virginia
WV
Minnesota
MN
Wisconsin
WI
Mississippi
MS
Wyoming
WY
Missouri
MO
BLOCK II. TECHNICAL CONTACT NAME/ADDRESS/PHONE
Enter the name, address, and telephone number (including
area code and extension, If applicable) of the person whom
EPA may contact for clarification of Information submitted
on this form. An importer or processor who elects to have
his supplier (either foreign or domestic) report the
identity of the chemical substance must enter the name and
address of his supplier in this block.*
* This report form Is designed so that the address entered In
block II will carbon copy onto the attached postcard. Since this
postcard will be returned to that address to verify EPA's receipt
of the form, one should remove the carbon paper between the
submitting company copy and the postcard if the technical contact
address is different from the submitting company address. On the
postcard enter the address to which the card should be sent. Do
not however, detach the postcard from the rest of the form to
insert separately in a typewriter, for example. The postcard
must remain attached to the form.
- 15 -
-------
BLOCK III.
CERTIFICATION STATEMENT AND SIGNATURE
SIGNATURE: The certification statement must be signed by a
person authorized by the importer or processor to sign his
official documents. If a trade association or other agent
reports on behalf of one or more importers or processors, a
duly authorized official of the trade association or agent
must sign the statement.
DATE: Enter the month, day, and year that the form was
signed.
NAME AND TITLE: Enter the name and title of the person who
signed the certification statement.
SUPPLIER SIGNATURE AND DATE: If an importer or processor
elects to have his supplier (either foreign or domestic)
report the identity of the chemical substance he imports or
processes, a duly authorized official of the supplier must
sign in the space provided, attesting to the truth of the
Certification Statement by Supplier on the back of the
form. Enter the date the certification statement was
s igned.
BLOCK IV. CHEMICAL SUBSTANCE IDENTITY/ACTIVITY/CONFIDENTIALITY
CLAIMS
CAS REGISTRY NUMBER: Enter the Chemical Abstracts Service
(CAS) Registry Number if known. Include hyphens. CAS
Registry Numbers for a great many chemical substances may be
found in the following sources:
-- CA Volume, or Collective Chemical Substance Indices
— CA Volume, or Collective Formula Indices
— CA INDEX GUIDE
-- CAS REGISTRY HANDBOOK — Common Names (on microform).
Refer to Appendix 2 for more information on these sources.
SPECIFIC CHEMICAL NAME: Following the instructions
presented in Chapter III enter a specific chemical name for
a Class 1 chemical substance or a specific name for a Class
2 chemical substance. EPA encourages the reporting of
synonymous names for each substance reported. Separate
synonyms from the "specific chemical name" and from another
with semi-colons. If there is insufficient space, write
synonyms in supplemental space at the bottom of the form.
OTHER CHEMICAL SUBSTANCE IDENTIFICATION INFORMATION:
Enter in the space provided for supplemental information, if
applicable, other information needed to identify clearly the
reported chemical substance. Refer to chapter 3 for a
specification of what information must be submitted when
reporting a Class 1 or Class 2 chemical substance.
ACTIVITY: Enter a check in the appropriate box under the
general heading "Activity" to indicate whether you process
or import the chemical substance. If you both process and
import the substance you may check both boxes.
CONFIDENTIALITY CLAIMS: Enter a check in the appropriate
box(es) to indicate which information is claimed
confidential. Trade associations are not permitted to make
any confidentiality claims. Read Chapter IV before making
confidentiality claims.
a. By checking the box labeled "Activity" you assert that
the link between your company and the activity, i.e.,
the fact that your company imports or processes the
chemical substance identified in Block IV for
commercial purposes, is confidential.
- 16 -
-------
commercial purposes, is confidential.
By checking the box labeled "Company" you assert that
the link between your company and the chemical
substance Identified in Block IV Is confidential.
By checking the box labeled "Method of Manufacture is
confidential" you assert that the information in Block
IV which you have designated as relating to the Method
by which the chemical substance reported on the form
was manufactured, is confidential.
-------
Chapter III
Identifying Chemical Substances
Which Have No Known CAS Registry Number
All chemical substances which are reported for the Inventory
must be identified clearly. For a substance with a Chemical
Abstracts Service (CAS) Registry Number, reporting the CAS
Registry Number and a specific chemical name usually will ensure
its unambiguous identification for the Inventory. (See Appendix
2 for Sources of CAS Registry Numbers.) To report a chemical
substance which has no known CAS Registry Number, one must
provide chemically descriptive information of the type specified
in this chapter. Such information should be entered in the
appropriate spaces provided in Block IV of the report form.
Supplemental sheets, if needed, should be attached to the form
and bear the identifying Form Number of the specific form to
which they are attached. (The Form Number is the eight digit
number which appears in the upper left-hand corner of each form.)
Class 1 and Class 2 Chemical Substances
The type of chemically descriptive information required to
identfy properly a chemical substance depends on whether the
substance is a Class 1 or Class 2 substance.
A Class 1 substance is a chemical substance whose
composition can be represented by a definite chemical structure
diagram. Examples of Class 1 substances are: benzene, sodium
chloride, and dimethylmercury.
A Class 2 substance is a chemical substance whose
composition cannot be represented by a definite chemical
structure diagram. Examples of Class 2 substances are: linseed
oil, chlorinated butyl rubber, and the glycerol monoester of
hydrogenated cottonseed oil acids.
As a special case, polymers which are prepared,solely using
Class 1 monomers are considered Class 1 substances. On the other
hand, polymers (for example, alkyd resins) which are prepared
using, in whole or in part, Class 2 monomers are considered Class
2 substances. (For a more complete discussion, see Introduction
of Volume I of the Initial Inventory.)
A. Reporting the Identity of a Class 1 Chemical Substance
The following information must be reported to identify a
Class 1 chemical substance which has no known CAS Registry
Number:
I. a specific chemical name,
II. the molecular formula, and
III. the chemical structure diagram.
Each item of information listed above is important to the
proper identification of a Class 1 chemical substance and is
discussed in detail below. In addition, several examples are
provided which illustrate the type of information needed to
identify and report a Class 1 chemical substance.
1. A Specific Chemical Name
In the space under "Specific Chemical Name" in Block IV of
the form, enter a name that clearly and uniquely identifies the
chemical substance being reported. The name should identify the
positions of attachment of chemical groups or of unsaturation, if
any, by the use of locants. (Locants are numerals or Greek or
Roman letters commonly used in a chemical name to designate the
positions of unsaturated bonds or attachments of chemical groups
in a molecule.) Failure to use locants in naming a substance
- 19 -
-------
that has several isomeric forms will create ambiguity in the
identification of the specific chemical substance being
reported. The following names, as examples, are ambiguous and
should not be used to describe Class 1 compounds: anisidine,
chlorotoluene, nitrosonaphthol, picoline, xylene. Chemical
groups should also be described by terms which are unambiguous
(e.g., "octyl" or "isooctyl" should not be used if "2-ethylhexyl"
is meant). Stereochemical descriptors should be included in the
substance name whenever appropriate.
If the substance is a salt, an ester, or an addition
compound and one or both of the components are polybasic, the
name should clearly specify the ratio of the components (or note
that the ratio is unknown). For example:
Pumaric acid, monosodium salt
Mono(2-ethylhexyl) citrate
Glycerol 1,3-dibenzoate
It is essential that the specific chemical name be
consistent with the other information used to identify the
substance. The name is the first item of information used in
identifying a chemical substance. Any inconsistency among the
name, the molecular formula, and the chemical structure diagram
will necessarily require further clarification on your part
before the chemical substance can be entered on the Inventory.
EPA also encourages you to enter, following the specific
chemical name and separated by semicolons, other common names by
which the chemical substance is identified in the scientific and
technical literature, or in product listings. Do not, however,
enter trademarks, abbreviations, acronyms, or laboratory
designations.
2. The Molecular Formula
There are several possible formats for molecular formulas.
Two important conventions are the Hill convention and the dot-
disconnect convention. The Hill convention lists carbon first,
then hydrogen, and then the rest of the elements in alphabetic
order. The dot-disconnect convention represents salts and
addition compounds as distinct units separated by a dot. In the
case of salts the dot-disconnect format lists acidic hydrogens in
the molecular formula, even though they may have been lost in the
salt formation (for example, silver nitrate is represented as
Ag.HN03). Since the Hill convention (and dot-disconnect if
appropriate) are used in the Inventory, this is the preferred
format; however, any unambiguous notation is acceptable.
For example, the molecular formula for the sodium salt of
acetic acid (sodium Acetate) could be presented as1
C2H3Na02 (single summation format, Hill
convention)
or
[preferred] CjH^t^.Na
or
CH3COONa
or
NaC2H3°2
- 20
-------
3. The Chemical Structure Diagram
The chemical structure diagram should be entered In the
space provided within Block IV and should clearly Indicate the
Identity of the atoms and the nature of the bonds joining In the
atoms. Commonly used functional group abbreviations or shortcuts
are acceptable as long as they are unambiguous. For example:
-Me
-SO,
-Et
-NO,
-Pr
-CO-
-C02h
-CHO
-so3h
-Ph
Alkyl groups represented by summation-type formulas (e.g., C.H. - or
CaH,7-) will be assumed to be normal or "straight chain" unless other-
wise designated (e.g., tert-C^Hg-). Carbon atoms in ring systems and
their attached hydrogen atoms need not be explicitly shown. For example:
o
0
Any ionic charges or sterechemistry should be shown clearly. All known
stereochemical details should be provided. There should also be some
indication whether the stereochemistry shown in the diagram is abso-
lute or merely relative. For example:
Me
Qr
trans
(i.e., relative)
absolute
(i.e., racemate)
Once again, just as in the case of the chemical substance name, the
ratio of the components for an addition compound or salt should be
indicated clearly if more than one form is at least theoretically
possible. For example:
(H02CCH2)2NCH2CH2N(CH2C02H)2 disodium salt
(H02CCH2)2NCH2CH2N(CH2C02H) tetrasodium salt
H N(CH.) NH dihydrochloride
2. ^6 2
Class 1 Chemical Substance Identification Examples
The eight examples which follow illustrate the information needed
to identify Class 1 chemical substances properly. Some examples are
introduced by a substance name which is too ambiguous to be used as
a Class 1 substance name. In such cases, the comment points out the
ambiguity. Proper information (name, formula, structure) for the
identification of one possible Class 1 substance is then
presented. (See also the discussion of class 2 substances where the
ambiguity genuinely exists in the chemical substance).
- 21 -
-------
A. N-(isobutoxymethyl)acrylamlde:
Comment: This chemical name unambiguously Identifies a
Class 1 substance.
NAME : 21" ( isobutoxymethyl)ac rylamide
FORMULA: CgH^NOg
STRUCTURE: CH =CH-C-NH-CH,-0-CH_-CH-CH,
II 2 I 3
o CH3
B. Dixylylethane:
Comment: The name dixylylethane Is ambiguous without the
use of locants. This name could either refer to a class 2
substance or could be an ambiguous synonym for a specific
Class 1 substance. The Incorporation of locants In the name
can eliminate the ambiguity. A specific Class 1 substance
would be identified as:
NAME: 1, l-Di-3 , 4-xylylethane
OR
1,1-Bis(3 j 4-dimethylphenyl)ethane
FORMULA: Cl8H22
STRUCTURE:
C. els- and trans-Plperylene
Comment: Piperylene, or 1,3-Pentadiene, can be found with
CAS Registry Number 504-60-9. This CAS Registry Number,
however, is for the nonstereospecific form of the
substance. The els- and trans-plperylenes, if reported as
individual chemical substances, should clearly distinguish
between the two isomeric forms.
NAME: els-Piperylene NAME: Trans-Plper.vlene
(or cis-1, 3-Pentadlene) (OR _trans_-l, 3-Pentadiene)
FORMULA: C^Hg FORMULA : ^Hg
STRUCTURE: Me CH=CH STRUCTURE: Me H
\ / 2 \ /
c=c c=c
/ \ / \
H H H CH=CH2
(1574-41-0) (2004-70-8)
COMMENT: Note the three different CAS Registry Numbers.
- 22 -
-------
D. cls-3-Methyl-A^-tetrahydrophthalle anhydride
Comment: While the naine 3-Methyl-A -tetrahydrophthalic
anhydride is a systematic or descriptive substance name, the
designation cis is ambiguous. Inspection of the structural
diagram for this substance shows three asymmetric carbon
atoms, that is carbon atoms joined to four different atoms
or groups of atoms.
The stereochemical designation "cis" indicated that two
chemical groups or atoms are located on the same side of a
reference plan through the molecule (in this case, the
cyclohexene ring). It would take two such designations to
uniquely describe the relationship among the three centers.
The following data would be adequate to describe a specific
substance.
NAME: cis,cls-3-Methyl-A^-tetrahydrophthallc anhydride
or
cls-3-Methyl-cls-A**-tetrahydrophthalic anhydride
FORMULA: C9H10C>3
STRUCTURE: Me 0
(iX/ "
0
E. Sodium sebacate
Comment: Sebacic acid is a dibasic acid (i.e., decanedioic
acid). Sodium sebacate could refer to the mono- or disodium
salt. If the designation "sodium sebacate" refers to the
fully neutralized acid, the precise designation "disodium
sebacate" should be used to eliminate the ambiguity. The
proper reporting in that case would be:
NAME: Disodium sebacate
FORMULA: C^QH-^gO^. 2N3. OR ^10^l6^^2^4
STRUCTURE: HO C (CH U, CO,H. 2Na
£ 2 ° 2
or
HC^C disodium salt
or
NaO^C (ch258 CO Na
F. Chromium manganese oxide
Comment: The reporting of mixed metal compounds containing
hydroxyl (-0H), oxy(-O), oxo(=0), or peroxy (-0-0-) groups
- 23 -
-------
presents special problems. Depending upon the nature of the
metals involved, these compounds may be represented as salts
of inorganic oxo acids or as mixed metal oxides with no
attempt to elucidate the structure beyond the basic
elemental composition. The substance CrMnOh can be
represented in three ways — the chromium (2+) salt of
manganic acids, the manganic (2 + ) salt of chromic acid or as
simple as chromium manganese oxide, i.e., structure
unknown. The reporting of such substance names is
encouraged. (Stock Numbers are Roman numerals added
parenthetically to indicate the state or states of
oxidations.) For example:
Iron(II) oxide
FeO
Iron(III) oxide
Iron(II,III) oxide
Fe203
FegOj,
The following shows a preferred format for reporting a specific
form of chromium manganese oxide.
NAME: Manganese (II) chromate (VI)
FORMULA: HoCr0„.Mn or MnCrO,,
STRUCTURE:
HgCrO^.Mn
O
HO-l:r-OH •
II
o
Mn
OR
"0-Cr-O' Mn
O
2+
G. Maleic acid-phthalic acid-propylene glycol terpolymer
Comment: Synthetic polymers reported for the Inventory
should be identified by name, structure, and formula in
terms of the monomer(s) from which they have been
prepared.
NAME: cis-maleic acid-phthalic acid-propylene glycol
terpolymer
FORMULA: ( C^Ojj . CgHgO^. CgHgOg ) x
STRUCTURE: /" H\ yH /C02H
C=C
/ \ ' • CTC"2
H02C C02H C02H OH
[Note that the structure diagram for maleic acid clearly
shows the cls-conflguratlon.]
or
Using specific names and CAS Registry Number:
maleic acid . phthalic acid . propylene glcycol
(110-16-7) (88-99-3) (57-55-6)
H. Disodium salt of polyethylene glycol lauryl ether
monosulfosuccinate
Comment: Polyethylene glycol and polypropylene glycol and
their many derivatives are most conveniently represented on
the basis of a structural repeating unit formula which
simplifies the description of the end groups. The preferred
reporting would Include:
NAME: Disodium salt of polyethylene glycol lauryl ether
monsulfosuccinate
- 24 -
-------
FORMULA: (CoH.O) C-,H,-O^S•2Na
£ 4 n lb JU /
OR
(C2H40)nC16H28Na2°7S
STRUCTURE:
SO,H
I 3
HO-CCH-CHC tOCH.CH-*- OC.-Hoc•2Na
i £ || i. i n 12
o
OR
SO,Na
I 3
Na02CCH2CHC (OCH2CH2-)^ OC12H25
0
OR
so3h
C12H25 (OCH2CH2^ OCCHCHjCX^H- 2Na
OR
S03Na
C12H2? *OCH2CH2*H OCCHCH2C02Na
- 25 -
-------
Reporting the Identity of a Class 2 Chemical Substance
The following information should be reported to identify a
Class 2 chemical substance having no known CAS Registry Number:
I. a specific name, and
II. the method of preparation
Note that the method of preparation refers to the method of
manufacture of the chemical substance being reported and not to
how the substance is being used by the processor. Even though
the processor is reporting the substance, the method of
preparation (manufacture) is necessary for adequate identification
of most Class 2 substances. This information may be held
confidential (refer to Chapter IV of this booklet). In addition, some
Class 2 substances may be represented by a partial or incomplete
structure diagram, or may be described in terms of their general
chemical composition. Each of these items of information is
discussed below and illustrated by several examples.
I. A Specific Name
A Class 2 chemical substance should be identified by a name,
entered in the space below "Specific Chemical Name" of Block IV,
which is as descriptive of the substance as possible. In some
cases, the name may take the form of a specific chemical name
containing locants, component ratios, and stereochemistry. In
other cases, the best possible name may only identify the
substance as the reaction product of specified reactants.
EPA encourages you to enter, following the specified name
and separated by semicolons, other common names by which the
chemical substance is identified in the scientific and/or
technical literature, or in product listings. Do not however,
enter trademarks, abbreviations, acronyms, or laboratory
designations.
XI. The Method of Preparation
In the space provided in Block IV, enter a description of
the final step of the method used to manufacture or produce the
Class 2 chemical substance.
For substances prepared by chemical reaction, the
description should appear in the form of a reaction scheme, for
example:
A + B—*C.
The final reaction scheme should unambiguously identify, by name,
the immediate precursor substance(s), the nature of the reaction,
and the reactants whether or not they are implied by the term
used to describe the nature of the reaction. The precursor
substance(s) and/or the reactants should also be identified by
their respective CAS Registry Number(s), if known. Reaction
description terms should be as specific as possible (e.g.,
acetylation, alkaline hydrolysis, chlorination, diazotization,
epoxidation). General reaction terms should not be used if at
all possible. (e.g., addition, condensation, reaction). The
examples which follow this discussion indicate the appropriate
placement of such information in the reaction scheme.
If a Class 2 chemical substance is produced through several
different final reaction schemes, describe each of these final
reaction schemes. For example, if it is produced by either A +
D ,c or by D + E—»C. Describe C in terms of both of these final
reaction schemes.
- 26 -
-------
Fop substances produced without chemical reaction, for
example by extraction from a natural source or reaction mass,
specify the source, extraction process and the nature of the
extract.
Other Information
In some cases, a Class 2 chemical substance can be
represented by a partial or incomplete chemical structure
diagram. For example:
A. Hexabrornobiphenyl
Br„ Br
y
x + y = 6
B. Sodium butyl (o-hydroxyphenyl)benzenesulfonate
OH
Bu
S03Na
Comment: butyl (Bu means CH^-CHj-CI^CHg- (straignt chain)
C. Ethoxylated hydrogenated tallow amide
-------
H2S04(7664-93-9)
PREPARATION: Phosphate rock —
Consists predominantly of CaH^(PO^)2, CaHPO^ and CaSO^.
Chlorinated butyl rubber
Comment: Chlorinated butyl rubber Is obtained by
chlorlnatlon of butyl rubber, which Is a copolymer of
lsobutylene and isoprene.
NAME: Chlorinated butyl rubber
or
Chlorinated (isobutylene-isoprene copolymer)
PREPARATION: (isobutylene-isoprene) CIS02C1 (7791-25-5)
X
9010-85-9
OR
chlorination
. °"°2C1
| / j Ch lnrinaf i nn
CH
chlorination
CH.
3 j
9010-85-9
Blown Castor Oil
Comment: Blown castor oil is prepared by reacting
castor oil with air or oxygen at 80-130°C. This
results In oxidation along with some polymerization.
NAME: Blown castor oil
or
Oxidized castor oil
02(7782-44-7)
PREPARATION: Castor oil > oxidation plus
*8001-79-^ 80-130°C some polymerization
Linseed oil-phthalic anhydride-glycerol resins
Comment: Linseed oil-phthalic anhydride-glycerol
resins should be reported on the basis of their
monomeric components as with any polymer.
NAME: Linseed oil-phthalic anhydride-glycerol resin
PREPARATION: 0 (^I^OH
Linseed oil + II I + CHOh
*8001-25-1 polymerization
0 ch2oh
56-81-5
or
Using a specific name and CAS Registry Number for each
reactant:
Linseed oil Phthalic anhydride Glycerol
*8001-26-1 + 85-^-9 + 56-81-5
polymerization
- 28 -
-------
E. C.I. Sulfur Brown 42
Comment: Sulfur dyes are made by heating organic
materials with sulfur and sodium sulfide. The exact
compositions of the resulting dyes are usually unknown.
NAME: sulfurlzed sodium 2-methyl-3,5-dinitrobenzene-
sulfonate
6274-37-9
F. Anhydrosorbltol monoester of hydrogenated castor oil
acids
Comment: While sorbitol Is a well defined substance,
anhydrosorbltol refers to a combination of cyclic
dehydration products and thus is a Class 2 substance.
The monoester might be reported as:
NAME: Anhydrosorbltol monoester of hydrogenated castor
oil acids
PREPARATION:
SOjNa
PREPARATIONS
Na2S (1313-82-2)
: >
S (7704-34-9)
hydrogenated
Anhydrosorbitol + castor oil acids
*61790-39-4
esterification * esters
mono
- 29 -
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
CHEMICAL SUBSTANCE INVENTORY REPORT
(Section 8(a) and |b) Toxic Substances Control Act 15 USC 2607)
FORM
FORM NUMBER
00000005
!i
<
a
a.
LU
o
LU
QC
<
Q.
LU
-L
FORM NUMBER
00000005
DO NOT REMOVE LABEL
I. COMPANY NAME/ADDRESS
namfIW, P,rpp,egsprp., Inc..,
AnnRFss~P(>7§, SfFeeit,
r.iTYT-iLrailria
nniiNryTl.i-.tp.hp.U,
I I I I I I I I I I I I I
I I I
i i i i i i i i I statfTal!
I I I [ I I [ I I 7ip"b6789 I
E. TECHNICAL CONTACT NAME/ADDRESS/PHONE
NAME |J,o,hn 3wl,th,
annRF^moe, Chemical. Co.
'I I I I I I I I I I 1 1 I I I I I I I I I I I I I I I
11,23 A, A. ,S.t,reeC.
¦ ' ' ' ' ' 1 ' '
' ' ' I ' ' ' ' ' ' ¦ '
r.iTv~farperii
' ' ' ' ' I 1 ¦
a m nM f"1 7t6,5i-i5t5,5i-i432 J-1
IstatfUnI
7ip123^5 I
m. CERTIFICATION STATEMENT I hereby certify mat (111 am eligible
to report for the Revised Inventory under 40 CFR Part 710.3(b). and.
to the best of ny Knowledge and belief. i2) the chemical substance
identified below ta) is eligible for inclusion on the inventory under
40 CFR 710 and tb) *as not manufactured or imported m bulk form
for a commercial purpose lor the first time after the effective date
of premanufacture notification requirements for manufacturers of
chemical suosiances ana \mpo«tars of chemical substances m buix
rorm; (3) all information entered on this 'orm i$ complete and
accurate; and <4) >ne confidentiality statements on the back of this
form are true as to that information ?or Ahicn I have asserted a
confidentiality ciaim l aqree to permit access to, and the copying
of recoros by a duly autnonzed representative of the EPA Admin-
istrator. n accordance with the Tcxic Substances Control Act. to
¦10Clament any information reported here
6/// 7 f
Raymond J. Johnson/Vice Presidpnt
NAME/TITLE (TYPE OR PRINT)
12. CHEMICAL SUBSTANCE IDENTITY/ACTIVITY/CONFIDENTIALITY
REGISTRY
NUMBER
SPECIFIC CHEMICAL NAME
(SEPARATE SYNONYMS WITH A SEMI-COLON)
N.N -(4-methvl-l f 3-phenvlene)bislN-(2-aminnp.fhy 11
urea )
ACTIVITY
lonfioentiai
Claims
v/
v/
IN THE SPACE PROVIDED BELOW, PROVIDE STRUCTURAL
INFORMATION, MOLECULAR FORMULA, AND OTHER
SUPPLEMENTAL INFORMATION TO AID IN THE SPECIFIC
IDENTIFICATION OF THE CHEMICAL SUBSTANCE:
C13H22N6°2
MOLECULAR FORMULA
See Attached Supplemental Description Sheets
(Write Form Number on all attachments)
No o(
Sn«ets
2,4-:
(1 mole)
Diisocyanato-l-methylbenzene
584-84-9
y
(c)
~
(d)
METHOD OF MANUFACTURE IS
CONFIDENTIAL
(Circle applicable information and
mark it CONFIDENTIAL)
CHEMICAL SUBSTANCE IDENTITY
IS CONFIDENTIAL
(1) SUBSTANTIATION:
~ No. of attached substantiation
sheets (write Form Number on
all substantiation sheets).
(2) Proposed Generic Name:
(3) I agree to the terms of
CONFIDENTIAL SUBSTANCE
IDENTITY STATEMENT on the back
of this form.
¦ ^ S S S S
(10 moles)
1,2-Ethanediamine
107-15-3
< 170°F
C-C-NH,
H H x
ii W '' 0
M-c-isZ-c-c.-^,
H (¦# ,
faifet see above name)j
THE ABOVE IS A HYPOTHETICAL EXAMPLE OF A
SUPPLIER ASSISTED REPORT. THE SUPPLIER HAS
CLAIMED THE METHOD OF MANUFACTURE TO BE CONFIDENTIAL.
EPA FILE COPY
-------
Chapter IV
CONFIDENTIALITY
Any or all of the information that you submit to EPA may be
claimed as confidential if it relates to trade secrets or
commercial or financial matters that you consider to be
confidential. You must make and substantiate your
confidentiality claims before you submit the completed forms to
EPA. If you fail to do so, EPA may disclose the information
without further notice to you.
If you make a claim in the manner specified below, EPA will
disclose the information only to the extent, and by means of the
procedures, set fortli in regulations governing EPA's treatment of
confidential business information. These regulations, appearing
In Part 2 Subpart B of Title 40 of the code of Federal
Regulations and also In the FEDERAL REGISTER (41 FR 36906,
September 1, 1976; as amended, 43 FR 39997, September 8, 1978),
specify the procedures EPA must follow in determining disclosure
of confidential information. (Contact EPA's Office of Industry
Assistance for a copy of these FEDERAL REGISTER notices.) Among
other things, the regulations require that EPA notify you in
advance of publicly disclosing any information you have claimed
as confidential and substantiated as specified below.
How to Claim Confidentiality: Activity and Company
You must make confidentiality claims in the spaces provided in
block IV of the form as illustrated on page 30. By checking any
box under the heading "Confidentiality Claims," you are claiming
as confidential the particular item of information that
corresponds to that box. For example, if you wish to claim as
confidential the link between your company and the substance you
are reporting, check the box labeled "Company." If you wish to
claim as confidential the link between your company and the
activity in which your company is engaged with respect to the
chemical substance, i.e., processing or importation, check the
box labeled "Activity."
Making a claim on one form does not effect the status of
information on another form. Therefore, you must make all
applicable confidentiality claims on each form you submit.
Substantiating Confidentiality Claims Other Than Chemical
Substance Identity
By signing the certification statement appearing on the
front of the form you are attesting to the truth of all
confidentiality claims you make on the form. This certification
statement Includes the following phrase:
I hereby certify that ... (3) the confidentiality
statements on the back of this form are true as to that
information for which I have asserted a confidentiality
claim.
The statements which appear on the back of the form are to
substantiate any and all of the claims of confidentiality on the
form except for chemical identity. There are four general
statements, which apply to all information you have claimed as
confidential on the form. Below them are three more statements,
each of which applies to a particular confidentiality claim. For
each claim of confidentiality you make, you must certify, by
signing this form, that all four general statements are true in
addition to the statement which corresponds to the particular
claim you made on the front of the form.
For example, in order to substantiate that the link between
your company and the reported chemical substance is confidential,
- 31 -
-------
you must attest, by signing the certification statement in Block
III, to the truth of:
1. all four general statements, and
2. the statement headed "Company,"
All of which appear on the back of the form. This example also
applies to a claim of confidentiality with respect to "Activity"
(i.e., "process" or "import") and "Method of Manufacture" (see
discussion of the later claim below).
If one or more of the statements is not true for a
particular item of information you wish to claim confidential,
you may not claim that information as confidential. All
applicable statements must be true for each item of information
you claim confidential.
Claiming Method of Manufacture Confidential
In many cases, in order to identify a chemical substance
with no known CAS Registry Number and whose composition cannot be
represented by a definite chemical structure diagram (a Class 2
substance), a processor or importer may need to provide a
description of the method used to manufacture the substance, in
addition to a specific chemical name for the substance. You may
wish to claim the method of manufacture as confidential even
though you do not consider the specific chemical name you provide
for the substance to be confidential.
If you check the box labeled "Method of Manufacture is
Confidential" under the heading "Confidentiality Claims," EPA
will hold as confidential that information on the form which
relates to the method by which the substance was manufactured.
To insure that EPA maintains the correct information as
confidential, circle that information and indicate that it be
held confidential.
If EPA does not consider the specific chemical name for'the
substance provided in block IV to be specific enough for
inclusion on the Inventory, EPA will select a more specific name
for the substance. This name may be based, in part, on the
method of manufacture. In such an event, you will be notified of
EPA's selection and given an opportunity to claim the identity of
the substance as confidential.
If you are assisted in reporting by your supplier, your
supplier may claim the method of manufacture as confidential.
Refer to the procedures in Chapter I.
Claiming Chemical Substance Identity as Confidential
If you wish to claim the chemical identity of a particular
chemical substance as confidential for purposes of the Inventory,
check the box in Block IV which is labeled "Chemical Substance
Identity is Confidential."
By claiming the chemical identity of a particular chemical
substance confidential for purposes of the Inventory, you are
asserting that, to the best of your knowledge, the fact that the
chemical substance is manufactured, imported, or processed for a
commercial purpose by anyone is confidential. This claim must be
substantiated in writing, as follows, for each chemical substance
whose identity you claim as confidential:
o In accordance with procedures specified below you must
prepare a letter and attach it to the form on which you
have claimed the chemical identity of a substance as
confidential.
- 32 -
-------
o Your letter must include a cross-reference to the
specifically numbered form. {The form number appears on
the upper left-hand side of the form).
o The letter must be signed by a responsible official with
direct knowledge of the information contained in the
letter.
o Your letter must address each of the following questions
in detail. (To the extent possible, provide factual
information or relevant examples to substantiate your
claim).
1. What harmful effects to your competitive position, if
any, do you think would result from the identity of the
chemical substance appearing on the Inventory? How
could a competitor use such information, given the fact
that the identity of the substance would otherwise
appear on the Inventory of chemical substances with no
link between the substance and your company or
industry? What is the causal relationship between the
disclosure and the harmful effects?
2. How long should confidential treatment be given? Until
a specific date, the occurrence of a specific event, or
permanently? Why?
3. Has the chemical substance been patented? If so, have
you granted licenses to others with respect to the
patent as it applies to the chemical substance? If the
chemical substance has been patented and therefore been
disclosed through the patent, why should it be treated
as confidential for purposes of the Inventory?
4. Has the identity of the chemical substance been kept
confidential to the extent that your competitors do not
know it is being manufactured, imported or processed
for a commercial purpose by anyone?
5. is the fact that the chemical substance is being
manufactured, imported or processed for a commercial
purpose publicly available, for example in technical
journals, libraries, or state, local, or federal agency
public files?
6. What measures have you taken to prevent undesired
disclosure of the fact that this chemical substance is
being manufactured, imported or processed for a
commercial purpose?
7. To what extent has the fact that this chemical
substance is manufactured, imported or processed for a
commercial purpose been revealed to others? What
precautions have been taken regarding these
disclosures? Have there been public disclosures or
disclosures to competitors?
8. Does this particular chemical substance leave the
processing site in any form, either as product,
effluent, emission, etc.? if so, what measures have
you taken to guard against discovery of its identity?
9. if the chemical substance leaves the site in a product
that is available to the public or your competitors,
can the substance be identified by analysis of the
product?
10. For what purpose do you process or import the
substance?
- 33 -
-------
11. Has EPA, another federal agency, or any federal court
made any pertinent confidentiality determinations
regarding this chemical substance? If so, please
attach copies of such determinations.
EPA will regard as confidential any information which you
furnish in response to the above questions provided it is marked
CONFIDENTIAL at the top of each page containing confidential
information and it is not otherwise possessed by EPA. EPA will
not disclose the information without your consent unless
disclosure is ordered by a federal court.
NOTE: In the box provided in Block IV, indicate the number
of pages in the attached letter substantiating the claim.
If a processor or importer is assisted in reporting by his
supplier, the supplier may claim the identity of the substance as
confidential. Refer to the procedures in Chapter II.
Further Information Required on the Form When Identity is
Claimed Confidential
A. Confidential Identity and CAS Registry Number (if known)
Even if you claim the chemical identity of the substance
reported on the form confidential, you must report the specific
identity on the form. Also report the CAS Registry Number if you
know it.
B. Proposed Generic Chemical Name
If you claim the chemical identity of a substance
confidential, you must furnish EPA with a proposed generic
chemical name which is only as generic as necessary to protect
the confidential chemical identity. EPA will publish a generic
chemical name in an appendix to the Inventory to inform the
public of the type of chemical substance which has been claimed
confidential. You should adhere to the procedures detailed in
the EPA document "Guidelines for Creating Proposed Generic Names
for Confidential Chemical Substances Identities for the TSCA
Inventory," which may be obtained from EPA's Industry Assistance
Office (see Chapter I, page 12). EPA will review your proposed
generic chemical name in accordance with these guidelines and
section 710.7(f) of the Inventory regulations, and may ask you to
submit other proposed names. If you fail to provide a proposed
generic chemical name for your chemical substance, EPA will
consider this a waiver of your claim of confidentiality and will
publish the chemical identity of the substance on the Inventory.
C. Agreement to EPA Disclosure to Bona Fide Manufacturer
If you claim the chemical identity of a substance
confidential, you must agree to the statement appearing on the
back of the form which authorizes EPA to disclose the fact that
the chemical substance is included on the Inventory to a person
with a bona fide intent to manufacture the chemical substance.
In addition, you agree that you have and will make available upon
request, the data specified in section 710.7(e) of the inventory
reporting regulations. If you fail to agree to this statement,
EPA will consider this a waiver of your claim of confidentiality
and will publish the chemical identity of the substance on the
Inventory.
- 34 -
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
CHEMICAL SUBSTANCE INVENTORY REPORT
(Section 8(a) and (b) Toxic Substances Control Act 15 USC 2607)
FORM
FORM NUMBER
00000005
FORM NUMBER
00000005
DO NOT REMOVE LABEL
I. COMPANY NAME/ADDRESS
hfIxyZi f.rQC,asflofs. .Inc..
ADDRfsslWft ft, fitjrpp?:, , I
L
rmlEMM ,
rni inty"1 -'U.W-'-JV-'-t Mi
l l M i l i l l
' ' '¦I I I » > I ¦ ¦
1 ' 1 1 1 ' 1 » » 1 ' '
1 ' ' 1 1 1 ' 1 1 « 1 1 1
I I i I I I I I stateMJ
' ' '
I 7ip~1W39I
E. TECHNICAL CONTACT NAME/ADDRESS/PHONE
NAME lA-ft.-i PfllyM-PPi
iiiiiiiiiii.ii i I
Annates")**?. PfAC^Sffprg, Jpp,
|5£7fti fritrppE. 111 11 i 11
riTvl^-pArft i
I i I I I
I i i i I I
punucl 5fli5i-i23A1-15A32i
I I I I I I I I I I I kTATrftLI
ZlptfiWl
m. CERTIFICATION STATEMENT: I hereby cerlily that (1) I am eligible
to report for the Revised Inventory under 40 CFR Part 710.3(b). and,
to the best of my Knowledge and belief. (2) the chemical substance
identilteC below tai is eligible for inctusion on the Inventory under
40 CFR 710 and (b) was not manufactured or imported in bulk form
for a commercial purpose tor the firs! time after the effective date
of premanufacture notification requirements tor manufacturers of
chemical substances and importers ot chemical substances in bulk
form; (3) all information entered on this form is complete and
accurate; and (4) the confidentiality statements on the back of this
form are true as to that information for which I have asserted a
confidentiality claim I agree to permit access to. and the copying
of, records by a duly authorized representative ot the EPA Admin-
istrator, in accordance with the Toxic Substances Control Act, to
document any information reported here.
Cl
Raymond J. Johnson/Vice President-
NAME/TITLE (TYPE OR PRINT)
Supplier Signature
H. CHEMICAL SUBSTANCE IDENTITY/ACTIVITY(CONFIDENTIALITY
CAS
REGISTRY
NUMBER
(IF KNOWN)
SPECIFIC CHEMICAL NAME
(SEPARATE SYNONYMS WITH A SEMI-COLON)
2,2,3.3,4.4.5,5.6,6,6-undecafluoroN,N-bls-
(2-hydroxyethyl)hexanarnlde
ACTIVITY
/
v/
/
IN THE SPACE PROVIDED BELOW, PROVIDE STRUCTURAL
INFORMATION, MOLECULAR FORMULA, AND OTHER
SUPPLEMENTAL INFORMATION TO AID IN THE SPECIFIC
IDENTIFICATION OF THE CHEMICAL SUBSTANCE:
C10H10F11N03
MOLECULAR FORMULA
~ See Attached Supplemental Description Sheets
{Write Form Number on all attachments)
NO. oi
Sheets
|| XH CH,OH
CF,CF,CF,CP,CF,-C-N^ * i
\CH 2CH2OH
fc£z:
~
(C)
7
-------
APPENDIX 1
Inventory Reporting Regulations
(40 CFR 710)
Part 710 Is established to read u fol-
lows:
8«s.
710.1 Scope and oompllun.
710.5 Definition*.
710.8 Applicability: Reporting for the Ini-
tial tad nrlasd Inventory.
710.4 Scop* of the inventory.
710.6 How to report lor the Inventory.
710.6 Wban .to report.
710.7 Confidentiality.
710.8 Eltsctlvs date.
AtrrHoarrr: Subeeetlon 8(a), Toxic Sub-
•tancea control Act (TSCA) (90 Stat. 3003,
(It U.8.C. 2807(a))).
g 710.1 Scope and compliance.
iai This Part establishes regulations
governing reporting by certain persons
who manufacture, Import, or process
chemical subsances for commercial pur-
poses under section 8(a) of the Toxic
Substances Control Act (IS V.8.C. 3607
(a>). Section 8(a) authorizes the Admin-
RULES AND REGULATIONS
Istrator to require reporting of Informa-
tion necessary for administration of the
Act and requires EPA to Issue regulations
for the purpose of compiling an Inven-
tory of chemical substances manufac-
tured or processed for a commercial pur-
pose, as required by section 8(b) of the
Act. Following an Initial reporting pe-
riod, EPA will publish an Initial Inven-
tory of chemical substances manufac-
tured or Imported for commercial pur-
poses. After a supplemental reporting
period, EPA will publish a revised in-
ventory including those additional chem-
ical substances processed or used for
commercial purposes or Imported for
commercial purposes as a part of a mix-
ture or article. Further, In accordanoe
with section 8(b), EPA periodically will
amend the Inventor? to Include new
chemical substances which are manufac-
tured or Imported for a commercial pur-
pose and reported under section 6(a) <1>
of the Act. EPA also will revise the cate-
gories of chemical substances and make
other amendments as appropriate.
(b) Section 16(3) of TSCA makes It
unlawful for any person to fall or refuse
to submit Information required under
these reporting regulations. In addition,
section 15(3) makes it unlawful for any
person to fall to keep, and permit access
to, records required by these regulations.
Section 16*provldee that any person who
violates a provision of section 16 is lia-
ble to the United States for a civil pen-
alty and may be criminally prosecuted.
Pursuant to section 17, the Government
may seek Judicial relief to compel sub-
mission of section 8(a) Information and
to otherwise restrain any violation of
section 16.
Not*.—A« a matter of traditional Agency
policy, spa dooa not Intend to oonoantmte
Ite enforonnant effort* on Insignificant cleri-
cal errors in reporting
(c) Each person who reports under
these regulations shall maintain records
that document Information reported un-
der these regulations and, in accordanoe
with the Act, permit access to, and the
copying of such records by EPA officials.
8 710.2 Definitions.
For the purposes of this Part: (a) Tbt
following terms shall have the mimnlng
contained In the Federal Food, Drue, and
Cosmetic Act, 21 U.8.C. 321 et seq.. and
the regulations Issued under such Act:
"cosmetic," "device." "drug," "food," and
"food additive." In addition, the term
"food" includes poultry and poultry prod-
ucts. as defined in the Poultry Products
Inspection Act, 21 UJS.C. 463 et seq.;
-meats and meat food products, as defined
in the Federal Meat Inspection Act, 21
OS.C. 60 et seq.; and eggs and egg prod-
ucts. as defined in the Egg Products In-
spection Act, 21 UB.C. 1033 et seq.
(b) The term "pesticide" shall have
the meaning contained In the Federal
Insecticide. Fungicide, and Rodenticlde
Act, 7 U.S.C. 136 et seq., and the regula-
tions issued thereunder.
(c) The following terms shall have the
meaning contained In the Atomic Energy
Act of 19S4, 42 U.S.C. 2014 et seq., and
the regulations Issued thereunder: "by-
64575
product material." "source material."
and "special nuclear material."
(d> "Act" means the Toxic Substances
Control Act. 16 DJS.C. 2001 et seq.
(e) "Administrator" means the Ad-
ministrator of the TJ.S. Environmental
Protection Agency, any employee or au-
thorised representative of the Agency to
whom the Administrator may either
herein or by order delegate his authority
to carry out his functions, or any other
person who shall by operation of law be
authorized to carry out such functions.
(f) An "article" is a manufactured
item (l) which is formed to a specific
shape or design during manufacture, (2)
which has end use functton(s) dependent
In whole or in part upon Its shape or de-
sign during end use, and (3) which has
either no change of composition
during its end use or only those changes
of composition which have no commercial
purpose separate from that of the article
and that may occur as described In 1 710.4
(d) (5); except that fluids and particles
are not considered articles regardless of
shape or design.
-------
64576
RULES AND REGULATIONS
lit) "EPA" means the U.S. Environ-
mental Protection Agency.
(1) "Importer" means any person who
imports any chemical substance or any
chemical substance as part of a mixture
or article into the customs territory of
the U.S. and Includes: (1) The person
primarily liable for the payment of any
duties on the merchandise, or (2) an au-
thorized agent acting on his behalf (as
defined In 10 CFR 1.11).
used for the intentional
manufacture of other chemical sub-
stance^) or mixture(s), or is intention-
ally present for the purpose of altering
the rate of such chemical reaction(s).
Note.—Tli® "equipment in which Jt was
manufactured" includes the reaction vessel
In which the chemical substance was manu-
factured and other equipment which is
•trtcUy ancillary to the reaction vessel, and
any other equipment through which the
chemical substance may flow during a con-
tinuous flow process, but does not Include
tanks or other vessels in which the chemical
substance Is stored after its manufacture.
-------
RULES AND REGULATIONS
64577
the persons not subject to the initial
Inventory.
(a) The initial inventory—<1) Domes-
tic manufacturers who must report con-
cerning chemical substances. Any per-
son who manufactured a chemical eub-
stance(s) in the United States (or a
commercial purpose during calendar year
1977 must report concerning:
il) All chemical substances which that
person manufactured in the United
States during calendar year 1977 at each
site lor which:
(1) of this
section that was manufactured at a site
during calendar year 1977 In quanti-
ties equal to or greater than 100,000
pounds.
Notx—Any person who la a "small manu-
facturer," as defined in i 110.2, and who has
mora than one site, is exempt from separately
reporting the chemical substances manufac-
tured at each site.
<2> Importers who must report con-
cerning chemical substances. Any per-
son who imported a chemical substance
Into the United States for a commercial
purpose during calendar year 1977 must
report concerning:
(1> All chemical substances which that
person Imported into the United States
during calendar year 197711:
(A) Thirty percent or more of the
weight of the products imported consists
of products of the types described under
Standard Industrial Classification (SIC)
Oroup 28 or 2911. or
0) of
this section that was imported during
calendar year 1977 In quantities equal
to or greater than 100,000 pounds.
Notx—Theae reporting requirements In-
clude all chemical substance* Imported in
bulk form. Including la cane, bottles, drums.
Barrels, package*, tanks, bags and other con-
tainer*. but do not lDclude chemical sub-
•tancee imported ae part of mixture* or
artlclee.
(3) Other manufacturers and import-
en toho should report chemical sub-
stances (1) In order to ensure that a
chemical substance is Included in the
initial Inventory, any person who manu-
factures or Imports, or who has manu-
factured or Imported a chemical sub-
stance (including the importation of a
chemical substance ae part of a mixture
or an article) for a commercial purpose
since January 1, 197S, may report con-
cerning that chemical substance.
ill) Any person permitted to report
under paragraph (a) (3) of this section
may either report Individually or. in
accordance with § 710.5(f). authorize a
trade association or other agent to report
on his behalf.
(b) Revised inventory. (1) During
the reporting period for the revised in-
ventory ;
Not*.—A chemical substance that is manu-
factured ae part of a mirture u sub)ect to
these reporting regulations. This exclusion
applies only to the mixture and not to the
chemical substances of which tbe mixture Is
comprised. The term "mixture" 1 Deludes al-
loys. Inorganic glasses, ceramics, frits, and
cements. Including Portland cement.
(3) Any chemical substance which Is
manufactured, Imported, or processed
solely in small quantities for research
ami development, as defined in 5 710.2
Any impurity.
(2 > Any byproduct which has no com-
mercial purpose.
No**.—A byproduct which has commercial
value only to municipal or private organisa-
tion* wbo (i) burn It as a fuel. (11} dispose of
It a* a waste. Including In a VandHlli or for
enriching soil, or (111) extract component
chemical substance* which have commercial
value, may be reported for the Inventory, but
will not be subject to pre manufacturing no-
tification under section 6 of tbe Act if not
included.
(a) Chemical substances subject to
these regulations. Only chemical sub-
stances which are manufactured, im-
ported, or prooessed "for a commercial
purpose," as defined in I 710.2, are sub-
ject to these regulations.
Naturally occurring chemical sub-
stances automatically included. Any
chemical substance which is naturally oc-
curring and <1> which is (1) unprocessed
or (il) processed .only by manual, me-
chanical. or gravitational means; by dis-
solution In water; by flotation; or by
heating solely to remove water; or
(2) which Is extracted from air by any
means, shall automatically be Included
in the inventory under the category
"Naturally Occurring Chemical Sub-
stances." Examples of such substances
are: raw agricultural commodities; wa-
ter, air. natural gas, and crude oil; and
rocks, ores, and minerals.
(c) Substances excluded by definition
or section S (b) of TSCA. The following
substances are excluded from the Inven-
tory:
(1) Any substance which is not con-
sidered a "chemical substance" as pro-
vided In subsection 3(2) (B) of the Act
<3> Any chemical substance which re-
sults from a chemical reaction that
occurs incidental to exposure of another
chemical substance, mixture, or article to
environmental factors such aa air, mois-
ture. microbial organisms, or sunlight.
(4) Any chemical substance which
results from a chemical reaction that
occurs incidental to storage of another
chemical substance, mixture, or article.
(5) Any chemical substance which re-
sults from a chemical reaction that oc-
curs upon end use of other chemical
substances, znxtures. or articles such as
adhesives, paints, miscellaneous cleans-
ers or other housekeeping products,
fuels and fuel additives, water softening
end treatment agents, photographic,
films, batteries, matches, and safety
flares, and which to not itself manu-
factured for distribution in commerce
or for use as an intermediate.
(6) Any chemical substance which re-
sults from a chemical reaction that oc-
curs upon use of curable plastic or rub-
ber molding compounds. Inks, drying
oils, metal finishing compounds, ad-
hesives, or paints; or other chemical
FEDERAL REGISTER, VOl. 4 J, NO. 24?—FRIDAY, DECEMBER 23, W7
- 39 -
-------
64578
RULES AND REGULATIONS
substances formed during manufacture
of an article destined for the market-
place without further chemical change
of the chemical substance except for
those chemical changes that may occur
as described elsewhere In this ! 710.4(d).
(7) Any chemical substance which re-
sults from a chemical reaction that oc-
curs when (1) a stabilizer, colorant,
odorant. antioxidant, filler, solvent, car-
rier, surfactant, plastlclzer, corrosion
Inhibitor, antifoemer or de-foamer, dis-
persant, precipitation inhibitor, binder,
emulsLfler, de-emulslfier, dewaterlng
agent, agglomerating agent, adhesion
promoter, flow modifier. pH neutralizes
sequesterant, coagulant, flocculant, fire
retardant. lubricant, chelating agent, or
quality control reagent functions as in-
tended or (11) a chemical substance, sole-
ly Intended to Impart a specific physico-
chemical characteristic, functions as in-
tended.
(8) Chemical substances which are not
Intentionally removed from the equip-
ment In which they were manufactured.
Note.—See not* to definition of "Inter-
mediate" at |710£(n) for explanation of
"equipment In which It was manufactured."
§ 710.5 How to report.
(a) General instructiont. (I) Except
for small manufacturers or small import-
ers, any person who is required to re-
port under f 710.3(a) (1) or (2) shall
follow the reporting procedures of para-
graphs (b), (c), and (d) of this sec-
tion.
(2) Any person who reports under
8710.3(a) (3) shall follow the reporting
procedures of paragraphs (b), (c), (d)
(1) and (d)(3) of this section. In addi-
tion, the Agency encourages these per-
sons to report In accordance with para-
graphs (d)(2) and (d)(4) of this sec-
tion. A trade association or other agent
may report aggregated production data
under paragraph (d) (4) of this section.
(3) Any person who Is required to
report under i 710.3(a) (1) or (2) and
who Is a small manufacturer or small
Importer as defined In 9 710.2 shall fol-
low the reporting procedures of para-
graphs (b). (c). and (d) (1) and (3)
of this section except that such person
Is exempt from reporting production
volume (for quantities less than 100,000
pounds) and site Information.
(4) Any person who reports under sec-
tion 7103(b) shall follow the reporting
procedures of paragraphs (b), (c), and
(d) (1) of this section.
(b) Reporting the identity of a
chemical susbtance. (1) Any person re-
porting under these regulations should
flnt read and carefully follow the re-
porting instructions, "Reporting for the
Chemical Substance Inventory," pub-
lished by and available through EPA.
(2) To report a chemical substance, a
person should first consult the TSCA
Candidate List of Chemical Substances
and any amendment to the Candidate
List. For assistance in using the Candi-
date List, consult the "Guide to the Use
of the TSCA Candidate List of Chemical
Substances."
(3) All persons required to report ex-
cept "small manufacturers and Im-
porters" must use a separate Form A. B,
or C to report chemical substances for
each site. Small manufacturers and im-
porters may report several chemical sub-
stances manufactured at different sites
on one form, as appropriate.
(4) To report a chemical substance
found in the Candidate List, or In an
amendment to the list, a person must
complete, sign, and submit EPA inven-
tory report Form A (EPA Form No. 7710-
3A). All forms. A through D. have OMB
No. 1585 77011.
(5) To report a chemical substance not
found in the Candidate List, or in aa
amendment to the list, but for which
there is a Chemical Abstracts Service
(CAS) Registry Number, a person must
complete, sign and submit EPA inventory
report Form B (EPA Form No. 7710-3B).
(6) To report a chemical substance
which Is not found in the Candidate List,
or in an amendment to the list, and for
which there is no known CAS Registry
Number, a person must complete, sign,
and submit EPA inventory report Form
C (EPA Form No. 7710-3C). Persons
must describe chemical substances on
Form C as specifically as possible, In ac-
cordance with the Instructions published
by EPA, "Reporting for the Chemical
Substance Inventory."
(7) To report a chemical substance
whose chemical identity is claimed to be
confidential, a person must complete,
sign, and submit EPA Inventory report
Form C (EPA Form No. 7710-3C). In
addition, he must substantiate the cIl
that the chemical identity Is confidential
at the time he submits the form to EPA,
in accordance with Instructions pub-
lished in "Reporting for the TSCA In-
ventory" and section 710.7.
Von.—The reporting instructions also de-
scribe a reporting Foim D (EPA Pons No.
7710-3D) This is for additional voluntary
reports which may be submitted by any per-
son who manufactures trademarked products
comprised of chemical aubstancas and la not
a substitute for any of the reports required
by thase regulation*.
(c) Reporting polymers. (1) To report
a polymer a person must list In the de-
scription of the polymer composition at
least those monomers used at -greater
than two percent (by weight) In the
manufacture of the polymer.
(2) Those monomers used at two per-
cent (by weight) or less in the manufac-
ture of the polymer may be included as
part of the description of the polymer
composition.
Not*.—The "percent (by weight)" of a
monomer is the weight of the monomer ex-
pressed as a percentage of the weight of the
polymeric chemical substance manufactured.
(d) Reporting other information con-
cerning a chemical substance. (1) For
purposes of the initial inventory, desig-
nate whether the person manufactures
and/or Imports the chemical substance.
For purposes of the revised inventory,
designate whether the person processes
and/or Imports the chemical substance.
(2) Report the slte(s) at which the
person manufactures and /or Imports the
chemical substance. The site, as defined
In { 710.2(w), for Importers is their busi-
ness address.
(3) Designate whether the person
manufactures and processes the chemical
substances only within a site and does
not distribute the chemical substance,
or any mixture or article containing that
substance for commercial purposes out-
side that site.
Ncrrz.—This requirement does not apply
to importers.
(4) Report the.amount of the chemical
substance which the person manufac-
tured at each site and/or Imported dur-
ing calendar year 1977. For each sub-
stance. report the digit (e.g., 0 through
9) which corresponds to the appropriate
volume range, according to the following
table. Enter "H" In the space provided
lor production amounts If the person
did not manufacture or Import the sub-
stance during calendar year 1977. Small
manufacturers or Importers, as defined
In S710.2(x), should enter "X" In the
space provided for production amounts
of less than 100,000 pounds (45,400 kilo-
grams) . II a small manufacturer or im-
porter reports these production amounts,
that person shall enter both "X" and the
appropriate digits (e.g., XO, XI, or X2).
For other production ranges, do not In-
clude an "X" (e.g., 3 through 9). Trade
associations or other agents should en-
ter "A" In the space provided lor pro-
duction amounts. If trade associations
or agents report production volumes,
they should enter both "A" and the ap-
propriate digits (e.g, A2 or At).
(0) Lass than 1,000 pounds; Leas th»n 454
kilograms.
(1) 1,000 to 10,000 pound* 464 to 4.MO
kilogram*.
(2) 10,000 to 100,000 pounds; 4,640 to
46.400 kilograms.
(3) 100,000 to 1 million pounds; 46,400 to
464,000 kilograms.
(4) 1 million to 10 million pounds; 464,000
to 4.64 million kilograms.
(6) 10 million to 60 million pounds; 4.64
million to 22.7 million kilograms.
(6) 60 million to 100 million pounds; 22.7
to 46.4 million kilograms.
(7) 100 million to 600 million pounds; 46.4
million to 227 million kilograms.
(8 ) 500 million to 1 billion pounds; 227
million to 464 million kilograms.
(0) owr 1 billion pounds; over 464 million
kilograms.
(A) Trad© associations or other agents.
(e) Importers. (1) Any Importer who
reports a chemical substance for the In-
ventory may authorize the foreign sup-
plier of the Imported chemical aub-
stance(s) to report to EPA on his behalf.
If both the foreign supplier and the im-
porter sign the declarations provided on
the reporting forms. A foreign supplier
may authorize an agent to act in his
behalf.
(2) The importer has the ultimate re-
sponsibility for reporting all information
required by this Part and for the com-
pleteness and truthfulness of such Infor-
mation. If certain Information is not or
cannot be provided by the foreign sup-
plier or his duly authorized agent, It
must be provided by the Importer.
FEDERAL REGISTER, VOL. 42, NO. 247—FRIDAY, DECEMBER 13, 1W
- 40 -
-------
RULES AND REGULATIONS
64579
(ft Trade associations or other affents.
il) A track association or other agent
may report on behalf of any person who
is not required to report for the initial
Inventory under S 710.3 (a)(1) and (a)
(2). Accordingly, a trade association or
other agent may report on behalf of a
manufacturer or importer of a chemi-
cal substance who chooses to report un-
der 5 710.3(a)(3), or any processor or
user of a chemical substance, or any Im-
porter of a chemical substance as part
of a mixture or an article who chooses
to report under S 710.3(b).
(2) For every chemical substance re-
ported by a trade association or other
agent under this section, at least one
manufacturer, importer or processor
must have certified to that agent, and be
able to document to EPA, in accordance
with 8 710.1(c), that the chemical sub-
stance was manufactured, imported, or
processed for a commercial purpose since
January 1, 1975.
§710.6 ^Iwn to report.
(a) All reports for the initial inven-
tory shall be submitted by May 1, 1978.
(b) AU reports concerning chemical
substances which are manufactured or
imported for a commercial purpose for
the first time during the period from
May 1. 1978 to the effective date of pre-
manufacture notification requirements
shall be submitted when such manufac-
turing or importation begins.
(c) All reports for the revised inven-
tory shall be submitted within 210 days
after publication of the initial inven-
tory.
§ 7)0.7 Confidentiality.
A manufacturer, Importer, or
processor may claim that for a particu-
lar chemical substance any or all of the
following items of information submit-
ted under this Part are entitled to confi-
dential treatment:
(1) Company name.
12) Site.
(3) The specific chemical Identity.
(4) Whether the chemical substance Is
manufactured. Imported, or processed.
(5) Whether the chemical substance
is manufactured and processed only
within one site and not distributed for
commercial purposes outside that site.
(«> The quantity manufactured, im-
ported. or processed.
Any claims of confidentiality must
accompany the Information at the time
it is submitted to EPA. The Maimf must
appear on the form on which the infor-
mation is submitted to EPA and in the
manner prescribed on the form. In ad-
dition. any claims of confidentiality
must be substantiated at the time the
information Is submitted to EPA In the
manner specified in the form instruc-
tions.
of this section) the fact
that the particular chemical substance
is included in the inventory for purposes
of TSCA section 5(a)(1)(A) premanu-
facture notification, and
(v) Have available, and agree to fur-
nish to EPA upon request, for the par-
ticular chemical substance, either an
X-ray diffraction pattern (In the case of
inorganic substances) or a mass spec-
trum for the particular chemical sub-
stance (in the case of most other sub-
stances), a sample of the substance In
its purest form, an elemental analysis,
any additional or alternative spectra, or
other data that may be required to re-
solve uncertainties with respect to the
identity of the substance. Failure to
meet any of these five requirements will
be considered a waiver of the claim and
will result in inclusion of the particular
chemical identity on the inventory.
-------
&45SO
RULES AND REGULATIONS
certainties with respect to the identity
of the substance.
Failure to submit any of the in-
formation required by EPA under this
par graph (g) (3) will be construed as a
waiver of the submitter's confidentiality
claim, and EPA will place the specific
chemical identity on the inventory with-
out further notice to the submitter.
(4) EPA will compare the information
submitted by the proposed manufacturer
under paragraph (g) (2) cf this section
with the information submitted under
paragraph (g> (3> of this section.
(5) If the comparison of either the
X-ray diffraction patterns or the mass
or alternative spectra is not sufficiently
similar to be consistent with a presump-
tion that the chemical substance; are the
same, and (ii) comparison of the other
information affirms this conclusion, EPA
will tell the person proposing to manu-
facture the particular substance that the
information submitted does not support
a conclusion that the substance is in-
cluded on the inventory, and, therefore,
that prem&nufacture notification is re*
Quired.
(7) A disclosure to a person with a
bona fide intent to manufacture a par-
ticular chemical substance will not be
considered a public disclosure.
§710.8 Effective dale.
These regulations shall take effect on
January 1, 1978.
Appendix A—Significant Comments and
Responses
Over 400 comment* were received In re-
sponse to the notices of proposed rulemaking
published in the Federal Recurs* on March
9, August 2, and October 3, 1077. The follow-
ing summarizes and responds to the sig-
nificant Issues raised In these comments.
Comments which concern problems specific
to one particular company were not generally
Included In these comments. These com"
meats were referred to EPA's Industry As-
sistance Office for direct reply.
Contents
Overall Approach to these Reporting Rule*.
Comments 1-12.
Which Person* are Subject to these Regula'
tions. Manufacturers, comments 13-17; Im-
porters, comments 18-23; Definition of Small
Manufacturer or Importer, comments 24-27;
Processors, comment 28.
Chemical Substances Manufactured or
Processed For a Commercial Purpose. Com-
ments 29-90.
Exclusions to the Definition of Chemical
Substances. Mixtures, comment* 31-36; Pes-
ticides and Foods. Food Additives, Drugs,
Cosmetics and Devices, comments 37-42.
Chemical Substances Excluded from, the
Jnven tory. Small Quantities for Research and
Development, comments 4-3-51; Byproducts,
comments 52-55; Articles, comments
Impurities, comment 61.
Chemical Substances Included in the In-
ventory. Comments 62-63; Test Marketing,
comments 64-66; Intermediates, comments
67-71; Naturally Occurring Substances, com-
ments 72-74.
Inventory Reporting Procedures. General,
comment 76; Reporting of Polymers, oom-
ments 77-82; Inventory Reporting Forms,
comments 83—87.
When To Report. Comments 88-02.
Confidentiality. Comments 93-103.
OVZXAXX APPROACH TO THESE RTPOiTXNC EtTCJSS
Comment 1: Reporting under these first
reporting rules should not only be for the
purpose of compiling the Inventory required
by section 8(b), but also to establish a base
line of information for further regulatory
action under TSCA. Failure to gather site,
production, use, Impurity, byproduct, dis-
posal, and worker exposure Information in a
comprehensive manner precludes a system-
atic approach to the regulation of chemicals.
Response: The Administrator agrees. In
part, with this comment. The August 2, 1977,
reproposal expanded the purpose of these
regulations as proposed on March 9, 1977.
These final regulations are similar to those
proposed on August 2nd.
In deciding the scope of these first sec-
tton 8(a) reporting requirements, EPA con-
sidered not only the interest of compiling
an Inventory of chemical substances as re-
quired by TSCA section 8(b), but also the
need for obtaining sufficient information
for monitoring chemical substances in the
environment and setting Agency priorities
for Implementing other provisions of TSCA.
The Agency decided that initial repor-...^
requirements should at least establish a
profile of the chemical Industry, including
sites where chemicals are being manufac-
tured and the relative quantities In which
they are produced or Imported into the
United States. With this information, EPA
will be able to estimate the potential expo-
sure to chemical substances for control, and
preventive actions. For example, plant site
Information will be useful in identifying
possible sources of hazardous chemical*, es-
pecially In an emergency. Data on the quan-
tities of chemical substances manufactured
tor a commercial purpose will enable EPA
and other agencies to select substance* for
priority attention from among the tens of
thousands of chemicals is commerce.
The Agency will not be requiring use, im-
purity. byproduct, disposal, or worker ex-
posure Information In these regulations. The
Administrator has determined that this in-
formation Is not now necessary for all chem-
ical substances manufactured for a commer-
cial purpose, and that the additional burden
to industry and consequent delay In publi-
cation of the inventory would not be justi-
fied. EPA intends, under the authority of
section 8(a). to require this additional In-
formation on a smaller number of chemicals
In order to assess their potential risks in
depth. These requirements win be directed
st manufacturers and processors of the
chemical substances to enable the Agency to
build a more complete profile on these
chemicals which are of concern.
Comment 2: EPA's proposed approach
would require unnecessarUy burdensome
and needlessly duplicative reporting. EPA
should compile and publish a list of chemi-
cal substances from government, industry,
and other sources, and allow manufacturers
and trade associations to report any chemi-
cal substances not included.
Response: The Administrator disagrees
with this comment. The Agency reviewed
existing lists of chemical substances and
found them Inadequate In several respects.
First, many existing lists contain chemical
substances which are not eligible for inclu-
sion on the TSCA Inventory. Second. In
existing lists, many of the entries are in
broad categories or use groups (such as "op-
tical brighurners") which would be inappro-
priate for the purposes of compiling a list
of discrete chemical substances manufac-
tured or processed for a commercial purpose
in the United States. Third, existing lists
would not permit EPA to identify the basic
manufacturers of a chemical substance. The
purposes of TSCA, accordingly, would not be
met if EPA were simply to publish currently
available lists as the inventory of chemical
substances and permit manufacturers to re-
port any substance not included.
EPA is Interested In minimizing the burden
of reporting for the inventory. Accordingly,
the Agency has published a Candidate List
of Chemical Substances which includes those
substances we have reason to believe have
been manufactured or processed In the
United States. For any chemical substance
included on the Candidate List reporting for
the Inventory is greatly simplified. By Fed-
esai. Register notice dated April 28, 1977
(42 PR 21639) and July 8, 1977 (42 FR
35183), the Agency announced the avall-
abUity of the Candidate List In hard copy
and computer readable tape. EPA plans to
supplement the Candidate List with at least
one additional list of substances. EPA will
announce the availability of any additional
list In the Fedexal RegXste*. By Feddlal
BzcxCT-nt notice dated April 12, 1977 (42 FR
19298) the Agency published a proposed
Guide to the Use of the Candidate List. "Hiis
Guide will be republished with some changes
to assist persons reporting for the Inven-
tory. This document and any supplement to
the Candidate List will be available from
EPA at the address listed above.
In a further effort to minimise duplica-
tive reporting to the extent consistent with
the needs of the Agency, {710.5(f) of these
final regulations permits all manufacturers
or importers not required to report by f 710.3
(a) (1) and (2) to report chemical sub-
stances through a trade association or other
agent. Further, any person who processes a
chemical substance is only subject to the
revised Inventory. These policies should elim-
inate a great amount of dupUcative report-
ing.
Comment Manufacturers should be re-
quired to report chemical substances manu-
factured for a commerlcal purpose by plant
site rather than by company headquarters.
Response: The Administrator agrees with
tills comment. The March 9, 1977 proposal
would only have required manufacturers to
report chemical substances by company
h.ea
-------
APPENDIX 2
SOURCES OP CAS REGISTRY NUMBERS
Chemical Abstracts Service (CAS) has assigned a unique
Registry Number to each of over four million chemical substances
and mixtures. Finding the CAS Registry Number for a substance
will greatly simplify its reporting for the Inventory. With its
CAS Registry Number, the substance may be identified simply by
entering the number and a specific chemical name. Without the
CAS Registry Number, the chemical substance must be identified by
detailed chemical information of the type specified in Chapter 3
of this booklet.
The format of a CAS Registry Number is AAAAA-BB-C, where A,
B, and C are numbers from 0-9. The first five digits may include
leading zeroes which are often omitted. For example, the number
00106-72-9 would be represented as 106-72-9, omitting the first
two zeroes.
CAS Publications
The Chemical Abstracts Service offers a number of documents
which are useful sources of CAS Registry Numbers. These are:
1. The CA (Volume or Collective) Chemical Substance
Indices,
2. The CA (Volume or Collective) Formula Indices,
3. The CA INDEX GUIDE, and
4. The CA REGISTRY HANDBOOK — Common Names (on
microform).
The first three sources are commonly found in major academic
libraries; the fourth is commercially available from the Chemical
Abstracts Service, located in Columbus, Ohio.
CAS Registry Numbers may be found in these publications by
searching lists of trivial or common names, systematic CA Index
Names, or molecular formulas. These sources cover the full range
of substances reported in the scientific and technical
literature.
The first three sources are published by CAS in conjunction
with the publication of Chemical Abstracts. Chemical Abstracts
is a weekly Journal comprised of abstracts and index entries for
recent publications relevant to chemistry and chemical
engineering. CAS compiles comprehensive volume indices every six
months. The CA Volume Chemical Substance Index relates the CA
Index Names of substances, along with their CAS Registry Numbers,
to CA Abstracts Numbers of publications, abstracted in the
volume, in which the substances were mentioned.
CAS also publishes the CAS REGISTRY HANDBOOK -- Number
Section, a comprehensive listing of substances registered in the
CAS Chemical Registry System. The Handbook lists, in ascending
CAS Registry Number order, the CA Index Name and molecular
formula for each CAS Registry Number. The Handbook is not
intended to be a source of CAS Registry Numbers. It may be used,
however, to confirm a chemical substance identity, a CA Index
Name, or molecular formula linked to a particular CAS Registry
Number. It cannot be emphasized too strongly that CAS
registrations are highly specific. Different postional isomers,
sterochemlcal isomers, and salt forms have distinct CAS Registry
Numbers. For example, there are four (4) registry numbers for
xylenes, one for each of the three Isomers, and one for an
undifferentiated combination of these Isomers. THE REGISTRY
-------
HANDBOOK — Number Section, with Its inclusion of the usually
systematic CA Index Names, will help to validate a CAS Registry
Number that might have been obtained from a search using a non-
chemlcally descriptive substance name.
Other Sources
CAS Registry Numbers may also be found in computer-based
information retrieval systems. Three on-line information systems
that include CAS Registry Numbers are the NIH/EPA Chemical
Substructure Search System, the National Library of Medicine's
CHEMLINE file, and Lockheed's CHEMNAME file. Many academic and
public libraries are equipped with facilities for searching these
computer-based files.
IMPORTANT: In reporting the identity of chemical substances
for the Inventory, care must be taken to ensure, first, that the
proper CAS Registry Number has been selected, and second that the
chemical name is as specific as possible. The substance name
should uniquely identify the substance and should include such
information as positions of chemical substitutent groups, salt
forms and ratios, and sterochemlstry as appropriate. Any
inconsistency between the structure associated with a particular
CAS Registry Number and the name supplied will prevent the
substance from being added to the Inventory until clarifying
information is provided. Also, the fact that a CAS Registry
Number exists for a chemical does not mean it Is necessarily a
reportable chemical substance. For example, many numbers refer
to mixtures, which may not be reported for the Inventory.
- 44 -
------- |