Guidance and Instructions for Reporting Asbestos Under TSCA Section 8(a)(1)


EPA-740-B-23-005

Guidance and Instructions for Reporting
Asbestos Under TSCA Section 8(a)(1)

U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics

October 2023

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DOCUMENT HISTORY

Document Date

Action

October 2023

Creation of original document and posting to TSCA website

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HIGHLIGHTS OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR

ASBESTOS UNDER TSCA 8(a)(1)

•	One-time reporting is required for manufacturers (including importers) or processors of
asbestos—including naturally occurring asbestos and asbestos present in mixtures, articles,
and as an impurity—in the last four calendar years prior to the effective date of the final
rule—August 24, 2023 (i.e., 2019, 2020, 2021, and 2022)

•	The only small business exemption in effect for this data call applies to small manufacturers
(including importers) and small processors of Libby Amphibole asbestos. You may be
required to report under this rule even if you are not required to report under other
TSCA requirements, such as CDR, due to a small business exemption.

•	You may be exempt from reporting if you manufacture (including import) or process asbestos
only in small quantities for research and development.

•	Information must be reported during the three-month data submission period (40 CFR
704.180(f)) beginning February 24, 2024 and ending May 24, 2024.

•	All reporting companies must report data electronically, using the section 8(a)(1) web-based
reporting tool within EPA's Central Data Exchange (CDX) system. Prior to submitting data,
submitters must register with CDX. Ensure that your pop-up blocker is disabled before you
begin to use the asbestos section 8(a)(1) tool to complete your form.

•	Reduced reporting requirements apply to reporters who know or can reasonably ascertain that
asbestos is a component of a mixture or article but are unable to determine the asbestos
quantity by weight.

•	Information submitted under this data call may be claimed as confidential; however, such
claims must be made at the time of submission and substantiated in accordance with TSCA
and the asbestos data reporting rule. Submitters must provide upfront substantiation of all
confidentiality claims except for claims made for quantities of products or asbestos, which are
exempt from substantiation requirements. Certain processing and use data elements or a
response that is designated as "not known or reasonably ascertainable" may not be claimed as
confidential (40 CFR 704.180(h)(l)(ii)(C)).

•	Visit the section 8(a)(1) rule website (https://www.ena.gov/assessine-and-managine-
chemicals-under-tsca/tsca-section-8al-revorting-and-recordkeeying) for other guidance
materials and contact information for technical assistance.

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TABLE OF CONTENTS

1.	Introduction	1-4

2.	Reporting Requirements	2-4

2.1	Step 1: Is Your Chemical Substance Subject to Section 8(a)(1)?	2-5

2.1.1	Is Your Chemical Substance Manufactured or Processed for
Commercial Purposes During the Reporting Period?	2-5

2.1.2	Were your annual sales, when combined with those of your ultimate
parent company (if any), greater than or equal to $500,000 in any
calendar year from 2019 to 2022?	2-6

2.2	Step 2: Do You Qualify for an Exemption or Reduced Reporting?	2-6

2.2.1	Do you qualify for a small manufacturer or small processor exemption? ...2-6

2.2.2	Do you qualify for a Research and Development (R&D) exemption?	2-7

2.2.3	Do you qualify for the Non-isolated Intermediate exemption?	2-7

2.2.4	Form A with Reduced Reporting Requirements	2-8

2.3	Step 3: What Information Must You Report?	2-11

3.	When You Must Report	3-1

4.	Instructions for Completing Asbestos section 8(a)(1) Reporting	4-1

4.1	Known to or Reasonably Ascertainable by Reporting Standard	4-1

4.2	Confidential Business Information (CBI) and Substantiation	4-4

4.2.1 Exemptions	4-5

4.3	Company and site information	4-5

4.3.1	Confidentiality of Company, Site, and Technical Contact Information	4-5

4.3.2	Special Provisions for Certain Sites	4-6

4.3.3	Parent Company Information	4-7

4.4	Asbestos Fibers	4-12

4.5	Reporting Activity Information	4-12

4.5.1	Confidentiality of Activity Information	4-13

4.5.2	Mined, milled, or imported bulk asbestos or bulk materials containing
asbestos, including as an impurity	4-14

4.5.3	Primary processers	4-15

4.5.4	Secondary processors	4-21

4.5.5	Importing of mixtures, or articles containing asbestos, including as an
impurity	4-22

4.5.6	Employee information	4-23

4.6	Certification	4-25

5.	How to Obtain Copies of Documents Cited in This Instructions Document	5-25

5.1	Obtaining Copies of the TSCA Rules	5-25

5.2	Obtaining Copies of Other Information Materials	5-25

Appendix A. Glossary of Terms	1

Appendix B. Descriptions of Codes for Reporting Number of Employees, Asbestos Type,
Disposition, Product Type	1

APPENDICES

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Appendix A. Glossary of Terms	A-l

Appendix B. Descriptions of Codes for Reporting Number of Employees, Asbestos Type, Disposition, Product TypeB-1

LIST OF TABLES

Table 2-1. Example Determination for Use of Form A or Form B	2-8

Table 2-2. Information to be Reported on Forms A and B	2-11

Table 4-1. Examples of the Application of the "Known to or Reasonably Ascertainable by" Reporting Standard for

Processing and Use Data	4-3

Table 4-2. Substantiation Questions	4-4

Table 4-3. Applying Highest-level Parent Company Definition in Different Situations	4-7

Table 4-4. Parent Company Name Standardization	4-8

Table 4-5. Parent Company Street Address Standardization	4-9

Table 4-6. Codes for Number of Employees	4-11

Table 4-7. Substantiation Questions for Activity Information	4-13

Table 4-8. Asbestos Types	Error! Bookmark not defined.

Table 4-9. Disposition Codes	4-14

Table 4-10. End Product Types	4-16

Table B-l. Codes for Number of Employees	B-l

Table B-2. Asbestos Types	B-l

Table B-3. Disposition Codes	B-2

Table B-4. End Product Types	B-2

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PREFACE

The primary goal of this document is to help the regulated community comply with the
requirements of the TSCA Section 8(a)(l) Reporting and Recordkeeping Requirements for
Asbestos rule, hereafter referred to as "asbestos section 8(a)(1) reporting". This document does
not substitute for that rule, nor is this a rule itself. This document does not impose legally
binding requirements on the regulated community or on the U.S. Environmental Protection
Agency (EPA).

Manufacturers (including importers) and processors are required by the asbestos section
8(a)(1) reporting rule to report certain exposure-related information to EPA, including quantities
of asbestos manufactured (including imported) or processed, types of use, and employee data.
Manufacturers (including importers) and processors are subject to the reporting requirements
based on manufacturing (including importing) and processing activities conducted between
January 1, 2019 and December 31, 2022. This is a one-time reporting event to inform EPA's risk
evaluation for asbestos and potential future risk management activities. This data collection is
authorized under TSCA section 8(a).

Data submissions are due by the close of the submission period, May 24, 2024. The
submission period will begin on February 24 2024, six months following the effective date of the
final rule and remain open for three months through May 24, 2024. Data must be submitted using
the "Asbestos 8(a)(1)" web service via EPA's Central Data Exchange (CDX). Submitters are
required to use the Asbestos 8(a)(1) web service to prepare their submissions. The web-based
reporting tool guides users through a "hands-on" process of creating an electronic submission.

This instructions document contains the following chapters and appendices:

•	Chapter 1 - Introduction to the TSCA asbestos section 8(a)(1) reporting rule.

•	Chapter 2 - Reporting requirements to determine which chemical substances are reportable,
who must report, and what information must be reported.

•	Chapter 3 - When you must report.

•	Chapter 4 - Instructions for completing asbestos section 8(a)(1) reporting.

•	Chapter 5 - How to obtain copies of documents cited in this Guidance and Instructions
document.

•	Appendix A - Glossary.

•	Appendix B - Descriptions of codes for reporting Number of Employees, Asbestos Type,
Disposition, and End Product Types.

Ill

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Chapter 1

Introduction

1.	Introduction

EPA is requiring persons that manufactured (including imported) or processed asbestos
and asbestos-containing mixtures and articles in any year from January 1, 2019 - December 31,
2022, to submit certain exposure-related information to EPA.

This document provides detailed information and examples to assist manufacturers
(including importers) and processors in reporting under TSCA section 8(a)(1).

Appendix A of this document provides a glossary of terms, which may help you to
understand the reporting requirements. Appendix B of this document provides a copy of all
codes used for reporting.

This document is not a substitute for the TSCA asbestos section 8(a)(1) rule in 40
CFR Part 704.180. To the extent that any inconsistencies exist between the asbestos section
8(a)(1) rule and this document, the requirements as promulgated in the rule should be followed.
You should carefully review 40 CFR Part 704.180 and the final rule preamble (available in this
rule's docket at www.regulations.gov; docket ID EPA-HQ-OPPT-2021-0357) to determine
whether you are required to report information under the asbestos section 8(a)(1) rule.

2.	Reporting Requirements

Asbestos reporting requirements apply to certain persons that manufactured (including
imported) or processed asbestos in any year since January 1, 2019. The term asbestos is defined
in Appendix A. Please note that any use of the term "manufacture" in this document will
encompass "import" and the term "manufacturer" will encompass "importer."

For reporting under the asbestos section 8(a)(1) data reporting rule, manufacturers
(including importers) and processers are required to use the section 8(a)(1) reporting tool via
EPA's CDX to submit information in response to the requirements of the asbestos section 8(a)(1)
rule (40 CFR Part 704). You must register with CDX to submit online, and you must register the
name of the company on whose behalf you are submitting. EPA does not accept paper
submissions or electronic media (diskette, CD-ROM, etc.) for any section 8(a)(1) submission (40
CFR 704).

You should consider the following three steps to determine whether you are required to report
for asbestos that you domestically manufacture (including import) or process in the United
States during each year since 2019 (i.e., consider calendar years 2019 through 2022):

•	Step 1: Is your chemical substance subject to 8(a)( 1)?

•	Step 2: Do you qualify for a reporting exemption?

•	Step 3: What information must you report?

This chapter discusses each of these steps and the associated reporting requirements in
more detail.

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Chapter 2

Reporting Requirements

2.1 Step 1: Is Your Chemical Substance Subject to Section 8(a)(1)?

2.1.1 Is Your Chemical Substance Manufactured or Processed for Commercial Purposes
During the Reporting Period?

The first step in determining your reporting requirements is to determine whether you
meet the definition of manufacture or process for commercial purposes. These terms are defined
in 40 CFR 704.3 and below:

Manufacture for commercial purposes means:

(1) to import, produce, or manufacture with the purpose of obtaining an immediate or eventual
commercial advantage for the manufacturer, and includes among other things, such
"manufacture " of any amount of a chemical substance or mixture:

(i)	For commercial distribution, including for test marketing.

(ii)	For use by the manufacturer, including use for product research and development, or
as an intermediate.

(2) Manufacture for commercial purposes also applies to substances that are produced
coincidentally during the manufacture, processing, use, or disposal of another substance or
mixture, including both byproducts that are separatedfrom that other substance or mixture
and impurities that remain in that substance or mixture. Such byproducts and impurities
may, or may not, in themselves have commercial value. They are nonetheless produced for
the purpose of obtaining a commercial advantage since they are part of the manufacture of a
chemical product for a commercial purpose. (40 CFR 704.3)

Process for commercial purposes means the preparation of a chemical substance or mixture
after its manufacture for distribution in commerce with the purpose of obtaining an immediate or
eventual commercial advantage for the processor. Processing of any amount of a chemical
substance or mixture is included in this definition. If a chemical substance or mixture containing
impurities is processed for commercial purposes, then the impurities also are processed for
commercial purposes. (40 CFR 704.3)

For purposes of section 8(a)(1) reporting, a chemical substance is manufactured only if it
is domestically produced or imported for commercial purposes.

2.1.1.1 Changes to Company Ownership or Legal Identity

Under 40 CFR 704.180(c), the reporting obligation falls to the person who manufactured
(including imported) or processed asbestos in bulk form, in an article and/or product, as an
impurity, or as a component of a mixture. EPA recognizes that in some cases, business
transactions occurring during the submission period have led to questions about who is now the
"person who manufactured or processed." The scenarios in Fact Sheet: Reporting After Changes
to Company Ownership or Legal Identity are intended to serve as a general aid in appropriately
resolving these questions, but they will not necessarily account for all the relevant circumstances
of a particular transaction {note that while this fact sheet was developedfor TSCA Chemical Data
Reporting (CDR), changes in company ownership or legal identity are to be handled the same
way for section 8(a)(1) reporting). It is ultimately the manufacturer's responsibility to report
appropriately under this data call, notwithstanding the complexity of its own business
transactions.

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Reporting Requirements

2.1.2 Were your annual sales, when combined with those of your ultimate parent

company (if any), greater than or equal to $500,000 in any calendar year from 2019
to 2022?

Under 40 CFR 704.180(c), Persons {i.e., plant sites) who have manufactured (including
imported), or processed asbestos, including asbestos as a component of a mixture, asbestos in
articles, or asbestos as an impurity in the four full calendar years prior to the effective date of this
rule, and with annual sales greater than or equal to $500,000, in any calendar year from 2019 to
2022, when combined with those of their ultimate parent company (if any), must report under
this subpart.

2.2 Step 2: Do You Qualify for an Exemption or Reduced
Reporting?

Limited exemptions are available for TSCA asbestos section 8(a)(1) reporting. You may
be required to report under this section even if you are exempt from other TSCA reporting rules,
such as Chemical Data Reporting Rule (CDR). Reporting under the TSCA asbestos 8(a)(1) rule
is separate from other TSCA reporting requirements and only the exemptions specifically listed
in the apply. The following subsections explain the exemptions and reduced reporting
requirements:

•	Small manufacturers (including importers) and processors exemption for Libby Amphibole
asbestos only;

•	Research and development exemption;

•	Non-isolated intermediates exemption; and

•	Short form (Form A) with reduced reporting requirements.

2.2.1 Do you qualify for a small manufacturer or small processor exemption?

If your business is a small manufacturer or processor of Libby Amphibole asbestos, you
may not be required to report on Libby Amphibole under asbestos section 8(a)(1). The
definitions of small manufacturer and small processor are provided below. For purposes of the
definition of a small manufacturer, total annual sales include all sales of the company (including
parent company(ies)), not just the total sales of a given chemical substance. The small
manufacturer or processor exemption applies only to Libby Amphibole asbestos. If you
manufacture or process any other form(s) of asbestos, you must report for those form(s) of
asbestos even if you meet the definition of small manufacturer or processor. Key terms are
defined in 40 CFR 704.3 and below:

Small manufacturer (the same standard will be used for all manufacturers):

First standard. A manufacturer (including importer) of a substance is small if its total
annual sales, when combined with those of its parent company (if any), are less than $120
million. However, if the annual production or importation volume of a particular substance at
any individual site owned or controlled by the manufacturer or importer is greater than 45,400
kilograms (100,000 lbs), the manufacturer (including importer) will not qualify as small for
purposes of reporting on the production or importation of that substance at that site, unless the
manufacturer (including importer) qualifies as small under standard (2) of this definition.

Second standard. A manufacturer (including importer) of a substance is small if its total
annual sales, when combined with those of its parent company (if any), are less than $12 million,

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Reporting Requirements

regardless of the quantity of substances produced or imported by that manufacturer (including
importer).

Small processor means any processor whose total annual sales, when combined with
those of its parent company (if any), are less than $12 million.

If you have determined that you are a small manufacturer or small processor that is
manufacturing or processing only Libby Amphibole, you do not need to report under asbestos
section 8(a)(1).

If you do not qualify for a small manufacturer or small processor exemption, evaluate
whether you qualify for another reporting exemption or whether you may report on Form A,
which requires less information from you.

2.2.2	Do you qualify for a Research and Development (R&D) exemption?

EPA is not requiring recordkeeping or reporting by persons who manufacture (including
import) or process asbestos in small quantities solely for research and development. If you
manufacture or process asbestos solely for research or analysis for the development of a product,
review the definitions below to determine whether you qualify for an R&D exemption. This
exemption applies only if research and development is the sole use of asbestos in manufacturing
or processing asbestos at your facility.

TSCA section 8(a)(1)(A) excludes from the scope of EPA's regulatory authority any
manufacturer (including importer) or processor of "a chemical substance described in
subparagraph (B)(ii)." TSCA section 8(a)(l)(B)(ii), in turn, provides EPA authority to require
recordkeeping and reporting by each person (other than a small manufacturer [including
importer] or processor) who manufactures (including imports) or processes, or proposes to
manufacture (including import) or process, a chemical substance "in small quantities... solely for
purposes of scientific experimentation or analysis or chemical research on, or analysis of, such
substance or another substance, including any such research or analysis for the development of a
product," but only to the extent EPA determines the recordkeeping and/or reporting is necessary
for the effective enforcement of TSCA. EPA is not requiring recordkeeping or reporting by
persons who manufacture (including import) or process—or propose to manufacture (including
import) or process—asbestos in small quantities solely for research or analysis for the
development of a product as described in TSCA section 8(a)(l)(B)(ii). The regulatory definition
for small quantities (40 CFR 704.3) is provided below:

Small quantities solely for research and development means quantities of a chemical
substance manufactured, imported, or processed or proposed to be manufactured, imported, or
processed solely for research and development that are not greater than reasonably necessary
for such purposes.

2.2.3	Do you qualify for the Non-isolated Intermediate exemption?

If you manufactured or processed asbestos solely as a non-isolated intermediate, you are
not required to report under Section 8(a)(1). However, if you believe you may manufacture or
process asbestos solely as a non-isolated intermediate, review the definitions of "non-isolated
intermediate" and "intermediate" below to determine if you are exempt from reporting.

Non-isolated intermediate means any intermediate that is not intentionally removedfrom
the equipment in which it is manufactured, including the reaction vessel in which it is
manufactured, equipment which is ancillary to the reaction vessel, and any equipment through

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Reporting Requirements

which the substance passes during a continuous flow process, but not including tanks or other
vessels in which the substance is stored after its manufacture. (40 CFR 704.3)

Intermediate means any chemical substance that is consumed, in whole or in part, in
chemical reactions usedfor the intentional manufacture of other chemical substances or
mixtures, or that is intentionally present for the purpose of altering the rates of such chemical
reactions. (40 CFR 704.3)

2.2.4 Form A with Reduced Reporting Requirements

If you do not qualify for a reporting exemption, consider whether you may qualify to
report by using data fields corresponding to the short form, Form A, rather than the standard
form, Form B. The Asbestos 8(a)(1) reporting software will assist you in selecting and
completing the correct data fields.

Entities that are aware of asbestos present in their product, but who are unable to
determine or estimate the quantity manufactured (including imported) or processed, will use the
Form A option to provide a subset of the information required by the Form B. This subset
consists of information related to manufacturing (including importing) or processing asbestos,
including as an impurity, in an article, or as a component of a mixture, and information about the
employees involved with such activities.

EPA requires that if a quantity of asbestos in a product is known to or reasonably
ascertainable by the submitter, then the submitter must provide the more detailed reporting
information required by Form B.

Form A. Report using the Form A option if you know or can reasonably ascertain that
asbestos is a component of a mixture or article but are unable to determine the asbestos quantity
by weight after exhausting all reasonable efforts to obtain or calculate the asbestos concentration
or quantity. For more on TSCA definition of the term "reasonably ascertainable," see Section
4.2.

Form B. Report using the Form B option if you know or can reasonably ascertain a
quantity for asbestos as a component or as an impurity.

Table 2-1. Example Determination for Use of Form A or Form B

Scenario

Kosull

Company A imports an article containing asbestos.
Company A contacts their supplier, who provides an
estimate of the asbestos percentage by weight in the
product.

Company A uses Form B to report because they can
make a reasonable estimate of the quantity of asbestos
they imported.

Company B processes a mixture containing asbestos.
Despite contacting their supplier and reviewing
product information sheets and Safety Data Sheets
(SDSs), company B is unable to determine the amount
of asbestos in the mixture.

Company B uses Form A to report because they do not
know and cannot reasonably ascertain the quantity of
asbestos they processed.

Company C imports brake pads. Internal testing shows
the imported brake pads contain approximately 30%
asbestos.

Company C uses Form B to report because they can
make a reasonable estimate of the quantity of asbestos
they imported.

Company D imports mufflers and transmissions and
knows that both products contain asbestos. Company D
knows the asbestos content of the mufflers. Despite

Company D uses Form B to report for the mufflers
because they know the quantity of asbestos imported in
the mufflers. Company D uses Form A to report for the

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Chapter 2

Reporting Requirements

Scenario

Kosull

contacting their supplier and reviewing their product
information, Company D is unable to determine the
asbestos content of the transmissions.

transmissions because they are unable to ascertain the
quantity of asbestos they imported in the transmissions.

Figure 2-1 presents a decision diagram that may help you determine whether you are a
manufacturer (including importer) or processor who must report with the standard form, Form B
or if you may qualify for an exemption or to use the short form, Form A.

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Chapter 2

Reporting Requirements

Figure 2-1. Decision Diagram for Evaluating Step 2 [40 CFR 704.180(c)]

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Chapter 2

Reporting Requirements

2.3 Step 3: What Information Must You Report?

If you determine from Step 1 (Section 2.1) and Step 2 (Section 2.2) that you are required
to report, this section will help you determine what information you must report. If you are able
to determine the quantity of asbestos you manufactured or processed, you must use the data
elements of the full reporting form, Form B. If you are unable to determine the quantity of
asbestos you manufactured or processed, you may use the data elements of the short form, Form
A. See Section 2.2.4 of this document for a detailed discussion of reporting exemptions and
determination of which form to use.

If you are reporting using Form A, you are not required to report all information required
for Form B. The online reporting software will guide you through the data elements required for
each form.

In most cases, each manufacturer or processor will submit only one form. However, if
you are able to determine the asbestos content of some products manufactured (including
imported) or processed at your facility, you may report using one Form B for the items with
known asbestos content and one Form A for the items with unknown asbestos content. If you are
reporting on behalf of multiple sites, you must create a profile for each site in your CDX
account.

Basic company and site identification information is required for all reporters by 40 CFR
711.15(b)(1) and (b)(2). Asbestos manufacturing, import, or processing activity information is
required for all reporters by 40 CFR 704.180, with certain more detailed information required
only for Form B. Information about employees involved in asbestos manufacturing or import is
required for all reporters by 40 CFR 704.180.

Table 2-2. Information to be Reported on Forms A and B

Company Information

Site Name and Address, ID numbers

Authorized Official

Technical Contact

Parent Company Name, Address

Site NAICS Code

Number of Employees

Activity Information - All Forms

Activity Information - Form B Only

Activities conducted

Quantity of asbestos manufactured/processed

Asbestos types

Disposition of asbestos

Bulk material or product types

Bulk material/product quantity

Bulk material or product disposition

Bulk material/product asbestos concentration

Annual production quantity*

Bulk material/product asbestos type

Imported asbestos never on site*

Bulk material/product testing

Number of employees involved

Workplace exposure data

Personal Protective Equipment

* Certain activity types only

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Chapter 3

When You Must Report

3. When You Must Report

You are required to report information pertaining to each calendar year since January 1,
2019 through December 31, 2022. The submission period is from February 24, 2024 to May 24,
2024, a three-month period which begins six months after the effective date of the asbestos
section 8(a)(1) final rule.

Your report must be submitted to EPA using the electronic asbestos section 8(a)(1)
reporting tool via EPA's Central Data Exchange (CDX) no later than the close of the submission
period. You should note that registration with CDX is required prior to accessing the online
asbestos section 8(a)(1) tool to submit your information. To get you started, a CDX guide is
available on EPA's website:

~ CDX Registration Guide, which covers the specifics of CDX registration
(httys://cdx. ena. gov/A bout/User Guide)

If you are required to report, failure to file your report during this period is a violation of
TSCA sections 8(a) and 15 and may subject you to penalties (See 40 CFR 711.1(c)).

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

4. Instructions for Completing Asbestos section
8(a)(1) Reporting

This chapter will help you complete asbestos section 8(a)(1) reporting. Section 4.1
describes how to certify your submission. Section 4.2 discusses the reporting standard - the
effort required to comply with the asbestos section 8(a)(1) reporting rule. Sections 4.3 through
Section 4.5 provide information to help you complete each required section of the reporting
form.

You are required to use the section 8(a)(1) online reporting tool in CDX to complete and
submit your asbestos section 8(a)(1) form. If you are reporting for multiple sites, you must
submit separate forms for each site. In most cases, you will submit exactly one form per site.
However, in certain cases you may submit one Form A and one Form B for one site; see Section
2.2.4 for a discussion of when to report using Form A or Form B.

The standard reporting form is comprised of a certification statement and two parts, as
follows:

•	The certification statement and Part I of the form are completed once per reporting site. Part I
contains company and site information, as well as contact information for the Authorized
Official and the technical contact.

•	Part II is completed for each type of activity occurring at the site. It contains information on
the type and quantity of asbestos mined, milled, processed, or imported, and the disposition of
the material or product as well as employee information including information on the number
of employees, type(s) of personal protective equipment (PPE) used, and assessments of
workplace exposure.

Form A reduces the number of fields to be reported for reporters who do not know the
quantity of asbestos they manufactured (including imported) or processed.

Note: Items such as the validation page and the SRS search page will appear in separate
windows. Ensure that your pop-up blocker is disabled before you begin to complete asbestos
section 8(a)(1) reporting.

4.1 Known to or Reasonably Ascertainable by Reporting Standard

Submitters are required to exercise certain levels of due diligence in gathering the
information required by the asbestos section 8(a)(1) rule. You must report your information to
the extent that the information is known to or reasonably ascertainable ("KRA") by you and
your company.

The term "known to or reasonably ascertainable by" is defined in 40 CFR 704.3, meaning
"all information in a person's possession or control, plus all information that a reasonable person
similarly situated might be expected to possess, control, or know."

Under TSCA section 8(a), EPA may collect information associated with chemical
substances to the extent that it is known to or reasonably ascertainable by the submitter. This
includes, but is not limited to, information that may be possessed by employees or other agents
of the company reporting under the section 8(a)(1) rule, including persons involved in the
research, development, manufacturing, or marketing of a chemical substance and includes

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

knowledge gained through discussions, symposia, and technical publications. For purposes of
section 8(a)(1), the known to or reasonably ascertainable by standard applies to all the
information required by the rule.

Examples of types of information that are considered to be in a person's possession or
control, or that a reasonable person similarly situated might be expected to possess, control, or
know include:

•	Files maintained by the manufacturer, such as marketing studies, sales reports, or customer
surveys,

•	Information contained in standard references, such as a safety data sheet (SDS) or a supplier
notification, and

•	Information from the Chemical Abstracts Service (CAS) and from Dun & Bradstreet
D-U-N-S®.

In the event that a manufacturer (including importer) or processor does not have actual
data (e.g., measurements or monitoring data) to report to EPA, the manufacturer (including
importer) or processor is required to make "reasonable estimates" of such information.
"Reasonable estimates" may rely, for example, on approaches such as mass balance calculations,
emissions factors, or best engineering judgment.

As noted in EPA's existing guidance on the KRA standard under the CDR rule,
information included in an SDS is an example of information that may be considered to be in a
person's possession or control, or that a reasonable person similarly situated might be expected
to possess, control, or know (see: https://www.epa.gov/sites/default/files/2020-
12 documents instructions for reporting 2020 tsca cdr 2020-1l-25.pdf). Therefore,
potentially affected entities with SDSs may consider the information included therein to
determine any reporting obligations. However, if a reporting entity has information on
manufactured (including imported) or processed asbestos that is known to or reasonably
ascertainable by them beyond an SDS, the entity must report that information to EPA as
applicable. In addition, if a material has physical properties characteristic of asbestos, or the
facility has other knowledge, then the SDS line of evidence alone does not meet the due
diligence standard. Further, because SDSs are not required for articles, the mere unavailability of
an SDS on its own may be an insufficient basis to indicate that the article does not contain
asbestos.

The hypothetical examples in Table 4-1 illustrate the anticipated application of the
"known to or reasonably ascertainable" reporting standard, in the specific context of the
collection of processing and use data under asbestos section 8(a)(1). Because the standard applies
on a case-by case basis, however, these examples cannot substitute for a complete analysis of a
submitter's particular circumstances.

This reporting standard does not confer a testing requirement on manufacturers. But, if
manufacturers have previously tested their products for the presence of asbestos, then that
information may be considered known to or reasonably ascertainable by them and should be
submitted to EPA as appropriate.

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Table 4-1. Examples of the Application of the "Known to or Reasonably Ascertainable by"
Reporting Standard for Processing and Use Data

Scenarios, Actions, and Outcomes

Scenario: Comoanv D discovers that it has no knowledge of how much asbestos is in imported brake Dads.
Company D has multiple suppliers, but it expects that it could estimate the total quantity of imported asbestos by
contacting its largest supplier and asking that supplier how much asbestos is in the brake pads.

Annlication of KRA Renorting Standard:

If:

Then:

Company D contacts its largest supplier and reports on the basis of the
data that the supplier was willing to provide.

Duties Likely Fulfilled

Company D did not endeavor to supplement the information it already
knew.

Duties Not Fulfilled

Scenario: Comranv E has never maintained information on the ultimate disposition of its asbestos waste
managed in the U.S. by waste management contractors. However, it is typical for comparable manufacturers to
collect such information as part of their reasonable business practices. Company E has multiple waste disposal
contractors, but it expects that it could substantially fill this data gap by contacting the contractor that receives
most of Company E's asbestos waste.

Ai)i)lication of KRA Rei)orting Standard:

If:

Then:

Company E contacts the contractor managing the majority of
Company E's asbestos waste, and reports on the basis of the
information provided by that contractor.

Duties Likely Fulfilled

Company E did not endeavor to supplement the information it already
knew.

Duties Not Fulfilled

Scenario: Comranv F imports marine caulk. In 2021. the com Dam initiated one-time testins for asbestos in its
imported products. The testing showed asbestos present at 0.1% by weight in Brand A of caulk and no asbestos
present in caulk from other brands.

Annlication of KRA Renorting Standard:

If:

Then:

Company F contacts its suppliers and receives lot-by-lot analysis
of the asbestos content of all caulk imported from 2019 through
2022.

Company F reports based on actual
asbestos content of the imported product.
Duties Likely Fulfilled.

Company F contacts Brand A but Brand A does not supply
additional information about the asbestos content of its caulks.

Company F estimates that all caulk
purchased from Brand A from 2019-
2022 contains 0.1% asbestos and other
brands did not contain asbestos. Duties
Likely Fulfilled.

Company F does not contact Brand A and reports only on the
basis of the imported lot found to contain asbestos.

Duties Not Fulfilled. Because Company
F knows some caulk imported from
Brand A contains asbestos. Company F
must make a reasonable estimate of the
asbestos contained in the imported caulk.

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4.2 Confidential Business Information (CBI) and Substantiation

Certain information reported in the asbestos section 8(a)(1) Reporting Form A and
Reporting Form B can be claimed as confidential if it is not already public information.
Confidentiality claims require upfront substantiation unless otherwise specified.

To assert a confidentiality claim, check the appropriate confidential business information
(CBI) box for the confidential data element(s). You will be prompted to complete the
substantiation questions prior to certifying the form. A CBI box will not appear for fields that
may not be claimed as confidential. Checking a CBI box automatically triggers the substantiation
questions, except for fields specifically exempted from substantiation requirements in section
4.3.1. See Table 4-2 for substantiation questions. If you fail to substantiate your CBI claims in
accordance with the statute and applicable rules, EPA may make the information claimed CBI
available to the public without further notice to you. For additional information about how to
answer CBI substantiation questions, visit www.ena.gov/tsca-cbi on the EPA website.

You may not claim the following data as confidential:

• Site NAICS code (see Section 4.4.3.4)

• The following chemical identities and bulk material forms:

o Most specific asbestos type for bulk asbestos (see Section 4.5.2.1)
o Bulk material type for bulk asbestos (see Section 4.5.2.2)
o Asbestos type for each bulk material type (see Section 4.5.2.2)
o Asbestos type and quantity for primary processors (see Section 4.5.3)
o Asbestos type and quantity for secondary processors (see Section 4.5.4)
o Asbestos type for imported products (see Section 4.5.5.2)

• Data elements left blank or designated as "not known or reasonably ascertainable"

• Workplace exposure measurement assessments and data (see Section 4.5.6.3), except:

o Information that would reveal processing information or the portion of a mixture
o Company name or address, financial statistics, and product codes used by a
company and contained in a study

o Other company information which is contained in a study and for which

disclosure would clearly be an unwarranted invasion of personal privacy (such as
individual medical records)

Table 4-2. CBI Substantiation Questions

No.

Question

Please specifically explain what harm to the competitive position of your business would be likely to
result from the release of the information claimed as confidential. How would that harm be substantial?
Why is the substantial harm to your competitive position likely (i.e., probable) to be caused by release of
the information rather than just possible? If you claimed multiple types of information to be confidential
(e.g., site information, exposure information, environmental release information), explain how disclosure
of each type of information would be likely to cause substantial harm to the competitive position of your
business.

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No.

Question



was previously reported to EPA as non-confidential (such as in an earlier version of this submission),
please explain the circumstances of that prior submission and reasons for believing the information is
nonetheless still confidential.

3.

(A)	Is any of the information claimed as confidential required to be publicly disclosed under any other
Federal law? If yes, please explain.

(B)	Does any of the information claimed as confidential otherwise appear in any public documents,
including (but not limited to) safety data sheets; advertising or promotional material; professional or
trade publications; state, local, or Federal agency files; or any other media or publications available to
the general public? If yes, please explain why the information should be treated as confidential.

(C)	Does any of the information claimed as confidential appear in one or more patents or patent
applications? If yes, please provide the associated patent number or patent application number (or
numbers) and explain why the information should be treated as confidential.

4.

Is the claim of confidentiality intended to last less than 10 (ten) years (see TSCA section 14(e)(1)(B))? If
yes, please indicate the number of years (between 1 (one) and 10 (ten) years) or the specific date after
which the claim is withdrawn.

5.

Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the
prior determination, whether the information was found to be entitled to confidential treatment, the entity
that made the decision, and the date of the determination.

4.2.1 Exemptions

The following data, if claimed CBI, are exempt from the substantiation requirement:

•	For mining, milling, or importing of bulk asbestos, the quantity of asbestos, in pounds

•	For mining, milling, or importing of bulk materials containing asbestos, the quantity of bulk
material manufactured or processed

•	For primary processing, the total quantity of asbestos processed

•	For primary processing, the total annual production quantity of end products produced

•	For secondary processing, the estimated total quantity of asbestos processed

•	For secondary processing, the total annual production quantity of end products produced

•	For importing, the estimated total quantity of asbestos imported

•	For importing, the total annual import quantity of the imported product

4.3 Company and site information

4.3.1 Confidentiality of Company, Site, and Technical Contact Information

Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim. Checking the CBI box automatically triggers the substantiation
questions. See Table 4-2 for substantiation questions related to these data elements. If you do not
check the CBI box for any information element, then that information is not claimed as CBI and
may be made public without further notice to you. Further, if you fail to substantiate your CBI
claims in accordance with the statute and applicable rules, EPA may make the information

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available to the public without further notice to you. For additional information about how to
answer substantiation questions, visit www.epa.gov/tsca-cbi on the EPA website.

You may assert a claim of confidentiality for a site, company, or technical contact
identity to protect the link between that information and the reported asbestos information. Such
claims should only be asserted where the linkage of that information to reportable asbestos is
confidential and not publicly available.

EPA also has observed that submitters sometimes claim only their company identity, but
not their site identity, as confidential. EPA will not impute the assertion of a CBI claim for site
identity as an assertion of a CBI claim for company identity, even if the company name appears
within the site identity information. In other words, if your intent is to claim company name as
confidential you must claim all data elements that reference or allude to company name as CBI.
Failure to do so will likely result in a denial of a CBI claim for company name.

4.3.2 Special Provisions for Certain Sites

For asbestos that is domestically manufactured or processed, the site is the location where
the asbestos is physically manufactured or processed.

For importers, the site where you import a chemical substance is considered the site of
the operating unit within your organization that is directly responsible for importing the
chemical substance and that controls the import transaction. For asbestos section 8(a)(1), all
importers must provide a U.S. address for the controlling site; this site may be your company's
headquarters in the United States. If there is no such operating unit or headquarters in the United
States, the site address for the importer is the U.S. address of an agent acting on the importer's
behalf who is authorized to accept service of process for the importer (40 CFR 711.3). In the
event that more than one person may meet the definition of "importer" (40 CFR 704.3), only one
person should report. See 40 CFR 711.22(b).

Example 4-1. The headquarters of your company is located in New Town. Your
company owns a plant site located in Old Town, which is in a different state. A
headquarters employee purchases and arranges to have 50,000 lb of asbestos
imported from Russia to the Old Town plant site. The headquarters site in New
Town controls the import transaction and is the site reported.

Example 4-2. The headquarters of your company is located in New Town. Your
company owns three manufacturing sites, Sites 1, 2, and 3, all located in different
states. An employee based at headquarters purchases and arranges to have 50,000 lb
of asbestos imported from Russia. The chemical is distributed as follows: 2,000 lb is
delivered to Site 1; 18,000 lb is delivered to Site 2; and 30,000 lb is delivered to Site
3. The headquarters in New Town controls the import transaction for all three sites,
and therefore is responsible for reporting all 50,000 lb of asbestos. The site reported
is New Town.

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4.3.3 Parent Company Information1

You must provide information about your parent company. For purposes of section
8(a)(1), a parent company is the highest-level company of your site's ownership hierarchy as of
the start of the submission period according to the definitions of parent company and highest-
level parent company at 40 CFR 711.3. Report your highest4evel parent company located in the
United States. Provide the company name, address, and D&B number following the instructions,
including the naming conventions, provided below. Table 4-3 contains examples of how to
identify the parent company in different situations.

Note that although some TSCA reporting requires you to report your U.S. parent company
and your foreign parent company, section 8(a)(1) reporting requires only the U.S. parent to be
reported.

Table 4-3. Applying Highest-level Parent Company Definition in Different Situations

Site Ownership

U.S. Parent Company

(1) If the site is entirely owned by a single U.S.
company that is not owned by another company

Then that single company is the U.S. parent company.

(2) If the site is entirely owned by a single U.S.
company that is, itself, owned by another U.S.-based
company (e.g., it is a division or subsidiary of a higher-
level company)

The highest-level domestic company in the ownership
hierarchy is the U.S. parent company.

(3) If the site is owned by more than one company
(e.g., company A owns 40 percent, company B owns
35 percent, and company C owns 25 percent of the
site)

The company with the largest ownership interest in the
site is the parent company. Under this scenario, this
would be either company A itself (if it doesn't have a
U.S.-based parent company), company A's parent, or,
if it exists, a single parent company that owns both
company B and company C, in which case that single
parent company would have the largest ownership
interest (e.g., corporation X owns companies B and C,
for a total ownership of 60 percent for the site).

If the parent company is a U.S. company owned by
another U.S. company, then the highest-level domestic
company in the ownership hierarchy is the U.S. parent
company.

If the parent company is a foreign company, then the
site is its own U.S. parent company.

(4) If the site is ultimately owned by a 50:50 joint
venture or a cooperative

The joint venture or cooperative is its own U.S. parent
company.

If the site is owned by a U.S. joint venture or
cooperative, the highest level of the joint venture or
cooperative is the U.S. parent company.

(5) If the site is entirely owned by a foreign company
(i.e., without a U.S.-based subsidiary within the
facility's ownership hierarchy)

The site is the U.S. parent company.

(6) If the site is a federally owned facility

The highest-level federal agency or department is the
U.S. parent company.

1 See Section 4.4.1 for information concerning CBI claims for Parent Company Information.

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Site Ownership

U.S. Parent Company

(7) If the site is owned by a non-federal public entity

That entity (such as a municipality. State, or tribe) is
the U.S. parent company.

4.3.3.1 U.S. Parent Company Name(s)

All sites must enter the full name of the U.S. parent company. EPA requires that parent
companies be referenced consistently by the same name so that site-level information can be
aggregated to the associated parent company. This can be challenging because filers within the
same parent company often submit names with small variations (e.g., Exopack vs. Exopack
Holdings Corp). When reporting your parent company name, eliminate all periods, commas, and
all leading, trailing, and duplicate spaces. Replace commonly used acronyms and corporate terms
according to Table 4-4:

Table 4-4. Parent Company Name Standardization

Use This

Not This

AND

CORP

CORPORATION

ASSOC

ASSOCIATION

COMPANY

COS

COMPANIES

DIV

DIVISION

INC

INCORP

INC

INCORP.

INC

INCORPORATED

INC

INCORPERATED

LIMITED PARTNERSHIP

LTD

LIMITED

LLC

LIMITED LIABILITY COMPANY

LLC

LIMITED LIABILITY CO.

PTNR

PARTNERSHIP

USA

U.S.

USA

U.S.A.

USA

U.S.A

USA

UNITED STATES OF AMERICA

USA

UNITED STATES

Parent Company Address

Enter the mailing address of each parent company, including the appropriate county or
parish, using standard addressing techniques as established by the U.S. or international postal

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services. Post office box numbers should be accompanied by a street address. If a post office box
is listed, it must be entered after the street address. Standardized conventions for listing a street
address should be used to account for common formatting discrepancies, such as punctuation (by
eliminating all periods, commas, and all leading, trailing, and duplicate spaces), capitalization,
and abbreviations in order to increase the reliability and usability of the data. Replace commonly
used acronyms and street abbreviations according to Table 4-5:

Table 4-5. Parent Company Street Address Standardization

Use This

Not This

AVE

AVENUE

AVE

AVE.

BLVD

BOULEVARD

BLVD

BLVD.

DRIVE

DR.

HWY

HIGHWAY

HWY

HWY.

JCT

JUNCTION

JCT

JCT.

LANE

LN.

PLACE

PL.

PO BOX

P.O. BOX

ROAD

RD.

RTE

ROUTE

STREET

ST.

Parent Company Dun & Bradstreet D-U-N-S® Number

Enter the 9-digit Dun & Bradstreet D-U-N-S® number (D&B number) associated with
each parent company name. The number may be obtained from the treasurer or financial officer
of the company.

D&B assigns separate numbers to subsidiaries and parent companies; you should make
sure that the number you provide EPA belongs to your U.S. parent company. To verify the
accuracy of your site and parent company D&B number and name, go to
www.dnb.com product dlw form cc4.htm or call 1-800-234-3867. Callers to the toll-free phone
number should understand that the D&B support representatives will need to verify that callers
requesting the D&B number are an agent of the business. D&B recommends knowing basic

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information such as when the business originated, officer names, and the name, address, and
phone number for the facility.

You must obtain a D&B number for your parent company if none exists. If your parent
company does not have a D&B number, you can request one from your local office of D&B.
There is no charge for this service, and you are not required to disclose sensitive financial
information to get a number. For more information on obtaining a D&B number, see
www.dnb.com. If you are already listed with D&B, but do not know your number, you can call 1-
800-234-3867 for assistance.

4.3.3.2 Authorized Official

This section requests information about the person who will serve as Authorized Official
for the submitter company and who will be able to sign the certification statement as described in
Section 4.1. Provide the authorized official's full name, mailing address, telephone number, and
e-mail address. Enter the authorized contact's full mailing address, using standard addressing
techniques as established by the U.S. or international postal services, as applicable. Post Office
box numbers should be accompanied by a street address. If a Post Office box is used as a mailing
address, the street address should be given followed by the Post Office box number.

Standardized conventions for listing a mailing address will be used to account for common
formatting discrepancies, such as punctuation (by eliminating all periods, commas, and all
leading, trailing, and duplicate spaces), capitalization, and abbreviations in order to increase the
reliability and usability of the data. See Table 4-5 in Section 4.4.3.1. If the authorized contact is
outside of the United States, include the country code for their telephone number.

4.3.3.3 Technical Contact Information

Provide the name of the person who will serve as technical contact for the submitter
company and who EPA may contact for clarification of the information in your CDR
submission. The technical contact should be a person who can answer questions about the
reported information. Typically, a person located at the manufacturing site is best able to answer
such questions. However, companies may use their discretion in selecting a technical contact or
multiple technical contacts, as provided by the web tool. In selecting the technical contact,
submitters should consider that EPA may have follow-up questions about a submission years
after the submission date. The technical contact need not be the person who signed the
certification statement.

Provide the technical contact's full name, mailing address, telephone number, and e-mail
address as described in Section 4.4.3.2 for authorized officials. The section 8(a)(1) online
reporting tool has an option to "Copy Information from CDX Registration" as appropriate.

4.3.3.4 Site Information

EPA requires the following information to be reported for each plant site at which
asbestos is manufactured or processed: the site name, street address, city, county (or parish),
state, and zip code, and six-digit North American Industry Classification System (NAICS)
code(s) of the site.

The section 8(a)(1) reporting tool will automatically populate the site name and street
address from the site used for Authorized Official's CDX registration. If you need to change this
information, you will need to make corrections or create a new site in CDX and create a new
form for the corrected or new site.

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Site D&B number

D&B assigns separate numbers to subsidiaries and parent companies; make sure that the
number you provide EPA belongs to the individual site for which you are reporting. You must
obtain a D&B number for the site, if none exists. If the site does not have a D&B number, you
can request one from your local office of D&B. Please refer to Section 4.4.3.1 for information on
obtaining a D&B number.

Other site identification numbers

Report any other site identification numbers, such as Facility Registry Service (FRS) ID
number, Resource Conservation and Recovery Act (RCRA) IDs, Toxics Release Inventory ID,
or other identification numbers.

Number of employees

Report the total number of employees at the site. Select the code from Table 4-6 that best
describes the number of people employed at the site during calendar years 2019-2022 (e.g., the
average number of employees).

Table 4-6. Codes for Number of Employees.

(ode

Uiiniio

VV1

Fewer than 10 employees

At least 10 but fewer than 25 employees

At least 25 but fewer than 50 employees

At least 50 but fewer than 100 employees

At least 100 but fewer than 500 employees

At least 500 but fewer than 1,000 employees

At least 1,000 but fewer than 10,000 employees

At least 10,000 employees

Physical Address is Different than Mailing Address

Check this box if appropriate and enter physical address information.

Site NAICS code(s)

Add the appropriate six-digit North American Industry Classification System (NAICS)
code(s) for each site reported. Up to three NAICS codes can be selected. The NAICS code is the
standard Federal statistical agencies use in classifying business establishments for the purpose of
collecting, analyzing, and publishing statistical data related to the U.S. business economy.
Information about NAICS codes can be obtained from the U.S. Census website at
www. census, gov/eos/www/naics/.

In some circumstances it may be challenging to identify a single NAICS code for the site.
In those circumstances, you may report up to three NAICS codes to more appropriately describe
your site. For example, headquarters sites that import for other sites may have difficulty
identifying a single NAICS code.

Note that the site NAICS code(s) may not be claimed as confidential.

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4.4 Asbestos Fibers

Report the most specific asbestos type(s) that applies by clicking "Add Asbestos Fiber".
Refer to Table 4-8 below. If the specific asbestos type is not known or reasonably ascertainable,
report the general listing, "asbestos CASRN 1332-21-4".

Table 4-7. Asbestos Types

CASRN

Asbestos Type

1332-21-4

Asbestos

12001-29-5

Chrysotile

12001-28-4

Crocidolite

12172-73-5

Amosite

77536-67-5

Anthophyllite

77536-68-6

Tremolite

77536-66-4

Actinolite

Libby Amphibole (mainly consisting of tremolite [CASRN 77536-68-6], winchite
[CASRN 12425-92-2], and richterite [CASRN 17068-76-7])

For form B, you will be prompted to report further information for each asbestos type
selected. The reporting tool will automatically display the required fields for Form A or Form B
based on whether you know the amount of asbestos in your product.

4.5 Reporting Activity Information

Select all the relevant activities conducted at the site for each asbestos type you selected.
If more than one activity applies, select all activities that apply. The activities you may choose
from are:

1. Mining of bulk asbestos or bulk materials containing asbestos, including as an impurity:
An asbestos mine is an entity that mines asbestos-containing ore. Milling of bulk asbestos
or bulk materials containing asbestos, including as an impurity. Mined (i.e., extracted)
asbestos-containing ore is further milled to produce bulk asbestos. Milling involves the
separation of the fibers from the ore, grading and sorting the fibers, or fiberizing crude
asbestos ore. An asbestos mill is an entity that mills asbestos-containing ore.

2. Importer of bulk asbestos or bulk materials containing asbestos, including as an impurity:
An importer of bulk asbestos imports bulk asbestos into the customs territory of the
United States. EPA anticipates that companies who are mining, milling, or importing
bulk asbestos will report using Form B, because the volume of asbestos is likely known
to or reasonably ascertainable by them.

3. Primary processor of bulk asbestos or bulk materials containing asbestos, including as an
impurity: A primary processor starts with bulk asbestos or bulk materials containing
asbestos and makes a mixture that contains asbestos as a component. A primary processor
may simply mix or repackage different types or sizes of fibers and then sell that product.
Mixtures that contain asbestos are products to which asbestos has been intentionally
added and which can be used or processed further and incorporated into other products.

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For example, asbestos cement, asbestos paper, and asbestos-reinforced plastics are
instances where asbestos is contained in a mixture. Primary processors are defined in the
40 CFR section 704.180(a), a definition adapted from the definition of primary processor
in the 1982 Asbestos Reporting Requirements Rule (see Unit II.C.l.).

4. Secondary processor of mixtures or articles containing asbestos, including as an impurity:
Secondary processors are those who start with asbestos when it is a component of a
mixture and incorporate the mixture into their own products. For example, persons who
fabricate an asbestos cement sheet by cutting the sheet to make an electrical switch board,
or persons who make garments by cutting an asbestos-containing textile, are secondary
processors. Secondary processors are defined in 40 CFR section 704.180(a), a definition
adapted from the definition of primary processor in the 1982 Asbestos Reporting
Requirements Rule (see Unit II.C. 1.).

5. Importer of products, mixtures, or articles containing asbestos, including as an impurity.
An importer of asbestos contained in a mixture or article that contain asbestos, including
as an impurity, imports these substances into the customs territory of the United States.

4.5.1 Confidentiality of Activity Information

Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for information being submitted in this section. Checking the CBI
box automatically triggers the substantiation questions. See Table 4-2 for substantiation
questions related to these data elements If you do not check the CBI box for any information
element, then that information is not claimed as CBI and may be made public without further
notice to you. Further, if you fail to assert your CBI claims in accordance with the statute and
applicable rules, EPA may make the information available to the public without further notice to
you. For additional information about how to answer substantiation questions, visit
www.epa.eov/tsca-cbi on the EPA website.

Table 4-8. Substantiation Questions for Activity Information

No.

Question

Has your business taken precautions to protect the confidentiality of the disclosed information? If yes,
please explain and identify the specific measures, including but not limited to internal controls, that your
business has taken to protect the information claimed as confidential. If the same or similar information
was previously reported to EPA as non-confidential (such as in an earlier version of this submission),
please explain the circumstances of that prior submission and reasons for believing the information is
nonetheless still confidential.

(A) Is any of the information claimed as confidential required to be publicly disclosed under any other
Federal law? If yes, please explain.

(B) Does any of the information claimed as confidential otherwise appear in any public documents,
including (but not limited to) safety data sheets; advertising or promotional material; professional or
trade publications; state, local, or Federal agency files; or any other media or publications available to
the general public? If yes, please explain why the information should be treated as confidential.

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No.

Question



(C) Does any of the information claimed as confidential appear in one or more patents or patent
applications? If yes, please provide the associated patent number or patent application number (or
numbers) and explain why the information should be treated as confidential.

4.

Is the claim of confidentiality intended to last less than 10 (ten) years (see TSCA section 14(e)(1)(B))? If
yes, please indicate the number of years (between 1 (one) and 10 (ten) years) or the specific date after
which the claim is withdrawn.

5.

Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the
prior determination, whether the information was found to be entitled to confidential treatment, the entity
that made the decision, and the date of the determination.

4.5.2 Mined, milled, or imported bulk asbestos or bulk materials containing asbestos,

including as an impurity

If you selected mining, milling, or importing bulk asbestos or bulk materials containing
asbestos, you will be prompted to report additional information about each asbestos type and
bulk material type as described in Section 4.5.2.1 and Section 4.5.2.2 below.

Quantity of asbestos (Form B only)

Report, in whole pounds and for each reporting year, the quantity of bulk asbestos of the
selected type that was mined, milled, or imported at the site. Report the quantity to at least two
significant figures; it should be accurate to the extent known to or reasonably ascertainable by
you. Quantities should be reported in numeric format, without commas (e.g., 6352000). Report
only the weight of asbestos mined, milled, or imported. Do not include the weight of any
other materials (e.g., containers or other chemical substances).

Disposition of asbestos (Form B only)

For each reporting year, use the disposition codes in Table 4-9 below to indicate the
disposition of the bulk asbestos of the selected type that was mined, milled, or imported at the
site. If you select code 6, "disposed of within the U.S.," you must provide a description of the
U.S. disposal. If you select code 7, "other," you must provide a description of the "other"
disposition.

Table 4-9. Disposition Codes

(ode

Disposition Description

1

Used on-site, including further processed

2

Stored on-site

3

Sent to another U.S. site (including intra-company transfer) for use or processing

4

Stored at another U.S. site (including intra-company transfer)

5

Exported outside of the U.S. without further processing

6

Disposed of within the U.S. (explain)

7

Other (explain)

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

4.5.2.1 Bulk material type

Report the bulk material type(s) manufactured or processed (e.g., talc, vermiculite). For
Form B, you will be prompted to report further information for each bulk material type selected.
All reporters must report the disposition of the bulk material.

Quantity of bulk material manufactured or processed (Form B only)

For each reporting year, report the quantity and units for the amount of bulk material
manufactured or processed. Report the quantity to at least two significant figures; it should be
accurate to the extent known to or reasonably ascertainable by you. Quantities should be reported
in numeric format, without commas (e.g., 6352000). Report only the weight of the bulk material
mined, milled, or imported. Do not include the weight of any other materials (e.g., containers).

Percent asbestos impurity by weight in bulk material (Form B only)

For each reporting year, report the percent of asbestos by weight present as an impurity in
the bulk material. Report the percent to at least two significant figures; it should be accurate to
the extent known to or reasonably ascertainable by you. Percentages should be reported in
numeric format including decimal points, without percentage signs (e.g., 8.5).

Testing or test results assessing asbestos content (Form B only)

Report any testing of or test results assessing the asbestos content of your bulk material in
the applicable reporting years. If testing was conducted, specify how often testing was conducted
on the presence of asbestos in your bulk material and what method and type of test was used for
determining asbestos content, and provide the test results. If testing was not conducted, explain
how you knew or reasonably ascertained the presence and amount of asbestos in the bulk
materials.

Disposition of bulk material

For each reporting year, use the disposition codes in Table 4-9 above to indicate the
disposition of the bulk asbestos of the selected type that was mined, milled, or imported at the
site. If you select code 6, "disposed of within the U.S.," you must provide a description of the
U.S. disposal. If you select code 7, "other," you must provide a description of the "other"
disposition.

4.5.3 Primary processers

If you selected primary processing of bulk asbestos or bulk materials containing asbestos,
including as an impurity, you will be prompted to report additional information about each
asbestos-containing product type as described in Section 4.5.3.2. Primary processors start with
bulk asbestos or bulk materials containing asbestos and make a mixture that contains asbestos as
a component.

4.5.3.1 Quantity of asbestos processed (Form B only)

Report the total quantity of asbestos processed, in whole pounds and for each reporting
year. Report the quantity to at least two significant figures; it should be accurate to the extent
known to or reasonably ascertainable by you. Quantities should be reported in numeric format,
without commas (e.g., 6352000). Report only the weight of asbestos processed. Do not include
the weight of any other materials (e.g., containers or other chemical substances).

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Instructions for Completing Asbestos section 8(a)(1) Reporting

4.5.3.2 End Product Types

Select all end product types produced at your facility containing asbestos. If an end
product produced at your facility is not listed in the table, select "other" from the appropriate
section (e.g., for a non-listed floor covering, select code 15, "Other" (specify generic name)). A
textbox will appear for you to add a description of the product and the unit of measure you will
use to report the quantity of end products produced. Select as many end product types as apply.
For each end product type, you will be prompted to provide additional information.

Table 4-10. End Product Types

Code

Name

End Product Unit of
Measure

Papers, Felts, or Related Products

01

Commercial paper

Short Tons

02

Rollerboard

Short Tons

03

Millboard

Short Tons

04

Pipeline wrap

Short Tons

05

Beater-add gasketing paper

Short Tons

06

High-grade electrical paper

Short Tons

07

Unsaturated roofing felt

Short Tons

08

Saturated roofing felt

Short Tons

09

Flooring felt

Short Tons

10

Corrugated paper

Short Tons

11

Specialty paper (specify generic name)

Short Tons

12

Other (specify generic name)

(Specify)

Floor Coverings

13

Vinyl asbestos floor tile

Square yards

14

Asbestos felt backed vinyl flooring

Square yards

15

Other (specify generic name)

(Specify)

Asbestos Cement Products

16

A/C pipe and fittings

Short Tons

17

A/C sheet, flat

100 sq. ft.

18

A/C sheet corrugated

100 sq. ft.

19

A/C shingle

Squares

20

Other (specify generic name)

(Specify)

Transportation Friction Materials (including aircrafts, marine vessels, railroad engine and railcars, and

other vehicles)

21

Drum brake lining (light-medium vehicle)

Pieces

22

Disc brake pads (light-medium vehicle)

Pieces

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Instructions for Completing Asbestos section 8(a)(1) Reporting

Code

Name

End Product Unit of
Measure

23

Disc brake pads (heavy vehicle)

Pieces

24

Brake block (heavy equipment)

Pieces

25

Clutch facings (all)

Pieces

26

Automatic transmission friction components

Pieces

27

Friction materials (industrial and commercial)

Pieces

28

Custom automotive body filler

Pieces

29

Transmissions

Pieces

30

Mufflers

Pieces

31

Radiator top insulation

Pieces

32

Radiator sealant

Pieces

33

Other (specify generic name)

(Specify)

Appliances

34

Appliance Industrial and consumer (specify generic name)

Pieces

35

Other (specify generic name)

(Specify)

Construction Products

36

Boiler and furnace baffles

Pieces

37

Decorated building panels

Pieces

38

Asbestos cement sheet

Pieces

39

Flexible Air Conductor

Pieces

40

Hoods and Vents

Pieces

41

Portable construction building

Pieces

42

Roofing, saturated

Pieces

43

Roof shingles

Pieces

44

Wallboard

Pieces

45

Wall/roofing panels

Pieces

46

Other (specify generic name)

(Specify)

Electrical Products and Components

47

Cable insulation

Pieces

48

Electronic motor components

Pieces

49

Electrical resistance supports

Pieces

50

Electrical switchboard

Pieces

51

Electrical switch supports

Pieces

52

Electrical wire insulation

Pieces

53

Motor armature

Pieces

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

Code

Name

End Product Unit of
Measure

54

Other (specify generic name)

(Specify)

Fire and Heat Shielding Equipment and Components

55

Arc deflectors

Pieces

56

Fire doors

Pieces

57

Fireproof absorbent paper

Short tons

58

Heat shields

Pieces

59

Molten metal handling equipment

Pieces

60

Oven and stove insulation

Short tons

61

Pipe wrap

Pieces

62

Stove lining, wood and coal

Pieces

63

Stove pipe rings

Pieces

64

Sleeves

Pieces

65

Thermal Insulation

Short tons

66

Other (specify generic name)

(Specify)

Textiles and Clothing

67

Cloth

Pounds

68

Thread, yarn, lap, roving, cord, rope, or wick

Pounds

69

Aprons

Pieces

70

Boots

Pieces

71

Gloves and mittens

Pieces

72

Hats and helmets

Pieces

73

Overgaiters

Pieces

74

Suits

Pieces

75

Aluminized cloth

Short Tons

76

Rope or braiding

Short Tons

77

Yarn, lap or roving

Short Tons

78

Wicks

Short Tons

79

Bags

Pieces

80

Belting

Short Tons

81

Blankets

Pieces

82

Carpet padding

Short Tons

83

Commercial/industrial dryer felts

Short Tons

84

Draperies

Pieces

85

Drip cloths

Pieces

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

Code

Name

End Product Unit of
Measure

86

Fire hoses

Pieces

87

Ironing board pads and insulation

Pieces

88

Mantles, lamp or catalytic heater

Pieces

89

Packing and packaging components

Pieces

90

Piano and organ felts

Pieces

91

Rugs

Pieces

92

Tape

Pieces

93

Theater curtains

Pieces

94

Umbrellas

Pieces

95

Other (specify generic name)

(Specify)

Gaskets

96

Sheet gasketing, rubber encapsulated beater addition

Pieces

97

Sheet gasketing, rubber encapsulated compressed

Pieces

98

Compressed sheet gasketing (other)

Pieces

99

Metal reinforced gaskets

Pieces

100

Automotive gaskets

Pieces

101

Other (specify generic name)

(Specify)

Marine Equipment and Supplies

102

Caulks, marine

Pounds

103

Liners, pond or canal

Pieces

104

Marine bulkheads

Pieces

105

Other (specify generic name)

(Specify)

Paints, Coatings, Sealants and Compounds

106

Asphaltic compounds

Pounds

107

Automotive/truck body coatings

Gallons

108

Buffing and polishing compounds

Pounds

109

Caulking and patching compounds

Pounds

110

Drilling fluid

Gallons

111

Flashing compounds

Pounds

112

Furnace cement

Pounds

113

Glazing compounds

Pounds

114

Plaster and stucco

Pounds

115

Pump valve, flange and tank sealing components

Pieces

116

Roof coatings

Gallons

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Chapter 4	Instructions for Completing Asbestos section 8(a)(1) Reporting

Code

Name

End Product Unit of
Measure

117

Textured paints

Gallons

118

Tile cement

Pounds

119

Other (specify generic name)

(Specify)

Other Products

120

Sheet gasketing (other than beater-add)

Square Yards

122

Packing

Pounds

123

Paints and surface coatings

Gallons

124

Adhesives and sealants

Gallons

125

Asbestos-reinforced plastics

Pounds

126

Insulation materials not elsewhere classified (specify generic name)

(Specify)

127

Mixed or repackaged asbestos

Short Tons

128

Aerial distress flares

Pieces

129

Acoustical product

Pieces

130

Ammunition wadding

Pieces

131

Ash trays

Pieces

132

Baking sheets

Pieces

133

Blackboards

Pieces

134

Candlesticks

Pieces

135

Chemical tanks and vessels

Pieces

136

Filters

Pieces

137

Grommets

Pieces

138

Gun grips

Pieces

139

Jewelry making equipment

Pieces

140

Kilns

Pieces

141

Lamp sockets

Pieces

142

Light bulbs (all types)

Pieces

143

Linings for vaults, safes, humidifies and filing cabinets

Pieces

144

Phonograph records

Pieces

145

Pottery clay

Pounds

146

Welding rod coatings

Pieces

147

Other (specify generic name)

(Specify)

Annual production quantity

Report the total annual production quantity of end products produced, using the unit of
measure provided for that product in Table 4-10 above.

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

Percent asbestos weight in end product (Form B only)

Report the percent of asbestos by weight present in the end product. Report the percent to
at least two significant figures; it should be accurate to the extent known to or reasonably
ascertainable by you. Percentages should be reported in numeric format including decimal
points, without percentage signs (e.g., 8.5).

Disposition of end product (Form B only)

For each reporting year, use the disposition codes in Table 4-9 above to indicate the
disposition of the end product. If you select code 6, "disposed of within the U.S.," you must
provide a description of the U.S. disposal. If you select code 7, "other," you must provide a
description of the "other" disposition.

Testing or test results assessing asbestos content (Form B only)

Report any testing of or test results assessing the asbestos content of your end product in
the applicable reporting years. If testing was conducted, specify how often testing was conducted
on the presence of asbestos in your end product and what method and type of test was used for
determining asbestos content, and provide the test results. If testing was not conducted, explain
how you knew or reasonably ascertained the presence and amount of asbestos in the end product.

4.5.4 Secondary processors

If you selected secondary processing of asbestos (processing asbestos when a component
of a mixture and articles containing asbestos, including as an impurity), you will be prompted to
report additional information about each asbestos-containing product type as described in
Section 4.5.4.2. Secondary processors are those who start with asbestos when it is a component
of a mixture and incorporate the mixture into their own products. For example, persons who
fabricate asbestos cement sheet by cutting the sheet to make an electrical switch board, or
persons who make garments by cutting an asbestos-containing textile, are secondary processors.

4.5.4.1	Quantity of asbestos processed (Form B only)

Report the total quantity of asbestos processed, in whole pounds. Report the quantity to at
least two significant figures; it should be accurate to the extent known to or reasonably
ascertainable by you. Report only the weight of asbestos processed. Do not include the weight
of any other materials (e.g., containers or other chemical substances).

4.5.4.2	End Product Types

Select all end product types produced at your facility containing asbestos from Table
4-10 above. If an end product produced at your facility is not listed in the table, select "other"
from the appropriate section (e.g., for a non-listed floor covering, select code 15). A textbox will
appear for you to add a description of the product and the unit of measure you will use to report
the quantity of end products produced. Select as many end product types as apply. For each end
product type, you will be prompted to provide additional information.

Annual production quantity

Report the total annual production quantity of end products produced, using the unit of
measure provided for that product in Table 4-10 above.

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Instructions for Completing Asbestos section 8(a)(1) Reporting

Percent asbestos weight in end product (Form B only)

Report the percent of asbestos by weight present in the end product. Report the percent to
at least two significant figures; it should be accurate to the extent known to or reasonably
ascertainable by you. Percentages should be reported in numeric format including decimal
points, without percentage signs (e.g., "8.5" for 8.5%, not "0.085").

Testing or test results assessing asbestos content (Form B only).

Report any testing of or test results assessing the asbestos content of your end product in
the applicable reporting years. If testing was conducted, specify how often testing was conducted
on the presence of asbestos in your end product and what method and type of test was used for
determining asbestos content, and provide the test results. If testing was not conducted, explain
how you knew or reasonably ascertained the presence and amount of asbestos in the end product.

Disposition of end product (Form B only)

For each reporting year, use the disposition codes in Table 4-9 above to indicate the
disposition of the end product. If you select code 6, "disposed of within the U.S.," you must
provide a description of the U.S. disposal. If you select code 7, "other," you must provide a
description of the "other" disposition.

4.5.5 Importing of mixtures, or articles containing asbestos, including as an impurity

If you selected import of mixtures or articles containing asbestos, including as an
impurity, you will be prompted to report additional information about each asbestos-containing
product type as described in Section 4.5.5.2.

4.5.5.1	Quantity of asbestos imported (Form B only)

Report the total quantity of asbestos imported, in whole pounds. Note that if you import
various mixtures containing asbestos, you should add all import volumes associated with each
mixture. For instance, if you import three mixtures and each mixture contains asbestos, then you
would determine the volume of asbestos in each mixture and report the aggregated amount.

Report the quantity to at least two significant figures; it should be accurate to the extent
known to or reasonably ascertainable by you. Report only the weight of asbestos imported. Do
not include the weight of any other materials (e.g., containers or other chemical substances).

4.5.5.2	Imported Product Types

Select all imported product types containing asbestos imported by your facility from
Table 4-10 above. If an imported product produced at your facility is not listed in the table, select
"other" from the appropriate section (e.g., for a non-listed floor covering, select code 15). A
textbox will appear for you to add a description of the product and the unit of measure you will
use to report the quantity of end products produced. Select as many product types as apply. For
each product type, you will be prompted to provide additional information.

Annual import quantity

Report the total annual imported quantity of the product, using the unit of measure
provided for that product in Table 4-10 above.

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Chapter 4

Instructions for Completing Asbestos section 8(a)(1) Reporting

Percent asbestos weight in end product (Form B only)

Report the percent of asbestos by weight present in the imported product. Report the
percent to at least two significant figures; it should be accurate to the extent known to or
reasonably ascertainable by you. Percentages should be reported in numeric format including
decimal points, without percentage signs (e.g., 8.5).

Testing or test results assessing asbestos content (Form B only)

Report any testing of or test results assessing the asbestos content of your imported
product in the applicable reporting years. If testing was conducted, specify how often testing was
conducted on the presence of asbestos in your imported product and what method and type of
test was used for determining asbestos content, and provide the test results. If testing was not
conducted, explain how you knew or reasonably ascertained the presence and amount of asbestos
in the imported product.

Disposition of end product (Form B only)

For each reporting year, use the disposition codes in Table 4-9 above to indicate the
disposition of the imported product. If you select code 6, "disposed of within the U.S.," you must
provide a description of the U.S. disposal. If you select code 7, "other," you must provide a
description of the "other" disposition.

4.5.5.3 For Imported Asbestos, Is the Asbestos Never Physically at Site?

Report whether or not your imported asbestos is physically at the reporting site. Report
one of the following choices:

• Yes, the imported asbestos is never physically at the reporting site (e.g., if you ship the
chemical substance from a foreign country directly to another location such as a warehouse, a
processing or use site, or a customer's site).

• No, the imported asbestos is physically present at the reporting site.

• NA, not applicable because the asbestos is not imported.

• NKRA, it is not known to or reasonably ascertainable by you whether the imported asbestos is
physically present at the reporting site.

4.5.6 Employee information

For each activity reported, you must report certain information about the employees
involved with the activity.

4.5.6.1 Number of employees involved with the activity

Select the range code that best describes the number of employees physically involved in
the activity from Table 4-6 above.

When a site employs temporary, seasonal, or contract workers in the manufacture or
processing of reportable asbestos, these workers should be included in the number of workers
involved in the activity if they work in areas where the asbestos is handled. Workers involved in
the activity do not include those employees whose jobs are not associated with potential
exposures to a chemical substance or mixture (e.g., administrative staff who never enter areas
where the chemical substance is manufactured) and who are unlikely to be exposed to a chemical
substance for even a brief period of time.

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Instructions for Completing Asbestos section 8(a)(1) Reporting

4.5.6.2	Personal protective equipment

Check the correct box indicating whether employees performing this activity use personal
protective equipment (PPE). If PPE is used, use the textbox to describe the type of PPE used and
which workers use each type of PPE, as specifically as possible.

4.5.6.3	Workplace exposure measurement assessments and data (Form B only)

Report any workplace exposure measurement assessments and data such as monitoring.
The reporting software will guide you through the process of uploading attachments if needed.

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Chapter 5

How to Obtain Copies of Documents Cited in This Instructions Document

4.6 Certification

Your submission(s) must be certified, indicating that your submitted information has
been completed in compliance with the asbestos reporting requirements, such as all information
known or reasonably ascertainable is submitted, and that the confidentiality claims made in this
report are true and correct. To certify, the certification statement must be electronically signed
and dated by an authorized official at your company. The authorized official typically is a senior
official with management responsibility for the person (or persons) completing the form(s). You
must include the printed name, title, and email address for the person signing the certification.
See the CDX user guide including CDX Registration for information on how to complete an
electronic signature agreement.

This certification statement applies to all the information supplied on the form(s). The
certification statements appear when the submission process has been initiated, at which time the
submitter must either certify or cancel the submission process. Note that knowingly providing
false or misleading information or concealing required information may be punishable by fine or
imprisonment or both under TSCA section 16(b).

5. How to Obtain Copies of Documents Cited in
This Instructions Document

5.1 Obtaining Copies of the TSCA Rules

The section 8(a)(1) rule, 40 CFR Part 704. is available on the U.S. Government
Publishing Office website, www.ecfr.sov.

You may also contact the TSCA Hotline by telephone at (202) 554-1404 or by email
tsca-hotline@epa.gov for assistance.

5.2 Obtaining Copies of Other Information Materials

EPA has developed documents to provide additional information on submitting
information for this reporting requirement. Except where otherwise noted, materials are available
on the section 8(a)(1) website at https://www.epa.gov/assessing-and-Managing-cheMicals-under-
tsca/tsca-section-8al-reporting-and-recordkeeping.

• Instructions on CDX registration: CDX Online Registration User Guide

• Section 8(a)(1) reporting tool getting started user guide

• Chemical Data Reporting (CDR) fact sheet on Reporting After Changes to CoMpany
Ownership or Legal Identity

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Appendix A

Glossary of Terms

Appendix A. Glossary of Terms

The definitions and descriptions of terms used in section 8(a)(1) reporting provided
below are taken from 40 CFR Part 704 unless otherwise noted.

Act means the Toxic Substances Control Act, as amended, 15 U.S.C. 2601 et seq.

Administrator means the Administrator of the Environmental Protection Agency. (See
TSCA 3(1))

Article means a manufactured item (1) which is formed to a specific shape or design
during manufacture, (2) which has end-use function(s) dependent in whole or in part upon its
shape or design during end use, and (3) which has either no change of chemical composition
during its end use or only those changes of composition which have no commercial purpose
separate from that of the article, and that result from a chemical reaction that occurs upon end
use of other chemical substances, mixtures, or articles; except that fluids and particles are not
considered articles regardless of shape or design. (40 CFR 704.3)

Asbestos is a collective term meaning any of the substances listed in Table 1 of this
paragraph. (40 CFR 704.180)

Table 1 in § 704.180(a) - CASRN of Asbestos Types

CASRN

Asbestos Type

1332-21-4

Asbestos

132207-32-0

Chrysotile

12001-28-4

Crocidolite

2172-73-5

Amosite

77536-67-5

Anthophyllite

77536-68-6

Tremolite

77536-66-4

Actinolite

NA

Libby Amphibole (mainly consisting of tremolite [CASRN 77536-68-6], winchite
[CASRN 12425-92-2], and richterite [CASRN 17068-76-7])

Bulk asbestos means any quantity of asbestos fiber of any type or grade, or combination
of types or grades, that is mined or milled with the purpose of obtaining asbestos. This term does
not include asbestos that is produced or processed as a contaminant or an impurity. (40 CFR
704.180)

Bulk materials containing asbestos means bulk materials in which asbestos is being
mined or milled as an impurity, such as in vermiculite or talc. (40 CFR 704.180)

Byproduct means a chemical substance produced without separate commercial intent
during the manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s). (40 CFR 704.3)

Central Data Exchange (CDX) means EPA's centralized electronic document receiving
system, or its successors, including associated instructions for registering to submit electronic
documents.

A-l

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Appendix A

Glossary of Terms

Chemical Information Submission System or CISS means EPA's electronic, web-
based reporting tool for the completion and submission of CDR data, reports, and other
information, or its successors. (40 CFR 704.180)

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 element or uncombined radical. "Chemical
substance" does not include:

(1)	Any mixture;

(2)	Any pesticide (as defined in the Federal Insecticide, Fungicide, and Rodenticide Act)
when manufactured, processed, or distributed in commerce for use as a pesticide;

(3)	Tobacco or any tobacco product;

(4)	Any source material, special nuclear material, or byproduct material (as such terms
are defined in the Atomic Energy Act of 1954 [42 U.S.C. 2011 et seq.] and the regulations issued
under such Act);

(5)	Any article the sale of which is the subject to the tax imposed by section 4181 of the
Internal Revenue Code of 1986 [26 U.S.C. 4181] (determined without regard to any exemptions
from such tax provided by section 4182 or 4221 or any other provision of such Code) and any
component of such an article (limited to shot shells, cartridges, and components of shot shells
and cartridges); and

(6)	Any food, food additive, drug, cosmetic, or device (as such terms are defined in
section 201 of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321]) when manufactured,
processed, or distributed in commerce for use as a food, food additive, drug, cosmetic, or device.
(See TSCA 3(2))

Commerce means trade, traffic, transportation, or other commerce: (A) between a place
in a State and any place outside of such State, or (B) which affects trade, traffic, transportation,
or commerce described in clause (A). (TSCA 3(3))

Commercial use means the use of a chemical substance or a mixture containing a
chemical substance (including as part of an article) in a commercial enterprise providing saleable
goods or services. (40 CFR 711.3)

Component means a chemical substance which is intentionally present with another
chemical substance. (40 CFR 704.180)

Consumer use means the use of a chemical substance or a mixture containing a chemical
substance (including as part of an article) when sold to or made available to consumers for their
use. (40 CFR 711.3)

Customs territory of the United States, as referenced in TSCA section 3 and defined in
general note 2 of the Harmonized Tariff Schedule of the United States, includes only the States,
the District of Columbia, and Puerto Rico.

Distribute in commerce and distribution in commerce, when used to describe an
action taken with respect to a chemical substance or mixture or article containing a substance or
mixture mean to sell, or the sale of, the substance, mixture, or article in commerce; to introduce
or deliver for introduction into commerce, or the introduction or delivery for introduction into
commerce of, the substance, mixture, or article; or to hold, or the holding of, the substance,
mixture, or article after its introduction into commerce. (TSCA 3(5))

A-2

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Appendix A

Glossary of Terms

EPA means the United States Environmental Protection Agency. (40 CFR 704.3)

Form A means an abbreviated form for persons that know or can reasonably ascertain
that they manufactured (including imported) or processed asbestos, including as an impurity,
during the reporting period described in paragraph (f) but do not know and cannot reasonably
ascertain the amount of asbestos manufactured (including imported) or processed by them. (40
CFR 704.180)

Form B means the standard form to be used by persons that know or can reasonably
ascertain that they manufactured (including imported) or processed asbestos, including as an
impurity, during the reporting period described in paragraph (f) and know or can reasonably
ascertain how much asbestos they manufactured (including imported) or produced. (40 CFR
704.180)

Highest-level Parent Company means the highest-level company of the site's ownership
hierarchy as of the start of the submission period during which data are being reported according to
the following instructions. The highest-level U.S. parent company is located within the United
States while the highest-level foreign parent company is located outside the United States. The
following rules govern how to identify the highest-level U.S. parent company and highest-level
foreign parent company (if applicable):

(1) If the site is entirely owned by a single U.S. company that is not owned by another
company, that single company is the U.S. parent company.

(2) If the site is entirely owned by a single U.S. company that is, itself, owned by another
U.S.-based company (e.g., it is a division or subsidiary of a higher-level company), the highest-
level domestic company in the ownership hierarchy is the United States parent company. If there is
a higher-level parent company that is outside of the United States, the highest-level foreign
company in the ownership hierarchy is the foreign parent company.

(3) If the site is owned by more than one company (e.g., company A owns 40 percent,
company B owns 35 percent, and company C owns 25 percent), the company with the largest
ownership interest in the site is the parent company. If a higher-level company in the ownership
hierarchy owns more than one ownership company, then determine the entity with the largest
ownership by considering the lower-level ownerships in combination (e.g., corporation x owns
companies B and C, for a total ownership of 60 percent for the site).

(i) If the parent company is a U.S. company owned by another U.S. company, then the
highest-level domestic company in the ownership hierarchy is the U.S. parent company. If the U.S.
parent company has a higher-level foreign company in the ownership hierarchy, then the highest-
level foreign company in the ownership hierarchy is the foreign parent company.

(ii) If the parent company is a foreign company, then the site is its own U.S. parent
company and the foreign parent company is the highest-level foreign company in the ownership
hierarchy.

(4) If the site is owned by a 50:50 joint venture or a cooperative, the joint venture or
cooperative is its own parent company. If the site is owned by a U.S. joint venture or cooperative,
the highest level of the joint venture or cooperative is the U.S. parent company. If the site is owned
by a joint venture or cooperative outside the United States, the highest level of the joint venture or
cooperative outside the United States is the foreign parent company.

(5) If the site is entirely owned by a foreign company (i.e., without a U.S.-based subsidiary
within the site's ownership hierarchy), the highest-level foreign parent company is the facility's
foreign parent company.

A-3

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Appendix A

Glossary of Terms

(6)	If the site is federally owned, the highest-level federal agency or department is the U.S.
parent company.

(7)	If the site is owned by a non-federal public entity, that entity (such as a municipality,
State, or tribe) is the U.S. parent company. (40 CFR 711.3)

Importer means

(1) any person who imports any chemical substance or any chemical substance as part of
a mixture or article into the customs territory of the United States, and includes:

(1)	the person primarily liable for the payment of any duties on the merchandise, or

(ii) an authorized agent acting on his/her behalf.

(2)	Importer also includes, as appropriate:

(i)	The consignee.

(ii)	The importer of record.

(iii)	The actual owner if an actual owner's declaration and superseding bond have been
filed in accordance with 19 CFR 141.20.

(iv)	The transferee, if the right to draw merchandise in a bonded warehouse has been
transferred in accordance with subpart C of 19 CFR 144.

(3)	For the purposes of this definition, the customs territory of the United States consists
of the 50 States, Puerto Rico, and the District of Columbia. (40 CFR 704.3)

Impurity means a chemical substance which is unintentionally present with another
chemical substance. (40 CFR 704.3)

Intermediate means any chemical substance that is consumed, in whole or in part, in
chemical reactions used for the intentional manufacture of other chemical substances or
mixtures, or that is intentionally present for the purpose of altering the rates of such chemical
reactions. (40 CFR 704.3)

Known to or reasonably ascertainable by means all information in a person's
possession or control, plus all information that a reasonable person similarly situated might be
expected to possess, control, or know. (40 CFR 704.3)

Manufacture means to manufacture, produce, or import, for commercial purposes. (40
CFR 704.3)

Manufacturer means a person who manufactures a chemical substance.

Manufacture for commercial purposes means: (1) to import, produce, or manufacture
with the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such "manufacture" of any amount of a chemical
substance or mixture:

(i)	For commercial distribution, including for test marketing.

(ii)	For use by the manufacturer, including use for product research and development, or
as an intermediate.

(2) Manufacture for commercial purposes also applies to substances that are produced
coincidentally during the manufacture, processing, use, or disposal of another substance or
mixture, including both byproducts that are separated from that other substance or mixture and
impurities that remain in that substance or mixture. Such byproducts and impurities may, or may

A-4

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Appendix A

Glossary of Terms

not, in themselves have commercial value. They are nonetheless produced for the purpose of
obtaining a commercial advantage since they are part of the manufacture of a chemical product
for a commercial purpose. (40 CFR 704.3)

Master Inventory File means EPA's comprehensive list of chemical substances which
constitute the Chemical Substances Inventory compiled under section 8(b) of the Act. It includes
substances reported under 40 CFR Part 710 and substances reported under Part 720 for which a
Notice of Commencement of Manufacture or Import has been received under § 720.120.

Mixture means any combination of two or more chemical substances if the combination
does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except
that such term does include any combination which occurs, in whole or in part, as a result of a
chemical reaction if none of the chemical substances comprising the combination is a new
chemical substance and if the combination could have been manufactured for commercial
purposes without a chemical reaction at the time the chemical substances comprising the
combination were combined. (15. U.S.C. 2602(10))

Naturally occurring substance is any chemical substance which is naturally occurring
and: (1) which is (i) unprocessed or (ii) processed only by manual, mechanical, or gravitational
means, by dissolution in water, by flotation, or by heating solely to remove water; or (2) which is
extracted from air by any means. (40 CFR 710.4(b))

Non-isolated intermediate means any intermediate that is not intentionally removed
from the equipment in which it is manufactured, including the reaction vessel in which it is
manufactured, equipment which is ancillary to the reaction vessel, and any equipment through
which the substance passes during a continuous flow process, but not including tanks or other
vessels in which the substance is stored after its manufacture. (40 CFR 704.3)

Parent Company is a company that owns or controls another company. (40 CFR 704.3)

Person means any individual, firm, company, corporation, joint venture, partnership, sole
proprietorship, association, or any other business entity; any State or political subdivision
thereof, or any municipality; any interstate body; and any department, agency, or instrumentality
of the Federal government. (40 CFR 704.3)

Primary processor means a person that starts with bulk asbestos or bulk materials
containing asbestos and makes a mixture that contains asbestos as a component. (40 CFR
704.180)

Process means to process for commercial purposes. (40 CFR 704.3)

Process for commercial purposes means the preparation of a chemical substance or
mixture after its manufacture for distribution in commerce with the purpose of obtaining an
immediate or eventual commercial advantage for the processor. Processing of any amount of a
chemical substance or mixture is included in this definition. If a chemical substance or mixture
containing impurities is processed for commercial purposes, then the impurities also are
processed for commercial purposes. (40 CFR 704.3)

Processor means any person who processes a chemical substance or mixture. (40 CFR

704.3)

Reasonably likely to be exposed means an exposure to a chemical substance which,
under foreseeable conditions of manufacture (including import), processing, distribution in
commerce, or use of the chemical substance, is more likely to occur than not to occur. Such
exposures would normally include, but would not be limited to, activities such as charging
reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations, materials

A-5

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Appendix A

Glossary of Terms

handling and transfers, and analytical operations. Covered exposures include exposures through
any route of entry (inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental
or theoretical exposures.

Repackaging means the physical transfer of a chemical substance or mixture, as is, from
one container to another container or containers in preparation for distribution of the chemical
substance or mixture in commerce.

Reportable chemical substance means a chemical substance described in § 711.5.

Secondary processor means a person that further processes asbestos, after primary
processing of asbestos is completed, as a component of a mixture, or an article containing
asbestos. (40 CFR 704.180)

Site means a contiguous property unit. Property divided only by a public right-of-way
shall be considered one site. More than one plant may be located on a single site.

(a) For chemical substances manufactured under contract, i.e., by a co-manufacturer, the
site is the location where the chemical substance is physically manufactured.

(b) The site for an importer who imports a chemical substance described in § 711.5 is the
U.S. site of the operating unit within the person's organization that is directly responsible for
importing the substance. The import site, in some instances, may be the organization's
headquarters in the United States. If there is no such operating unit or headquarters in the United
States, the site address for the importer is the United States address of an agent acting on behalf
of the importer who is authorized to accept service of process for the importer.

(c) For portable manufacturing units sent out to different locations from a single
distribution center, the distribution center shall be considered the site.

Site-limited means a chemical substance is manufactured and processed only within a
site and is not distributed for commercial purposes as a substance or as part of a mixture or
article outside the site. Imported substances are never site-limited. Although a site-limited
chemical substance is not distributed for commercial purposes outside the site at which it is
manufactured and processed, the substance is considered to have been manufactured and
processed for commercial purposes.

Small government means the government of a city, county, town, township, village,
school district, or special district with a population of less than 50,000. (40 CFR 704.3)

Small manufacturer means a manufacturer (including importer) that meets either of the
following standards:

(1) First standard. A manufacturer (including importer) of a substance is small if its total
annual sales, when combined with those of its parent company (if any), are less than $120
million. However, if the annual production or importation volume of a particular substance at
any individual site owned or controlled by the manufacturer or importer is greater than 45,400
kilograms (100,000 lbs), the manufacturer (including importer) will not qualify as small for
purposes of reporting on the production or importation of that substance at that site, unless the
manufacturer (including importer) qualifies as small under standard (2) of this definition.

(2) Second standard. A manufacturer (including importer) of a substance is small if its
total annual sales, when combined with those of its parent company (if any), are less than $12
million, regardless of the quantity of substances produced or imported by that manufacturer
(including importer). (40 CFR 704.3)

A-6

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Appendix A

Glossary of Terms

Small processor means any processor whose total annual sales, when combined with
those of its parent company (if any), are less than $12 million. (40 CFR 704.180)

Small quantities solely for research and development (or "small quantities solely for
purposes of scientific experimentation or analysis or chemical research on, or analysis of, such
substance or another substance, including such research or analysis for the development of a
product") means quantities of a chemical substance manufactured, imported, or processed or
proposed to be manufactured, imported, or processed solely for research and development that
are no greater than reasonably necessary for such purposes. (40 CFR 704.3)

State means any State of the United States, the District of Columbia, the Commonwealth
of Puerto Rico, the Virgin Islands, Guam, the Canal Zone, American Samoa, the Northern
Mariana Islands, or any other territory or possession of the United States. (TSCA 3(16))

Submission period means the period in which data are submitted to EPA.

Test marketing means the distribution in commerce of no more than a predetermined
amount of chemical substance, mixture, or article containing that chemical substance or mixture,
or a mixture containing that substance, by a manufacturer or processor, to no more than a defined
number of potential customers to explore market capability in a competitive situation during a
predetermined testing period prior to the broader distribution of that chemical substance,
mixture, or article in commerce. (40 CFR 704.3)

United States, when used in the geographic sense, means all of the States. (TSCA 3(17))

Use means any utilization of a chemical substance or mixture that is not otherwise
covered by the terms manufacture or process. Relabeling or redistributing a container holding a
chemical substance or mixture where no repackaging of the chemical substance or mixture
occurs does not constitute use or processing of the chemical substance or mixture.

A-7

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type

Appendix B. Descriptions of Codes for
Reporting Number of Employees, Asbestos Type,
Disposition, Product Type

The following descriptions were developed by EPA to assist persons submitting
information in response to 40 CFR 704.180 and used for section 8(a)(1) reporting.

Table B-5-1 provides the codes for each range of employment numbers. These codes are
used to report in Parts I and III.

Table B-l. Codes for Number of Employees.

Code

Range

W1

Fewer than 10 employees

W2

At least 10 but fewer than 25 employees

W3

At least 25 but fewer than 50 employees

W4

At least 50 but fewer than 100 employees

W5

At least 100 but fewer than 500 employees

W6

At least 500 but fewer than 1,000 employees

W7

At least 1,000 but fewer than 10,000 employees

W8

At least 10,000 employees

Table B-5-2 shows the CAS Registry Number for each type of asbestos. These are used
for reporting requirements in Part II.

Table B-2. Asbestos Types

CASRN

Asbestos Type

1332-21-4

Asbestos

132207-32-0

Chrysotile

12001-28-4

Crocidolite

2172-73-5

Amosite

77536-67-5

Anthophyllite

77536-68-6

Tremolite

77536-66-4

Actinolite

NA

Libby Amphibole (mainly consisting of tremolite [CASRN 77536-68-6], winchite
[CASRN 12425-92-2], and richterite [CASRN 17068-76-7])

B-l

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type

Table B-5-3 provides the codes for each description of asbestos disposition. These codes
are used to report in Part II.

Table B-3. Disposition Codes

Code

Disposition Description

1

Used on-site, including further processed.

2

Stored on-site

3

Sent to another U.S. site (including intra-company transfer) for use or processing.

4

Stored at another U.S. site (including intra-company transfer)

5

Exported outside of the U.S. without further processing

6

Disposed of within the U.S. (explain)

7

Other (explain)

Table B-5-4 contains the codes for a range of end products which may contain asbestos.
Reporters must provide these codes in Part II.

Table B-4. End Product Types

Code

Name

End Product Unit of
Measure

Papers, Felts, or Related Products

01

Commercial paper

Short Tons

02

Rollerboard

Short Tons

03

Millboard

Short Tons

04

Pipeline wrap

Short Tons

05

Beater-add gasketing paper

Short Tons

06

High-grade electrical paper

Short Tons

07

Unsaturated roofing felt

Short Tons

08

Saturated roofing felt

Short Tons

09

Flooring felt

Short Tons

10

Corrugated paper

Short Tons

11

Specialty paper (specify generic name)

Short Tons

12

Other (specify generic name)

(Specify)

Floor Coverings

13

Vinyl asbestos floor tile

Square yards

14

Asbestos felt backed vinyl flooring

Square yards

15

Other (specify generic name)

(Specify)

Asbestos Cement Products

B-2

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type

Code

Name

End Product Unit of
Measure

16

A/C pipe and fittings

Short Tons

17

A/C sheet, flat

100 sq. ft.

18

A/C sheet corrugated

100 sq. ft.

19

A/C shingle

Squares

20

Other (specify generic name)

(Specify)

Transportation Friction Materials (including aircrafts, marine vessels, railroad engine and railcars, and
other vehicles)

21

Drum brake lining (light-medium vehicle)

Pieces

22

Disc brake pads (light-medium vehicle)

Pieces

23

Disc brake pads (heavy vehicle)

Pieces

24

Brake block (heavy equipment)

Pieces

25

Clutch facings (all)

Pieces

26

Automatic transmission friction components

Pieces

27

Friction materials (industrial and commercial)

Pieces

28

Custom automotive body filler

Pieces

29

Transmissions

Pieces

30

Mufflers

Pieces

31

Radiator top insulation

Pieces

32

Radiator sealant

Pieces

33

Other (specify generic name)

(Specify)

Appliances

34

Appliance Industrial and consumer (specify generic name)

Pieces

35

Other (specify generic name)

(Specify)

Construction Products

36

Boiler and furnace baffles

Pieces

37

Decorated building panels

Pieces

38

Asbestos cement sheet

Pieces

39

Flexible Air Conductor

Pieces

40

Hoods and Vents

Pieces

41

Portable construction building

Pieces

42

Roofing, saturated

Pieces

43

Roof shingles

Pieces

44

Wallboard

Pieces

45

Wall/roofing panels

Pieces

B-3

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type

Code

Name

End Product Unit of
Measure

46

Other (specify generic name)

(Specify)

Electrical Products and Components

47

Cable insulation

Pieces

48

Electronic motor components

Pieces

49

Electrical resistance supports

Pieces

50

Electrical switchboard

Pieces

51

Electrical switch supports

Pieces

52

Electrical wire insulation

Pieces

53

Motor armature

Pieces

54

Other (specify generic name)

(Specify)

Fire and Heat Shielding Equipment and Components

55

Arc deflectors

Pieces

56

Fire doors

Pieces

57

Fireproof absorbent paper

Short tons

58

Heat shields

Pieces

59

Molten metal handling equipment

Pieces

60

Oven and stove insulation

Short tons

61

Pipe wrap

Pieces

62

Stove lining, wood and coal

Pieces

63

Stove pipe rings

Pieces

64

Sleeves

Pieces

65

Thermal Insulation

Short tons

66

Other (specify generic name)

(Specify)

Textiles and Clothing

67

Cloth

Pounds

68

Thread, yarn, lap, roving, cord, rope, or wick

Pounds

69

Aprons

Pieces

70

Boots

Pieces

71

Gloves and mittens

Pieces

72

Hats and helmets

Pieces

73

Overgaiters

Pieces

74

Suits

Pieces

75

Aluminized cloth

Short Tons

76

Rope or braiding

Short Tons

B-4

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type

Code

Name

End Product Unit of
Measure

77

Yarn, lap or roving

Short Tons

78

Wicks

Short Tons

79

Bags

Pieces

80

Belting

Short Tons

81

Blankets

Pieces

82

Carpet padding

Short Tons

83

Commercial/industrial dryer felts

Short Tons

84

Draperies

Pieces

85

Drip cloths

Pieces

86

Fire hoses

Pieces

87

Ironing board pads and insulation

Pieces

88

Mantles, lamp or catalytic heater

Pieces

89

Packing and packaging components

Pieces

90

Piano and organ felts

Pieces

91

Rugs

Pieces

92

Tape

Pieces

93

Theater curtains

Pieces

94

Umbrellas

Pieces

95

Other (specify generic name)

(Specify)

Gaskets

96

Sheet gasketing, rubber encapsulated beater addition

Pieces

97

Sheet gasketing, rubber encapsulated compressed

Pieces

98

Compressed sheet gasketing (other)

Pieces

99

Metal reinforced gaskets

Pieces

100

Automotive gaskets

Pieces

101

Other (specify generic name)

(Specify)

Marine Equipment and Supplies

102

Caulks, marine

Pounds

103

Liners, pond or canal

Pieces

104

Marine bulkheads

Pieces

105

Other (specify generic name)

(Specify)

Paints, Coatings, Sealants and Compounds

106

Asphaltic compounds

Pounds

107

Automotive/truck body coatings

Gallons

B-5

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type

Code

Name

End Product Unit of
Measure

108

Buffing and polishing compounds

Pounds

109

Caulking and patching compounds

Pounds

110

Drilling fluid

Gallons

111

Flashing compounds

Pounds

112

Furnace cement

Pounds

113

Glazing compounds

Pounds

114

Plaster and stucco

Pounds

115

Pump valve, flange and tank sealing components

Pieces

116

Roof coatings

Gallons

117

Textured paints

Gallons

118

Tile cement

Pounds

119

Other (specify generic name)

(Specify)

Other Products

120

Sheet gasketing (other than beater-add)

Square Yards

122

Packing

Pounds

123

Paints and surface coatings

Gallons

124

Adhesives and sealants

Gallons

125

Asbestos-reinforced plastics

Pounds

126

Insulation materials not elsewhere classified (specify generic name)

(Specify)

127

Mixed or repackaged asbestos

Short Tons

128

Aerial distress flares

Pieces

129

Acoustical product

Pieces

130

Ammunition wadding

Pieces

131

Ash trays

Pieces

132

Baking sheets

Pieces

133

Blackboards

Pieces

134

Candlesticks

Pieces

135

Chemical tanks and vessels

Pieces

136

Filters

Pieces

137

Grommets

Pieces

138

Gun grips

Pieces

139

Jewelry making equipment

Pieces

140

Kilns

Pieces

141

Lamp sockets

Pieces

142

Light bulbs (all types)

Pieces

B-6

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Appendix B	Descriptions of Codes for Reporting Number of Employees, Asbestos Type,

Disposition, Product Type





I'.nd Product I nil of
Measure

143

Linings for vaults, safes, humidifies and filing cabinets

Pieces

144

Phonograph records

Pieces

145

Pottery clay

Pounds

146

Welding rod coatings

Pieces

147

Other (specify generic name)

(Specify)

B-7

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