Inventory
Update
Rule
Amendments
Data
Use
Plan
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
Economics,
Exposure,
and
Technology
Division
August
23,
2002
Inventory
Update
Rule
Amendments
Data
Use
Plan
This
document
provides
an
overview
of
uses
of
the
data
to
be
collected
once
the
TSCA
Inventory
Update
Rule
Amendments
(
IURA)
are
finalized.
Specific
examples,
complete
with
sample
mockup
tables
and
reports,
are
included
in
the
final
section
of
this
report.

I.
Introduction
The
IURA
will
provide
data
on
over
9,000
chemicals,
including
processing
and
use
data
for
about
4,000
of
those
chemicals.
The
current
IUR
database
is
the
backbone
of
almost
all
of
EPA's
Office
of
Pollution
Prevention
and
Toxic's
(
OPPT's)
programs.
It
is
the
only
broad­
scope
database
of
chemical
production
available
and,
as
mandated
by
law,
is
updated
regularly
to
reflect
changes
in
the
dynamic
chemical
industry.
The
IUR
Amendments
(
IURA)
will
greatly
enhance
the
utility
of
the
IUR
data
by
adding
general
exposure,
processing,
and
use
information
to
the
bare­
bones
production
data
currently
collected.
As
with
the
Toxics
Release
Inventory
(
TRI)
data
EPA
collects,
it
is
impossible
to
predict
all
of
the
myriad
uses
for
the
IURA
data.
Just
as
the
current
IUR
is
used
on
a
day­
to­
day
basis
within
OPPT
and
the
Agency
at
large,
the
improved
IURA
will
be
of
even
greater
use,
and
will
help
EPA
and
others
to
make
sound
policy
decisions
regarding
chemical
safety.

EPA
is
authorized
under
TSCA
to
collect
information
on
the
chemical
industry.
EPA
will
use
the
IURA
data
to
assist
in
prioritizing
and
assessing
the
potential
risks
presented
by
the
use
of
thousands
of
chemicals
in
the
United
States.
Not
only
will
the
IURA
information
enable
the
Agency
to
identify
and
begin
to
address
potential
risks
faster,
it
will
allow
more
effective
and
efficient
use
of
Agency
and
other
scarce
public
resources.

The
need
for
EPA
to
properly
allocate
resources
and
set
priorities
for
its
programs
has
been
widely
recognized
and
documented.
Reports
by
the
Science
Advisory
Board
("
Reducing
Risk:
Setting
Priorities
and
Strategies
for
Environmental
Protection")
and
the
National
Academy
of
Public
Administration
("
Setting
Priorities,
Getting
Results,
A
New
Direction
for
EPA")
recognize
that
EPA's
ability
to
improve
the
way
it
sets
priorities
and
allocates
resources
has
been
limited
by
the
lack
of
current
exposure
data.
The
IURA
data
will
improve
the
Agency's
ability
to
identify
chemical
substances
or
industry
sectors
that
may
pose
the
greatest
risk
to
human
health
and
the
environment.

In
setting
priorities
for
its
programs,
EPA
utilizes
a
variety
of
paradigms.
Most
often,
both
the
effects
of
the
chemical
substances
on
health
and
the
magnitude
of
exposure
to
such
chemical
substances
are
factors
in
establishing
priorities,
assessing
potential
risks,
and
making
risk
management
decisions.
The
IURA
focuses
on
the
exposure
factor.
1Originally
compiled
in
1977,
the
TSCA
Chemical
Inventory
is
a
comprehensive
listing
of
chemicals
in
commerce
in
the
United
States.
Chemicals
are
added
to
the
Inventory
when
a
Notice
of
Commencement
(
NOC)
is
submitted
to
the
Agency,
after
the
chemical
has
been
submitted
to
EPA's
New
Chemicals
program.

2Manufacturers
and
importers
of
organic
chemicals
producing
10,000
lbs
or
more
per
site
report
under
the
current
IUR.
Chemicals
excluded
from
the
current
IUR
include
polymers,
inorganic
substances,
microorganisms,
and
naturally
occurring
chemical
substances.
Chemicals
subject
to
reporting
will
be
altered
by
the
IURA
to
include
inorganic
chemicals
but
to
exclude
natural
gas
chemicals
(
6
specific
substances).
Additionally,
the
reporting
threshold
will
be
raised
to
25,000
lbs
or
more
per
chemical
per
site.

3The
Chemical
Identifying
number
is
required
reporting
for
both
the
current
IUR
and
the
amended
IUR;
however,
the
IURA
will
limit
the
identifying
number
to
only
those
three
listed
here.
II.
Description
of
Data
IURA
data
will
be
submitted
by
manufacturers
and
importers
of
certain
chemicals
listed
on
the
TSCA
Chemical
Inventory.
1
The
TSCA
Inventory
does
not
include
substances
specifically
excluded
by
statute
or
regulation,
such
as
pesticides.
Under
the
IURA,
manufacturers
and
importers
of
subject
chemicals
will
report
the
following
for
chemicals
produced
or
imported
in
volumes
of
25,000
lbs
or
greater
per
site
(
not
per
company),
to
the
extent
that
this
information
is
known
to
or
"
reasonably
ascertainable"
by
the
submitter.
(
data
elements
identified
by
an
asterisk
(*)
are
submitted
through
the
current
Inventory
Update
Rule2):

°
*
Parent
company
name
°
Parent
company
Dun
&
Bradstreet
number
°
*
Technical
contact
name,
address,
and
phone
number
°
Technical
contact
e­
mail
address
°
*
Plant
site
name,
address,
and
Dun
&
Bradstreet
number
°
Plant
site
county
°
*
Chemical
name
and
identifying
number
(
CAS
registry
number,
accession
number,
or
PMN
case
number)
3
°
*
Site
limited
status
°
*
Activity
(
is
the
chemical
manufactured
or
imported?)
°
*
Production
volume
°
Number
of
workers
reasonably
likely
to
be
exposed
to
the
chemical
(
reported
in
ranges)
°
Maximum
concentration
of
the
chemical
(
when
leaving
plant)
(
reported
in
ranges)
°
Physical
form(
s)
and
associated
percent
production
volumes
4Certain
multichemical
petroleum
streams
and
other
specifically
listed
chemical
substances
are
exempted
from
this
part
of
the
reporting,
regardless
of
production
volume.
Subject
inorganic
chemicals
will
report
this
information
beginning
with
the
second
reporting
period
following
promulgation
of
the
IURA.
Manufacturers
and
importers
of
subject
chemicals
will
also
report
the
following
for
chemicals
produced
or
imported
in
volumes
of
300,000
lbs
or
greater
per
site
(
not
per
company),
to
the
extent
that
such
information
is
"
readily
obtainable"
by
the
submitter:
4
°
Industrial
Processing
and
Use
data
S
Type
of
Process
or
Use
S
North
American
Industrial
Classification
System
(
NAICS)
5­
digit
code
S
Industrial
Function
Categories
S
Percent
Production
Volume
S
Number
of
Sites
(
reported
in
ranges)

S
Number
of
Workers
(
reported
in
ranges)

°
Commercial
and
Consumer
End­
Use
data
S
Commercial
and
Consumer
Product
Categories
S
Use
in
Children's
Products
S
Percent
Production
Volume
Associated
with
Each
Category
S
Maximum
Concentration
Associated
with
Each
Category
(
reported
in
ranges)

Table
1
briefly
discusses
specific
potential
uses
of
each
processing
and
use
data
element.
The
rest
of
this
document
discusses
and
provides
examples
of
the
overall
use
of
the
IURA
data.
5
Table
1:
Utility
of
IURA
Processing
and
Use
Data
by
Data
Elements
Data
Elements
Use
of
Data
Element
Consequence
of
Not
Having
Data
Industrial
Processing
and
Use
Information
Part
III
­
Section
I.
Processing
and
Use
Information
Type
of
Process
or
Use
(
code,
CBI)
The
Type
of
Process
or
Use,
along
with
NAICS
and
Industrial
Function
Category
(
IFC)
codes,
provides
basic
information
for
EPA
to
develop
potential
exposure
scenarios.
This
data
element
also
affects
EPA's
decisionmaking
during
risk
screening
exercises.
For
example,
a
process
and
use
code
indicating
repackaging
(
PK:
Processing
 
repackaging)
would
potentially
indicate
lower
exposures
than
a
process
and
use
code
indicating
that
a
chemical
is
incorporated
into
a
formulation
or
mixture
(
PF:
Processing
 
incorporating
into
formulation,
mixture
or
reaction
product.)
Processing
and
use
code
descriptions
contain
basic
TSCA
statutory
terms
that
are
essential
for
characterizing
exposures.
Without
these
data,
EPA
must
conservatively
assume
that
chemicals
are
processed
and
used
in
the
operations
that
result
in
potentially
higher
exposures
and
releases.
The
absence
of
these
data
may
result
in
overly
conservative
characterizations
of
exposures.

NAICS
(
code,
CBI)
NAICS
information
describes
the
industrial
sectors
associated
with
each
industrial
processing
or
use
operation
reported.
Some
EPA
tools,
such
as
EFAST
(
Exposure,
Fate
Assessment
Screening
Tool),
use
industrial
sector
information
to
select
streamflow
distributions
which
are
needed
to
estimate
surface
water
concentrations
and
hence
indirect
human
exposures
and
risks
from
ingestion
of
contaminated
drinking
water
and
contaminated
fish
as
well
as
risk
to
aquatic
organisms.
Without
this
information,
EPA
must
make
assumptions
and
generalizations
regarding
industrial
operations,
which
increases
the
opportunity
for
mischaracterization
of
industrial
processes
and
releases
and
occupational,
indirect
human
and
environmental
exposures
associated
with
those
processes.

Industrial
Function
Category
(
code,
CBI)
The
Industrial
Function
Category
(
IFC)
indicates
the
types
of
activities
that
workers
may
be
involved
in
and,
subsequently,
the
types
of
exposures
they
may
encounter.
EPA
tools
such
as
ChemSTEER
(
Chemical
Screening
Tool
for
Exposures
and
Environmental
Releases)
use
industrial
function
information
to
select
specific
scenarios
for
exposure
and
release
estimates.

For
example,
a
solvent
that
is
used
for
cleaning
and
degreasing
(
IFC
U27
 
Solvents
for
cleaning
and
degreasing)
would
not
have
the
same
exposure
and
release
assessment
as
a
solvent
used
for
chemical
manufacture
(
IFC
U29
 
Solvents
for
chemical
manufacture
and
processing).
A
cleaning
and
degreasing
solvent
may
be
used
in
a
manner
that
directly
exposes
users
to
vapors,
while
a
solvent
used
in
manufacturing
may
be
used
in
a
closed
system.
Absence
of
the
Industrial
Function
Category
data
will
require
EPA
to
make
generic
assumptions
about
how
a
chemical
is
processed
and
used.
These
assumptions
may
result
in
mischaracterized
worker
activities
and
occupational
exposures
to
chemical
substances,

which
would
lead
to
erroneous
risk
scenarios.
Table
1:
Utility
of
IURA
Processing
and
Use
Data
by
Data
Elements
Data
Elements
Use
of
Data
Element
Consequence
of
Not
Having
Data
6
%
Production
Volume
(%,
CBI)
The
Percent
Production
Volume
(%
PV)
will
enable
EPA
to
allocate
specific
portions
of
a
production
volume
to
certain
combinations
of
Processing
and
Use
Categories,
NAICS,
and
Industrial
Function
Categor
codes.
%
PV
is
a
direct
input
for
the
EPA
ChemSTEER
tool.
For
most
chemicals,
%
PV
is
currently
rarely
available.
EPA's
new
chemical
PMN
form
does
include
this
data
element;
however,
the
information
is
provided
before
the
chemical
is
introduced
to
the
market
and
is
expected
to
change
over
time.
ChemSTEER
uses
this
data
element
to
allocate
exposures
and
releases
to
appropriate
populations
and
media.
Without
Percent
Production
Volume,
EPA
will
have
to
use
a
variety
of
other
methods
to
estimate
the
production
volume
allocation,

resulting
in
conservative
allocations
to
processing
and
use
categories
that
could
overestimate
worker
exposure,
general
population
exposure,
and
environmental
releases.

Number
of
Sites
(
code,
CBI)
The
Number
of
Sites
enables
EPA
to
estimate
the
extent
of
general
population
exposures,
as
well
as
to
allocate
releases
to
land,
air,
and
water.

This
data
element
is
a
direct
input
for
the
ChemSTEER
and
E­
FAST
tools,

which
were
developed
for
EPA's
new
chemicals
program
but
are
also
used
to
evaluate
existing
chemicals.
The
number
of
sites
is
a
data
element
in
the
PMN
submissions,
but
is
not
consistently
provided.
In
instances
where
it
is
not
provided
and
for
existing
chemicals,
EPA
must
rely
on
Generic
Scenarios
and/
or
past
PMN
cases
that
may
not
be
good
"
use"
analogs
for
a
chemical
currently
under
review
(
see
attached
example
3
for
a
further
discussion
of
generic
scenarios).
The
number
of
sites
directly
affects
the
distribution
of
general
population
exposures
as
well
as
environmental
releases.
This
data
element,
along
with
Number
of
Workers,
would
also
provide
exposure
data
for
the
Use
Cluster
Scoring
System
(
UCSS),
a
priority
setting
tool
used
to
rank
clusters
of
chemicals.
[
A
chemical
cluster
is
a
group
of
chemicals
that
perform
a
similar
function
(
e.
g.
surfactant).]
The
absence
of
the
Number
of
Sites
handicaps
EPA's
ability
to
provide
the
public
with
general
population
exposure
information,
as
well
as
potential
environmental
release
information.
Table
1:
Utility
of
IURA
Processing
and
Use
Data
by
Data
Elements
Data
Elements
Use
of
Data
Element
Consequence
of
Not
Having
Data
7
Number
of
Workers
(
code,
CBI)
The
Number
of
Workers
provides
an
indication
of
the
size
of
the
potentially
exposed
working
population.
This
data
element
is
vital
to
chemical
exposure
screening
since,
in
many
cases,
the
highest
potential
for
exposure
occurs
during
the
processing
and
use
of
a
chemical.
The
Number
of
Workers
is
a
primary
input
for
the
ChemSTEER
tool
and
is
used
in
conjunction
with
estimated
chemical
dose,
a
valuable
input
to
screening
chemicals
for
exposure
risk.
This
data
element
would
also
provide
much
needed
exposure
data
to
the
UCCS,
which
has
been
criticized
in
the
past
for
the
absence
of
such
data.
The
Number
of
Workers
is
useful
to
make
test
rule
exposure
findings.
Without
these
data,

EPA
at
times
cannot
proceed
with
a
needed
test
rule,
and
may
not
be
able
to
determine
if
a
test
rule
is
even
needed.
This
information
is
also
essential
for
evaluating
occupational
exposures.
However,
it
is
not
typically
available
and
is
difficult
to
estimate.
The
best
data
available
are
the
NOES
data,
which
are
limited
due
to
age
(
20
years
old)
and
scope.

EPA
has
been
criticized
by
industry
for
using
NOES
data.

Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Commercial
and
Consumer
Product
Category
(
code,
CBI)
The
Commercial
and
Consumer
Product
Category
indicates
the
types
of
products
to
which
consumers
and
nonindustrial
workers
may
be
exposed.

The
Commercial
and
Consumer
Product
Category
is
a
direct
input
for
EFAST
(
E­
FAST
Consumer
Exposure
Module).
This
information
may
also
be
useful
in
updating
the
Indoor
Air
Source
Ranking
Database
(
SRD),
a
prioritysetting
tool
used
by
EPA
in
identifying
potential
chemicals
used
in
products.
The
absence
of
these
data
would
require
EPA
to
make
generic
assumptions
about
how
a
chemical
is
used
and
what
types
of
products
contain
certain
chemical
substances.
This
element
is
important
in
characterizing
whether
a
chemical
is
used
in
consumer
and
commercial
applications.
Some
of
the
most
vulnerable
populations
such
as
the
elderly
and
children
could
be
exposed
to
chemicals
of
concern
that
have
primarily
commercial
and
consumer
uses.
Table
1:
Utility
of
IURA
Processing
and
Use
Data
by
Data
Elements
Data
Elements
Use
of
Data
Element
Consequence
of
Not
Having
Data
8
Use
in
Children's
Product
(
y/
n/?,
CBI)
Identifying
the
presence
of
a
chemical
in
products
intended
for
use
by
children
furthers
the
Agency's
commitment
to
children's
protection.
Through
collection
of
these
data,
EPA
will
obtain
needed
information
regarding
the
use
of
inventory
chemicals
in
children's
products.
Additionally,
the
Agency
will
be
able
to
track
changes
from
one
reporting
period
to
the
next.
Eliminating
these
data
will
deny
EPA
the
opportunity
to
track
changes
in
the
use
of
various
chemicals
in
children's
products
and
will
put
the
Agency
in
a
serious
information
deficit
in
instances
where
concerns
are
raised
about
the
use
of
specific
chemicals
in
children's
products.
Children,
an
especially
vulnerable
subpopulation,
may
not
be
afforded
protection
from
chemical
exposures.

Percent
Production
Volume
Associated
with
Each
Category
(%,
CBI)
This
data
element
will
enable
EPA
to
allocate
specific
portions
of
a
production
volume
among
commercial
and
consumer
end­
use
categories.

This
will
allow
EPA
to
input
more
accurate
use
volume
information
into
the
E­
FAST
tool,
which
evaluates
general
population
risks.
Without
these
data,
EPA
will
have
to
resort
to
conservative
allocations
of
the
production
volume
to
consumer
and
commercial
use
categories
that
could
overestimate
general
population
exposure.

Maximum
Concentration
Associated
with
Each
Category
(
code,
CBI)
Chemical
Concentration
is
an
essential
element
of
occupational
exposure
models
used
for
screening
chemicals.
This
data
element
also
establishes
upper
limits
for
exposure
and
releases
and
is
a
direct
input
to
the
ChemSTEER
and
E­
FAST
tools.
Absence
of
chemical
concentration
would
require
EPA
to
use
worst­
case
chemical
concentration
estimates
and
would
potentially
generate
overestimates
of
exposure.
Errors
in
chemical
concentration
directly
impact
hazard
rankings
and
cause
relative
risks
to
be
misperceived.
9
III.
Data
Management
OPPT's
Information
Management
Division
is
responsible
for
receiving
and
managing
the
IURA
data.
When
received,
IURA
reports
will
be
quickly
reviewed
for
completeness
and
entered
into
the
IUR
database.
Both
Agency
staff
and
contractor
support
will
be
dedicated
to
IURA
processing
activities.
Based
on
EPA
experience
with
the
1998
IUR
collection,
a
very
high
percentage
of
forms
(
perhaps
as
high
as
95%)
will
be
submitted
electronically,
using
IURA
software.
The
use
of
electronic
reporting
will
ensure
that
IURA
data
will
be
readily
available
and
not
subject
to
subsequent
data
entry
errors.
Additionally,
the
database
will
provide
the
IURA
data
in
a
form
suitable
for
the
OPPT
analytical
databases
and
tools.

EPA
will
begin
processing
upon
receipt
of
the
first
IURA
form.
The
agency
expects
to
complete
all
data
management
activities,
such
as
providing
quality
control
for
manually
processed
forms,
ensuring
that
all
chemicals
reported
are
on
the
TSCA
Inventory,
investigating
CBI
claims,
and
identifying
and
combining
joint
submissions,
within
5
months
of
the
end
of
the
reporting
period.
Any
issues
that
arise
after
the
completion
date
(
such
as
IUR
corrections
filed
by
industry)
will
be
handled
as
expeditiously
as
possible.

IV.
Discussion
and
Examples
of
Data
Uses
The
IURA
database
will
be
a
fairly
shallow
but
broad
collection
of
exposure­
related
information
from
a
small
portion
of
the
over
76,000
chemicals
on
the
TSCA
Chemical
Inventory.
Only
TSCA
provides
the
authority
for
EPA
to
collect
this
type
of
information
­
and
to
collect
it
regularly
so
that
information
remains
current
and
trends
can
be
identified.
EPA
will
use
this
use
and
exposurerelated
information
database
to:

°
Support
priority
setting
and
risk­
based
screening
of
chemicals
(
e.
g.,
IURA
data
can
be
used
to
provide
a
risk­
based
context
for
hazard
information
being
submitted
under
the
HPV
Challenge
Program);
°
Empower
resource
allocation
decisions
by
enabling
EPA
to
make
science­
based
decisions
about
which
chemicals
to
focus
its
limited
resources
on
for
further
review;
°
Provide
a
first
place
to
look
when
a
new
concern
is
identified;
°
Provide
an
overview
of
chemical
use
and
exposure,
over
time,
in
a
unique
database;
°
Inform
a
variety
of
Agency
and
other
programs,
such
as
the
TSCA
testing
program,
OSW
programs,
and
NIOSH,
OSHA,
and
CPSC
programs;
°
Provide
initial
exposure
information
for
the
development
of
government,
industry,
and
public
programs,
such
as
EPA's
voluntary
programs
(
e.
g.,
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP)
or
Design
for
the
Environment
(
DfE));
and
°
Enhance
EPA's
ability
to
meet
statutory
obligations
under
the
Government
Performance
and
Results
Act
(
GPRA).

These
are
discussed
in
more
detail
below.
10
Supporting
Risk­
Based
Screening
of
Chemicals
Data
obtained
through
the
IURA
will
provide
EPA
with
general
information
on
exposure
to
chemicals
during
their
manufacture,
processing,
and
use.
Used
in
conjunction
with
hazard
information
from
the
HPV
Challenge
Program,
the
Voluntary
Children's
Chemical
Exposure
Program,
and
other
sources,
EPA
will
use
the
IURA
data
to
identify
priorities
and
make
risk
management
decisions
(
based
upon
appropriate
additional
information
and/
or
analyses).
If
the
additional
analysis
indicates
that
there
is
a
reasonable
basis
to
conclude
that
the
manufacture,
processing,
distribution
in
commerce,
use,
or
disposal
of
a
chemical
substance
or
mixture
presents
an
unreasonable
risk
of
injury
to
health
or
the
environment,
the
Agency
can
take
action
to
mitigate
the
risk.

To
assess
and
rank
relative
risks,
EPA
will
use
tools
such
as
the
Use
Cluster
Scoring
System
(
UCSS),
a
flexible
tool
that
groups
chemical
substances
by
relative
risk
and
suggests
alternative
chemicals
that
can
be
used
to
minimize
risk.
Incorporating
exposure
data
from
the
IURA
and
hazard
data
from
other
sources,
EPA
can
use
the
UCSS
to
develop
relative
risk­
based
rankings
of
chemicals
and
industries
which
may
potentially
expose
workers,
the
general
population,
and
the
environment.
Example
4,
attached,
further
explains
how
the
UCSS
works.
Priority
setting
using
the
IURA
information
in
the
UCSS
will
provide
Agency
decision­
makers
with
the
information
needed
to
determine
where
more
detailed
assessments
are
needed.
These
assessments
could
lead
to
regulatory
actions,
cooperative
investigations
with
other
agencies
of
the
Federal
Government,
or
other
nonregulatory
actions.
IURA
data
will
provide
necessary
information
to
initially
screen
chemicals,
helping
to
prioritize
and
direct
Agency
actions
to
chemicals
posing
higher
potential
risks
to
workers,
vulnerable
subgroups,
and
the
general
population
of
the
United
States
and
will
further
the
goal
of
creating
a
chemically
safe
America.

Empowering
Resource
Allocation
Decisions
Information
is
key
to
making
good
resource
allocation
decisions.
The
Agency
needs
more
information
on
chemicals
to
determine
where
its
programs
should
focus,
and
to
determine
which
programs
should
get
a
greater
emphasis,
which
programs
are
less
effective,
or
which
chemicals
are
of
lesser
concern.
The
IURA
will
provide
information
vital
to
these
decisions.
For
example,
the
Agency
could
use
potential
exposure
data
for
workers
and
children
to
identify
EPA
programs
that
may
warrant
a
greater
emphasis
and
perhaps
higher
budget
considerations.

Providing
a
First
Place
to
Look
When
a
New
Concern
is
Identified
New
human
health
and
environmental
concerns
arise
from
many
sources:
the
presence
of
persistent
chemicals
in
species
used
for
human
consumption,
the
occurrence
of
unanticipated
chemicals
in
human
biological
samples,
association
of
environmental
effects
with
untoward
outcomes
in
fauna,
and
the
occurrence
of
deleterious
health
effects
in
workers
in
selected
occupations.
The
IURA
will
provide
a
readily
available
database
that
can
be
used
to
rapidly
evaluate
the
existence
of
potential
exposures.
11
Providing
an
Overview
of
Chemical
Use
and
Exposure,
over
Time,
in
a
Unique
Database
The
IURA
will
require
industry
to
assess
the
potential
of
worker,
general
population,
and
children's
exposure
to
chemical
substances.
By
highlighting
these
potential
exposures,
the
IURA
may
motivate
chemical
producers
to
minimize
exposure
of
workers,
select
alternative
chemical
substances
that
are
less
persistent,
bioaccumulative,
and
toxic,
and
to
carefully
consider
the
use
of
chemical
substances
in
products
used
by
sensitive
subpopulations,
such
as
children.
Quadrennial
reporting
of
the
IURA
information
allows
the
Agency
and
others
to
identify
changes
over
time
and
to
evaluate
the
effect
of
those
changes.

The
IURA
data
will
also
allow
for
trend
analyses
of
chemicals,
such
as
measuring
success
of
a
regulatory
or
voluntary
program
(
e.
g.,
lead
or
DfE).
The
increasing
or
declining
volumes
of
chemicals
in
certain
use
categories
can
be
used
as
a
measure
of
the
effect
of
a
program
or
focus.
This
is
especially
important
in
voluntary
programs,
where
it
can
be
difficult
to
evaluate
the
effectiveness
of
programs.

Informing
a
Variety
of
Agency
and
Other
Programs
The
chemical
industry
is
dynamic,
as
demonstrated
by
the
30%
change
in
chemicals
reported
to
the
IUR
from
one
reporting
period
to
the
next.
The
Agency
needs
updated
information
to
allow
its
programs
to
be
relevant
and
current.
However,
EPA's
efforts
to
collect
information
on
a
variety
of
chemical
substances
have
been
hindered
by
a
lack
of
resources
and
a
disparity
of
methods
and
objectives.
For
example,
NIOSH's
National
Occupational
Exposure
Survey
(
NOES)
data,
which
characterize
worker
exposure
to
chemicals
and
other
hazards
in
the
workplace,
are
over
two
decades
old.
EPA,
as
well
as
NIOSH,
OSHA,
and
other
concerned
parties,
requires
a
database
that
is
current
and
able
to
readily
provide
data
when
a
potential
occupational
hazard
is
identified.
In
addition
to
providing
a
rapid
response,
the
IURA
database
will
allow
the
Agency
more
effective
and
efficient
use
of
limited
resources
in
determining
which
occupational
and
environmental
hazards
of
concern
to
investigate.

Providing
Initial
Exposure
Information
for
the
Development
of
Agency
and
Public
Programs
The
IURA
information
will
provide
a
starting
point
for
the
development
of
programs
to
identify
chemicals
and
groups
of
chemicals
based
upon
use
or
other
exposure
criteria.
A
broad­
based
reservoir
of
information
is
needed
to
rank
and
compare
all
chemical
substances.
Data
to
be
collected
under
the
IURA
will
inform
decision­
makers
about
alternative
chemical
exposures,
and
therefore
potential
risks,
that
should
be
considered
before
committing
resources
to
more
in­
depth
study.
This
is
anticipated
to
be
especially
true
for
subpopulations
likely
to
be
exposed
to
greater
amounts
of
hazardous
chemical
substances,
such
as
workers,
or
those
likely
to
be
more
affected
by
exposures,
such
as
children
(
due
to
their
smaller
body
mass).
12
Encouraging
the
Development
of
Information
Needed
for
Industry
Product
Stewardship
Programs
IURA
information
can
be
used
to
start
or
improve
industry
product
stewardship
programs.
By
requiring
industry
to
collect
and
report
on
the
exposures
of
workers
and
others,
this
information
will
be
brought
to
the
attention
of
the
chemical
industry
and
may
encourage
companies
to
reduce
potential
exposures,
possibly
improving
their
public
image.

Enhancing
EPA's
Ability
to
Meet
Statutory
Obligations
Under
GPRA
Under
the
GPRA,
EPA
is
accountable
for
using
resources
wisely
and
achieving
program
results.
GPRA
requires
agencies
to
develop
plans
for
what
they
intend
to
accomplish,
measure
how
well
they
are
doing,
make
appropriate
decisions
based
on
the
information
they
have
gathered,
and
communicate
information
about
their
performance
to
Congress
and
to
the
public.
The
IURA
data,
especially
the
new
data
on
the
potential
exposure
of
workers
and
on
the
uses
of
the
chemicals,
will
allow
EPA
to
better
allocate
resources.
As
a
result,
EPA
can
meet
GPRA
goals
in
a
more
cost­
effective
way.

Other
Uses
of
IURA
Data
1)
The
IURA
will
provide
data
needed
to
develop
proactive
strategies
to
identify
and
manage
high
risk
chemicals
and
use
activities.
The
IURA
data
can
provide
real
data
confirmation
of
assumed
trends
and
practices.

2)
The
IURA
data
will
improve
analyses
conducted
under
TSCA
for
both
the
existing
chemicals
program
(
e.
g.,
SIDS)
and
the
new
chemicals
program
(
e.
g.,
evaluation
of
PMN
submissions).
For
instance,
the
data
will
enhance
industry­
specific
occupational
exposure
and
release
estimate
documents.
These
documents
contain
generic
approaches
used
to
develop
screening­
level
environmental
release
and
occupational
exposure
estimates
for
new
chemicals
when
actual
data
are
not
available.

3)
IURA
data
will
help
build
a
more
complete
industry
profile.
A
more
complete
profile
would
improve
the
accuracy
of
impact
assessments
of
proposed
rulemakings
(
e.
g.,
which
chemicals
are
used
in
which
industries,
how
many
facilities
in
each
sector
may
be
affected
by
regulation
pertaining
to
specific
chemicals.)

4)
EPA's
sector­
based
programs
will
benefit
from
access
to
a
much
broader
set
of
chemical
use
data
that
can
be
characterized
by
type
of
process
and
industrial
sector.
Improvement
will
come
from
an
enhanced
ability
to
prioritize
future
efforts
and
more
accurate
analyses
due
to
improved
raw
data.
For
example:

°
The
Design
for
the
Environment
(
DfE)
program
can
access
IURA
data
to
decide
where
to
focus
future
resources
and
effort
for
maximum
positive
effect.
13
°
The
TRI
program
can
use
the
IURA
data
to
assess
the
need
for
future
rulemaking
with
respect
to
chemicals
and
industries.
IURA
data
will
be
useful
in
evaluating
program
scope
and
when
considering
either
expansions
or
reductions.
°
IURA
data
could
help
maximize
the
effectiveness
of
compliance
assistance
efforts,
by
guiding
effort
toward
those
sectors
with
the
greatest
potential
for
significant
environmental
releases
or
occupational
and
consumer
exposures.

5)
The
IURA
data
will
provide
a
broad
framework
to
support
exposure
assessments.
For
example,
it
is
essential
to
have
broad
and
current
exposure
information
to
combine
with
the
toxicity
data
generated
under
the
High
Production
Volume
(
HPV)
Chemical
initiative.
In
the
absence
of
other
information,
the
IURA
will
supply
the
initial
information
to
help
put
the
HPV
hazard
data
into
context,
allowing
the
Agency
to
begin
to
prioritize
and
screen
those
chemicals
for
potential
risk.

6)
The
IURA
data
will
help
identify
potential
pollutants
of
concern
during
sector­
based
regulatory
development
efforts
conducted
under
the
Clean
Water
Act.

7)
Over
time,
the
IURA
data
will
provide
a
broad
set
of
chemical
use
and
exposure­
related
data
for
environmental
performance
tracking
and
measurement.

8)
IURA
data
could
be
used
to
help
shape
green
programs
to
target
the
sectors,
processes,
and
chemicals
with
the
greatest
potential
for
exposure
or
risk
reduction.

9)
The
IURA
will
provide
broader,
more
up­
to­
date
data
on
chemical
use
and
potential
exposure
than
other
Federal
programs
such
as
the
NIOSH
National
Occupational
Exposure
Survey
(
NOES).

10)
The
production
volume
and
NAICS
code
information
can
be
used
to
estimate
typical
use
rates
for
each
industry
sector
when
more
detailed
information
is
not
available.
Use
rates
are
an
estimation
of
the
rate
of
use
or
consumption
of
a
chemical
(
typically)
on
a
per
site
basis
 
different
exposures
are
expected
at
sites
with
larger
volumes
than
at
sites
with
smaller
volumes.
These
rates
can
be
used
by
any
program
office
to
enhance
an
industry
profile.

11)
The
production
volume
and
NAICS
code
information
can
also
be
used
in
combination
with
release
data
from
the
TRI
program
to
calculate
emission
factors.
When
actual
use
or
emission
data
are
not
available,
emission
factors
serve
as
surrogate
estimates
of
rates
of
release
that
are
based
on
the
rate
of
chemical
feed
(
e.
g.,
1
pound
of
chemical
X
fed
into
Process
A
yields
5
pounds
of
process
waste.
Therefore,
10
pounds
of
chemical
X
feed
would
yield
50
pounds
of
waste.).
14
V.
Sample
Reports
of
IURA
Data
Attached
are
sample
reports
that
can
be
prepared
from
the
IURA
data
submitted
by
industry.
The
reports
illustrate
a
diversity
of
uses
for
IURA
data
such
as
priority
setting,
initial
risk
screening,
trend
analysis,
identification
of
chemical
substitutes,
and
regulatory
efforts
such
as
the
TSCA
testing
program.
It
should
be
noted
that,
as
with
other
data
collection
efforts
such
as
TRI,
it
is
difficult
to
identify
all
possible
uses
for
the
data.
The
discussion
above
and
the
sample
reports
demonstrate
the
usefulness
and
importance
of
the
IURA
data.

All
of
the
data
used
in
these
examples
are
made
up.

EPA
Examples
Example
1:
Overall
screening
of
full
data
set
­
Example
Report
Example
2:
Using
IURA
Data
for
Prioritization
Example
3:
Using
IURA
Data
for
TSCA
Pre­
Manufacturing
Notice
(
PMN)
Review
Example
4:
Use
of
IURA
Data
by
OPPT
to
Prioritize
Chemicals
and
Industry
Sectors,
and
to
Identify
Potential
Substitutes
Example
5:
Using
IURA
Data
for
Trend
Analysis
Example
6:
Using
IURA
Data
to
Meet
GPRA
Requirements
Example
7:
Using
IURA
Data
to
Meet
GPRA
Requirements
Example
8:
IUR
Data
Use
and
Green
Chemistry
Challenge
Awards
Example
9:
Using
IURA
Data
by
Office
of
Water
to
Identify
Pollutants
of
Concern
for
Regulatory
Development
Other
Examples
Example
10:
OSHA
Use
of
IURA
Data
Example
11:
CPSC
Use
of
IURA
Data
15
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
1:
Overall
screening
of
full
data
set
­
Example
Report
(
please
note
­
this
example
is
several
pages
long
and
is
in
the
form
of
a
report)

Summary
of
Chemical
Screening
Using
IURA
Data
HYPOTHETICAL
REPORT
Office
of
Pollution
Prevention
and
Toxics
Washington,
DC
Examples
are
for
explanatory
purposes
only
and
do
not
use
actual
TSCA
CBI
data.
All
data
used
in
this
report
are
made
up.
16
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Executive
Summary
This
hypothetical
report
presents
mock­
up
results
using
chemical
screening
data
from
the
first
Inventory
Update
Rule
Amendments
(
IURA)
collection.
These
results
were
developed
using
mocked
up
data
from
several
possible
data
sources,
and
hypothetically
using
this
data
in
several
models
and
scenarios
developed
for
screening
evaluations.
The
IURA
data
included
processing
and
use
data
on
nearly
4,000
organic
chemicals
produced
in
higher
volumes.
Use
data
on
inorganic
chemicals
will
be
available
beginning
with
the
second
IURA
collection,
as
use
information
on
inorganic
chemicals
will
not
be
reported
during
the
first
collection.
While
these
processing
and
use
data
will
be
used
to
support
many
OPPT
programs,
as
well
as
many
other
programs
in
the
Agency,
one
primary
purpose
of
the
data
collection
is
to
enable
screening
of
these
chemicals
for
signs
of
potential
risks
to
workers,
the
public,
and
the
environment.
Identifying
potential
risks
is
just
the
first
step
in
analyzing
the
situation;
once
the
screening
is
completed,
EPA
can
perform
more­
detailed
analyses
on
the
chemicals
that
raised
a
possible
concern.
The
hypothetical
results
of
OPPT's
risk
screening
using
IURA
data
are
presented
below,
and
in
Table
1.
Table
2
presents
the
hypothetical
results
of
the
risk
screening
process
for
a
representative
chemical.
The
remainder
of
this
report
is
presented
as
an
actual
report,
as
if
the
analyses
were
really
completed.

Risk
Screening
Results
Concerns
for
Potential
Occupational
Risk
EPA
used
several
models
and
scenarios
developed
over
the
past
three
decades
to
screen
4,000
chemicals
to
identify
potential
risks
to
workers,
both
at
the
manufacturing
site
and
downstream
sites.
EPA
used
IURA
exposure
information
such
as
the
physical
form
of
the
chemical,
the
number
of
workers
potentially
exposed,
and
the
maximum
concentration
of
the
chemical,
combined
with
hazard
data
from
the
HPV
challenge
program
and
elsewhere,
to
identify
the
following
levels
of
concern:

­
3,836
chemicals
without
immediate
concerns
due
to
low
hazard
and
very
low
exposure.

­
102
chemicals
with
moderate
exposure
and
hazard
concerns.
EPA
is
conducting
additional
analyses
to
evaluate
these
scenarios
further.

­
34
chemicals
with
immediate
concerns
for
potential
exposure
and
hazard.
EPA
is
engaging
stakeholders
in
meetings
about
these
chemicals,
to
determine
if
more
data
are
available
regarding
specific
use
patterns,
and
to
share
our
information.

Example:
Trimethyl
ziptone
(
CAS
#
987­
65­
4),
or
TMZ,
is
a
solvent
that
IURA
data
indicate
is
widely
used
in
plastics
product
manufacturing
(
NAICS
code
3261).
Hazard
data
(
e.
g.
HPV
program
data)
suggest
TMZ
may
cause
neurological
problems
at
dermal
exposure
levels
believed
to
be
typical.
IURA
data
further
indicate
that
TMZ
is
a
dry
powder
and,
when
used
in
an
industrialized
setting,
is
incorporated
into
a
formulation
or
mixture.
These
data
help
identify
TMZ
as
a
17
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
potential
high
risk
chemical.
EPA
has
contacted
industry
representatives
to
determine
the
extent
of
personal
protective
equipment
(
PPE)
use
(
such
as
to
determine
whether
protective
procedures
such
as
the
wearing
of
gloves
are
typically
in
place)
and
to
highlight
Agency
concerns.

­
28
chemicals
that
may
pose
a
risk,
but
for
which
more
hazard
data
are
needed.
Exposure
levels
are
expected
to
be
quite
high
based
on
production,
processing,
or
industrial/
commercial
use
information
gathered
through
the
IURA.
EPA
is
collecting
more
hazard
data,
as
related
chemicals
suggest
hazards
may
be
present.

Concerns
for
Risks
to
the
Public
While
consumer
behavior
is
difficult
to
define,
EPA
has
developed
several
models,
databases,
and
scenarios,
enabling
the
Agency
to
screen
chemicals
for
potential
risk
to
the
general
public.
Information
from
the
IURA
on
commercial
and
consumer
product
categories,
the
amount
of
chemicals
used
in
each
category,
and
the
potential
for
use
by
children
was
used
to
screen
the
4,000
IURA
chemicals.
Of
the
4,000
chemicals
screened:

­
2,333
chemicals
had
no
reported
consumer
use
­
1,512
chemicals
were
without
immediate
concerns
due
to
low
hazard
and
very
low
expected
exposure,
as
indicated
by
the
reported
product
categories
and
volumes
used
in
those
categories.

­
72
chemicals
with
moderate
exposure
and
hazard
concerns.
EPA
is
conducting
more
modeling
and
may
collect
additional
data
to
analyze
these
scenarios
further.

­
38
chemicals
with
immediate
concerns
for
potential
exposure
and
hazard.
EPA
is
engaging
stakeholders
in
meetings
about
these
chemicals
to
share
Agency
findings
and
exchange
information
on
specific
use
patterns.

Example:
IURA
data
indicate
that
p­
alkyl­
nehi
is
a
commonly
used
fragrance
in
soaps
and
detergents.
Hazard
data
suggest
it
may
cause
respiratory
problems
at
potential
exposure
levels.
EPA
has
met
with
industry
to
determine
the
extent
of
consumer
use,
and
to
gather
additional
information.

­
28
chemicals
that
may
pose
a
risk,
but
for
which
more
hazard
data
are
needed.
Exposure
levels
are
expected
to
be
quite
high
based
on
production,
processing,
or
industrial/
commercial
use
information
gathered
through
the
IURA.
EPA
is
collecting
more
hazard
data,
as
related
chemicals
suggest
hazards
may
be
present.

­
12
chemicals
with
concerns
specific
to
children,
from
either
developmental
toxicity,
or
higher
exposure
to
children.
EPA
is
investigating
these
scenarios
aggressively,
and
is
coordinating
with
ongoing
activities
related
to
children
(
such
as
the
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP))
18
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Concerns
for
Environmental
Risk
­

EPA
used
several
models,
databases
(
including
IURA
data),
and
scenarios
developed
over
the
past
three
decades
to
screen
4,000
chemicals
for
potential
risks,
which
could
be
resulted
from
releases
at
the
manufacturing
site,
downstream
industrial/
commercial
sites,
and
possible
consumer
use.
For
instance,
IURA
manufacturing
and
use
data
were
used
to
generate
environmental
release
estimates
to
water.
These
estimates,
NAICS
code
data
from
the
IURA
(
to
identify
streamflow
distributions
by
industry
sector),
and
hazard
dose­
response
data
were
input
into
EPA's
E­
FAST
model,
which
estimated
the
chemicals'
surface
water
concentrations
and
risks
to
aquatic
organisms.
The
results
were
used
to
screen
and
initially
prioritize
chemicals
based
on
concerns
for
environmental
risks.

EPA
identified
the
following
levels
of
concern:

­
3,748
chemicals
without
immediate
concerns
due
to
low
hazard
and
very
low
exposure.

­
91
chemicals
with
possible
persistent
bio­
accumulative
toxic
(
PBT)
concerns.
PBTs
remain
in
the
environment
for
extended
periods,
and
can
cause
damage
to
human
health
and
the
ecosystem.
The
IURA
has
shown
that
some
chemicals
that
have
been
previously
identified
as
PBT
also
have
high
occupational
exposure
(
through
data
elements
like
Number
of
Workers,
Number
of
Sites).
EPA
is
conducting
more
analyses
to
evaluate
these
chemicals
in
more
detail.

­
34
chemicals
with
immediate
concerns
for
potential
exposure
and
ecological
hazard.
EPA
is
holding
stakeholder
meetings
about
these
chemicals,
to
identify
additional
data
regarding
specific
use
and
disposal
patterns,
and
to
share
our
information.

Example:
Nitronitrile
(
CAS
#
5551­
21­
2)
is
a
dispersant
that
IURA
data
indicate
is
widely
used
in
production
of
printing
inks
(
NAICS
code
32591).
Hazard
data
suggest
it
may
be
toxic
to
aquatic
ecosystems
in
concentrations
believed
to
be
common
in
industrial
wastewater.
Standard
industry
practice
does
not
require
pretreatment
or
disposal
to
POTWs.
EPA
met
with
industry
to
determine
which
disposal
methods
are
actually
used,
and
the
extent
of
pretreatment
or
POTW
discharge.
At
this
time
it
appears
firms
are
aware
of
the
potential
risk,
and
most
have
taken
appropriate
steps
to
mitigate
water
releases.

­
99
chemicals
that
may
pose
an
ecological
risk,
but
for
which
more
data
are
needed.
Hazard
data
may
be
unavailable,
and
use
patterns
must
be
examined
more
closely,
but
release
levels
are
expected
to
be
quite
high
in
production,
processing,
industrial/
commercial
use,
or
consumer
use.
EPA
is
collecting
for
more
detailed
data,
as
analogues
suggest
hazards
may
be
present.

­
28
chemicals
may
contribute
substantially
to
ozone
depletion
if
discharged
into
the
atmosphere.
OPPT
has
referred
these
chemicals
to
the
Office
of
Air
and
Radiation.
19
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Table
1:
Summary
of
IURA
Screening
Results
Type
of
Risk
Concern
Number
of
Chemicals
Details
(
see
discussion
in
report
text
for
more
information)
Action
Occupational
3,836
Chemicals
without
immediate
concerns
due
to
potential
low
hazard
and
very
low
exposure
None
at
this
time
Occupational
102
Chemicals
with
moderate
potential
exposure
and
hazard
concerns
Further
Analysis
Occupational
34
Chemicals
with
immediate
concerns
for
potential
exposure
and
hazard
Immediate
Outreach
Occupational
28
Chemicals
that
may
pose
a
potential
risk,
but
for
which
more
hazard
data
are
needed
Data
Search
Consumer/
Public
2,333
Chemicals
with
no
consumer
use
at
all,
and
no
risk
potential
None
at
this
time
Consumer/
Public
1,512
Chemicals
without
immediate
concerns
due
to
low
hazard
and
very
low
exposure
None
at
this
time
Consumer/
Public
72
Chemicals
with
moderate
potential
exposure
and
hazard
concerns
Further
Analysis
Consumer/
Public
38
Chemicals
with
immediate
concerns
for
potential
exposure
and
hazard
Outreach
Consumer/
Public
12
Chemicals
with
concerns
specific
to
children,
from
either
developmental
toxicity,
or
higher
potential
exposure
to
children
Further
Analysis/
Outreach
Ecological
3,748
Chemicals
without
immediate
concerns
due
to
low
hazard
and
very
low
exposure
None
at
this
time
Ecological
91
Chemicals
with
possible
persistent
bioaccumulative
toxic
(
PBT)
concerns
Further
Analysis
Ecological
34
Chemicals
with
immediate
concerns
for
exposure
and
ecological
hazard
Outreach
Ecological
99
Chemicals
that
may
pose
a
potential
ecological
risk,
but
for
which
more
data
are
needed
Data
Search
Ecological
28
Chemicals
that
may
contribute
substantially
to
ozone
depletion
if
discharged
into
the
atmosphere
Referred
to
OAR
20
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Table
2
presents
the
results
of
the
risk
screening
process
for
a
representative
chemical.
As
discussed
earlier
in
this
example,
results
were
derived
from
IURA
exposure
data,
hazard
data
from
sources
such
as
the
HPV
program,
basic
chemical
property
data,
and
estimates
derived
from
EPA
experience
with
other
similar
chemicals.
A
similar
table
could
be
produced
for
each
chemical
screened
for
this
example
report.
Results
from
all
of
these
chemicals
were
combined
to
produce
the
summary
information
above.

Table
2:
Summary
of
Screening
Results
­
Snorzone
(
CAS
#
0001­
01­
1)

Occupational
Risk
Screen
Models
Results
Action
UCSS
ChemSTEER
low
relative
risk­
based
ranking
low
exposure/
low
hazard
No
action
at
this
time
Consumer/
Public
Risk
Screen
Models
Results
Actions
UCSS
SRD
low
relative
risk­
based
ranking
low
relative
risk­
based
ranking
No
action
at
this
time
Ecological
Risk
Screen
Models
Results
Actions
E­
FAST
high
releases/
hazard
unknown
Data
search
21
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
2:
Using
IURA
Data
for
Prioritization
OPPT's
Design
for
the
Environment
(
DfE)
branch
identifies
candidate
industry
sectors
for
Stewardship
Partnership
programs.
IUR
data
could
be
used
to
rank
industry
sectors
and
functional
uses
by
the
number
of
facilities
that
use
certain
chemicals
and
also
by
the
number
of
workers
that
may
be
exposed.
This
information
would
be
used
to
determine
where
to
put
Agency
resources
within
this
program.

This
example
illustrates
the
process
of
identifying
the
top
industry
sector
among
three
candidate
sectors.
The
top
three
chemicals
for
each
of
these
sectors
were
identified
using
information
from
the
amended
IUR.
Using
the
NAICS
codes
reported
on
the
amended
IUR,
EPA
could
first
determine
the
chemicals
used
in
the
industry,
then
rank
those
chemicals
based
on
a
variety
of
criteria
­
production
volume,
use
volume
in
industry,
number
of
potentially
exposed
workers,
or
number
of
use
sites.
The
screening
results
can
be
used
to
show
that
the
Textile
Manufacturing
industry
may
be
the
highest
priority
for
further
analysis,
based
on
potential
exposure,
due
to
the
number
of
facilities
involved
and
the
number
of
workers
potentially
exposed.
The
Agency's
next
steps
would
likely
be
to
collect
information
on
the
chemicals
used
in
textile
manufacturing,
the
hazard
characteristics
of
the
chemicals,
and
the
potential
risk
associated
with
those
chemicals.

NAICS
CODE
+
INDUSTRY
SECTOR
TOP
3
CHEMICALS
IN
SECTOR
NAME
(
CAS
NUMBER)
NUMBER
OF
PROCESSING
SITES
PRODUCTION
VOL
(
M
LB)
NUMBER
OF
WORKERS
32111
Wood
Preserving
Creosote
(
8001589)
25­
100
10­
50
500­
100
Naphthalene
(
91203)
1­
10
1­
10
25­
50
1,2,4
trimethyl­
benzene
(
95636)
1­
10
1­
10
25­
50
31611
Leather
Tanning
and
Finishing
Formic
Acid
(
64186)
25­
100
10­
50
100­
500
N­
methyl­
2pyrrolidone
(
872504)
1­
10
1­
10
50­
100
Triethylamine
(
121448)
1­
10
1­
10
50­
100
3132,3133,
3141,3151
Textile
Manufactur­
ing
Methanol
(
67561)
25­
100
50­
100
500­
1000
Methyl
Ethyl
Ketone
(
78933)
25­
100
10­
50
500­
1000
Toluene
(
108883)
25­
100
10­
50
500­
1000
IURA
Data
Used:
NAICS
Codes/
Industry
Sector
Number
of
Processing
Sites
Production
Volume
Number
of
Workers
associated
with
NAICS
22
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
3:
Using
IURA
Data
for
TSCA
Pre­
Manufacturing
Notice
(
PMN)
Review
Generic
scenarios
are
tools
routinely
used
in
the
preparation
of
Initial
Review
Engineering
Reports
within
the
Agency's
PMN
Review
program.
Generic
scenarios
are
industry
specific
profiles
developed
by
the
Agency
which
contain
assumptions
based
on
industrial
site
surveys,
historical
data,
and
technical
research
(
e.
g.
use
volume,
concentration,
#
of
sites,
#
of
workers).
These
generic
scenarios
are
routinely
used
by
OPPT,
in
the
absence
of
data,
to
estimate
potential
occupational
exposure
and
releases
of
new
chemicals
(
those
not
currently
on
the
TSCA
Chemical
Inventory
and
therefore
are
not
eligible
to
be
used
in
the
United
States).
These
profiles
are
needed
because
pre­
manufacture
notifications
(
or
PMNS,
submitted
under
section
5
of
TSCA
­­
part
of
the
process
necessary
to
have
a
chemical
added
to
the
TSCA
Chemical
Inventory)
often
lack
information
needed
to
perform
a
screening
level
analysis
for
the
end
uses.

Whenever
possible,
EPA
uses
real
data
instead
of
assumptions
in
the
generic
scenarios,
part
of
OPPT's
on­
going
effort
to
improve
and
develop
generic
scenarios.
The
IURA
contains
crucial
data
elements
(
e.
g.,
production
or
use
volume,
concentration,
#
of
sites,
#
of
workers)
that
can
be
used
to
augment
the
existing
generic
scenarios
as
well
as
to
develop
new
ones.
Improved
scenarios
will
enable
the
Agency
to
better
screen
new
chemicals
for
potential
risk,
either
eliminating
situations
where
the
Agency,
because
of
conservative
assumptions
in
the
generic
scenarios,
would
have
required
additional
testing
before
agreeing
to
the
substances'
production,
or
identifying
situations
where
the
new
chemicals
may
require
further
testing.
Additionally,
these
generic
scenarios
are
used
for
other
projects
on
an
as­
needed
basis,
and
improved
scenarios
will
make
screening
results
for
those
projects
more
accurate
as
well.

An
example
report
of
the
type
of
data
useful
for
improving
generic
scenarios
is:

NAICS
Code
Chemical
Name
Industrial
Function
Category
Overall
Chemical
Production
Volume
(
M
lbs)
%
of
PV
Number
of
Sites
Number
of
Workers
32551
Titanium
U08
1,000
+
50
1,000­
10,000+

32551
Ethylene
U28
100
­
500
25
1,000­
10,000+

32551
Diethylene
U28
500
­
1,000
10
1,000­
10,000+

32551
Zinc
oxide
U08
1
­
10
50
1,000­
10,000+

32551
­
Paint
and
Coating
Manufacturing
U08
­
Coloring
agents,
pigments
U28
­
Solvents
(
which
become
part
of
product
formulation
or
mixture)

IURA
Data
used:
NAICS
code
Number
of
Sites
Industrial
function
Number
of
Workers
%
of
Production
Volume
23
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
4:
Use
of
IURA
Data
by
OPPT
to
Prioritize
Chemicals
and
Industry
Sectors,
and
to
Identify
Potential
Substitutes
The
Use
Cluster
Scoring
System
(
UCSS)
is
a
computer­
based
risk­
screening
system
with
information
on
nearly
3,200
chemicals
and
the
380
clusters
­­
or
families
­­
into
which
these
chemicals
are
grouped.
Developed
by
EPA
to
systematically
identify
clusters
of
chemicals
and
to
prioritize
those
chemicals
and
clusters
within
specific
industry
groups,
each
cluster
contains
a
group
of
chemicals
that
can
be
substituted
interchangeably
for
the
same
use
or
application.
The
UCSS
allows
comparisons
among
chemicals
within
a
cluster
and
comparisons
between
different
clusters
for
ranking
and
prioritization
purposes.
For
instance,
a
cluster
for
chemicals
that
can
be
used
as
paint
solvents
may
contain
10
chemicals
(
e.
g.,
A
through
J).
Each
one
of
these
chemicals
has
its
own
potential
risk
score
based
on
available
hazard
and
exposure
information.
Using
the
individual
risk
scores,
chemicals
in
this
cluster
can
be
compared
to
each
other
to
determine
the
chemical
of
highest
potential
concern
within
the
cluster.
To
compare
clusters,
the
individual
chemical
scores
are
used
to
develop
an
overall
score
for
each
cluster.
The
cluster
score
(
in
this
case
the
Paint
Solvent
Cluster)
can
then
be
compared
against
scores
for
other
clusters
(
e.
g.,
Metal
Plating
Chemicals
Cluster,
Chelating
Agent
Chemical
Cluster,
etc.).
The
relative
score
information
can
be
used
to
prioritize
clusters
for
purposes
such
as
resource
allocation.

The
current
risk
based
algorithm
in
the
UCSS
includes
hazard
information
(
e.
g.,
from
EPA's
HPV
Program)
and
production
volume,
which
serves
as
a
proxy
for
exposure.
The
EPA
Science
Advisory
Board
(
SAB)
reviewed
the
UCSS
and
concluded,
in
part,
that
there
are
no
easily
accessible
exposure
data
and
that
the
exposure
component
of
the
algorithm
needs
improvement.
The
exposure
information
in
the
UCSS
is
incomplete;
what
is
there
has
been
collected
over
many
years
from
various
scattered
sources
and
can
be
outdated.
The
IURA
data
will
be
one
of
the
few
direct
sources
of
exposure
information
and,
with
the
IUR's
quadrennial
reporting,
will
be
current
information.
IURA
exposure
data
will
thereby
enhance
the
UCSS
algorithm's
exposure
component,
resulting
in
improved
risk­
based
comparison
of
chemicals
and
clusters
by
strengthening
the
exposure
component
of
risk.
Information
obtained
from
the
IURA
will
make
the
system
more
comprehensive,
hence
resulting
in
improved
priority
setting
and
identification
of
potential
safer
substitutes.

Table
1
provides
an
example
of
how
the
IURA
data
can
be
used
by
the
UCSS.
IURA
data
can
be
fed
directly
into
the
UCSS
to
develop
use
clusters.
In
the
Table
1
example,
a
use
cluster
is
identified
for
four
different
IURA
chemicals
from
the
same
NAICS
sector.
Table
2
shows
how
hazard
data
could
be
combined
with
additional
IURA
data
elements
to
develop
a
relative
risk
ranking
among
chemicals
in
a
single
cluster
(
NAICS
32XXX
Sector).
According
to
this
screening,
chemical
H
would
be
a
top
priority
for
further
investigation
or
referral
to
an
existing
program.
24
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Table
1.
IURA
Information
Used
to
Develop
a
Use
Cluster
IURA
Inputs
Output
Chemical
NAICS
Functional
Use
Activity
Use
Cluster
A
32599(
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing)
U27(
Solvents
used
as
cleaner)
Use
Solvents
used
as
cleaner
B
32599(
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing)
U27(
Solvents
used
as
cleaner)
Use
Solvents
used
as
cleaner
C
32599(
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing)
U27(
Solvents
used
as
cleaner)
Use
Solvents
used
as
cleaner
D
32599(
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing)
U27(
Solvents
used
as
cleaner)
Use
Solvents
used
as
cleaner
*
Use
Clusters
­
a
set
of
chemicals
used
in
a
similar
function
for
a
given
sector.

Table
2.
Ranking
of
Chemicals
within
a
Sector
IURA
Input
Output
Chemical
NAICS
No.
of
Sites
Volume
(
M
lbs)
%
Production
Volume
No.
of
Workers
Consumer
Use
HPV
Hazard
Relative
Sector
Ranking
E
32513
1,000­
10,000
10­
50
30
1,000
­
10,000
None
M
L
F
32221
100­
250
1­
10
75
1,000
­
10,000
None
H
M
G
32619
250­
1,000
10­
50
15
10,000+
None
M
M
H
32331
250­
1,000
10­
50
100
10,000+
None
M
H
IURA
Data
used:
NAICS
code
Functional
use
Activity
Number
of
sites
Percent
production
volume
Number
of
workers
Consumer
use
25
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
5:
Using
IURA
Data
for
Trend
Analysis
IURA
data
such
as
chemical
identity,
use
information,
and
production
volumes
can
be
very
useful
for
tracking
how
chemicals
are
used.
The
information
can
help
to
answer
such
questions
as:
Has
the
exposure
to
workers
decreased
over
a
certain
time
period?
Is
a
chemical
being
phased
out?
What
are
the
uses
of
a
chemical?
The
trend
analysis
information
below
could
be
one
component
of
measuring
the
success
of
regulatory
or
voluntary
programs.

The
information
such
as
that
outlined
below
can
be
used
to
measure
success
of
a
regulatory
or
voluntary
program
by
demonstrating
the
decrease
or
increase
in
the
number
workers
exposed
to
a
chemical
(
or
chemicals)
of
concern
in
a
regulatory
or
voluntary
program,
or
by
measuring
the
change
in
amount
of
chemical
used
for
a
specific
use.

Chemical
Use
Number
of
Potentially
Exposed
Workers
2002
2006
2010
Inorgano
Alpha
U01
­
Adsorbent/
Absorbent
1,000
­
10,000
1,000
­
10,000
500
­
1,000
U25
­
Process
Regulator
1,000­
10,000
1,000
­
10,000
1,000
­
10,000
Inorgano
Beta
U01
­
Adsorbent/
Absorbent
10,000+
10,000+
10,000+

U25
­
Process
Regulator
500­
1000
500­
1000
500­
1000
Inorgano
Gamma
U01
­
Adsorbent/
Absorbent
10,000+
10,000+
500­
1000
U25
­
Process
Regulator
50­
100
25­
50
50­
100
IURA
Data
used:
Chemical
Industrial
use
Production
Volume
in
use
Data
over
time
26
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
6:
Using
IURA
Data
to
Meet
GPRA
Requirements
EPA's
GPRA
Goal
4:
Preventing
Pollution
and
Reducing
Risk
in
Communities,
Homes,
Workplaces
and
Ecosystems
Under
the
Revised
Strategic
Plan
goal
(
Objective
4.5),
EPA
can
commit
to
Voluntary
Partnerships
(
New
33/
50
Program)
for
a
20%
reduction
in
non­
recycled
TRI
wastes
by
2005.
EPA
would
identify
a
core
group
of
TRI
chemicals
that
are
produced
or
used
in
high
volumes
for
particular
attention.
Facilities
would
publicly
set
their
emission
and
waste
reduction
targets
and
emphasize
source
reduction
and
avoidance
of
cross­
media
pollutant
transfers.

EPA
needs
to
allocate
resources
to
voluntary
partnerships
to
reduce
non­
recycled
TRI
wastes.
The
following
industries
are
being
considered
(
data
not
from
actual
reports):

NAICS
TRI
Release
of
Chemicals
Production
Volume
Number
of
Workers
Most
Frequent
Processing/
Use
Code
32111
100,000
lbs/
yr
50,000,000­
100,000,00
lbs/
yr
1,000­
10,000
PF
31611
100,000
lbs/
yr
50,000,000­
100,000,000
lbs/
yr
1,000­
10,000
PA
32511
100,000
lbs/
yr
50,000,000­
100,000,000
lbs/
yr
10,000
plus
PK
Processing/
Use
Codes:
PF:
Processing­­
incorporation
into
formulation,
mixture,
or
reaction
product
PA:
Processing­­
incorporation
into
article
PK:
Processing­­
repackaging
Why
the
new
IURA
data
elements
are
essential:
EPA
and
its
industrial
partners
have
limited
resources
and
must
be
very
careful
to
use
those
resources
wisely.
In
order
to
best
meet
its
requirement
under
GRPA
Goal
#
4,
it
is
crucial
that
EPA
allocate
its
resources
to
partner
with
industry
sectors
of
highest
concern.
Making
this
judgement
solely
on
the
basis
of
the
volume
of
TRI
releases
or
production
volume
will
not
best
meet
this
requirement
in
the
most
cost­
effective
way.
TRI
releases
alone
or
combined
with
production
volume
do
not
translate
directly
to
actual
exposure.
TRI
releases
and
production
volume
give
no
indication
of
the
number
of
potentially
exposed
workers
(
essential
for
determining
the
extent
of
occupational
risk)
or
chemical
use
(
essential
for
determining
both
occupational
and
consumer
exposure
and
risk).
27
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
In
this
case,
EPA
could
determine
that
the
number
of
workers
reported
under
NAICS
code
32511
is
higher
than
those
reported
under
other
NAICS
codes.
This
could
in
turn
prompt
EPA
to
further
investigate
the
possibility
of
creating
a
voluntary
partnership
with
stakeholders
of
NAICS
32511
to
reduce
exposure
and
protect
human
health
and
the
environment.
In
the
absence
of
this
data,
each
of
the
NAICS
codes
would
have
been
equivalent
and
EPA
would
have
had
no
way
of
making
this
determination
quickly
and
cost­
effectively.
The
use
of
the
new
IURA
data
elements
provide,
in
this
case,
the
crucial
elements
that
EPA
and
its
industrial
partners
need
to
allocate
their
resources
wisely.
28
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
7:
Using
IURA
Data
to
Meet
GPRA
Requirements
EPA's
GPRA
Goal
4:
Preventing
Pollution
and
Reducing
Risk
in
Communities,
Homes,
Workplaces
and
Ecosystems
According
to
EPA's
strategic
plan
(
as
of
Sept.
2000),
by
2005
EPA
and
its
partners
will
increase
recycling
and
decrease
the
quantity
and
toxicity
of
waste
generated.
EPA
meets
this
GPRA
goal
using
various
voluntary
partnership
programs,
such
as
the
Design
for
the
Environment
(
DfE)
Program.
The
DfE
Program
forms
partnerships
with
industry,
universities,
research
institutions,
public
interest
groups,
and
other
government
agencies.
This
program
ensures
that
the
information
developed
through
these
voluntary
efforts
reaches
the
decision­
makers
and
promotes
the
incorporation
of
environmental
considerations
into
the
traditional
business
decisionmaking
process.

The
DfE
program
(
as
well
as
other
voluntary
programs)
needs
broad
use
and
exposurerelated
information
to
make
better
decisions
on
which
industries
to
partner
with,
taking
into
consideration
both
the
relative
concern
for
an
industry
and
EPA's
available
resources.
Current
TRI
data
only
covers
a
fraction
of
the
chemicals
in
production
and
provides
no
data
on
chemical
use.
The
following
hypothetical
table
provides
an
example
of
how
IURA
data
can
be
used
to
assist
EPA
in
this
regard.

Chemical
Production
Volume
in
lbs/
yr
Process
or
Use
Operation
Industrial
Function
Number
of
Sites
Commercial/
Consumer
Use
Chemical
A
1,000,000­
10,000,000
PA
U12
(
flame
retardant)
10­
25
C18
(
Wood
&
wood
furniture)

Chemical
B
1,000,000­
10,000,000
PF
U31
(
surfactant)
25­
100
C16
(
soaps
&
detergents)

Chemical
C
1,000,000­
10,000,000
PA
U28
(
solvent
as
part
of
mixture)
>
10,000
C12
(
Paints
&
coatings)

PA:
Processing...
incorporation
into
article
Why
the
new
IURA
data
elements
are
essential.

Examining
this
table,
you
would
note
that
these
chemicals
appear
similar
in
the
sense
that
the
production
volumes
are
all
within
the
same
range.
For
many
organic
chemicals,
production
volume
has
been
available
through
the
IUR,
and
has
been
used
as
a
proxy
for
exposure.
However,
production
volume
is
no
substitute
for
actual
exposure
or
knowledge
of
industrial
use.
The
new
IURA
data
elements
in
this
case
provide
information
on
where
a
chemical
is
used,
how
it
29
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
is
used,
the
number
of
sites
where
it
is
used
and
whether
there
is
any
commercial
or
consumer
use.
Using
this
information,
it
would
be
possible
to
identify
the
most
serious
pollutants
and
give
priority
to,
perhaps,
chemical
C
which
has
the
highest
number
of
workers,
consumer
use
in
paints
and
coatings,
and
contains
solvents
as
a
part
of
the
product.
Without
the
new
IURA
data
elements,
no
determination
could
have
been
made
quickly
and
cost­
effectively.
This
saves
both
EPA
and
its
industrial
partners
substantial
resources
and
allows
all
parties
to
use
their
resources
wisely.
30
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
8:
IUR
Data
Use
and
Green
Chemistry
Challenge
Awards
The
Presidential
Green
Chemistry
Challenge,
a
program
begun
under
George
H.
W.
Bush,
recognizes
accomplishments
and
promotes
the
research,
development,
and
implementation
of
innovative
green
chemical
technologies
that
have
been
or
can
be
utilized
by
industry
in
achieving
pollution
prevention
goals.
The
annual
Presidential
Green
Chemistry
Challenge
Awards
Program
recognizes
outstanding
chemical
technologies
by
inviting
nominations
that
describe
the
technical
benefits
of
a
green
chemistry
technology
as
well
as
human
health
and
environmental
benefits.
An
independent
panel,
selected
by
the
American
Chemical
Society,
judges
nominations
for
the
Awards.
Presidential
Green
Chemistry
Challenge
Awards
recipients
receive
national
public
recognition
for
their
outstanding
accomplishments
in
the
research,
development,
and/
or
implementation
of
green
chemical
technologies.
Judges
for
the
award
nominations
need
to
distinguish
between
many
worthwhile
entries.
The
additional
information
in
a
non­
confidential
version
of
the
IURA
database
would
assist
judges
in
determining
which
industrial
areas
would
benefit
most
by
the
introduction
of
green
chemical
technologies.
The
IURA
information
can
demonstrate
which
entries
under
consideration
would
have
the
highest
impact
with
regard
to
human
health
and
the
environment.
For
instance,
Entry
#
3
affects
a
higher
number
of
workers
than
the
other
entries.

Green
Chemistry
Award
Nominee
PV
of
similar
use
chemicals
in
lbs/
yr
Process
or
Use
Operation
Industrial
Function
Number
of
Workers
Commercial
&
Consumer
Use
Entry
#
1
1,000,000­
10,000,000
PA
U12
10,000
­
100,000
C18
Entry
#
2
1,000,000­
10,000,000
PF
U31
10,000­
100,000
C16
Entry
#
3
1,000,000­
10,000,000
PC
U29
100,000­
200,000
C12
PA:
Incorporated
into
article
PF:
Processing­
incorporation
into
formulation,
mixture
or
reaction
product
PC:
Processing
as
a
reactant
U12:
flame
retardant
U31:
surfactant
U29:
solvents
(
for
chemical
manufacture
and
processing
and
not
part
of
product
at
greater
than
1%
by
weight)

C18:
Wood
&
Wood
Furniture
C16:
Soaps
&
Detergents
C12:
Paints
&
Coatings
31
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
9:
Using
IURA
Data
by
Office
of
Water
to
Identify
Pollutants
of
Concern
for
Regulatory
Development
One
step
in
the
development
of
effluent
guidelines
by
the
Office
of
Water
(
OW)
is
determining
the
pollutants
of
concern.
This
is
typically
accomplished
through
surveys
of
the
industry
and/
or
wastewater
sampling
for
the
entire
list
of
potential
pollutants.
OW
could
use
this
information
to
prioritize
pollutants
and
industries
with
regard
to
their
need
for
an
Effluent
Limitation
Guideline.
In
the
table
below,
chemicals
and
their
production
volumes
within
an
industrial
sector
(
NAICS
code
25199)
are
identified.

NAICS
Chemical
Name
Production
Volume
(
LB)
25199
Methanol
100,000,000­
500,000,000
25199
Ethanol
50,000,000­
100,000,000
25199
Acetone
10,000,000­
50,000,000
25199
Isopropanol
10,000,000­
50,000,000
25199
Acetic
acid
10,000,000­
50,000,000
25199
Methylene
chloride
10,000,000­
50,000,000
Note:
325199­
All
Other
Basic
Organic
Chemical
Manufacture
IURA
Data
used:
NAICS
32
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
10:
OSHA
Use
of
IURA
Data
The
IURA
data
could
be
used
to
identify
the
scope
of
potential
worker
exposure
to
specific
chemicals.
This
could
be
used
as
either
a
prioritization
tool,
or
to
help
facilitate
alerts
or
outreach
for
specific
chemicals
by
identifying
the
number
of
sites
and
workers
immediately
affected
by
the
outreach
effort.
In
general,
this
information
is
not
available
elsewhere.

For
instance,
OSHA
may
ask
for
information
on
specific
chemicals,
such
as
the
type
of
data
in
the
table
below.
Alternatively,
OSHA
may
request
a
list
of
all
chemicals
with
potential
exposure
to
over
10,000
workers.

Chemical
Name
Number
of
Sites
Number
of
Workers
Methylene
chloride
1,000­
10,000
10,000+

Disodium
4­
amino­
3­((
4'­((
2,4­
diaminophenyl)
10,000+
10,000+

Disodium
(
5­((
4'­((
2,6­
dihydroxy­
3­((
2­
hydroxy
1,000­
10,000
1,000­
10,000
IURA
Data
used:
Number
of
sites
Number
of
workers
33
NOTE:
THIS
IS
AN
EXAMPLE
USING
MADE
UP
IURA
DATA
Example
11:
CPSC
Use
of
IURA
Data
The
Consumer
Product
Safety
Commission
(
CPSC)
has
expressed
interest
in
the
IURA
data.
Data
of
this
type
is
not
elsewhere
available.
CPSC
may
use
the
IURA
data
to
track
chemicals
used
in
consumer
and
children's
products.
For
instance,
CPSC
may
have
a
list
of
chemicals
they
are
interested
in
due
to
hazard
issues.
CPSC
would
ask
EPA
for
a
list
of
the
IURA
information
for
those
chemicals,
specifically
identifying
consumer
uses
and
any
use
in
children's
products.
Additionally,
CPSC
could
use
IURA
data
to
look
at
trends
over
time,
identifying
if
there
are
any
chemicals
that
are
being
used
more
or
less
frequently
in
consumer
products.

NAICS
Code
Chemical
Name
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
33993
DiA
phthalate
C12
Y
33993
TeBphthalic
anhydride
C01
Y
32561
1,­
TriCethane
C16
32551
D
oxide
C01
32551
D
oxide
C12
33993
­
Doll,
Toy,
and
Game
Manufacturing
32561
­
Soap
and
Cleaning
compound
Manufacturing
32551
­
Paint
and
Coating
Manufacturing
C01
­
Artists'
supplies
C12
­
Paints
and
coatings
C16
­
Soaps
and
detergents
IURA
Data
Used:
NAICS
Consumer
and
Commercial
Product
Category
Children's
Use
