	U.S. ENVIRONMENTAL PROTECTION AGENCY 

	INSTRUCTIONS FOR THE SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP)

	PROGRAM INFORMATION NOTICE AND TSCA/SNAP ADDENDUM

	

EPA-1265-07 June 30, 2014	Office of Atmospheric Programs		Washington, DC
 20460

The U.S. Environmental Protection Agency (EPA) has prepared this
instruction manual to help you in submitting information on alternatives
to ozone-depleting chemicals to the Significant New Alternatives Policy
(SNAP) program.  This manual provides instructions on submitting the
SNAP Information Notice and TSCA/SNAP Addendum forms, asserting
confidentiality claims, and submitting test data and optional
information.  However, please note that in the event of any
discrepancies between this document and the Code of Federal Regulations
(CFR), the CFR requirements are legally binding and take precedence.				
			

TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc291754993"  1. INTRODUCTION
TO THE SNAP PROGRAM	  PAGEREF _Toc291754993 \h  2  

  HYPERLINK \l "_Toc291754994"  A.	What is the purpose of the SNAP
Program?	  PAGEREF _Toc291754994 \h  2  

  HYPERLINK \l "_Toc291754995"  B.	Do I need to submit information to
the SNAP Program?	  PAGEREF _Toc291754995 \h  2  

  HYPERLINK \l "_Toc291754996"  C.	When can I qualify for an exemption
from submitting information to SNAP?	  PAGEREF _Toc291754996 \h  3  

  HYPERLINK \l "_Toc291754997"  D.	Who must submit to the SNAP Program?	
 PAGEREF _Toc291754997 \h  4  

  HYPERLINK \l "_Toc291754998"  2. INTRODUCTION TO THE SNAP SUBMISSION
FORMS	  PAGEREF _Toc291754998 \h  5  

  HYPERLINK \l "_Toc291754999"  A.	Which form do I submit—the SNAP
Information Notice form or the TSCA/SNAP Addendum form?	  PAGEREF
_Toc291754999 \h  5  

  HYPERLINK \l "_Toc291755000"  B.	When do I need to submit to the SNAP
Program?	  PAGEREF _Toc291755000 \h  5  

  HYPERLINK \l "_Toc291755001"  C.	Is there a fee for submitting to the
SNAP Program?	  PAGEREF _Toc291755001 \h  5  

  HYPERLINK \l "_Toc291755002"  D.	How should I fill out the SNAP
Information Notice form?	  PAGEREF _Toc291755002 \h  5  

  HYPERLINK \l "_Toc291755003"  3. CONFIDENTIALITY CLAIMS	  PAGEREF
_Toc291755003 \h  6  

  HYPERLINK \l "_Toc291755004"  A.	Can EPA keep confidential the
information in my SNAP submission?	  PAGEREF _Toc291755004 \h  6  

  HYPERLINK \l "_Toc291755005"  B.	How do I make a claim of Confidential
Business Information?	  PAGEREF _Toc291755005 \h  6  

  HYPERLINK \l "_Toc291755006"  C.	What do I need to provide to EPA to
substantiate my CBI claim?	  PAGEREF _Toc291755006 \h  7  

  HYPERLINK \l "_Toc291755007"  D.	What kinds of data am I not allowed
to claim as confidential?	  PAGEREF _Toc291755007 \h  7  

  HYPERLINK \l "_Toc291755008"  E.	Does anyone besides EPA staff see my
SNAP submission?	  PAGEREF _Toc291755008 \h  8  

  HYPERLINK \l "_Toc291755009"  F.	Does EPA ever reconsider which data
are confidential?	  PAGEREF _Toc291755009 \h  8  

  HYPERLINK \l "_Toc291755010"  4. BEGINNING THE SNAP INFORMATION NOTICE
  PAGEREF _Toc291755010 \h  8  

  HYPERLINK \l "_Toc291755011"  A.	Should I mark my form as a
manufacturer’s submission or as a petition?	  PAGEREF _Toc291755011 \h
 8  

  HYPERLINK \l "_Toc291755012"  B.	What are the types of petitions
allowed under the SNAP Program?	  PAGEREF _Toc291755012 \h  8  

  HYPERLINK \l "_Toc291755013"  C.	What are reasons for submitting a
petition?	  PAGEREF _Toc291755013 \h  9  

  HYPERLINK \l "_Toc291755014"  D.	What do I need to include in my
petition?	  PAGEREF _Toc291755014 \h  9  

  HYPERLINK \l "_Toc291755015"  E.	What does EPA consider when reviewing
my petition?	  PAGEREF _Toc291755015 \h  9  

  HYPERLINK \l "_Toc291755016"  F.	What kinds of test data and effects
data do I need to provide to EPA?	  PAGEREF _Toc291755016 \h  10  

  HYPERLINK \l "_Toc291755017"  5. STEP-BY-STEP INSTRUCTIONS FOR
COMPLETING THE SNAP INFORMATION NOTICE	  PAGEREF _Toc291755017 \h  10  

  HYPERLINK \l "_Toc291755018"  Part I – INTRODUCTION AND GENERAL
INFORMATION	  PAGEREF _Toc291755018 \h  10  

  HYPERLINK \l "_Toc291755019"  Part I, Initial Information (Page 1 and
Page 2)	  PAGEREF _Toc291755019 \h  10  

  HYPERLINK \l "_Toc291755020"  Part I, Section A - Submitter
Identification  (Page 3)	  PAGEREF _Toc291755020 \h  10  

  HYPERLINK \l "_Toc291755021"  Part I, Section B - Alternative
Identification  (Page 4)	  PAGEREF _Toc291755021 \h  11  

  HYPERLINK \l "_Toc291755022"  Part II - ALTERNATIVE-SPECIFIC
INFORMATION	  PAGEREF _Toc291755022 \h  13  

  HYPERLINK \l "_Toc291755023"  Part II, Section A - Physical and
Chemical Properties  (Page 6)	  PAGEREF _Toc291755023 \h  13  

  HYPERLINK \l "_Toc291755024"  Part II, Section B - Atmospheric
Information  (Page 7)	  PAGEREF _Toc291755024 \h  14  

  HYPERLINK \l "_Toc291755025"  Part II, Section C - Other Statutes 
(Page 8)	  PAGEREF _Toc291755025 \h  15  

  HYPERLINK \l "_Toc291755026"  Part II, Section D - Cost and
Availability of the Alternative  (Page 9)	  PAGEREF _Toc291755026 \h  16
 

  HYPERLINK \l "_Toc291755027"  PART III - RELEASE AND EXPOSURE DATA	 
PAGEREF _Toc291755027 \h  16  

  HYPERLINK \l "_Toc291755028"  Part III, Section A - Toxicity and
Hazard Information  (Page 10)	  PAGEREF _Toc291755028 \h  17  

  HYPERLINK \l "_Toc291755029"  Part III, Section B - Environmental
Release and Disposal at Manufacture (Page 10)	  PAGEREF _Toc291755029 \h
 17  

  HYPERLINK \l "_Toc291755030"  Part III, Section C - Occupational
Exposure at Manufacture  (Page 11)	  PAGEREF _Toc291755030 \h  18  

  HYPERLINK \l "_Toc291755031"  Part III, Section D - Environmental
Release and Disposal in End-use  (Page 11)	  PAGEREF _Toc291755031 \h 
18  

  HYPERLINK \l "_Toc291755032"  Part III, Section E - Occupational
Exposure at End-use  (Page 12)	  PAGEREF _Toc291755032 \h  18  

  HYPERLINK \l "_Toc291755033"  Part III, Section F - Consumer Exposure 
(Page 12)	  PAGEREF _Toc291755033 \h  18  

  HYPERLINK \l "_Toc291755034"  Part III, Section G - General Population
Exposure - OPTIONAL (Page 13)	  PAGEREF _Toc291755034 \h  19  

  HYPERLINK \l "_Toc291755035"  Part IV - LIST OF ATTACHMENTS (Page 14)	
 PAGEREF _Toc291755035 \h  19  

  HYPERLINK \l "_Toc291755036"  Part V - CERTIFICATION (Page 15)	 
PAGEREF _Toc291755036 \h  19  

  HYPERLINK \l "_Toc291755037"  6. JOINT REVIEW WITH OTHER EPA OFFICES	 
PAGEREF _Toc291755037 \h  19  

  HYPERLINK \l "_Toc291755038"  A.	What is the relationship between the
SNAP Program and the New Chemicals (Pre-Manufacture Notice) Program?	 
PAGEREF _Toc291755038 \h  19  

  HYPERLINK \l "_Toc291755039"  B.	What forms should I submit to the
SNAP program and to the New Chemicals program?	  PAGEREF _Toc291755039
\h  19  

  HYPERLINK \l "_Toc291755040"  C.	When should I submit to the SNAP
program if I am also submitting a PMN?	  PAGEREF _Toc291755040 \h  20  

  HYPERLINK \l "_Toc291755041"  D.	Do both the SNAP program and the New
Chemicals program have a 90 day review?	  PAGEREF _Toc291755041 \h  20  

  HYPERLINK \l "_Toc291755042"  E.	How does EPA treat confidentiality
during co-review of a chemical under the SNAP program and under the New
Chemicals program?	  PAGEREF _Toc291755042 \h  20  

  HYPERLINK \l "_Toc291755043"  F.	What is the relationship between the
SNAP Program and review of antimicrobials under FIFRA?	  PAGEREF
_Toc291755043 \h  20  

  HYPERLINK \l "_Toc291755044"  G.	What form do I submit to SNAP for a
sterilant?	  PAGEREF _Toc291755044 \h  20  

  HYPERLINK \l "_Toc291755045"  7.  CONSULTATION WITH EPA CONCERNING THE
SNAP INFORMATION NOTICE	  PAGEREF _Toc291755045 \h  21  

  HYPERLINK \l "_Toc291755046"  A.	Where do I get more information about
submitting to the SNAP program?	  PAGEREF _Toc291755046 \h  21  

  HYPERLINK \l "_Toc291755047"  B.	How will EPA interact with me after I
submit to the SNAP program?	  PAGEREF _Toc291755047 \h  21  

  HYPERLINK \l "_Toc291755048"  APPENDIX A: LIST OF END-USES WITHIN
SECTORS INCLUDED IN THE SNAP PROGRAM	  PAGEREF _Toc291755048 \h  22  

  HYPERLINK \l "_Toc291755049"  APPENDIX B: SECTOR-SPECIFIC DATA
REQUIREMENTS	  PAGEREF _Toc291755049 \h  24  

 

1. INTRODUCTION TO THE SNAP PROGRAM

A.	 What is the purpose of the SNAP Program?

The Significant New Alternatives Policy (SNAP) program is designed to:

(	Identify and evaluate substitutes for end-uses that have historically
used ozone-depleting substances (ODSs)

(	Look at overall risk to human health and the environment of both
existing and new substitutes

(	Publish lists of acceptable and unacceptable substitutes by end-use

(	Promote the use of acceptable substitutes for ozone-depleting
substances

(	Provide the public with information about the environmental and health
impacts of substitutes for ozone-depleting substances

To arrive at determinations on the acceptability of substitutes, the
Agency performs a cross-media analysis of risks to human health and the
environment from the use of various substitutes in different industrial
and consumer uses that have historically used ODS.

For additional information on the SNAP program and a copy of the
existing listing decisions, please see the SNAP Program web site at
http://www.epa.gov/ozone/snap/index.html or call the Stratospheric Ozone
Hotline at (800) 296-1996.

For the purposes of this document, EPA is using the word "substitute" as
a synonym for "alternative". 

B.	Do I need to submit information to the SNAP Program? tc \l2 "A.
General Instructions 

You may need to submit information to EPA’s Significant New
Alternatives Policy (SNAP) program if you are introducing a substance,
process, or product for sale, import, export or use in one of the
following industrial sectors:

(	refrigeration and air-conditioning

(	foam blowing

(	solvent cleaning

(	fire suppression and explosion protection

(	tobacco expansion

(	adhesives, coatings and inks

(	aerosols

(	sterilants

In certain cases, you may be exempt from the requirement to submit
information under the SNAP program.

C.	When can I qualify for an exemption from submitting information to
SNAP?

Below are a number of exemptions from the general requirement to submit
information to the SNAP Program.  (40 CFR 82.176(b))

1. Substitutes Already Listed Under SNAP in the Same End Use

You do not need to submit to SNAP if someone else has already submitted
the same substance, process, or product for the same end use and it has
already been listed as acceptable (see Appendix A for the list of end
uses by industrial sector).  To find out if someone else has already
submitted, first check the SNAP listings  HYPERLINK
"http://www.epa.gov/ozone/snap/lists/lists/index.html" online  or in the
 HYPERLINK "http://www.regulations.gov/" \l
"!docketDetail;D=EPA-HQ-OAR-2003-0118" docket . 

  

2. Small Sectors

The major industrial use sectors included under SNAP are those that
historically used ODS:  refrigeration and air-conditioning; foam
blowing; fire suppression and explosion protection; solvent cleaning;
adhesives, coatings, and inks; aerosols; sterilization; and tobacco
expansion.  If your product is not or will not be used under one of
these sectors, you do not need to submit under SNAP.  

3. Small Volume Use within SNAP Sectors

Producers of substitutes produced in annual quantities of 10,000 lbs per
year or less for a sector do not need to notify EPA of their activities
under SNAP.  Note that this applies to total use within the industrial
sector and not just to the individual producer.  EPA encourages
producers to maintain documentation describing the basis for their view
that any substitute being used meets this small use definition.  This
documentation could be necessary in the event the Agency receives a
petition to evaluate such substitutes.  Documentation should take the
form of production volume and sales information.

4. Formulation Changes

In general, formulation changes that accommodate introduction of a
substitute do not require submitting to SNAP.  Such changes may be
necessary, for example, when a new foam blowing agent necessitates the
replacement of the catalyst formerly used with the ozone-depleting
blowing agent.  However, if a SNAP submitter has reason to believe such
changes will significantly influence the environmental and human health
risk characteristics associated with the use of any substitute, you
should share this concern with the Agency.  EPA may also review any
changes in formulation in connection with review of substitute compounds
where the Agency has reason to believe the formulation change may affect
the risk profile of a substitute. Further, formulation changes in a
substitute do require submission to SNAP (e.g., a refrigerant blend with
a new formulation).

5. Test Marketing

You do not need to send in a SNAP Information Notice form or TSCA/SNAP
Addendum form if use of alternatives is for the sole purpose of test
marketing. Once you decide to sell an alternative as a class I or class
II substitute, you must provide the Agency with notification at least 90
days prior to commercialization.  Producers of new chemicals must still
abide by the provisions of section 5(h)(1) of TSCA, which authorizes EPA
to grant exemptions from TSCA-reporting requirements, provided that test
marketing will not present an unreasonable risk to human health or the
environment.  

If you plan to take advantage of this exemption, you must send a test
marketing notification to EPA at least 30 days before you start test
marketing.  Your notification must include:

the name of the substitute, 

the volume you intend to test market, 

the industrial sector and end use(s) for the test market, and

the expected duration of the test market period,

Send your test marketing notification to the same address as for the
SNAP Information Notice form.

6. Research & Development

Substitutes manufactured or imported solely for research and development
are exempt from reporting requirements under the SNAP Program.  For new
chemicals, the provisions of Section 720.36 of EPA’s TSCA
Premanufacture Notice (PMN) rule (40 CFR Part 720) are in effect for
chemicals produced solely for research and development.   

7. Substitutes Used as Feedstock

Substitutes that could replace ozone-depleting chemicals which are used
solely as intermediates in the production of other chemicals are exempt
from reporting to the SNAP program.

D.	Who must submit to the SNAP Program?

Manufacturers, formulators, and end-users may need to submit under the
SNAP program.

1.	Designated Submitters

Anyone who produces a substitute for a class I or class II
ozone-depleting substance must provide the Agency with that person's
unpublished health and safety studies on the substitute.  The producer
of the substitute must also notify the Agency at least 90 days before
introducing the substitute or a product using the substitute into
interstate commerce for significant new use as an alternative.    

The Agency recognizes that a substitute can potentially pass through
numerous steps prior to its introduction into interstate commerce. 
Therefore, we consider responsibility for notification under SNAP to
rest with the person who produces the substitute in its final form for
interstate commerce for purchase by an end-user. Therefore, the
designated submitter could potentially be a manufacturer, formulator, or
an end-user.  

  	a.	Manufacturers 	

Manufacturers producing a substitute (a chemical, alternative process or
technology) in its final form for direct commercial sale to the end-user
are required to notify the Agency about the existence of that
substitute.  For instance, if a chemical manufacturer intends to market
a chemical as a substitute foam blowing agent to companies that
manufacture insulation products, the chemical manufacturer would be
required to notify the Agency about the existence of the substitute.  
If the substitute is a new chemical not already on the TSCA Inventory,
it must also undergo review under EPA’s New Chemicals (Pre-Manufacture
Notice) program.  For more information on this simultaneous review
process, see Section 6 of this document. 

  	b.	Formulators 

A formulator is engaged in the preparation or formulation of a
substitute, after chemical manufacture of the substitute or its
components, for distribution or use in commerce.  Formulators usually
only sell substitutes based on existing chemicals, since they do not
ordinarily possess chemical manufacturing capabilities.  Chemicals used
in such substitutes are frequently in common use and have already been
approved for general use through other chemical review programs such as
TSCA or FIFRA.

However, formulators can be considered directly responsible for
production of the substitute for an end-use.  For example, by offering a
specific solvent formulation for an industrial cleaning process,
formulators would be subject to reporting requirements under SNAP.  In
such cases, the formulator is best suited to present information on how
substitutes based on existing chemicals are or could be used.  In cases
where the manufacturer of a chemical is also the formulator of a blend,
the manufacturer is responsible for meeting reporting requirements on
the substitute.  

  	c.	End-users

End-users of substitutes are not obligated to meet SNAP reporting
requirements, except in rare cases where the end-user is also the
substitute producer and will be the first to introduce it into commerce.
 While the Agency expects that this situation will occur infrequently,
several companies have developed substitutes for their own use and
subsequently have notified EPA of their intent to offer those
substitutes for commercial sale.  

2. INTRODUCTION TO THE SNAP SUBMISSION FORMS

A.	Which form do I submit—the SNAP Information Notice form or the
TSCA/SNAP Addendum form?

	Use the   HYPERLINK "http://www.epa.gov/ozone/snap/submit/snapform.pdf"
 SNAP Information Notice form  (“SNAP application”) if you are
applying to use an existing substance that is already being produced and
sold or imported into the U.S., or if you are applying for a new
technology or process.  Most SNAP submitters use this form.

	Use the   HYPERLINK
"http://www.epa.gov/ozone/snap/submit/tsca-snap.doc"  TSCA/SNAP Addendum
form  only if you have already prepared a Pre-Manufacture Notice (PMN)
to send to EPA for a new chemical.  You will include the PMN form as an
attachment to the TSCA/SNAP Addendum form.  

	If you are not sure if the chemical you intend to use is considered to
be an existing chemical, consult with EPA’s New Chemicals Program
(TSCA Hotline at 202-554-1404).  Existing chemicals are listed on the
TSCA Inventory.  You can find more information on  HYPERLINK
"http://www.epa.gov/oppt/newchems" EPA’s New Chemicals Program web
site . .

B.	When do I need to submit to the SNAP Program?

You must submit a SNAP notice at least 90 days before you begin sale of
a new substitute for an ozone-depleting substance.  A petition may be
submitted any time adequate data exists for EPA consideration.

C.	Is there a fee for submitting to the SNAP Program?

No.  There is no application fee for submitting information to the SNAP
program.

D.	How should I fill out the SNAP Information Notice form?

You must file a separate notice for each substitute you submit for
evaluation.  However, a single alternative may be submitted for multiple
end-uses simultaneously provided that the appropriate information is
submitted for each specific end-use.  See Appendix A for a list of
sector end-uses included under SNAP.  If you submit a substitute for
review under more than one sector, you may wish to complete a separate
notice for each sector.  Please check the type of notice submitted on
page 1 of the form.  If this notice is being submitted as part of a
petition to the Agency, indicate the type of petition.  See Section 4
for an explanation of the different types of petitions.

Checklist for Completing the SNAP Information Notice form

Please type the SNAP form or print legibly in black ink.  

All information must be in English.  

Provide all information requested on the notice form to the extent that
you know or can reasonably ascertain it.  If you do not know or cannot
reasonably ascertain the information, enter "unknown" (for not known). 
However, if you cannot answer a question that is needed for evaluation
of the substitute within a given sector (see Appendix B), review of the
substitute may be delayed.  

You may attach continuation sheets to any subsection or item on the
form.  

You may photocopy the notice form or sections of the form, or download
extra copies, as needed.  

Send your completed submission notice to the SNAP Document Control
Officer (6205J), whose address appears on page 1 of the form.  

For paper submissions, you must submit three copies of the submission to
EPA.  If information is claimed as confidential, it must be removed from
one of the copies, which will be placed in the public docket; the other
two copies must include all confidential material.  If you do not claim
any information as confidential, all copies must be identical.  

For CD-ROM submissions, if information is claimed as confidential, it
must be removed from one of the files on the CD-ROM, which will be
placed in the public docket; the other file must include the
confidential material.  (See below for further guidance on handling of
confidential information under SNAP.)

3. CONFIDENTIALITY CLAIMS

A.	Can EPA keep confidential the information in my SNAP submission?

	EPA will keep information confidential provided that you make a claim
of confidential business information at the time you submit and that you
provide reasons for that claim.  As described below, you may not claim
certain types of information as confidential business information.

B.	How do I make a claim of Confidential Business Information?

If you submit information for which you request Confidential Business
Information (CBI) status, you must make a claim of confidentiality at
the time of submission.  If you do not assert a claim of confidentiality
at the time of submission, EPA may disclose the information to the
public without further notice to you.  Information which is publicly
available (e.g., in journals, trade magazines, product literature, etc.)
cannot be claimed as CBI.  Requesting CBI status for such public
information could delay EPA’s review.  EPA will treat all claims of
confidentiality consistent with 40 CFR Part 2, Subpart B.

To claim information as CBI, circle or bracket the specific information
you claim as confidential and check the box at the bottom of the page. 
Then provide reasons why you are claiming this information as
confidential on an attachment to the notice.  For example, if you submit
a study which describes a physical or chemical property and it is only
that property which you wish to claim as confidential, bracket only that
property.  Do not simply mark "Confidential" on the page which contains
that property.  EPA requires substantiation of all CBI claims under SNAP
or a submission will be considered incomplete.  

If you claim the identity or formulation of a substitute as
confidential, you must provide a generic description of this
information.  Section 5 of this document gives guidance on developing
generic names.

For paper submissions, only two of the three copies of your submission
should include CBI material.  To ensure that no confidential information
is disclosed to the public, you must delete all CBI from a third
"sanitized" public copy, including attachments, which will become part
of the public docket.  The following special preparation is required for
the sanitized copy:

(	Remove from the body of the submission any information you claim as
confidential.  Replace with generic information if it is available.

(	Mark the sanitized copy plainly on both its cover and its title page
with the phrase "Public Docket Material -- contains no information
claimed as confidential."

For CD-ROM submissions, one file on the CD-ROM should include CBI
material and one should be sanitized.  Prepare the CBI and sanitized
files in the same way as described above for paper submissions.  When
you are ready to save the files to the CD-ROM, ensure that the file with
the CBI material is clearly identified by the words “contains CBI”
in the file name.

If you claim CBI but do not provide the sanitized copy with your
submission, EPA will consider your submission incomplete.  This may
delay or prevent publishing an acceptability determination on your
product.  EPA recognizes that substantial portions of submissions may be
omitted from the public docket copy.  However, all CBI claims must be
substantiated to warrant restricting access to such information.  

C.	What do I need to provide to EPA to substantiate my CBI claim?

  

EPA requires substantiation of all confidentiality claims at the time of
submission.  In making these claims, the following applies: 

(	The specific information to which the claim applies must be clearly
marked as subject to a claim of confidentiality;

( 	A `Supplemental Statement of Data Confidentiality Claims' must be
submitted, identifying each section claimed confidential and describing
in detail the basis for the claim (see below for specific points that
should be addressed);

(	The `Supplemental Statement of Data Confidentiality Claims' must be
signed and dated and must include the typed name and title of the
official who signed it.

If you do not provide the required substantiation when submitting
information claimed as confidential, EPA may make the complete submitted
information available to the public without further notice.



Supplemental Statement of Data Confidentiality Claims

For any portion of a submission that you claim as confidential, the
following information must be included in a Supplementary Statement of
Data Confidentiality Claims:

(	Identify specifically by page and line number(s) each portion of the
document for which you claim confidentiality.

(	Give the reasons why the cited passage qualifies for confidential
treatment.

(	Indicate the length of time - until a specific date or event, or
permanently - for which the information should be treated as
confidential.

(	Identify the measures you have taken to guard against undesired
disclosure of this information.

(	Describe the extent to which the information has been disclosed, and
what precautions have been taken in connection with these disclosures.

(	Enclose copies of any determinations of confidentiality previously
made by EPA, other Federal agencies, or courts concerning this
information.

(	If you assert that disclosure of this information would be likely to
result in substantial harmful effects to you, describe those harmful
effects and explain why they should be viewed as substantial.

(	If you assert that the information is voluntarily submitted, indicate
whether you believe disclosure of this information might tend to lessen
the availability to EPA of similar information in the future, and if so,
how.

D.	What kinds of data am I not allowed to claim as confidential?

	Publicly available information may not be claimed as confidential.

	

Under section 114(c) of the Clean Air Act, emissions data may not be
claimed as confidential.  

Toxicity or health and safety studies, to the extent that confidential
treatment is prohibited under the Toxic Substances Control Act (TSCA) or
the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), cannot
be held confidential.  However, other information can be maintained as
confidential subject to the provisions of 40 CFR, Part 2, Subpart B, so
long as it is: a) information other than emissions data, b) not health
and safety data, and c) not data on the effects of a substance on human
health and the environment.  The Agency  requests that you do not
identify the following information as confidential:  all information
concerning the objectives, methodology, results, or significance of any
toxicity test or experiment performed on or with a substitute or its
degradation products;  any information concerning the effects of the
substitute on any organism (e.g., fish, wildlife, humans and other
mammals) or the environment (e.g., studies related to persistence,
translocation, and fate); emissions data; and
pharmacokinetics/metabolism studies. Examples of information that may be
claimed as confidential include discussion of process information,
composition of proprietary blends, identity of the submitter or the
substitute, and cost and availability of the substitute. 

E.	Does anyone besides EPA staff see my SNAP submission?

	Before issuing a decision, EPA posts the public version of your SNAP
submission in our public docket.   The SNAP docket is docket number
EPA-HQ-OAR-2003-0118, available online at  HYPERLINK
"http://www.regulations.gov/" www.regulations.gov .

Information submitted as CBI may be accessed by companies designated as
Authorized Representatives of the United States Environmental Protection
Agency (EPA) under an EPA contract for the purpose of assisting EPA in
the development and implementation of national regulations for the
protection of stratospheric ozone, including the development of the SNAP
program.  These Authorized Representatives may have access to any
information received by the Stratospheric Protection Division within
EPA's Office of Atmospheric Programs for use in reviewing the need for
possible control of any substance, practice, process or activity that
may reasonably be anticipated to affect stratospheric ozone.  In
general, this information will pertain to the feasibility, costs, and
environmental and health impacts of using substitutes for class I and
class II substances.  Access to such information is necessary to ensure
that these companies can complete the work required by the contract.

Authorized Representatives of EPA are subject to the provisions of 42
U.S.C. 7414(c) respecting confidential business information as
implemented by 40 CFR 2.301(h).

F.	Does EPA ever reconsider which data are confidential?

EPA may reconsider confidentiality assertions even when confidentiality
claims are received. This could occur, for example, if EPA receives a
Freedom of Information Act (FOIA) request on a particular substitute. 
These circumstances and others are described in 40 CFR Part 2, Subpart
B.  You will be contacted if EPA reconsiders the confidential status of
your data or if we receive a FOIA request that includes your
confidential data. In such a case, EPA would typically ask for
additional information to support whether the data should remain
confidential.

4. BEGINNING THE SNAP INFORMATION NOTICE

A.	Should I mark my form as a manufacturer’s submission or as a
petition?

	If you are providing information on a new substitute that you produce,
formulate, use, or distribute, you should check the box for a
manufacturer’s submission.  

Petitions may be submitted by anyone.  The petition provision serves two
principal needs.  The first is to give the public a way to appeal
existing Agency determinations under the SNAP program.  The second is to
provide a way for individuals and organizations to bring to the Agency's
attention new information on substitutes that could affect existing
listing determinations or result in new ones.  

If you file a petition for EPA to review a substitute that has not
previously been reviewed, you will provide the same information as for a
manufacturer’s submission.  There are other types of petitions that do
not require submitting the SNAP Information Notice form.

B.	What are the types of petitions allowed under the SNAP Program?

Five types of petitions exist (see 40 CFR 82.184):

(1)	Petitions to add a substitute not previously reviewed under the SNAP
program to the acceptable list;

(2)	Petitions to add a substitute not previously reviewed under the SNAP
program to the unacceptable list;

(3)	Petitions to move a substitute from the acceptable list to the
unacceptable list or to move a substitute from the unacceptable list to
the acceptable list;

(4)	Petitions to add or delete use restrictions on an acceptability
listing, and  

(5)	Petitions to grandfather general use of a substitute found
"unacceptable" or "acceptable subject to narrowed use limits" in
specified applications within an end-use.  

C.	What are reasons for submitting a petition?

A petitioner may submit a petition for several reasons, including:

(	Availability of new information on substitutes or end-uses not covered
in the existing SNAP determinations;

(	Requests to extend the effective date for prohibitions on uses of an
unacceptable substitute;

(	New technologies or practices that reduce exposure to a substitute
previously unacceptable under SNAP due to toxicity or flammability
concerns.

All of the above are examples of valid justifications for submitting a
petition.  Other bases for petitioning the Agency may exist as well, and
all petitions with adequate supporting data will receive consideration
under the SNAP program.

D.	What do I need to include in my petition?

Petition types (1) and (2) must contain the information requested in
the SNAP Information Notice.  Information requirements for such
petitions and for manufacturers’ submissions are the same.  For
petition types (3) and (4), which request a reexamination of a
substitute previously reviewed under the SNAP program, the submitter may
reference the prior submission rather than submit duplicate information.
 In this case, the petitioner should specifically indicate any new or
additional data and submit complete test reports.

For petition type (5), EPA must consider a specific test to determine
whether grandfathering should be allowed for specified applications
within an end use.  This test involves balancing the results of four
analyses, including whether the new rule represents an abrupt departure
from previously established practice, the extent to which a party relied
on the previous rule, the degree of burden which application of the new
rule would impose on the party, and the statutory interest in applying
the new rule immediately.  Thus, petition type (5) requires information
about the current level of use of the substitute and other information
to allow EPA to conduct these analyses.

For all petitions, the Agency also requires the following information:

(	Action requested:  A brief statement describing the type of petition;
and

(	Rationale:  A brief summary of the basis for the petition and the data
that support the petition.

 

E.	What does EPA consider when reviewing my petition?

EPA will only review and grant or deny petitions based on the sector and
end-use identified in the petition. For example, the fact that a
substitute is placed on the list of unacceptable substitutes for a
particular end-use in the solvents cleaning sector does not mean the
substitute is unacceptable for any specific end-use as a refrigerant.  A
similar caveat applies for petitions on end-uses within a sector.  If a
substitute, for instance, is found acceptable for a specific end-use
within a sector, it will not automatically be deemed acceptable for any
other end-use in that sector or in other sectors.

F.	What kinds of test data and effects data do I need to provide to EPA?
tc \l2 "C.	Test Data and Other Data 

You are required to provide test data on the health and environmental
effects of alternatives, including data on physical/chemical properties,
in your possession or control, and a description of any other health and
environmental effects data on the substance known to or reasonably
ascertainable by you.  The Agency considers data in the possession or in
control of either a parent company or an affiliated subsidiary located
outside the U.S. to be data that should be known to or reasonably
ascertainable by a submitter.    



Complete test data, not summaries of data, must be submitted if they do
not appear in the published literature.  Incomplete reports (e.g., from
ongoing studies) are exempt from full reporting.  However, you must
describe the nature and objective of any incomplete study, report, or
test; the name and address of any laboratory developing the data;
progress to date, type of data collected; significant preliminary
results; and an anticipated completion date.  If significant preliminary
results or final results are obtained prior to the completion of the
notice review period or any other additional information significant to
the review of the notice becomes available to you, you must submit this
information within 10 days of receipt.  If information becomes available
during the last 5 days of the review period, you should immediately
inform EPA by telephone.  Data must be submitted in English. 

Lists of the test data you must submit for each sector are provided in
Appendix B at the end of this manual.  For additional information on
health and safety studies and on submitting test data, see (82.172 and
82.178 of the SNAP Rule and Section 5 of these instructions.  

5. STEP-BY-STEP INSTRUCTIONS FOR COMPLETING THE SNAP INFORMATION NOTICE

Part I – INTRODUCTION AND GENERAL INFORMATION tc \l3 "Part I - GENERAL
INFORMATION 

You must complete all of Part I for your submission to be accepted for
review under SNAP.  See below for sector-specific data requirements.

Part I, Initial Information (Page 1 and Page 2) tc \l4 "Part I, Initial
Information 

Please select the appropriate box on page 1 indicating the type of
notice (manufacturer submission or petition, see Section 4.A-C above)
and check the boxes on page 2 indicating the sector(s) for which you are
submitting information on the substitute and the types of test data
included in your submission.  Attach all test data to the notice form
and reference them by page number in Part IV-List of Attachments (pg.
14).  

Part I, Section A - Submitter Identification tc \l4 "Part I, Section A -
Submitter Identification   (Page 3)

1a.	Person submitting notice - Enter information for the official who
signs the certification on page 15.

 b.	Agent - Complete only if you authorize an agent to assist you in
preparing this notice.  The agent must also sign the certification as
noted above.

 c.	Joint Submitter - Identify the joint submitter, if any, who is
authorized by the primary submitter to provide some of the information
required in the notice.  A submission will not be considered complete
until EPA receives all information.  If information from multiple
parties will not be sent together, mark each set clearly with the same
alternative identification information.

If you authorize another person (e.g., a foreign manufacturer or
supplier) to provide information directly to EPA, indicate which
information will be supplied by the other person.  Identify that person
by name, company, and address in a continuation sheet.  Such a letter in
support of your notice should be provided by the other person on company
letterhead.  An example of where this option could apply would be in
situations where alternative formulation information is held
confidentially by a foreign manufacturer.  A notice will be considered
incomplete until this information is provided.  Whenever possible, use
the same alternative identification information (e.g., generic name) to
link this information to your submission.

2.	Technical Contact - Identify a person who can provide EPA with
additional technical information on the substitute during the review
period.  The technical contact identified should be located within the
U.S. and be available to be reached by telephone during normal business
hours.

3.	Provide information on any prior communication with EPA regarding
this submission.  Provide the EPA staff person's name, the date, and the
form of communication (e.g., letter or phone).  Mark the box labeled
“Mark (X) if None” if no prior communication has occurred.

Part I, Section B - Alternative Identification  (Page 4) tc \l4 "Part I,
Section B - Alternative Identification  (Page 4) 

EPA must receive a complete and unambiguous identification of the new
substitute.  If the alternative is not adequately identified, we will
consider the submission incomplete.  If you are an importer of an
alternative and do not know the chemical identity of a substitute
because it is confidential, you must contact the manufacturer or
supplier and have the specific chemical identity provided directly to
EPA.  In this way, manufacturers can protect confidential business
information.  This information may be provided in a letter on company
letterhead from the supplier or in a joint submission, referencing the
earlier submission.  

1.	Commercial/Trade Name(s) of the Alternative - Indicate the name(s)
under which the alternative is marketed.

2.	Name of Chemical, Process, or Alternative Technology - Enter the
specific name of the chemical substance, the Chemical Abstracts Service
(CAS) registry number, and the molecular formula of the alternative.  In
describing chemical substances, EPA prefers that International Union of
Pure and Applied Chemistry (IUPAC) nomenclature be used for
identification purposes.  If the substitute is a blend of chemicals, you
must provide the exact composition and/or the range of percent
composition of all components (where appropriate) of a substitute.  In
addition to active ingredients, you must also list other chemical
substances in blends, such as solvents, inhibitors, etc., that may also
be present in the alternative.

	For agents where the discharged agent is different from the original
formulation, such as pyrotechnically generated aerosol fire
suppressants, include composition information for both the original
formulation and for the gaseous and/or particulate constituents of the
discharged agent.

For alternative technologies and/or processes, provide a detailed
description and diagram of the technology or process and information on
any chemical constituents.

Also, if you have applied for or hold a patent on the substitute,
provide the patent name, number (if available), and information on
topics covered in the patent.  

Sector-Specific Data Requirements

Solvents; Aerosols; Adhesives, Coatings, & Inks: Give the function of
each constituent as well as the percent composition.  For example, in an
aerosol product, such a list may include: 

  HFC-134a	 	(propellant)

  dimethyl ether		(propellant)

  methanol 		(solvent)

  silicone 		(active ingredient)

3.	Generic name - If the identity of a substitute is claimed as
confidential or if the formulation or process is such that it cannot be
identified by its individual chemical components, you must provide a
generic name that is only as generic as necessary to protect the
confidential identity.  The name should reveal the chemical identity or
alternative process description to the maximum extent possible.  The
generic name may be published in the Federal Register notice announcing
EPA’s acceptability determination of your alternative.  If the name
seems more generic than necessary, EPA will contact you and assist you
in developing an adequate name.  

The generic name should provide sufficient information for the public by
indicating the classes of chemicals which the alternative contains
without revealing specific information about the product's composition. 
For example, it may be necessary to reveal that a refrigerant blend
contains an HCFC in order to allow users or importers to comply with
regulations issued under sections 604or 608 of the CAA.

When reviewing the SNAP lists for the solvents, aerosols, and adhesives,
coatings and inks sectors you will notice that many of the listings are
grouped into general classes of substitutes.  If your substitute is
already included under one of these classifications, you need to submit
information to EPA for review under SNAP only if your substitute
contains a new chemical which is subject to review under the PMN
program.  

4.	Specific End-use - Identify the specific end-uses in which the
alternative is to be used.  Be sure to provide a broad description (e.g.
terpene-based semi-aqueous solvent cleaner of metal parts as an
alternative for methyl chloroform, or HFC refrigerant as an alternative
for CFC-12 centrifugal chillers.)  

Specify the ozone-depleting substance (ODS) being replaced, and include
an estimate of the quantity of alternative (lbs.) needed to replace the
ODS for each end-use.  This is known as the replacement ratio.  For
example, if 100 pounds of a new refrigerant will replace 150 pounds of
CFC-12, the replacement ratio is 1:1.5.

See Appendix A for a list of end-uses included under SNAP.  If you are
proposing a new end-use, please indicate why the substitute does not fit
into an existing one.

Sector-Specific Data Requirements	

Refrigerants:  Indicate whether the alternative is a candidate for use
in retrofits of existing equipment, for use in new equipment only, or
both.  If the alternative can be used both as a retrofit and in new
equipment, these uses should be treated as separate end-uses throughout
the notice.  If the substitute is a chemical replacement, provide the
size of the average charge used in each end-use. Describe the technology
or the industry standard that will be used to recover the substitute.

Foams:  If the alternative blowing agent can be used in several
different types of foam, treat each end-use separately throughout the
notice.

Fire Suppression:  Provide information on the weight and storage volume
equivalence replacement ratio for the substitute versus the ODS being
replaced, using the method described in Appendix B.

Tobacco Expansion:  Specify the base replacement ratio values on the
amount of new expansion agent consumed per unit mass of tobacco compared
to the amount of CFC-11 consumed per unit mass.

5.	Impurities - Identify by name, weight percent, and CAS number (where
available) each impurity that you reasonably anticipate will be present
in the alternative as manufactured for commercial purposes.  An impurity
is any chemical substance that is unintentionally present in the
alternative.  List all impurities, regardless of weight percent.  If the
substance contains some unidentified impurities, also enter
"unidentified".  Do not include substances that are mixed with the new
substance after manufacture of the primary ingredients.  If there are no
impurities, enter "None."

6.	Byproducts - Describe any byproducts or degradation products that
you reasonably anticipate will result from the manufacture, processing,
use, or disposal of the alternative both at sites you control and in
end-use.  Identify these byproducts or degradation products by specific
name or class or range of structures (e.g., HF or other acid gases
formed from the combustion of halocarbon compounds), CAS Registry number
(where available), and the estimated amount formed.  Also indicate where
the byproduct or degradation product is formed (e.g., during
manufacture, during end-use, following disposal).

Sector-Specific Data Requirements

Foams:  Provide information on the catalyst used in manufacture and an
analysis of breakdown products under different external conditions, such
as temperature, during use.

Fire Suppression:  Provide information on the degradation products of
the alternative following discharge in a fire situation.  Explain the
conditions used in determining these products, such as the flame
temperature, time required to extinguish the fire, amount of O2 present,
and the combustible material.

Part II - ALTERNATIVE-SPECIFIC INFORMATION tc \l3 "Part II -
ALTERNATIVE-SPECIFIC INFORMATION 

EPA requires certain information on all substitutes.  However, the data
that are required may vary by sector.  See Appendix B for more
information on sector-specific requirements.

Part II, Section A - Physical and Chemical Properties  (Page 6) tc \l4
"Part II, Section A - Physical and Chemical Properties  (Page 6) 

Include all data on the physical or chemical properties of the
alternative that are reasonably available to you.  Those properties
included in this section are illustrative and are not an exhaustive list
of potential data.  See Appendix B for sector-specific data needs within
this section.

If you are extracting this information from a public reference source
(e.g., CRC Handbook of Chemistry and Physics, Merck Index), please
indicate the reference in Question 27, "Other".  If you have performed
chemical analysis and testing on the substitute to derive the
properties, attach copies of all test reports and specify the protocol
used.

1-27.	Complete the form as appropriate for the specific substitute. 
Many physical characteristics will apply to more than one sector; see
Appendix B to these instructions for detail by sector.  For flammable
substances or mixtures, be sure to fill in items 22-26.

28.	Provide all test data regarding flammability of the substitute,
including the procedures used for determining flammability and any other
information on flammability concerns.  If a substitute is flammable
under the conditions expected in the proposed end-use, describe any
abatement techniques being used to minimize the risks associated with
use of a flammable substance (e.g., equipment design modifications or
alternate labeling).  EPA recognizes that many flammable alternatives
may be promising.

If an alternative is flammable (this applies to both blends and pure
materials), you must analyze the risk of fire resulting from the use of
the substitute in each proposed end-use.  This assessment should
include, but not be limited to, a description of typical scenarios in
which the substitute is used, potential leak scenarios, sources of
ignition, and probabilities of ignition.  It should also assess the
likelihood of injury within each scenario.  Significant differences
exist both in the design and in the ambient conditions for various
end-uses.  Thus, risk assessments are extremely sensitive to end-use. 
Low risk in one end-use does not, in general, imply low risk in another
end-use.  

Sector-Specific Data Requirements	

Refrigerant alternatives:  Information on the flammability of a blend as
well as its individual constituents must be provided.  Flammability
testing should include the lower flammability limit (LFL) and upper
flammability limit (UFL) for the blend as well as its constituents. 
Testing of all blends should identify the compositions for which the
blend itself is flammable.  Blends that contain flammable components
should be tested during leaks in system components containing two phases
to identify limits of fractionation.  Worst-case of formulation for
flammability (WCF) and worst-case of fractionation for flammability
(WCFF) compositions must be reported and analyzed under normal
operation.  For flammable substitutes, also submit documentation of
testing safety results conducted by independent laboratories.  Include
both evaporator and condenser temperature and pressure conditions. 
Provide a flammability risk assessment and a fault-tree analysis that
analyzes the probability of failures that might lead to a fire or
explosion.  You can find samples of fault tree analyses for  HYPERLINK
"http://www.regulations.gov/" \l
"!documentDetail;D=EPA-HQ-OAR-2008-0664-0005" motor vehicle air
conditioning  and for  HYPERLINK "http://www.regulations.gov/" \l
"!documentDetail;D=EPA-HQ-OAR-2009-0286-0023" household refrigerators
and freezers .  See Appendix B for suggested tests and examples of
potential scenarios to be examined in a risk assessment.

Foam blowing agents.  If you are submitting for a flammable substitute
for use in spray foams, provide a training program to address
flammability risks.

Sterilants:  If the substitute is a blend with ethylene oxide (EtO),
include information on the critical flammability ratios.

Aerosols:  If the product contains an immiscible component, address the
potential flammability of the product that could be expelled if the
entire mixture is not shaken immediately before each use.

Part II, Section B - Atmospheric Information tc \l4 "Part II, Section B
- Atmospheric Information   (Page 7)

1.	Provide information on the predicted 100-year ozone depletion
potential (ODP) of the alternative relative to CFC-11, if known.  If the
substitute is a blend, provide the ODPs of the individual constituents. 
You should also provide supporting documentation indicating how and by
whom this value was calculated.  This information may be provided as a
citation from the published literature or by providing the background
information used to develop the ODP.  

For purposes of calculating ODP, EPA recommends the methodology used in
the Scientific Assessment of Ozone Depletion prepared for the United
Nations Environment Programme (UNEP) by the World Meteorological
Organization (WMO).  The ODP refers to the amount of ozone destroyed by
a gas over its entire atmospheric lifetime (e.g. at a steady state)
relative to that due to emissions of the same mass of CFC-11.  It is
defined in modeling calculations as follows:

 

Calculations should reflect ground level emissions.  For aircraft
applications, be sure to also consider emissions at the appropriate
altitude.

You should also include any other related data available to you, such as
information on the substitute's atmospheric lifetime and chlorine or
bromine loading potential.  See the  HYPERLINK
"http://ozone.unep.org/Assessment_Panels/SAP/Scientific_Assessment_2010/
index.shtml" 2010 WMO Scientific Assessment of Ozone Depletion  for
additional information on calculating ODPs and related information.  

2.	Provide information on the 100-year global warming potentials (GWPs)
of a substitute relative to CO2, as well as atmospheric lifetime of a
substitute.  If they are available, you may also provide the 20- and
500-year GWPs, and the GWP relative to CFC-11, known as the halocarbon
GWP (HGWP).  If the substitute is a blend, provide the GWPs of the
individual constituents and an estimate of the blend at its nominal
composition.  

Provide GWPs as listed in the most recent   HYPERLINK
"http://www.ipcc.ch/publications_and_data/publications_and_data_reports.
shtml"  assessment reports from the Intergovernmental Panel for Climate
Change  (IPCC AR4).  Alternate sources may include the  HYPERLINK
"http://ozone.unep.org/Assessment_Panels/SAP/Scientific_Assessment_2010/
index.shtml" 2010 WMO Scientific Assessment of Ozone Depletion  or the
peer-reviewed literature.  IPCC defines GWP of the emissions of a
greenhouse gas as the time integrated commitment to climate forcing from
the instantaneous release of 1kg of a trace gas expresses relative to
that from 1 kg of CO2.

 

where:

ai = the instantaneous radiative forcing due to a unit increase in the
concentration of trace gas, i

ci = the concentration of trace gas, i, remaining at time, t, after its
release, and

n = the number of years over which the calculation is performed.

Corresponding values for CO2 are in the denominator.

	Provide GWPs using a 100-year time integration; GWPs using other time
horizons may also be provided.

	For GWP values that do not come from AR4 or WMO 2010, you should also
include the data used to calculate these potentials such as atmospheric
lifetime, infrared adsorption spectrum, and infrared absorption
capacity.  Reference the source of this information.

	To the extent that data is available, EPA considers total global
warming impacts (both direct and indirect effects) of a substitute for
each end use.  GWPs provide a measure of direct effects, i.e., they
refer to the direct contribution to global warming from use of the
substitute due to its radiative forcing.  Indirect effects are
contributions to global warming resulting from changes in energy
consumption and corresponding changes in emissions of CO2 and other
trace gases.  If known, provide information on the energy efficiency of
the substitute relative to that of the substance being replaced and
results of any testing or modeling done on the substitute.  See Appendix
B for a list of applicable tests.  Data on energy efficiency is
particularly of interest for alternative refrigerants and foam blowing
agents.

If the alternative is captured as a byproduct of another manufacturing
or industrial process, indicate the source of the alternative.  This
information is important in assessing the effects of the new use of the
substitute versus those effects occurring strictly because of the
release of a byproduct.

Part II, Section C - Other Statutes tc \l4 "Part II, Section C - Other
Statutes   (Page 8)

Please provide all information that is reasonably available regarding
regulation of a substitute under other regulatory authorities.  The
Agency will evaluate substitutes under the SNAP program subject to
existing regulatory constraints.  This information allows EPA to
coordinate regulatory efforts within EPA and among other authorities.

1.	Environmental Statutes - Provide information on whether the
manufacture, use, or disposal of a substitute is regulated under any
other environmental statutes such as:

(	Titles of the Clean Air Act (CAA) other than Title VI

(	the Clean Water Act (CWA)

(	the Safe Drinking Water Act

(	the Resource Conservation and Recovery Act (RCRA)

(	the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

(	the Toxic Substances Control Act (TSCA)

(	the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA)

(	the Emergency Planning and Community Right-to Know Act (EPCRA or SARA
Title III)

(	state and local laws

List any concentration-based or other numerical standards to which the
substitute is subject under the above statutes or regulations.

For example, many alternative solvents are considered to be volatile
organic compounds (VOCs) and are subject to emission restrictions under
Title III of the CAA.  If you know your alternative is either regulated
or exempt as a VOC or Hazardous Air Pollutant (HAP), please indicate
this.

2.	Other Statutes - Indicate whether occupational, consumer, or general
population exposure to the substitute is regulated under other statutory
authorities concerned with health and safety issues, such as those
implemented by:

(	the Food and Drug Administration (FDA)

(	the Occupational Safety and Health Administration (OSHA)

(	the Department of Transportation (DOT)

(	and state and local laws.

Also include information on any other standard-setting bodies who will
be evaluating the substitute, such as the National Fire Protection
Association (NFPA), Underwriters Laboratories (UL), or the American
Society of Heating, Refrigerating and Air Conditioning Engineers
(ASHRAE).  List any concentration-based or other numerical standards
(e.g., permissible exposure limit (PEL), short-term exposure limit
(STEL), ASHRAE safety classification) to which the substitute is subject
under these statutes or organizations.

Part II, Section D - Cost and Availability of the Alternative tc \l4
"Part II, Section D - Cost and Availability of the Alternative   (Page
9)

1.	Estimate the cost per pound ($/lb) of the chemical substitute or,
where appropriate, indicate the cost per unit volume or per packaging
unit (e.g., aerosol spray can).  If the cost is not per pound of
material, specify the units.  For alternative processes and
technologies, describe the equipment costs and other costs such as those
associated with installing the new substitute.  Costs may be either
commercial or consumer, as long as you provide information on the basis
for your cost estimate.

2.	Provide information on the levels of production and market
penetration that you expect for the substitute.  Include values for
total production in lbs/yr both at the start of production and in the
future (e.g., 3 years from now), the number of years you anticipate
until the substitute reaches its maximum market penetration, and the
total production level that you anticipate for the substitute when it
reaches the point of market saturation.  Finally, if possible, estimate
the percentage of the market held by the ODS being replaced that will be
captured by this substitute.  If the substitute is not currently
available, indicate when you anticipate it will enter the marketplace.

If you are submitting the substitute for several end-uses, you must
provide this information for each end-use.

3.	Describe any new equipment and how the substitute or alternative
technology is used.  If retrofitting of existing equipment is possible,
detail changes in technologies needed to use the substitute.  Also
provide information on materials compatibility and attach any available
test results.  Provide specific information on each different end-use,
including cost of equipment, equipment lifetime, changes in labor, and
changes in energy costs.  For example, if the substitute is an
alternative refrigerant that may be used both as a retrofit in existing
equipment or used in new equipment for chillers, information on the
equipment changes should be provided for both retrofit and new equipment
scenarios.  This cost information may be provided as a range where
equipment may be optimized to different levels of energy efficiency.

All claims that an agent is a "drop-in" for the ODS it is replacing must
be substantiated, and qualified by a description of any necessary
technical changes to existing equipment. 

PART III - RELEASE AND EXPOSURE DATA tc \l3 "PART III - RELEASE AND
EXPOSURE DATA 

The following sections describe the types of human health and safety and
environmental exposure data used to evaluate substitutes under the SNAP
program.  For existing chemicals, specific data requirements may depend
on what types of data are already available.  Attach all complete test
reports that are reasonably available to you.  Also indicate all
concentration-based exposure limits that have been set for the
substitute, such as PELs, occupational exposure limits (OELs), or
acceptable exposure limits (AELs) set by the manufacturer.  You may
submit references to studies that have already been submitted to the
SNAP program.  If you have done a literature search on the alternative
or its constituents, please include it as well.

Decisions on data requirements will be determined by the exposure
patterns of the sector(s) in which the substitute is to be used.  For
example, substitutes used only in settings which would generally
preclude all but acute exposures (such as in fire extinguishing) may not
require chronic toxicity data.  For other sectors, such as solvent
cleaning, where aqueous cleaners are used, additional tests related to
impacts on aquatic life may be necessary depending on the means of
discharge and disposal of the substitute.

If the substitute is a blend containing constituents not previously
reviewed under SNAP for any end-use, additional data other than those
specified below may be required.

Part III, Section A - Toxicity and Hazard Information tc \l4 "Part III,
Section A - Toxicity and Hazard Information   (Page 10)

1.	For chemical alternatives and for chemicals used with alternative
processes, summarize information on the acute and chronic toxicity of
the substitute and/or of its constituent chemicals on any organism (e.g.
humans, other mammals, fish, wildlife, plants, etc.).  For mammals, EPA
requests a minimum submission of the following tests to characterize
substitute risks: a range-finding study, and a 28-day subchronic
repeated dose study in an appropriate rodent species.  In addition to
those data mentioned specifically below, attach all supporting
information such as test reports, if available.  In addition, attach a
copy of any hazard warning statement, label, material safety data sheet
(MSDS) or other information that will be provided to any person who is
reasonably likely to be exposed. Include any data on toxicity of
impurities and degradation products if known.  

Sector-Specific Data Requirements   

Refrigerants:  A cardiosensitization study, usually measuring
cardiotoxic effects in the dog, may be required.  This requirement also
applies to blends of chemicals which have already been tested
individually.  Blends can exhibit unpredictable cardiotoxicity levels,
and testing is necessary.

Foams:  A study on the degradation products of the foam under different
external conditions, including the catalyst used during manufacture and
the temperature during use is required.  EPA's assessment of potential
hazards for insulation foam suggests that breakdown/degradation products
of foam during use may be significant, and thus information on such
processes is required.

Solvents:  To characterize aquatic toxicity, both acute and chronic
toxicity data for a variety of species may be required.  The Agency
requires a minimum aquatic data set to be submitted as described in
"Guidelines for Deriving Numerical National Water Quality Criteria for
the Protection of Aquatic Organisms and Their Uses," which is available
through the National Technical Information Service (#PB 85-227049).  If
other regulatory limits such as effluent guidelines exist, these values
may be used in lieu of compiling toxicity data.

Fire Suppression:   See the document “ HYPERLINK
"http://www.epa.gov/ozone/snap/fire/fire/index.html" A Guide to
Completing a Risk Screen: Collection and Use of Risk Screen Data –
Fire Suppression Sector .”  A cardiosensitization study, usually
measuring cardiotoxic effects in the dog, may be required.  For
specialized halon use, such as in airline cabins, information on central
nervous system (CNS) depression may also be required.  An exposure
assessment, such as personal monitoring testing, for evaluation of
alternative streaming agents may also be required.

For powdered aerosol fire suppressants, provide results of testing for
ocular and dermal irritation.

Aerosols:  A cardiotoxicity study, usually measuring cardiotoxic effects
in the dog, may be required.  Information on central nervous system
(CNS) depression may also be required.  

Adhesives, Coatings, & Inks:  Depending on the end-use, data
requirements for this sector may be similar to the solvents sector. 
Submit all relevant information, to the best of your knowledge.

Sterilants: Provide copies of the toxicity testing provided for review
under FIFRA.  As stated above, attach copies of hazard warning
statements, labels, and MSDSs that will be provided to any person likely
to be exposed.

Part III, Section B - Environmental Release and Disposal at Manufacture
tc \l4 "Part III, Section B - Environmental Release and Disposal at
Manufacture  (Page 10)

Identify by name and address all manufacturing site(s) (within the U.S.
and worldwide) of each chemical or alternative technology.  Also
identify all site locations for manufacturing of products containing the
substitute (e.g. refrigerators containing substitutes).  If you are
unable to identify all manufacturing sites, provide data on a typical
facility.  Identify all points of release and/or exposure during
manufacture of the substitute and any products containing the substitute
and the magnitude of the release.  Also indicate the environmental media
to which it is released (e.g., indoor air, outdoor air, water, land).

Part III, Section C - Occupational Exposure at Manufacture tc \l4 "Part
III, Section C - Occupational Exposure at Manufacture   (Page 11)

Provide information on occupational exposure during manufacture of the
substitute or alternative technology.  This entry should include
information on exposure during manufacture of the substitute itself
and/or manufacture of products containing the substitute, where
appropriate (e.g., refrigerators containing the alternative).  Describe
all activities in which workers may be exposed to the substitute,
estimate the levels of exposure, and describe any protective measures
taken to limit exposure.  If possible, include the approximate
dimensions or range of estimates for the size of a room in which the
systems will be manufactured.

Part III, Section D - Environmental Release and Disposal in End-use tc
\l4 "Part III, Section D - Environmental Release and Disposal in End-use
  (Page 11)

Provide information in this section as it applies to the sector(s) in
which the alternative will be used.  For example, information applicable
to wastewater treatment should be included for solvent cleaning
alternatives but is not relevant to refrigeration substitutes.  For each
substitute, provide information on any releases or discharges of the
chemical to the environment at the point of, or subsequent to, the
end-use, including quantities (in kg/day) and the environmental media to
which it is released (e.g. air, water, land).

Describe any control technologies used to limit emissions and indicate
the method and location of disposal and/or treatment of the substitute. 
For example, explain if disposal will be performed on site, by a
contractor, by a vendor, or by other means.  If the substitute is to be
recycled, describe any necessary equipment and programs that may be set
up to encourage recycling.

Identify the recovery technology that will be used to recapture the
substitute for disposal in specific end use sectors.  Is current
technology available to recover the substitute?  If yes, please describe
the technology by providing specifications or the specific industry
standard. However, if current recovery technology is not available
please describe how the substitute will be recovered again by providing
new equipment specifications, new industry standards or the new method.

Part III, Section E - Occupational Exposure at End-use tc \l4 "Part III,
Section E - Occupational Exposure at End-use   (Page 12)

Provide information on occupational exposure during end-use (e.g.,
during use of an alternative solvent in an open-tank cleaning system). 
Describe all activities in which workers may be exposed to the
substitute, including details on the average and maximum number of
workers, duration of activity, contact pathway, and physical form of the
substitute.  Estimate the average and high-end levels of exposure,
including units of measure.  Also describe any protective measures taken
to limit exposure.  If available, provide the rate of airflow in the
area in which occupational exposure could occur.

Sector-Specific Information

Fire Suppression:  Personal monitoring may be required for streaming
agents, depending on the amount of agent required for fire suppression
and the cardiotoxic level of the agent.  For total flooding agents,
indicate the extinguishing concentration using either a cup burner in
heptane or full scale testing, and the design concentration of the
substitute as defined by the National Fire Protection Association (NFPA)
(cup burner plus 20 per cent).  Indicate actual design concentration if
it is likely to be higher, based on manufacturer recommendations.

Solvents, aerosols, and adhesives, coatings and inks.  If available,
provide personal monitoring data from end use.  If personal monitoring
data are not available, provide estimates using surrogates with similar
properties for the same end use.

Part III, Section F - Consumer Exposure tc \l4 "Part III, Section F -
Consumer Exposure   (Page 12)

Provide information in this section as it applies to the sector(s) and
end-use(s) in which the substitute will be used.  If the alternative is
intended for industrial use only (e.g., a refrigerant for cold storage
warehouses) you need not provide information in this section.  We expect
information on consumer exposure for household refrigerators and
freezers; residential air conditioning; motor vehicle air conditioning;
dehumidifiers; water coolers; aerosol propellants; and rigid cell foams
used in residential construction or insulation.

Part III, Section G - General Population Exposure tc \l4 "Part III,
Section G - General Population Exposure  - OPTIONAL (Page 13)

You do not need to provide the information requested in the General
Population Exposure section unless you choose to do so.  “General
Population Exposure” refers to exposure to the general population
located near an industrial facility manufacturing or using the
substitute.

Part IV - LIST OF ATTACHMENTS (Page 14) tc \l3 "Part IV - LIST OF
ATTACHMENTS  (Page 14) 

Attach any continuation sheets for sections of the form, test data, and
other data that may assist EPA review of an alternative after the last
page of the form.  Clearly identify the attachment and the section to
which it relates on page 14, where appropriate.  Number consecutively
the pages of each attachment and enter the inclusive page numbers on
page 14.  Enter the total number of pages in the notice, including
attachments, on page 1 of the form.

Mark (X) in the CBI box next to any attachment name that you claim as
confidential.  See Chapter 3 of this manual for information on how to
claim any information in an attachment as confidential.  

Part V - CERTIFICATION (Page 15) tc \l3 "Part V - CERTIFICATION  (Page
15) 

The official named in Part I, Section A of the form as the person
submitting the notice must sign the certification on page 15 of the
notice form.  This official is responsible for the truth and accuracy of
each statement in the certification.  If an agent assists you in
preparing the notice, the agent must also sign the certification.  All
signatures must be original.  If the submission is not signed, EPA will
consider the submission incomplete and will not review the substitute.

6. JOINT REVIEW WITH OTHER EPA OFFICES  tc \l1 "2. SUPPLEMENTARY
INFORMATION 

A.	What is the relationship between the SNAP Program and the New
Chemicals (Pre-Manufacture Notice) Program?

New chemical substitutes must undergo review both under section 612 of
the Clean Air Act (the SNAP program) and section 5 of TSCA (the New
Chemicals or Premanufacture Notice program).  EPA has established a
joint review process between the SNAP and TSCA Premanufacture Notice
(PMN) programs.  This process has been structured to minimize reporting
burden and to ensure consistency in decisions between the two programs. 


B.	What forms should I submit to the SNAP program and to the New
Chemicals program?

A submitter requesting review under both the SNAP and New Chemicals
programs should:

(	Complete the PMN form (EPA Form 7710-25) following the  HYPERLINK
"http://www.epa.gov/opptintr/newchems/pubs/pmnforms.htm" Instructions
Manual .

(	Indicate on page 11 of the PMN form, "Optional Pollution Prevention
Information," that the chemical is also to be considered under the SNAP
program.

(	Complete a SNAP TSCA addendum form, available at
http://www.epa.gov/ozone/snap/submit/index.html. 

The completed PMN form and the SNAP addendum together will comprise the
data submission for review and listing decisions for the SNAP program
for new chemicals to be used as ODS substitutes.  

Any questions regarding the completion of these forms can be directed to
either the PMN pre-notice coordinator or the SNAP DCO.

C.	When should I submit to the SNAP program if I am also submitting a
PMN?

EPA encourages you to submit to both programs at the same time. 
Contacting both programs early in your preparation of your submission
form and documents will help clarify procedures, ensure coordination of
reviews by the two programs, and generally result in a more expeditious
review of the information. 

D.	Do both the SNAP program and the New Chemicals program have a 90 day
review?

	Both the PMN and SNAP programs have a review period of 90 days.  For
the SNAP program, the 90-day period begins upon the date when EPA
receives all information needed for review and determines your
submission is complete.  For the New Chemicals program, the 90-day
review period is subject to suspensions and extensions described in the
PMN rule (40 CFR 720.75).  

E.	How does EPA treat confidentiality during co-review of a chemical
under the SNAP program and under the New Chemicals program?

EPA will treat all information claimed as confidential business
information (CBI) submitted as part of the joint PMN/SNAP review
consistent with TSCA security procedures.  Confidentiality claims will
be processed and reviewed in a manner consistent with 40 CFR Part 2,
Subpart B.  

When you send your TSCA/SNAP Addendum, please include in your cover
letter a statement that you are submitting information as “Clean Air
Act CBI.”  This will allow EPA’s SNAP program to share this
information with our contractors (authorized representatives) to assist
in our evaluation. There is no substantive difference in how CBI is
maintained under the Clean Air Act and under TSCA, but there are
different offices verifying that security requirements are met. 

F.	What is the relationship between the SNAP Program and review of
antimicrobials under FIFRA?

Any new pesticide or amendment of an existing formulation, including
antimicrobials, is already subject to Agency approval under provisions
of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), P.L.
100-460, 100-464 to 100-526, and 100-532.  Medical sterilants that
substitute for blends of ethylene oxide and CFC-12 or HCFCs are reviewed
both as substitutes for ODS under SNAP and as antimicrobials under
FIFRA.  FIFRA reviews will address factors commonly examined during
pesticide amendments and registrations.  The SNAP Program will also
consider atmospheric impacts such as ozone depletion potential, global
warming potential, and impacts on air quality.  The two program offices
responsible for these reviews will coordinate their efforts and share
pertinent data to ensure appropriate technical consideration of the
substitute.

G.	What form do I submit to SNAP for a sterilant?

You should submit the FIFRA form for pesticide registration to  EPA’s
Office of Pesticide Programs, and submit a copy of the SNAP Information
Notice form to the SNAP DCO.

If you are submitting an amendment to a product registration under
FIFRA that currently contains a class I or II ozone-depleting substance,
you should note in Section II ("Amendment Information") of the FIFRA
form that the amendment was filed in response to the CAA production
phase-out.  Similarly, if you are submitting an application for a new
pesticide registration that would otherwise have been based on a class I
or II compound, you should note in Section II of the FIFRA form that the
registration includes a class I or II ozone-depleting substitute.  You
should also identify both the substitute chemical and the class I or II
compound it is replacing.  Further, if you are aware that a particular
chemical intended for use as a substitute for an ozone-depleting
substance in a pesticide formulation has already been approved through
earlier SNAP/FIFRA determinations, you should also reference the
relevant part of the prior review.  

7.  CONSULTATION WITH EPA CONCERNING THE SNAP INFORMATION NOTICE tc \l2
"D.	Consultation with EPA Concerning the SNAP Information Notice 

A.	Where do I get more information about submitting to the SNAP program?

Copies of the SNAP rule, listing decisions, this Instruction manual, the
SNAP Information Notice form, the TSCA/SNAP Addendum and other materials
relating to the rule are available online on EPA’s SNAP web page
(http://www.epa.gov/ozone/snap/index.html).  You may contact the
Stratospheric Protection Division of EPA in Washington, DC at (202)
343-9410.  Written inquiries may be sent to:

SNAP Coordinator

U.S. EPA

Mail Code 6205J 

1200 Pennsylvania Ave. NW

Washington, DC  20460

B.	How will EPA interact with me after I submit to the SNAP program?

EPA’s 90-day notice review period begins when your notice is
determined to be complete by the SNAP Document Control Officer (DCO). 
You will receive written notification if EPA determines that your notice
is "incomplete" as described in (82.180.  If your notice is complete,
you will receive an acknowledgment letter confirming the date EPA
received your notification and the date EPA's 90-day review period
begins. If your alternative has already been listed under the SNAP
program for the proposed end-use, you will be notified that your
substitute is not subject to further SNAP review, and therefore you are
free to begin sale immediately.

Following expiration of EPA’s 90-day review period, you are free to
sell, import, export, and use your substitute, provided that EPA has not
already listed the alternative as unacceptable through
notice-and-comment rulemaking.

Review of petitions will occur by the same process and schedule as
submissions from manufacturers of new substitutes.

C.	How do I contact EPA’s SNAP program?

 tc \l2 "E.	EPA Contact Information 

Stratospheric Ozone Information Hotline	(800) 296-1996

Stratospheric Protection Division	(202) 343-9410

	

APPENDIX A: LIST OF END-USES WITHIN SECTORS INCLUDED IN THE SNAP
PROGRAM tc \l1 "APPENDIX A: LIST OF END-USES WITHIN SECTORS INCLUDED IN
THE SNAP PROGRAM 

Listings under the SNAP program are provided for specific end-uses that
previously used ozone-depleting substances, including the end-uses
listed below.  A listing in an end-use does not imply EPA has reviewed
the substitute for another end-use.  Please specify all end-uses for
which you would like to have your substitute evaluated.  If the product
or process for which the substitute is intended does not fit into one of
the following end-uses, please provide a description of the product or
process with adequate detail to assess the potential risks to human
health and the environment presented by using the substitute therein.

Refrigeration and Air Conditioning

Note: All end-uses within this sector are further broken down into
"Retrofit" and "New Equipment" subcategories

(	Commercial Comfort Air Conditioning (Centrifugal, Reciprocating, and
Screw Chillers);

(	Industrial Process Refrigeration Systems;

(	Industrial Process Air Conditioning;

(	Ice Skating Rinks;

(	Uranium Isotope Separation Processing;

(	Cold Storage Warehouses;

(	Refrigerated Transport;

(	Retail Food Refrigeration;

(	Vending Machines;

(	Water Coolers;

(	Commercial Ice Machines;

(	Household Refrigerators and Freezers;

Residential and Light Commercial Air Conditioning and Heat Pumps;

(	Residential Dehumidifiers;

(	Motor Vehicle Air Conditioning;

(   Motor Vehicle Air Conditioning for Buses and Passenger Rail       

(   Non-mechanical Heat Transfer;

(	Very Low Temperature Refrigeration

ODS replaced may include CFC-12, CFC-113, CFC-114, CFC-115, HCFC-22,
blends of HCFC-22 or

HCFC-142b, R-500, and R-502.

Foam Blowing

(	Polyurethane and Polyisocyanurate, Rigid Laminated Boardstock

(	Polyurethane, Rigid Appliance

(	Polyurethane, Rigid Spray, Commercial Refrigeration Foams, Spray Foams
and Sandwich Panel Foams

(	Polyurethane, Rigid Slabstock and Other

(	Polystyrene, Extruded Boardstock and Billet

(	Phenolic, Insulation Board

(	Polyurethane, Flexible

(	Polyurethane, Integral Skin

(	Polystyrene, Extruded Sheet

(	Polyolefin

ODS replaced may include CFC-11, CFC-12, CFC-113, CFC-114, HCFC-141b,
HCFC-142b, and HCFC-22.

Solvent Cleaning

(	Metals Cleaning

(	Electronics Cleaning

(	Precision Cleaning

ODS replaced may include methyl chloroform, CFC-113, and HCFC-225ca/cb.

Note that solvent cleaning applies to use in industrial cleaning
equipment such as vapor degreasers or automated, conveyorized equipment.
 SNAP does not currently cover dry cleaning, manual cleaning with
non-aerosol solvents, non-aerosol mold release agents, or component
testing agents. 

Fire Suppression and Explosion Protection

(	Streaming Agents

(	Total Flooding Agents

ODS replaced may include halon 1211, halon 1301, and HCFC blends.

Aerosols

(	Propellants

(	Solvents

ODS replaced may include CFC-11, HCFC-22, HCFC-142b, CFC-113, methyl
chloroform, HCFC-141b, and HCFC-225ca/cb.

Sterilants	

(	Medical sterilants

These replace the 12/88 Blend of EtO/CFC-12 or blends of ethylene oxide
and HCFC-22 or HCFC-124.

Tobacco Expansion

 Tobacco Expansion Agents

ODS replaced may include CFC-11.

Adhesives, Coatings, and Inks

(	Adhesives

(   Coatings

(   Inks

ODS replaced may include methyl chloroform or HCFC-141b.APPENDIX B:
SECTOR-SPECIFIC DATA REQUIREMENTS tc \l1 "APPENDIX B: SECTOR-SPECIFIC
DATA REQUIREMENTS 

The following lists give guidance about what particular characteristics
are of interest within each sector, in addition to Ozone Depletion
Potential and Global Warming Potential.

Refrigeration and Air Conditioning

Physical and Chemical Properties

(	Molecular weight

(	Physical state at room temperature

(	Boiling point

(	Vapor pressure (provide curve across a range of temperatures)

(	Critical temperature

(	Critical pressure

(	Flash point

(	Flammability limits (LFL, UFL)

(	Heat of combustion

(	Maximum pressure of combustion

(	Maximum rate of pressure increase during combustion

Suggested test data

(	ASTM E681 for flammability limits in air

(	Fractionation during leakage

Energy Efficiency

(	Laboratory testing of equipment using the alternative refrigerant vs.
the ODS being replaced.  Values should be given in kWh/day or a similar
measure.  Also address refrigerant/oil solubility.

(	Computer models should account for compressor efficiency, refrigerant
transport properties and mass flow rates for given tubing geometry,
capillary tube/suction line heat transfer, and liquid and vapor specific
heats.

Toxicity

( 	Cardiotoxicity

Foam Blowing

Physical and Chemical Properties

(	Thermal Conductivity

(	Flash Point

Energy Efficiency

Toxicity

(	Degradation Products

Solvents

Physical and Chemical Properties

(	Boiling Point

(	Specific Gravity

(	Odor Threshold

(	Solubility

(	Vapor Pressure

(	Dissociation constant

(	Volatilization from soil and water

(	pH

(	Flash Point

(	Flammability limits

Toxicity

(	List any PELs, STEL, AELs, etc.

(	Aquatic toxicity testing may be required

Fire Suppression Agents

Physical and Chemical Properties

(	Molecular weight

(	Boiling point

(	Specific gravity

(	Vapor pressure

(	Particle size distribution (applies to non-gaseous agents)

(	Vapor heat capacity

(	Heat of vaporization

(	Viscosity

(	Weight Equivalence

(	Storage Volume Equivalence

(	Extinguishment Concentration (specify method)

(	Design Concentration

Toxicity

(	Cardiotoxicity

(	Personal Monitoring (streaming agents)

(   Ocular and Dermal Irritation (powdered aerosols)

Formula for determining Weight and Volume Equivalence:

NOTE:  Weight and volume equivalents are calculated using a single,
fuel-specific design concentration (heptane); therefore, they do not
represent the exact weight or volume of the agent needed to protect any
specific space against any specific hazard.  The information used to
calculate the equivalents is provided from agent manufacturers and NFPA
2001, "Standard on Clean Agent Fire Extinguishing Systems."  Equivalents
are included in SNAP rulemakings for general comparison and
informational purposes only.

EPA understands that fire suppression agents must be evaluated in the
context of the fire extinguishing system equipment with which they are
used.  Design concentration, and weight and volume equivalents are only
meaningful when evaluated in specific system hardware configurations. 
This is especially important when comparing storage volume where storage
container fill density varies with the equipment used.  Agent fire
suppression performance will vary with the system used and the detailed
design of the system.  Therefore, fire suppression agent manufacturers
do not generally recommend design concentrations as these are also a
function of the system hardware in which they are used.  Hence, these
data are provided for general guidance only and do not reflect a
recommendation for system design or a basis for rigorous quantitative
comparison.

(1) Weight and volume equivalent data should be presented relative to
Halon 1301 at 120 per cent of cup burner as well as at 5 per cent, a
typical use concentration;

(2)  weight and volume equivalents should be based on agent
concentrations at Standard Temperature and Pressure;

(3)  weight and volume equivalents should be done at both the
manufacturer's recommended design concentration and at 120 per cent of
the cup burner value where the values are not the same;

(4)  volume equivalents will be based on agent volume only (exclusive of
container volume, fill density, etc.) at 70 degrees Fahrenheit and the
storage pressure specified by the manufacturer since this varies widely
and the required agent mass determined in item (5) below; and

(5)  the required agent weight equivalents should be determined by the
following equation:

W = V/S(C/100-C)

where C = design concentration (% volume)

V = one cubic foot

S = agent specific vapor volume at 70 degrees F (ft3/lb).

(6)  Appropriate references to the technical literature on which the
data are based should be provided.

Aerosols

Physical and Chemical Properties

(	Molecular weight

(	Boiling point

(	Odor threshold

(	Solubility

(	Vapor pressure

(	Flash point

(	Flammability limits

(	Explosive range

(	Viscosity

Toxicity

	(   Cardiotoxicity

Adhesives, Coatings, and Inks

Physical and Chemical Properties

(	Molecular weight

(	Physical state

(	Melting point

(	Boiling point

(	Specific gravity

(	Odor threshold

(	Solubility

(	Volatilization from water and soil

(	pH

(	Flash point

(	Flammability limits

(	Explosive range

Toxicity

Data requirements are similar to those for solvents.  Submit all
relevant data.

Sterilants

Physical and Chemical Properties

(	Molecular weight

(	Physical state

(	Vapor pressure

(	Specific gravity

(	Flash point

(	Flammability limits

(	Explosive range

Provide copies of toxicity testing provided for review under FIFRA
and/or FDA reviews

Pesticides - Review under FIFRA will cover most data analysis

Physical and Chemical Properties

(	Provide what data are readily available

Ozone Depletion Potential

(	Provide if information is available

Global Warming Potential

(	Provide if information is available

Cost and Use Information

 PAGE  3 

