Draft
Instructions
for
2006
Inventory
Update
Rule
Reporting
Under
the
Toxic
Substances
Control
Act
(
TSCA)

U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
August
2002
Draft
Instructions
for
2006
Inventory
Update
Rule
Reporting
Under
the
Toxic
Substances
Control
Act
(
TSCA)

U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
August
2002
DRAFT
iii
TABLE
OF
CONTENTS
PREFACE
1.0
Introduction
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1­
1
1.1
Changes
from
2002
IUR
Reporting
Requirements
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1­
2
1.2
Rationale
for
IUR
Changes
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1­
2
1.3
Use
of
Exposure­
Related
Information
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1­
3
2.0
Reporting
Requirements
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2­
1
2.1
Is
Your
Chemical
Substance
Reportable
Under
the
IUR?
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2­
1
2.1.1
Is
Your
Chemical
Substance
in
the
TSCA
Inventory?
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2­
1
2.1.1.1
What
is
the
TSCA
Inventory?
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2­
1
2.1.1.2
How
Do
You
Determine
Whether
a
Chemical
Substance
is
Listed
on
the
TSCA
Chemical
Substance
Inventory?
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2­
3
2.1.1.3
What
Do
You
Do
if
You
Cannot
Find
Your
Chemical
Substance
in
the
TSCA
Chemical
Substance
Inventory?
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2­
3
2.1.2
Is
Your
Chemical
Substance
Excluded
from
Reporting?
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2­
5
2.1.2.1
Polymers
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2­
6
2.1.2.2
Microorganisms
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2­
6
2.1.2.3
Natural
Gases
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2­
6
2.1.2.4
Naturally
Occurring
Substances
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2­
7
2.1.3
When
Must
You
Still
Report
an
Excluded
Substance?
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2­
8
2.1.4
When
is
the
Manufacture
or
Importation
of
Chemical
Substances
Subject
to
TSCA
but
not
Included
on
the
TSCA
Chemical
Substance
Inventory?
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2­
8
2.2
Are
You
a
Manufacturer
Who
Is
Required
to
Report
That
Chemical
Substance?
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2­
9
2.2.1
Are
You
a
Small
Manufacturer?
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2­
9
2.2.2
Do
You
Manufacture
the
Chemical
in
Quantities
of
25,000
Pounds
or
More?
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2­
11
2.2.2.1
Definitions
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2­
11
2.2.2.2
Meeting
the
25,000­
Pound
Annual
Production
Volume
Threshold
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2­
12
2.2.3
Do
You
Qualify
for
Any
Additional
Reporting
Exemptions
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2­
13
2.3
What
Information
Do
You
Need
to
Report?
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2­
15
2.3.1
What
Information
Do
All
Submitters
Report?
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2­
15
2.3.2
What
Additional
Information
Do
I
Report
If
My
Production
Volume
Is
Over
300,000
Pounds?
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2­
15
2.3.2.1
Petroleum
Process
Streams
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2­
15
TABLE
OF
CONTENTS
(
continued)
DRAFT
iv
2.3.2.2
Inorganic
Substances
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2­
15
2.3.2.3
Partial
Exemption
for
Specific
Chemical
Substances.
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2­
16
3.0
When
You
Must
Report
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3­
1
4.0
How
to
Report
CBI
Information
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4­
1
4.1
How
to
Assert
CBI
Claims
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4­
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4.1.1
Chemical
Identity
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4­
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4.1.2
Manufacturing
Plant
Site
Identity
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4­
2
5.0
Completing
Form
U
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5­
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5.1
Form
of
Submission
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5­
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5.2
Part
I
 
Section
I
Certification
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5­
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5.2.1
Signature
(
Part
I,
Block
1.1)
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5­
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5.2.2
Date
(
Part
I,
Block
1.2)
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1
5.2.3
Name
and
Official
Title
(
Part
I,
Blocks
1.3
and
1.4)
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5­
1
5.3
Part
I
 
Section
II
Parent
Company
and
Technical
Contact
Information
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2
5.3.1
Parent
Company
Name
(
Part
I,
Block
2.1)
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5­
2
5.3.2
Parent
Company
Dun
&
Bradstreet
Number
(
Part
I,
Block
2.2)
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5­
2
5.3.3
Technical
Contact
Name
(
Part
I,
Block
2.3)
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5­
2
5.3.4
Technical
Contact
Telephone
Number
and
E­
mail
Address
(
Part
I,
Blocks
2.4
and
2.5)
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5­
2
5.3.5
Technical
Contact
Mailing
Address
(
Part
I,
Blocks
2.11
through
2.15)
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5­
2
5.4
Part
I
 
Section
III
Plant
Site
Identification
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5­
2
5.4.1
Plant
Site
Name
(
Part
I,
Block
3.1)
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5­
3
5.4.2
Plant
Site
Dun
&
Bradstreet
Number
(
Part
I,
Block
3.2)
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5­
3
5.4.3
Plant
Site
Street
Address
(
Part
I,
Blocks
3.3
through
3.8)
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5­
3
5.5
Part
II
 
Section
1
Chemical
Identification
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5­
3
5.5.1
Chemical
Identifying
Number
(
Part
II,
Block
1.1)
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5­
3
5.5.1.1
CAS
Registry
and
Other
Identifying
Numbers
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5­
3
EPA
Accession
Number
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5­
4
PMN
Number
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5­
4
5.5.1.2
Obtaining
CAS
Registry
and
Accession
Numbers
from
EPA
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5­
4
5.5.2
ID
Code
(
Part
II,
Block
1.2)
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5­
5
5.5.3
Chemical
Name
(
Part
II,
Block
1.3)
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5­
6
5.6
Part
II
 
Section
II
Manufacturing
Information
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5­
6
5.6.1
Company
Information
CBI
(
Part
II,
Block
2.1)
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5­
6
5.6.2
Plant
Site
CBI
(
Part
II,
Block
2.2)
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5­
7
5.6.3
Site
Limited
(
Y/
N)
(
Part
II,
Block
2.3)
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5­
7
5.6.4
Activity
(
M
=
Manufacture
or
I
=
Import)
(
Part
II,
Block
2.4)
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5­
7
5.6.5
Production
Volume
Range
(
Part
II,
Block
2.5)
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5­
7
5.6.6
Production
Volume
(
Part
II,
Block
2.6)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
7
5.6.7
Number
of
Workers
(
Part
II,
Block
2.7)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
8
TABLE
OF
CONTENTS
(
continued)
DRAFT
v
5.6.8
Maximum
Concentration
(
Part
II,
Block
2.8)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
9
5.6.9
Physical
Form
and
Percentage
of
Production
Volume
(
Part
II,
Blocks
2.9
through
2.14)
.
.
.
.
.
.
.
.
.
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.
.
5­
9
5.7
Part
III
 
Processing
and
Use
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
10
5.7.1
Part
III
 
Section
I
Industrial
Processing
and
Use
Exposure­
Related
Data
(
Part
III,
Blocks
1.1
through
1.10)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
11
5.7.1.1
Type
of
Process
or
Use
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
11
5.7.1.2
Five­
Digit
NAICS
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
12
5.7.1.3
Industrial
Function
Category
(
IFC)
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
12
5.7.1.4
Percentage
of
Production
Volume
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
14
5.7.1.5
Number
of
Sites
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
15
5.7.1.6
Number
of
Workers
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
15
5.7.2
Part
III
 
Section
II
Consumer
and
Commercial
End­
Use
Exposure­
Related
Data
(
Part
III,
Blocks
2.1
through
2.10)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
16
5.7.2.1
Consumer
and
Commercial
Product
Category
Code
.
.
.
.
.
.
.
5­
17
5.7.2.2
Use
in
Children's
Product
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
18
5.7.2.3
Percentage
of
Production
Volume
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
19
5.7.2.4
Maximum
Concentration
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
20
6.0
How
to
Submit
Your
Form
U
to
EPA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.1
Sending
Forms
to
EPA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.2
Correcting
Errors
in
Submissions
for
Original
Inventory
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.3
Recordkeeping
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.4
Special
Instructions
for
Importers
and
Foreign
Suppliers
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
3
7.0
How
To
Obtain
Copies
of
Documents
Cited
in
These
Instructions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.1
Obtaining
Copies
of
TSCA
Regulations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.2
Obtaining
Copies
of
the
Public
Inventory
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.2.1
Obtaining
Copies
of
Printed
Editions
of
the
Public
Inventory
.
.
.
.
.
.
.
.
7­
1
7.2.2
Obtaining
the
Public
Inventory
in
Computer­
Readable
Format
.
.
.
.
.
.
.
7­
2
7.3
Obtaining
Copies
of
Form
U
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
2
8.0
How
To
Request
Assistance
with
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
8­
1
Appendix
A
.
.
.
.
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.
.
.
.
A­
1
Appendix
B
.
.
.
.
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.
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.
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.
.
.
.
B­
1
Appendix
C
.
.
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.
.
.
C­
1
Appendix
D
.
.
.
.
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.
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.
.
.
D­
1
Appendix
E
.
.
.
.
.
.
.
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.
.
.
E­
1
DRAFT
vi
LIST
OF
FIGURES
2­
1.
Decision
tree
for
determining
compliance
obligations
under
the
IUR.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
2
DRAFT
vii
LIST
OF
TABLES
1­
1.
Changes
Made
to
2002
IUR
Reporting
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
4
1­
2.
Selected
Potential
Uses
of
Exposure­
Related
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
6
2­
1.
Additional
Chemical
Substances
Excluded
from
IUR
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
6
2­
2.
Chemical
Substances
Covered
by
Natural
Gas
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
7
2­
3.
Examples
of
Evaluating
Naturally
Occurring
Substance
Exemptions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
8
2­
4.
Small
Manufacturer
Exemption
Examples
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
10
2­
5.
Annual
Production
Volume
Threshold
Examples
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
12
2­
6.
Examples
of
Reporting
Exemptions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
14
2­
7.
Examples
of
Reporting
Requirements
for
Form
U,
Part
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
16
4­
1.
Substantiation
Questions
To
Be
Answered
When
Making
Chemical
Identity
CBI
Claims
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
3
4­
2.
Substantiation
Questions
To
Be
Answered
When
Making
Plant
Site
Identity
CBI
Claims
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
4
4­
3.
Production
Volume
Ranges
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
4
5­
1.
ID
Code
for
Chemical
Identifying
Numbers
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
6
5­
2.
Production
Volume
Ranges
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
8
5­
3.
Codes
for
Reporting
Number
of
Workers
Exposed
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
9
5­
4.
Codes
for
Reporting
Maximum
Concentration
of
Chemical
Substance
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
9
5­
5.
Codes
Corresponding
to
Processing
or
Use
Operations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
11
5­
6.
Codes
for
Reporting
IFCs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
13
5­
7.
Examples
of
Reporting
Industrial
Processing
and
Use
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
14
5­
8.
Codes
for
Reporting
Numbers
of
Sites
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
15
5­
9.
Codes
for
Reporting
Number
of
Workers
Exposed
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
16
5­
10.
Codes
for
Reporting
Commercial
and
Consumer
Product
Categories
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
17
5­
11.
Examples
of
Use
in
Children's
Product
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
19
DRAFT
viii
PREFACE
On
[
DATE
TO
BE
ADDED],
the
U.
S.
Environmental
Protection
Agency
(
EPA)

promulgated
a
final
rule
(
FR
CITE
TO
BE
ADDED)
amending
the
Inventory
Update
Rule
(
IUR).

Sites
affected
by
this
rule
are
subject
to
the
revised
reporting
requirements
beginning
in
2006
for
activities
conducted
during
the
2005
calendar
year.
The
first
reports
are
due
by
[
DATE
TO
BE
ADDED];
sites
are
to
use
the
revised
Form
U
for
reporting
to
EPA.
Additional
information
on
the
IUR
amendments
can
be
found
in
(
FR
CITE
TO
BE
ADDED).

The
primary
goal
of
this
document
is
to
help
the
regulated
community
comply
with
the
requirements
of
the
IUR
regulations.
This
document
does
not
substitute
for
those
regulations,

nor
is
it
a
regulation
itself.
It
does
not
impose
legally
binding
requirements
on
the
regulated
community.
Determinations
regarding
compliance
with
the
IUR
requirements
will
be
based
solely
on
the
statute
and
regulations.
Interested
parties
are
free
to
raise
questions
about
the
application
of
this
guidance
to
a
particular
situation.
Where
appropriate,
EPA
retains
the
discretion
to
adopt
approaches
on
a
case­
by­
case
basis
that
differ
from
this
guidance.

This
guidance
document
contains
the
following
sections
and
appendices:


Chapter
1
­
Introduction
to
IUR
reporting
and
changes
made
from
the
2002
reporting
requirements.


Chapter
2
­
Instructions
on
determining
which
chemical
substances
you
must
report.


Chapter
3
­
When
you
must
report.


Chapter
4
­
Asserting
and
reasserting
your
claims
of
Confidential
Business
Information
(
CBI).


Chapter
5
­
Step­
by­
step
guidance
on
completing
Form
U.


Chapter
6
­
Questions
on
submitting
your
report
to
EPA
(
includes
contact
phone
numbers
and
addresses).


Chapter
7
­
Instructions
on
obtaining
copies
of
documents
you
may
need
to
better
understand
the
TSCA
IUR.


Chapter
8
­
Requesting
assistance
with
IUR
reporting.


Appendix
A
­
2006
Form
U.


Appendix
B
­
Definitions
of
terms
used
in
this
document.
DRAFT
ix

Appendix
C
­
List
of
CAS
numbers
of
chemicals
that
are
subject
to
a
special
regulatory
action
under
TSCA
and,
therefore,
must
be
reported.


Appendix
D
­
Instructions
for
electronic
IUR
reporting.


Appendix
E
­
Case
studies
illustrating
how
to
complete
Form
U.
DRAFT:
Chapter
1.0
Introduction
1­
1
Manufacturers
and
importers
of
chemical
substances
are
encouraged
to
carefully
review
the
IUR
(
Federal
Register
Notice).
1.0
Introduction
In
1977,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
promulgated
a
rule
under
Toxic
Substances
Control
Act
(
TSCA)
section
8(
a),
15
U.
S.
C.
2607(
a),
to
compile
and
keep
current
an
inventory
of
chemical
substances
in
U.
S.
commerce.
This
inventory
is
called
the
TSCA
Chemical
Substances
Inventory
(
TSCA
Inventory).
In
1986,
EPA
promulgated
the
Inventory
Update
Rule
(
IUR),
also
under
TSCA
section
8(
a),
to
facilitate
the
periodic
updating
of
the
TSCA
Inventory
database
and
to
support
activities
associated
with
implementing
TSCA.
When
first
promulgated,
the
IUR
required
chemical
manufacturers
(
including
importers)
to
report
to
EPA
every
4
years
the
identity
of
chemical
substances
manufactured
(
including
imported)
annually
in
quantities
of
10,000
pounds
or
greater
at
each
plant
site
they
owned
or
controlled.
In
2002,
EPA
amended
the
IUR,
adjusting
the
universe
of
chemicals
and
plant
sites
reporting,
the
type
of
data
reported,
and
the
Confidential
Business
Information
(
CBI)
claim
procedures.

The
TSCA
Inventory
currently
includes
more
than
76,000
chemical
substances.
Approximately
8,900
of
these
chemical
substances
were
reported
under
the
IUR
in
1998.
In
the
past,
EPA
has
used
the
TSCA
Inventory
and
IUR
data
to
support
many
TSCA­
related
activities
and
to
provide
overall
support
for
a
number
of
EPA
and
other
federal
health,
safety,
and
environmental
protection
activities.
In
addition
to
the
past
uses,
EPA
will
use
the
new
information
reported
in
2006
to
help
EPA,
other
agencies,
and
the
general
public
more
readily
screen
chemicals
for
exposure
and
risk.
These
reviews
will
allow
for
better
prioritization
of
chemicals
to
identify
those
warranting
more
detailed
assessments
and
to
eliminate
chemicals
of
lesser
concern
from
further
review.

This
document
updates
the
2002
guidance
manual
(
EPA
749­
B­
98­
001,
June
1998)
to
incorporate
the
IUR
Amendments
(
IURA)
reporting
requirements
for
2006
reporting.
These
instructions,
however,
should
not
be
construed
as
a
substitute
for
the
IUR.
[
FR
Notice
cite
needed]
Manufacturers
and
importers
of
chemical
substances
are
encouraged
to
carefully
review
the
IUR
reporting
requirements
in
the
Federal
Register
to
determine
whether
they
are
subject
to
these
requirements
and
what
information
is
to
be
reported.

Businesses
required
to
comply
with
the
IUR
should
have
a
thorough
understanding
of
the
TSCA
Inventory
and
the
criteria
used
to
determine
a
substance's
presence
in
the
TSCA
Inventory.
Information
on
the
scope
and
organization
of
the
TSCA
Inventory
can
be
found
in
the
introductory
pages
of
the
TSCA
Chemical
Substance
Inventory:
1985
Edition
(
a
complete
version
of
the
Public
Inventory
current
as
of
July
1985)
and
in
the
TSCA
Chemical
Substance
Inventory:
DRAFT:
Chapter
1.0
Introduction
1­
2
1990
Supplement
(
a
supplement
to
the
1985
edition
current
as
of
February
1,
1990).
Chapter
7
provides
instructions
on
how
to
obtain
copies
of
the
IUR
and
TSCA
regulations.

1.1
Changes
from
2002
IUR
Reporting
Requirements
EPA
made
several
major
changes
to
the
2002
IUR
reporting
requirements,
which
are
highlighted
in
Table
1­
1
and
explained
later
in
this
document.
In
addition,
Form
U
was
revised
to
incorporate
these
changes.
Appendix
A
contains
the
Draft
2006
Form
U,
which
is
still
being
improved.

1.2
Rationale
for
IUR
Changes
EPA
amended
the
IUR
on
[
DATE
TO
BE
ADDED]
for
three
primary
reasons:


To
tailor
the
chemical
substance
reporting
requirements
to
more
closely
match
EPA's
information
needs;


To
obtain
new
and
updated
information
concerning
potential
exposures
to
a
subset
of
chemical
substances
listed
in
the
TSCA
Inventory;
and

To
improve
the
utility
of
the
information
reported.

These
goals
are
supported
by
the
policy
in
TSCA
section
2(
b)(
1)
that
"
adequate
data
should
be
developed
with
respect
to
the
effect
of
chemical
substances
and
mixtures
on
health
and
the
environment
and
that
the
development
of
such
data
should
be
the
responsibility
of
those
who
manufacture
and
those
who
process
such
chemical
substances
and
mixtures."
EPA
believes
that
the
data
currently
available
to
EPA
are
generally
inadequate
for
risk
screening
purposes.
TSCA
section
8(
a)(
2)
authorizes
EPA
to
require
manufacturers
and
processors
of
chemical
substances
to
report
a
wide
variety
of
data,
including
exposure­
related
information
that
will
be
reported
for
certain
chemical
substances
under
the
revised
IUR.
The
IUR
amendments
removed
certain
reporting
requirements
and
added
others
to
allow
the
Agency
to
collect
information
that
is
most
needed
by
EPA
and
other
federal
agencies
for
screening,
assessing,
and
managing
risk.
The
availability
of
these
data
will
enhance
public
awareness
of
basic
information
about
chemical
substances.

The
information
collected
under
this
revised
IUR
will
enable
EPA
to
develop
a
more
systematic
and
comprehensive
approach
to
the
chemicals
prioritization
process.
EPA
uses
exposure
information
in
a
wide
variety
of
analyses
and
decision­
making,
including
that
associated
with
projects
within
the
Existing
Chemicals
Program,
the
High
Production
Volume
(
HPV)
Program,
and
Design
for
the
Environment
(
DfE).
(
Further
information
on
these
projects
can
be
found
at
http://
www.
epa.
gov/
opptintr/.)
Often
under
these
programs,
EPA
completes
an
initial
review
of
chemical
substances
to
identify
those
substances
that
raise
particular
concerns
as
to
the
potential
risks
they
present
to
human
health
and
the
environment.
See
EPA's
report
entitled
[
ADD
DUP
report
title]
for
additional
explanations
and
examples
of
anticipated
uses
of
the
IUR
exposure
data.
[
add
docket
reference
for
location
of
report]
DRAFT:
Chapter
1.0
Introduction
1­
3
1.3
Use
of
Exposure­
Related
Information
The
new
IUR
reporting
requirements
for
exposure­
related
information
are
related
to,
or
are
indicative
of,
three
components
of
exposure:


The
number
of
ecosystems
or
size
of
human
populations
potentially
exposed
(
e.
g.,
data
elements
concerning
number
of
sites,
number
of
workers,
and
use
in
consumer
products);


The
potential
routes,
magnitudes,
and
concentrations
of
exposures
experienced
by
the
environment
or
by
humans
(
e.
g.,
data
elements
concerning
function
of
chemical
substances
in
industrial
processes,
physical
form
of
chemical
substances,
industrial
sectors
where
chemical
substances
are
manufactured
and
used,
and
maximum
concentration);
and

The
frequency
and
duration
of
potential
exposures
(
e.
g.,
data
elements
concerning
industrial
function
categories
and
commercial
and
consumer
use
categories).

Effective
risk
screening
and
risk
management
depend
on
both
exposure
information
and
hazard
information.
The
IURA
will
provide
EPA
with
data
that
will
more
accurately
and
realistically
gauge
potential
exposure.
The
exposure­
related
information
reported
under
the
IURA
will
be
used
in
combination
with
hazard
information
such
as
that
developed
under
TSCA
section
4
test
rules
and
enforceable
consent
agreements/
orders,
through
voluntary
efforts
such
as
the
HPV
Program,
and
other
sources.
Because
of
the
limitations
of
the
data
available
from
past
information
collections
(
such
as
the
one­
time
reporting
of
information
by
a
subset
of
the
manufacturers
of
a
small
number
of
selected
high
production
volume
chemicals
as
was
included
in
EPA's
voluntary
Use
and
Exposure
Information
Project
(
UEIP)),
EPA
is
collecting
the
information
necessary
to
develop
an
exposure
database.
Table
1­
2
provides
examples
of
how
the
exposure
information
will
be
used.
The
new
data
elements
included
in
the
2006
IUR
collection
will
supplement
the
data
collected
under
the
previous
IUR,
improving
EPA's
ability
to
evaluate
each
of
these
components
of
exposure.
This
new
exposure­
related
information
will
facilitate
a
more
efficient
and
effective
screening
of
chemical
substances
based
either
on
exposure
or
on
risk.
DRAFT:
Chapter
1.0
Introduction
1­
4
Table
1­
1.
Changes
Made
to
2002
IUR
Reporting
Requirements
Reporting
thresholds
increased
The
production
volume
reporting
threshold
was
raised
from
10,000
lbs/
yr
to
25,000
lbs/
yr.
A
larger­
volume
reporting
threshold
of
300,000
lbs/
yr
was
added
for
the
reporting
of
exposure­
related
processing
and
use
information.

Reporting
of
manufacturing
exposure­
related
information
added
Manufacturers
(
including
importers)
are
required
to
report
(
1)
the
number
of
workers
(
in
ranges)
reasonably
likely
to
be
exposed
to
the
chemical
substance
at
the
site
of
manufacture
or
import,
(
2)
the
physical
form(
s)
of
the
substance
as
it
leaves
the
submitter's
possession,
(
3)
the
percentage
of
the
total
production
volume
associated
with
each
physical
form,
and
(
4)
the
maximum
concentration
(
in
ranges)
of
the
chemical
substance
at
the
time
it
is
reacted
on­
site
to
produce
a
different
chemical
substance
or
it
leaves
the
submitter's
possession.

Reporting
of
industrial,
commercial,
and
consumer
exposure­
related
information
added
Chemical
manufacturers,
including
importers,
of
larger­
volume
(
300,000
lbs/
yr
or
greater)
chemical
substances
are
required
to
report
information
concerning
the
processing
and
use
of
each
reportable
chemical
substance.
Specifically,
the
following
information
is
to
be
reported
(
in
ranges
where
applicable):
Industrial
Processing
and
Use
Information

Type
of
industrial
processing
or
use
operation
at
each
site,
including
downstream
sites

Five­
digit
North
American
Industrial
Classification
System
(
NAICS)
codes
that
best
describe
the
industrial
activities
associated
with
the
use
or
processing
of
the
substance

Industrial
functions
of
the
chemical
substances
during
the
processing
or
use
operation
for
each
NAICS
code
reported

Percentage
of
production
volume
associated
with
each
industrial
function
category

Number
of
processing
and
use
sites

Aggregate
number
of
workers
reasonably
likely
to
be
exposed
to
the
chemical
substance
in
each
processing
and
use
operation

Commercial
and
Consumer
Use
Information

Commercial
and
consumer
product
use
categories
of
the
chemical
substance

Indication
of
the
presence
of
the
substance
in
consumer
products
intended
for
children

Percentage
of
production
volume
associated
with
each
commercial
and
consumer
product
use
category

Maximum
concentration
of
the
chemical
substance
in
each
commercial
and
consumer
product
use
category.

Reporting
requirements
for
site
identity
added
The
reporting
of
the
plant
site's
county
or
parish
was
added.
Additionally,
a
provision
to
supply
an
email
address
for
the
technical
contact
was
added.

Reporting
of
inorganic
chemical
substances
added
Reporting
is
required
for
inorganic
chemical
substances.
For
2006
reporting,
a
partial
reporting
exemption
for
inorganic
chemicals
substances
is
in
place.
For
reporting
in
future
years,
manufacturers
must
fully
report
these
substances.
DRAFT:
Chapter
1.0
Introduction
1­
5
Petroleum
process
stream
exemption
added
A
partial
reporting
exemption
was
created
for
certain
listed
petroleum
process
streams.

Natural
gas
exemption
added
A
full
exemption
from
IUR
reporting
for
certain
forms
of
natural
gas
was
added.

Records
retention
period
extended
The
records
retention
period
was
extended
from
4to
5years.

Reporting
changed
The
period
for
which
reporting
is
required
was
changed
from
a
corporate
fiscalyear
basis
to
a
calendar­
year
basis.

CBI
claims
for
production
volume
ranges
allowed
Submitters
can
now
claim
their
production
volume
ranges
as
CBI,
in
addition
to
the
existing
requirement
that
submitters
report
a
specific
production
volume
number
and
the
CBI
status
of
that
number.
This
change
allows
submitters
to
assert
a
confidentiality
claim
for
specific
production
volume
information
while
releasing
the
more
general
production
volume
range
as
public
information.

Up­
front
substantiation
for
plant
site
CBI
claims
required
Up­
front
substantiation
of
plant
site
confidentiality
claims
is
now
required
for
IUR
submissions
to
EPA.
This
requirement
is
similar
to
the
up­
front
substantiation
requirement
for
chemical
identity
claims.

Partial
exemption
for
specific
chemical
substances
added
A
partial
reporting
period
was
created
for
specific
chemical
substances
where
EPA
identified
that
there
is
a
low
interest
in
the
IURA
processing
and
use
information
related
to
the
chemical.
These
chemicals
are
not
subject
to
the
reporting
of
processing
and
use
information.
EPA
has
identified
a
list
of
chemicals
that
are
covered
by
this
partial
exemption,
which
can
be
found
at
40
CFR
711.26(
b)(
2)(
iv).
DRAFT:
Chapter
1.0
Introduction
1­
6
Table
1­
2.
Selected
Potential
Uses
of
Exposure­
Related
Information
!
Identify
and
manage
human
health
and
environmental
risks
by
providing
EPA
with
exposure
information
on
nationwide
chemical
production
and
exposure
so
that
all
chemicals
in
commerce
can
be
screened
for
safe
use.

!
Provide
indispensable
information
for
the
creation
and
implementation
of
voluntary
and
regulatory
multimedia
pollution
prevention
activities
by
federal
and
state
chemical
managers.

!
Identify
chemicals
to
which
large
number
of
workers
are
exposed
 
to
the
benefit
of
EPA,
Occupational
Safety
and
Health
Administration,
National
Institute
of
Occupational
Safety
and
Health,
National
Institutes
of
Health,
organized
labor,
chemical
industry,
and
other
organizations'
risk
management
programs.

!
Identify
chemicals
to
which
large
numbers
of
consumers
are
exposed
 
to
the
benefit
of
Consumer
Product
Safety
Commission,
EPA,
and
public
consumer
protection
organizations'
risk
management
programs.

!
Provide
data
to
support
TSCA
Test
Rules
promulgated
to
supplement
the
HPV
Program,
Voluntary
Children's
Health
Testing
Program,
and
other
testing
programs
and
single
rules.

!
Identify
industries
and
clusters
of
chemicals
for
the
DfE
program.
Provide
data
to
determine
the
focus
of
DfE
projects.

!
Provide
comprehensive
data
that
will
allow
EPA
to
develop
better
assessment
models
to
be
used
in
the
review
of
new
and
existing
chemicals
and
in
the
Use
Cluster
Scoring
System
(
UCSS).

!
Provide
data
needed
to
screen
and
prioritize
large
numbers
of
chemicals
in
a
more
timely
and
efficient
manner.

!
Provide
information
in
a
database
format
that
is
easy
to
use,
easy
to
search,
and
readily
accessible
to
EPA
employees.
This
format
allows
more
efficient
use
of
the
information.

!
Provide
EPA
and
other
federal,
state,
local,
and
tribal
risk
managers
with
the
necessary
building
blocks
to
assist
the
public
in
better
examining
the
substances
they
may
be
exposed
to
in
the
products
they
buy
and
use.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
1
2.0
Reporting
Requirements
This
chapter
explains
the
reporting
requirements
for
the
2006
IUR
reporting
cycle.
Reporting
requirements
have
changed
since
the
last
reporting
cycle
in
2002.
To
ascertain
your
reporting
requirements,
you
must
make
two
determinations
for
each
chemical
substance
that
you
manufacture
in
the
United
States
or
import
into
the
United
States:


Is
the
substance
reportable
under
the
IUR?


Are
you
a
manufacturer
(
or
an
importer
or
company
that
manufactures
chemicals
for
export
only)
who
is
required
to
report
that
substance?

Figure
2­
1
is
a
decision
tree
summarizing
the
questions
that
must
be
answered
to
determine
your
reporting
obligations
for
a
particular
substance.
Detailed
reporting
obligations
are
discussed
further
in
this
chapter.
Appendix
B
provides
definitions
of
terms
used
for
IUR
reporting.

2.1
Is
Your
Chemical
Substance
Reportable
Under
the
IUR?

A
chemical
substance
that
is
reportable
under
the
IUR
must
appear
in
the
TSCA
Inventory
as
of
August
25,
2002,
and
not
be
exempt
from
reporting
under
the
IUR.
The
TSCA
Inventory
and
the
specific
exemptions
from
reporting
are
described
below.

2.1.1
Is
Your
Chemical
Substance
in
the
TSCA
Inventory?

The
following
subsections
provide
information
to
determine
if
your
chemical
substance
is
listed
in
the
TSCA
Inventory.

2.1.1.1
What
is
the
TSCA
Inventory?
The
TSCA
Inventory
is
a
list
of
toxic
chemical
substances
distributed
in
commerce
in
the
United
States.
The
TSCA
Inventory
was
originally
compiled
from
reports
submitted
in
1978
and
1979
by
manufacturers,
importers,
and
certain
processors.
Subpart
A
of
40
CFR
Part
711
prescribes
criteria
for
including
a
substance
in
the
TSCA
Inventory.
New
chemical
substances
are
added
to
the
TSCA
Inventory
when
companies
that
have
submitted
Premanufacture
Notifications
(
PMNs)
or
Polymer
Exemption
Applications
to
EPA
under
section
5
of
TSCA
notify
EPA
that
they
have
begun
to
manufacture
or
import
the
chemical
substance.

EPA
keeps
a
Master
Inventory
File,
which
is
the
authoritative
list
of
all
the
eligible
chemical
substances
that
have
been
reported
to
EPA
for
inclusion
in
the
TSCA
Inventory.
EPA
also
makes
the
inventory
list,
commonly
referred
to
as
the
Public
Inventory,
available
to
the
general
public.
The
Public
Inventory
does
not
contain
the
specific
identities
of
chemical
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
2
Is
substance
on
Inventory?

Substance
a
polymer,
natural
gas
stream,
microorganism
or
naturally
occurring?

Did
you
manufacture
or
import
the
substance
under
circumstances
for
which
reporting
is
not
required?
Are
you
a
small
manufacturer
of
this
substance?

Did
you
manufacture
or
import
25,000
lb
or
more
in
2001
at
a
single
site?

You
must
complete
Parts
I,
II,
III,
&
IV
of
Form
U
Did
you
manufacture
or
import
300,000
lb
or
more
in
2001
at
a
single
site?
Is
this
substance
inorganic
or
a
multichemical
petroleum
stream?
Is
this
substance
subject
to
a
special
regulatory
action
under
TSCA?

You
need
not
report
You
must
complete
only
Parts
I,
II,
&
IV
of
Form
U
YES
YES
YES
NO
NO
NO
NO
NO
YES
YES
NO
YES
NO
YES
YES
NO
Figure
2­
1.
Decision
tree
for
determining
compliance
obligations
under
the
IUR.
substances
that
have
been
claimed
as
CBI;
it
only
contains
generic
chemical
names
for
these
CBI
chemical
substances.
See
Chapter
7
for
information
on
obtaining
copies
of
the
Public
Inventory.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
3
Hydrates
are
not
listed
in
the
TSCA
Inventory.
However,
you
are
required
to
report
the
CAS
registry
number
of
the
corresponding
anhydrous
form.
Adjust
the
reported
production
volume
to
exclude
water.

50,000
lbs.
CuSO
5H
O
159.6
lbs.
CuSO
249.7
lbs.
CuSO
5H
O
=
31,
658
lbs.
CuSO
4
2
4
4
2
4
 
×
 
2.1.1.2
How
Do
You
Determine
Whether
a
Chemical
Substance
is
Listed
on
the
TSCA
Chemical
Substance
Inventory?
You
may
use
the
following
methods
to
determine
if
your
chemical
substance
is
listed
in
the
TSCA
Inventory:


Locate
the
substance
in
the
Public
Inventory
(
see
Chapter
7
for
more
information);


Search
company
records
to
determine
if
the
substance
was
previously
reported
to
EPA
under
the
IUR;


Search
company
records
for
a
PMN
or
other
communication
that
confirmed
with
EPA
the
substance
was
in
the
TSCA
Inventory;
and

Search
company
records
for
a
Notice
of
Commencement
of
manufacture
or
import
for
a
PMN
substance
that
was
submitted
to
EPA.

Several
commercial
databases
have
incorporated
the
Public
Inventory
(
which
excludes
substances
with
confidential
identities)
and
indicate
whether
a
given
chemical
substance
is
included
in
the
TSCA
Inventory.
Because
these
databases
are
not
generated
or
peer­
reviewed
by
EPA,
the
Agency
cannot
guarantee
the
accuracy
of
the
information
in
these
databases.
Thus,
there
is
no
penalty
for
reporting
a
substance
that
may
be
listed
on
a
commercial
database,
but
is
not
required
to
be
reported.
However,
if
a
commercial
database
that
you
use
fails
to
include
all
reportable
chemicals
and,
as
a
result,
you
fail
to
report
information
for
these
chemicals,
you
would
be
in
violation
of
TSCA.
Please
note
that
hydrates
are
not
listed
in
the
TSCA
Inventory;
however,
you
are
required
to
report
the
CAS
registry
number
of
the
corresponding
anhydrous
form.
You
should
adjust
the
reported
production
volume
to
exclude
water.

For
example,
Company
A
manufactures
50,000
pounds
of
copper
(
II)
sulfate
hydrate,
CuSO
4

5H
2
O.
This
chemical
should
be
reported
under
the
anhydrous
form
of
copper
(
II)
sulfate,
CuSO
4.
To
calculate
the
production
volume,
multiply
the
mass
of
hydrated
compound
by
the
weight
fraction
(
ratio
of
molecular
weights)
of
anhydrous
copper
(
II)
sulfate,
CuSO
4,
in
the
hydrated
copper
(
II)
sulfate,
CuSO
4

5H
2
O.
The
molecular
weights
of
CuSO
4
and
CuSO
4

5H
2
O
are
159.6
pounds
per
pound­
mole
and
249.7
pounds
per
pound­
mole,
respectively.
Company
A
should
report
31,658
pounds
of
anhydrous
copper
(
II)
sulfate
on
Form
U
based
on
the
following
calculation:

Since
31,658
pounds
is
greater
than
or
equal
to
25,000
pounds
but
less
than
300,000
pounds,
Company
A
should
complete
Parts
I
and
II
of
Form
U.

2.1.1.3
What
Do
You
Do
if
You
Cannot
Find
Your
Chemical
Substance
in
the
TSCA
Chemical
Substance
Inventory?
If
after
having
checked
the
above
sources,
you
are
still
uncertain
as
to
whether
a
chemical
substance
is
listed
on
the
TSCA
Inventory,
write
a
letter
to
EPA
at
the
following
address:
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
4
ATTN:
Inventory
Update
Rule
OPPT
Document
Control
Officer
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7407M)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460.

Your
letter
should
request
that
EPA
search
the
Master
Inventory
File,
including
confidential
substances,
to
determine
whether
the
substance
is
listed.
Because
searches
of
the
Master
Inventory
File
are
labor­
intensive,
you
are
urged
to
request
such
a
search
only
if
your
search
of
the
Public
Inventory,
commercial
databases,
and
your
company's
records
fails
to
resolve
your
question.
Moreover,
if
your
request
is
not
received
prior
to
October
25,
2006,
EPA
cannot
guarantee
that
you
will
receive
a
response
in
time
for
you
to
complete
the
reporting
form
before
the
end
of
the
reporting
period.

In
communicating
with
EPA,
you
must
substantiate
the
fact
that
you
are
manufacturing
or
importing
the
substance
in
question
by
providing
the
following
information:


Company
identification,
address,
and
telephone
number;


Specific
chemical
identity
of
the
substance,
preferably
a
Chemical
Abstracts
Service
(
CAS)
Preferred
or
Index
Name,
a
CAS
Registry
Number
(
if
available),
and
a
structural
diagram
(
if
available);


A
statement
signed
by
a
company
officer
that
your
company
is
manufacturing
and/
or
importing
the
chemical
substance
for
commercial
purposes;


A
statement
signed
by
a
company
officer
that
your
company
is
requesting
this
search
pursuant
to
the
IUR;
and

An
elemental
analysis
of
the
substance.

Your
letter
may
be
claimed
CBI
if
you
have
reason
to
believe
that
release
of
the
information
would
reveal
trade
secrets
or
confidential
commercial
or
financial
information
(
as
provided
by
section
14
of
TSCA
and
40
CFR
Part
2).
If
you
assert
that
any
of
the
information
contained
in
the
letter
is
CBI,
you
must
clearly
identify
the
information
that
is
claimed
confidential
by
marking
the
specific
information
on
each
page
with
a
label
as
"
confidential
business
information,"
"
proprietary,"
or
"
trade
secret."
EPA's
procedures
for
processing
and
reviewing
confidentiality
claims
are
set
forth
at
40
CFR
Part
2,
subpart
B.
EPA
strongly
encourages
you
to
review
confidentiality
claims
carefully
to
ensure
that
the
information
in
question
falls
within
the
protection
of
TSCA
section
14
and
to
limit
confidentiality
claims
as
much
as
possible.

If
you
claim
CBI,
EPA
recommends
that
you
place
your
letter
and
any
accompanying
materials
in
a
double­
wrapped
package
for
maximum
security.
The
inner
wrapper
should
be
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
5
Polymers,
certain
natural
gas
streams,
and
microorganisms
are
not
excluded
from
reporting
when
they
are
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.
labeled
with
the
recipient's
name
and
the
statement
"
TSCA
Confidential
Business
Information."
The
outer
wrapper
should
be
labeled
only
with
the
name
and
address
of
the
recipient
and
your
return
address.
Nothing
on
the
outer
wrapper
should
indicate
that
the
package
contains
CBI.
This
package
should
be
sent
to
EPA
by
certified
or
registered
mail,
return
receipt
requested,
or
sent
by
courier
service
or
U.
S.
Postal
Service
Express
Mail.
Regular
first
class
mail
should
never
be
used
to
send
CBI
to
EPA.
Failure
to
follow
proper
procedures
regarding
CBI
materials
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
you.
Thus,
it
is
important
that
you
follow
up
with
EPA
to
determine
if
your
claim
was
substantiated.

After
processing
your
response,
EPA
will
inform
you
whether
the
chemical
substance
is
in
the
TSCA
Inventory
and
whether
the
substance
is
subject
to
reporting
under
the
IUR.
If
the
chemical
substance
is
found
on
the
confidential
TSCA
Inventory,
EPA
will
notify
the
person(
s)
who
originally
reported
the
substance
that
another
person
has
requested
information
pursuant
to
the
IUR
procedures
and,
therefore,
was
told
that
the
chemical
substance
is
in
the
TSCA
Inventory
and
that
it
is
subject
to
reporting.

If
you
are
an
importer
and
cannot
provide
all
of
the
required
information
because
your
foreign
manufacturer/
supplier
is
maintaining
it
as
confidential,
the
manufacturer/
supplier
can
send
the
information
directly
to
EPA.
Be
advised
that
it
is
the
obligation
of
the
importer
to
ensure
that
the
foreign
manufacturer
complies
with
the
IUR
requirements.
See
Chapter
6,
Section
6.4of
this
document
for
more
details
related
to
foreign
manufacturers/
suppliers.

2.1.2
Is
Your
Chemical
Substance
Excluded
from
Reporting?

Four
categories
of
substances,
though
included
in
the
TSCA
Inventory,
are
largely
excluded
from
reporting
under
the
IUR.
These
categories
are
polymers,
certain
natural
gas
streams,
microorganisms,
and
naturally
occurring
substances.
Refer
to
section
711.26
of
the
IUR
and
to
the
preamble
of
the
Federal
Register
notice
announcing
the
rule
(
need
FR
reference)
for
precise
definitions
of
these
categories.
Polymers,
certain
natural
gas
streams,
and
microorganisms
are
not
excluded
from
reporting
when
they
are
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.

Certain
petroleum
process
streams
are
excluded
from
parts
of
the
reporting
requirements
(
although
some
information
must
still
be
reported
for
petroleum
process
streams).
Inorganic
substances,
which
were
previously
excluded,
are
no
longer
excluded
from
IUR
reporting;
however,
inorganic
substances
are
excluded
from
parts
of
the
reporting
requirements
for
the
2006
reporting
cycle.
See
Section
2.3.2
for
further
information.

To
help
identify
excluded
substances,
EPA
has
labeled
most
of
these
substances
in
the
printed
and
electronic
versions
of
the
TSCA
Inventory
with
an
"
XU"
flag.
Note
that
you
are
advised
to
use
the
flag
only
as
a
guide;
submitters
are
responsible
for
verifying
exemptions.
If
a
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
6
The
"
XU"
Flag
and
Polymers
Please
note
that
a
few
of
the
polymerization
gases
that
are
not
considered
polymers
might
have
been
incorrectly
flagged
because
of
the
inclusion
of
the
word
"
polymer"
in
the
chemical
name.
These
substances
are
reportable
under
the
IUR.
substance
does
not
bear
an
"
XU"
flag
and
section
711.26
of
the
IUR
does
not
provide
sufficient
guidance
to
determine
whether
the
substance
is
excluded,
contact
the
TSCA
Hotline
at
(
202)
554­
1404
for
assistance.
Table
2­
1
lists
substances
not
flagged
with
"
XU"
that
are
excluded
from
IUR
reporting.

Table
2­
1.
Additional
Chemical
Substances
Excluded
from
IUR
Reporting
Name
CAS
Registry
Number
Carbon
black
1333­
86­
4
Carbon
7440­
44­
0
Graphite
7782­
42­
5
Charcoal
16291­
96­
6
2.1.2.1
Polymers.
The
IUR
definition
of
polymer
is
sufficiently
broad
to
include
virtually
all
those
substances
that
are
generally
considered
polymers.
These
include
siloxanes,
silicone,
rubber,
lignin,
polysaccharides
(
such
as
sugar
and
gums),
proteins
(
such
as
gelatin
and
hemoglobin),
and
enzymes.
However,
substances
that
result
from
hydrolysis,
depolymerization,
or
chemical
modification,
regardless
of
the
extent
of
these
processes,
of
polymers
so
that
the
final
products
are
no
longer
polymeric
(
e.
g.,
a
mixture
of
amino
acids
that
is
the
result
of
hydrolysis
of
a
polypeptide)
are
not
considered
to
be
polymers
and
must
be
reported
if
not
otherwise
excluded.
For
reporting
purposes,
salts
of
polymers
are
also
considered
to
be
polymers.
Please
note
that
a
few
of
the
polymerization
gases
that
are
not
considered
polymers
might
have
been
incorrectly
flagged
with
"
XU"
because
of
the
inclusion
of
the
word
"
polymer"
in
the
chemical
name.
These
substances
are
reportable
under
the
IUR.
See
40
CFR
711.26(
a)(
1)
for
the
regulatory
definition
of
polymers.

2.1.2.2
Microorganisms.
A
microorganism
is
any
combination
of
chemical
substances
that
is
a
living
organism
and
that
meets
the
definition
of
"
microorganism"
at
40
CFR
725.3.
Any
chemical
substance
produced
from
a
living
microorganism
is
reportable
unless
otherwise
excluded..

2.1.2.3
Natural
Gases.
Table
2­
2
identifies
certain
forms
of
natural
gas
that
are
exempt
from
IUR
reporting;
the
natural
gas
exemption
is
new
for
the
2006
reporting
cycle.
EPA
believes
that
adequate
information
has
been
collected
on
these
chemical
substances
to
date
to
fulfill
EPA's
current
needs
and
the
needs
of
other
IUR
users.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
7
Table
2­
2.
Chemical
Substances
Covered
by
Natural
Gas
Exemption
Form
of
Natural
Gas
CAS
Number
Petroleum,
raw
liquid
mix
64741­
48­
6
Natural
gas
condensates
68919­
39­
1
Gasoline
natural
8006­
61­
9
Gasoline
(
natural
gas),
natural
68425­
31­
0
Natural
gas
8006­
14­
2
Natural
gas,
dried
68410­
63­
9
2.1.2.4
Naturally
Occurring
Substances.
Chemical
substances
that
are
manufactured
according
to
the
conditions
in
40
CFR
711.4(
b)
of
the
TSCA
Inventory
Reporting
Regulations
are
considered
"
naturally
occurring"
and
are
not
reportable
under
TSCA.
Examples
of
substances
that
are
typically
naturally
occurring
materials
are
raw
agricultural
commodities,
water,
air,
natural
gas,
crude
oil,
rocks,
ores,
and
minerals.
However,
since
the
section
711.4(
b)
exclusion
is
a
process­
specific
exclusion
rather
than
a
chemical­
specific
one,
if
you
produce
any
substance
in
a
manner
other
than
as
described
in
section
711.4(
b),
you
are
required
to
report
unless
otherwise
excluded.
For
this
reason
minerals
and
certain
agricultural
products
are
sometimes
considered
not
to
be
naturally
occurring
because
of
their
method
of
production.

Further,
section
711.26(
a)(
3)
intentionally
exempts
from
IUR
reporting
any
chemical
substance
that
is
isolated/
removed
from
nature
for
a
commercial
purpose
by
any
of
the
means
listed
in
section
711.4(
b).
It
also
exempts
any
other
chemical
substance
derived
or
separated
from
the
substance
originally
removed
from
nature,
provided
such
derivation
involved
only
the
means
specified
in
that
section
(
e.
g.,
being
obtained
by
aqueous
extraction
or
flotation
or
by
pressing).
Whether
a
substance
is
considered
"
naturally
occurring"
depends
on
the
manner
in
which
it
is
produced
and
isolated.
Table
2­
3
presents
some
examples
of
evaluating
the
naturally
occurring
substance
exemption.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
8
Table
2­
3.
Examples
of
Evaluating
Naturally
Occurring
Substance
Exemptions
!

Calcined
clays
that
are
formed
by
heating
naturally
occurring
clay
are
must
be
reported
because
such
heating
is
not
done
solely
to
remove
water;
a
chemical
change
is
primarily
intended.

!

The
naturally
occurring
substance
category
contains
only
those
substances
that
are
removed/
isolated
from
nature
essentially
by
physical
or
natural
means.
Using
water
to
extract
a
chemical
substance
from
a
naturally
occurring
substance
is
considered
a
natural
means
of
removal.
However,
using
any
other
solvent
is
not
considered
a
natural
means
of
removal.

!

In
an
electrostatic
separation,
small
particles
are
removed
from
a
liquid
or
gas
stream.
The
process
is
essentially
analogous
to
a
filtration
or
gravitational
separation.
Substances
that
are
processed
by
this
means
fall
within
the
naturally
occurring
substances
category.

!

The
mining
of
coal
is
included
in
the
naturally
occurring
chemical
substances
category.
However,
heating
coal
to
produce
light
oils
or
other
chemical
substances
is
not
included
in
this
category
and
must
be
reported.

!

Ammonia
and
nitric
acid
are
generally
produced
by
chemical
synthesis
and
are,
therefore,
not
considered
naturally
occurring.

2.1.3
When
Must
You
Still
Report
an
Excluded
Substance?

With
the
exception
of
naturally
occurring
substances,
a
chemical
substance
that
falls
into
one
of
the
excluded
categories
must
still
be
reported
if
it
is
the
subject
of
any
of
the
following:
a
rule
proposed
or
promulgated
under
sections
4,
5(
a)(
2),
5(
b)(
4),
or
6
of
TSCA;
an
order
issued
under
TSCA
sections
5(
e)
or
5(
f);
or
relief
that
has
been
granted
under
a
civil
action
under
TSCA
sections
5
or
7.
Appendix
C
lists
the
chemical
substances
that
fall
into
these
categories.
However,
if
you
are
unable
to
determine
whether
the
specific
chemical
substance
you
manufacture
or
import
falls
under
one
of
the
generic
chemical
names
listed
in
Appendix
C,
you
can
contact
EPA
to
see
if
the
specific
substance
is
reportable
(
see
Chapter
8
for
contact
information).

If
you
qualify
as
a
small
manufacturer
(
see
Section
2.2.1),
you
must
still
report
if
you
produced
25,000
pounds
or
more
of
a
reportable
substance
that
is
the
subject
of
a
rule
proposed
or
promulgated
under
sections
4,
5(
b)(
4),
or
6
of
TSCA;
an
order
under
TSCA
section
5(
e);
or
relief
granted
under
a
civil
action
under
TSCA
sections
5
or
7.
Appendix
C
lists
all
substances
that
fall
into
these
categories.

2.1.4
When
is
the
Manufacture
or
Importation
of
Chemical
Substances
Subject
to
TSCA
but
not
Included
on
the
TSCA
Chemical
Substance
Inventory?

When
checking
the
chemical
substances
you
manufacture
or
import
against
the
TSCA
Inventory,
you
may
discover
that
you
are
manufacturing
or
importing
substances
that
are
not
in
the
TSCA
Inventory
but
should
have
been
reported
to
EPA
and
were
not.
Such
manufacture
or
importation
is
in
violation
of
section
15
of
TSCA
and
could
subject
you
to
administrative
or
criminal
penalties.
Similarly,
if
you
are
manufacturing
or
importing
a
substance
that
was
previously
in
the
TSCA
Inventory
but
has
subsequently
been
delisted,
then
you
are
also
in
violation
of
section
15
of
TSCA.
If
either
of
these
situations
applies
to
you,
you
should
send
a
letter
to
EPA
at
the
following
address:
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
9
Small
manufacturers
are
still
required
to
report
on
substances
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.
Director
Toxics
and
Pesticides
Enforcement
Division
Office
of
Regulatory
Enforcement
(
2245)
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Information
in
your
letter
may
be
claimed
as
confidential
by
circling
or
bracketing
the
text
to
be
protected
and
marking
the
page
"
Confidential."
Failure
to
so
mark
this
information
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
you.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

Significant
reductions
in
penalties
are
given
for
people
voluntarily
disclosing
such
information.
Note,
however,
that
continued
manufacture
or
importation
of
such
chemical
substances
remains
in
violation
of
section
15
of
TSCA,
even
after
you
have
contacted
EPA,
until
the
reporting
requirements
of
TSCA
have
been
met.

2.2
Are
You
a
Manufacturer
Who
Is
Required
to
Report
That
Chemical
Substance?

Even
if
you
manufacture
(
including
companies
that
manufacture
solely
for
export)
or
import
a
chemical
substance
reportable
under
the
IUR,
you
may
be
exempt
from
the
reporting
requirements
for
that
substance.
To
determine
whether
you
must
report,
you
must
answer
the
following
three
questions:


Do
you
qualify
as
a
small
manufacturer
with
respect
to
the
chemical
substance?


Did
you
manufacture
or
import
25,000
pounds
or
more
of
the
reportable
substance
at
any
single
site
during
the
calendar
year
immediately
preceding
the
reporting
period
(
e.
g.,
during
2005)?


Did
you
manufacture
or
import
the
reportable
substance
under
circumstances
that
do
not
require
reporting
(
e.
g.,
considering
other
reporting
exemptions)?

2.2.1
Are
You
a
Small
Manufacturer?

Small
manufacturers
(
including
both
manufacturers
and
importers)
are
usually
exempt
from
reporting
under
the
IUR.
Small
manufacturers
are
still
required
to
report
on
substances
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.
You
qualify
as
a
small
manufacturer
if
you
meet
either
one
of
the
following
criteria:
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
10

Your
total
annual
sales,
combined
with
those
of
your
parent
company,
domestic
or
foreign
(
if
any),
do
not
exceed
$
4
million
regardless
of
annual
production
volume;
or

Your
total
annual
sales,
combined
with
those
of
your
parent
company,
domestic
or
foreign
(
if
any),
are
less
than
$
40
million
with
respect
to
a
particular
substance
for
those
plant
sites
at
which
annual
production
volume
of
that
substance
does
not
exceed
100,000
pounds.
If
the
annual
production
volume
of
the
substance
at
any
of
your
sites
is
over
100,000
pounds,
you
are
required
to
report
only
for
those
sites.
Note
that
it
is
possible
to
qualify
as
a
small
manufacturer
with
respect
to
some
substances
and
not
others
or
with
respect
to
some
plant
sites
and
not
others.

Table
2­
4
provides
some
examples
of
how
the
small
manufacturing
exemption
applies.

Table
2­
4.
Small
Manufacturer
Exemption
Examples
Description
2006
Reporting
Requirement
Site
1,
which
is
one
of
several
sites
owned
by
Company
A,
had
a
production
volume
of
120,000
pounds
of
Chemical
X
in
2005.
The
total
annual
sales
of
Company
A
(
all
sites
combined)
were
$
1,250,000
in
2005.
Site
1
is
not
required
to
report
for
Chemical
X
because
combined
sales
in
2005
did
not
exceed
$
4
million.
The
annual
production
volume
for
a
specific
chemical
is
immaterial.

Site
2,
which
is
one
of
several
sites
owned
by
Company
B,
had
a
production
volume
of
90,000
pounds
of
Chemical
X
in
2005.
The
total
annual
sales
of
Company
B
(
all
sites
combined)
were
$
20,000,000
in
2005.
Site
2
is
not
required
to
report
for
Chemical
X
because
annual
production
volume
of
that
chemical
did
not
exceed
100,000
pounds
and
Company
B
had
total
annual
sales
of
less
than
$
40
million.

Site
3,
which
is
one
of
several
sites
owned
by
Company
C,
had
a
production
volume
of
200,000
pounds
of
Chemical
X
in
2005.
Site
4,
another
site
owned
by
Company
C,
had
a
production
volume
of
75,000
pounds
of
Chemical
X
in
2005.
The
total
annual
sales
of
Company
C
(
all
sites
combined)
were
$
30,000,000
in
2005.
Company
C
must
report
for
Chemical
X
at
Site
3
because
annual
production
volume
at
Site
3
exceeded
100,000
pounds.
Company
C
is
not
required
to
report
for
Chemical
X
at
Site
4
because
annual
production
volume
at
site
4
did
not
exceed
100,000
pounds
and
total
annual
sales
were
less
than
$
40
million.

Site
5,
which
is
one
of
several
sites
owned
by
Company
D,
had
a
production
volume
of
50,000
pounds
of
Chemical
X
in
2005.
The
total
annual
sales
of
Company
D
(
all
sites
combined)
were
$
100,000,000
in
2001.
Company
D
must
report
for
Chemical
X
at
Site
E
because
total
annual
sales
in
2005
exceeded
$
40
million.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
11
If
your
company
is
importing
a
chemical
substance
at
a
given
site,
more
than
one
person
may
meet
the
criteria
for
importer.
In
this
instance,
only
one
person
should
submit
a
report
to
EPA.
2.2.2
Do
You
Manufacture
the
Chemical
in
Quantities
of
25,000
Pounds
or
More?

Unless
you
are
a
small
manufacturer
as
described
in
Section
2.2.1,
if
you
manufactured
(
including
imported)
25,000
pounds
or
more
of
a
reportable
chemical
substance
at
any
single
site
you
owned
or
controlled
at
any
given
time
during
calendar
year
2005,
you
are
subject
to
reporting.

2.2.2.1
Definitions.
The
definitions
of
three
terms
necessary
to
understand
these
requirements
are
presented
here.

Manufacture.
Manufacture
means
to
import,
produce,
or
manufacture
with
the
purpose
of
obtaining
an
immediate
or
eventual
commercial
advantage.
This
includes,
for
example,
manufacturing
or
importing
any
amount
of
a
chemical
substance
for
commercial
distribution
(
including
test
marketing)
or
for
use
by
the
manufacturer,
including
use
for
product
research
and
development
or
as
an
intermediate.
If
you
manufacture
an
IUR­
reportable
chemical
substance
solely
for
export,
you
are
required
to
report
and
otherwise
comply
with
all
IUR
requirements
applicable
to
manufacturers
of
all
IUR­
reportable
chemicals.

Importers.
The
site
where
you
import
a
chemical
substance
is
considered
the
site
of
the
operating
unit
within
your
organization
that
is
directly
responsible
for
importing
the
substance
and
controls
the
import
transaction.
In
some
cases,
the
import
site
may
be
the
organization's
headquarters
in
the
United
States;
in
others,
it
is
a
specific
plant
site
or
a
broker.
If
your
company
is
importing
a
chemical
substance
at
a
given
site,
more
than
one
person
may
meet
the
criterion
for
importer.
In
this
instance,
only
one
person
should
submit
a
report
to
EPA.

Example
2­
2.
The
headquarters
of
Company
A
is
located
in
Town
U.
Site
1
of
Company
A
is
located
in
Town
V,
which
is
in
a
different
state.
Employee
M,
based
at
the
headquarters,
purchases
and
arranges
to
have
500,000
pounds
of
Chemical
X
imported
from
Japan
to
Site
1.
Employee
N,
based
at
Site
1,
is
also
involved
with
making
arrangements
to
receive
Chemical
X.
Both
Employee
M
and
Employee
N
are
defined
as
importers,
but
only
one
is
required
to
report.

Example
2­
3.
The
headquarters
of
Company
A
is
located
in
Town
U.
Company
A
controls
three
manufacturing
sites,
Sites
1,
2,
and
3,
all
located
different
states.
Employee
M,
based
at
the
headquarters,
purchases
and
arranges
to
have
500,000
pounds
of
Chemical
X
imported
from
Japan.
20,000
pounds
is
delivered
to
Site
1;
180,000
pounds
is
delivered
to
Site
2;
and
300,000
pounds
is
delivered
to
Site
3.
The
20,000
pounds
delivered
to
Site
1
does
not
need
to
be
reported
because
it
is
below
the
25,000
pound
threshold.
Company
A
must
complete
two
forms,
one
for
Site
2
and
one
for
Site
3.
These
forms
may
be
completed
by
either
a
representative
from
company
headquarters
or
a
site
representative,
but
not
both.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
12
2.2.2.2
Meeting
the
25,000­
Pound
Annual
Production
Volume
Threshold.
You
must
report
a
chemical
substance
only
if
you
manufactured
and/
or
imported
25,000
pounds
or
more
of
the
substance
at
any
single
site
you
owned
or
controlled
during
the
calendar
year
immediately
preceding
the
reporting
period.
Moreover,
if
during
the
year
you
manufactured
25,000
pounds
or
more
of
the
substance
at
some
sites
and
less
than
25,000
pounds
at
other
sites,
you
will
need
to
report
the
substance
only
for
those
sites
at
which
you
manufactured
and/
or
imported
25,000
pounds
or
more.
Some
companies
may
both
manufacture
and
import
the
same
substance.
These
companies
should
add
together
the
manufacturing
and
importation
volumes
at
each
site
to
determine
whether
they
exceed
the
25,000­
pound
threshold.

In
many
cases,
reportable
substances
are
contained
within
a
mixture.
Although
mixtures
are
not
reportable,
the
chemical
substances
making
up
a
mixture
are
reportable.
If
you
manufacture
the
substances
as
part
of
a
mixture,
you
must
determine
for
each
substance
in
the
mixture
whether
the
production
volume
was
over
25,000
pounds.
Similarly,
if
you
import
a
mixture,
you
must
determine
for
each
substance
in
the
mixture
whether
its
importation
volume
is
25,000
pounds
or
more.
Note,
however,
that
a
person
who
produces
a
mixture
by
combining
existing
substances
without
a
chemical
reaction
is
not
a
manufacturer
of
those
substances
and,
therefore,
does
not
have
to
report
those
substances
under
the
IUR.

Table
2­
5
provides
some
examples
of
how
the
annual
production
volume
reporting
requirement
applies.

Table
2­
5.
Annual
Production
Volume
Threshold
Examples
Description
2006
Reporting
Requirement
Company
A,
which
has
only
one
manufacturing
site,
manufactured
26,000
pounds
of
Chemical
X,
which
is
not
exempt
from
reporting,
at
its
site
in
2005.
Company
A
must
report
for
Chemical
X
because
it
manufactured
25,000
pounds
or
more
of
Chemical
X
in
2005.

Company
B,
which
has
only
one
manufacturing
site,
manufactured
26,000
pounds
of
Chemical
X
at
its
site
in
2004
and
20,000
pounds
of
Chemical
X
in
2005.
Company
B
is
not
required
to
report
for
Chemical
X
because
it
manufactured
less
than
25,000
pounds
of
Chemical
X
in
2005.

Company
C
has
two
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
13,000
pounds
of
Chemical
X
and
Site
2
manufactured
15,000
pounds
of
Chemical
X.
Company
C
is
not
required
to
report
for
Chemical
X
at
either
site
because
2005
production
was
less
than
25,000
pounds
at
each
site.

Company
D
has
two
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
10,000
pounds
of
Chemical
X
and
Site
2
manufactured
150,000
pounds
of
Chemical
X.
Company
D
is
not
required
to
report
for
Chemical
X
for
Site
1
because
2005
production
was
less
than
25,000
pounds,
but
must
report
for
Chemical
X
at
Site
2
because
at
this
location
production
was
25,000
pounds
or
more
in
2005.
DRAFT:
Chapter
2.0
Reporting
Requirements
Description
2006
Reporting
Requirement
2­
13
Company
E
has
one
site
where
it
imports
and
manufactures
Chemical
X.
Company
E
manufactured
21,000
pounds
of
Chemical
X
and
imported
5,000
pounds
of
Chemical
X
in
2005.
Company
E
must
report
for
Chemical
X
because
the
total
produced
and
imported
in
2005
was
25,000
pounds
or
more.

In
2005,
Company
F
manufactured
100,000
pounds
of
a
liquid
that
contains
Chemical
X
at
50%
by
weight.
Company
F
produced
Chemical
X
via
a
chemical
reaction;
it
did
not
combine
existing
chemicals
to
form
a
mixture.
Company
F
must
report
for
Chemical
X,
because
it
manufactured
50,000
pounds
of
Chemical
X
in
2005.
If
Company
X
simply
combined
existing
chemicals
into
a
mixture,
Chemical
X
is
exempt
from
reporting.

2.2.3
Do
You
Qualify
for
Any
Additional
Reporting
Exemptions.
If
you
manufacture
or
import
reportable
substances
under
the
following
circumstances,
you
are
not
required
to
report
for
those
substances
under
the
IUR:


The
chemical
substance
is
manufactured
or
imported
solely
in
small
quantities
for
research
and
development
and
not
intended
for
other
uses.
For
purposed
of
IUR
reporting,
small
quantities
for
research
and
development
is
defined
as
any
chemical
substance
manufactured,
imported,
or
processed
in
quantities
less
than
1,000
pounds
annually
and
used
for
research
and
development
purposes.


The
chemical
substance
is
imported
as
an
article
or
part
of
an
article.
An
article
is
defined
in
40
CFR
711.3(
d)
as
"
a
manufactured
item
(
1)
which
is
formed
to
a
specific
shape
or
design
during
manufacture,
(
2)
which
has
end­
use
function(
s)
dependent
in
whole
or
in
part
upon
its
shape
or
design
during
end
use,
and
(
3)
which
has
either
no
change
of
chemical
composition
during
its
end
use
or
only
those
changes
resulting
in
compositions
which
have
no
commercial
purpose
separate
from
that
of
the
article
and
that
may
occur
as
described
in
section
711.4(
d)(
5),
except
that
fluids
and
particles
are
not
considered
articles
regardless
of
shape
or
design."
EPA
considers
imported
items
as
articles
if
they
are
manufactured
in
a
specific
shape
or
design
for
a
particular
end­
use
application
and
this
design
is
maintained
as
an
essential
feature
in
the
finished
product.
Thus,
EPA
views
materials
such
as
metal
or
plastic
sheets,
wire,
coated
fabric,
rolled
carpet,
sheets
of
plywood,
and
other
similar
materials
as
articles,
even
if,
for
example,
subsequent
to
import
they
are
rolled
or
drawn
thinner,
cut,
printed,
laminated,
or
thermoformed,
so
long
as
they
meet
the
above
criteria.
Substances
that
are
part
of
such
articles
are
not
subject
to
reporting
under
the
IUR.
If
an
item
is
manufactured
in
a
particular
shape
for
the
purpose
of
shipping
convenience
and
the
shape
has
no
function
in
the
end
use,
it
would
not
be
considered
an
article.
Thus,
chemical
substances
that
are
part
of
items
such
as
metal
ingots,
billets,
and
blooms
are
subject
to
reporting
under
the
IUR.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
14

The
chemical
substance
is
manufactured
as
an
impurity,
by­
product,
or
nonisolated
intermediate.
Section
40
CFR
720.3(
e)
provides
the
regulatory
definitions
of
these
terms.


If
between
August
25,
2005,
and
August
24,
2006,
you
submitted
the
information
required
by
the
IUR
in
response
to
another
rule
promulgated
under
TSCA,
such
as
the
Preliminary
Assessment
Information
Rule,
Subpart
B,
or
the
Comprehensive
Assessment
Information
Rule,
Subpart
D,
you
are
not
required
to
report
under
the
IUR
for
the
same
substance
during
2006.

Table
2­
6.
Examples
of
Reporting
Exemptions
Description
2006
Reporting
Requirement
Company
A,
manufactures
400,000
pounds
of
a
chemical
intermediate
called
Chemical
X
during
the
production
of
a
polymer.
Chemical
X
is
manufactured
in
Reactor
1
and
is
directly
transferred
to
Reactor
2
where
it
is
mixed
with
other
reactants
to
form
the
desired
polymer,
at
which
point
Chemical
X
is
destroyed.
Chemical
X
never
leaves
Reactors
1
or
2
without
being
reacted.
Company
A
does
not
need
to
report
a
Form
U
for
Chemical
X
because
it
is
considered
to
be
a
nonisolated
intermediate
and
is
therefore
fully
exempt.

Company
B,
manufactures
400,000
pounds
of
a
chemical
intermediate
called
Chemical
Y
during
the
production
of
a
polymer.
Chemical
Y
is
manufactured
in
Reactor
1
and
transferred
to
a
storage
tank
until
needed.
Chemical
Y
is
then
transferred
to
Reactor
2
where
it
is
mixed
with
other
reactants
to
form
the
desired
polymer,
at
which
point
Chemical
Y
is
destroyed.
Chemical
Y
never
leaves
this
production
site.
Company
B
is
required
to
report
Chemical
Y
because
the
transfer
operation
to
the
storage
tank
"
isolated"
Chemical
Y.

Company
C
imports
10,000,000
pounds
of
Chemical
Z
in
the
form
of
thin
sheets.
Company
C
cuts
these
sheets
into
the
desired
size
and
shape,
which
is
sold
to
consumers.
Company
C
is
not
required
to
report
Chemical
Z
because
it
is
considered
to
be
an
article
and
therefore
exempt
from
reporting.

Company
D
imports
10,000,000
pounds
of
Chemical
W
in
the
form
of
pellets.
Company
D
subsequently
melts
and
molds
Chemical
W
into
the
desired
shape,
which
is
sold
directly
to
consumers.
Company
D
is
required
to
report
Chemical
W
because
the
pellets
were
processed
and
cannot
be
considered
articles.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
15
2.3
What
Information
Do
You
Need
to
Report?

Now
that
you
have
determined
that
you
need
to
file
a
Form
U
for
a
chemical
substance,
the
following
sections
will
help
you
to
determine
what
information
you
need
to
report.

2.3.1
What
Information
Do
All
Submitters
Report?

All
submitters
must
complete
Parts
I
and
II
of
Form
U
(
see
Appendix
A
for
a
copy
of
the
form).
Part
I
collects
basic
company
and
facility
identification
information.
Part
II
collects
chemical
identification
and
manufacturing
or
importing
exposure­
related
information.
(
Submitters
reporting
information
for
more
than
one
chemical
should
make
the
necessary
number
of
photocopies
of
Part
II
and
report
information
for
only
one
chemical
on
each
photocopy.
Submitters
using
electronic
forms
should
use
the
directions
provided
in
Appendix
D).

2.3.2
What
Additional
Information
Do
I
Report
If
My
Production
Volume
Is
Over
300,000
Pounds?

If
you
produce
300,000
pounds
or
more
in
calendar
year
2005
of
a
reportable
substance
at
a
single
facility,
you
must
also
complete
Part
III
of
Form
U
for
each
chemical
meeting
the
300,000­
pound
threshold
(
submitters
reporting
information
for
more
than
one
chemical
should
make
the
necessary
number
of
photocopies
of
Part
III
and
report
information
for
only
one
chemical
on
each
photocopy.
Submitters
using
electronic
forms
should
use
the
directions
provided
in
Appendix
D).
Part
III
collects
information
on
the
industrial,
commercial,
and
consumer
uses
of
the
chemical
substance
and
other
use­
related
exposure
information.

Three
categories
of
substances
are
exempt
from
this
reporting
requirement.
Manufacturers
and
importers
of
certain
petroleum
process
streams
and
inorganic
substances,
regardless
of
the
production
volume,
do
not
need
to
complete
Part
III
of
Form
U
for
these
substances.
EPA
also
created
a
partial
exemption
for
specific
chemical
substances
where
EPA
has
identified
that
there
is
a
low
interest
in
the
IUR
processing
and
use
information
related
to
the
chemical.
These
three
categories
are
described
in
more
detail
below
.

2.3.2.1
Petroleum
Process
Streams.
For
purposes
of
this
rule,
the
petroleum
process
streams
included
in
the
exemption
are
the
multicomponent
complex
chemical
substances
listed
by
CAS
Registry
Number
at
40
CFR
Part
711.26(
b)(
1).

The
chemical
substances
listed
as
petroleum
process
streams
were
derived
from
the
1983
publication
of
the
American
Petroleum
Institute
(
API)
entitled
Petroleum
Process
Stream
Terms
Included
in
the
Chemical
Substances
Inventory
Under
the
Toxic
Substances
Control
Act
(
TSCA)
(
API,
1985).
Chemical
substances
listed
in
the
API
document
consisting
of
a
single­
component
chemical,
except
for
water,
are
not
considered
petroleum
process
streams
for
IUR
reporting
purposes.

2.3.2.2
Inorganic
Substances.
For
the
2006
reporting
cycle,
manufacturers
(
including
importers)
of
inorganic
substances,
as
defined
in
40
CFR
711.26.(
b)(
3),
are
exempt
from
reporting
the
information
collected
by
Part
III
of
Form
U
for
those
substances.
Manufacturers
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
16
(
including
importers)
of
inorganic
substances
must
report
the
information
collected
by
Parts
I
and
II
of
Form
U
if
other
reporting
criteria
are
met.
You
must
complete
Part
III
for
inorganic
chemicals
you
manufacture
and/
or
imported
in
quantities
greater
than
300,000
pounds
for
all
reporting
cycles
following
the
2006
reporting
cycle.

2.3.2.3
Partial
Exemption
for
Specific
Chemical
Substances.
EPA
created
a
partial
exemption
for
the
specific
chemical
substances
listed
at
40
CFR
711.26(
b)(
2)(
iv).
EPA
determined
there
is
a
low
interest
in
the
IURA
processing
and
use
information
related
to
these
chemicals.
Manufacturers
(
including
importers)
of
these
substances
are
exempt
from
reporting
the
information
requested
on
Part
III
of
Form
U
but
must
still
report
the
information
requested
on
Parts
I
and
II
of
Form
U
if
other
reporting
criteria
are
met.
EPA
is
establishing
a
process
for
revising
the
list
of
exempted
chemical
substances,
which
allows
anyone
to
submit
a
written
request
for
EPA
to
update
the
list
of
chemical
substances
covered
under
this
partial
exemption.
EPA
reserves
the
right
to
revise
the
list
on
its
own
initiative.
Table
2­
7
provides
some
examples
of
when
Form
U,
Part
III
reporting
requirements
apply.

Table
2­
7.
Examples
of
Reporting
Requirements
for
Form
U,
Part
III
Description
2006
Reporting
Requirement
Company
A,
which
has
only
one
manufacturing
site,
manufactured
300,000
pounds
of
Chemical
X,
which
is
not
exempt
from
reporting,
at
its
site
in
2005.
Company
A
must
complete
Parts
I,
II,
and
III
for
Chemical
X
because
it
manufactured
300,000
pounds
or
more
of
Chemical
X
in
2005.

Company
B,
which
has
only
one
manufacturing
site,
manufactured
300,000
pounds
of
Chemical
X
at
its
site
in
2004
and
200,000
pounds
of
Chemical
X
in
2005.
Company
B
is
not
required
to
complete
Part
III
for
Chemical
X
because
it
manufactured
less
than
300,000
pounds
of
Chemical
X
in
2005.
Company
B
must
complete
Parts
I
and
II
for
Chemical
X.

Company
C
has
two
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
130,000
pounds
of
Chemical
X
and
Site
2
manufactured
170,000
pounds
of
Chemical
X.
Company
C
is
not
required
to
complete
Part
III
for
Chemical
X
at
either
site
because
2005
production
was
less
than
300,000
pounds
at
each
site.
Company
C
should
complete
Parts
I
and
II
for
Chemical
X
at
both
sites.
DRAFT:
Chapter
2.0
Reporting
Requirements
Description
2006
Reporting
Requirement
2­
17
Company
D
has
three
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
10,000
pounds
of
Chemical
X,
Site
2
manufactured
30,000
pounds
of
Chemical
X,
and
Site
3
manufactured
350,000
pounds
of
Chemical
X.
Company
D
is
not
required
to
report
for
Chemical
X
for
Site
1
because
2005
production
was
less
than
25,000
pounds.
Company
D
must
complete
Parts
I
and
II
for
Chemical
X
at
Site
2
because
at
this
location
production
was
25,000
pounds
or
more
in
2005.
Company
D
must
complete
Parts
I,
II,
and
III
for
Chemical
X
at
Site
3
because
production
was
300,000
pounds
or
more
at
this
location.

Company
E
has
one
site
where
it
imports
and
manufactures
Chemical
X.
Company
E
manufactured
210,000
pounds
of
Chemical
X
and
imported
100,000
pounds
of
Chemical
X
in
2005.
Company
E
must
complete
Parts
I,
II,
and
III
for
Chemical
X
because
the
combined
manufactured
and
imported
in
2005
was
300,000
pounds
or
more.

In
2005,
Company
F
manufactured
700,000
pounds
of
a
liquid
that
contains
Chemical
X
at
50%
by
weight.
Company
F
produced
Chemical
X
via
a
chemical
reaction;
it
did
not
combine
existing
chemicals
to
form
a
mixture.
Company
F
must
complete
Parts
I,
II,
and
III
for
Chemical
X,
because
it
manufactured
350,000
pounds
of
Chemical
X
in
2005.
If
Company
X
simply
combined
existing
chemicals
into
a
mixture,
Chemical
X
is
fully
exempt
from
reporting.
DRAFT:
Chapter
3.0
When
You
Must
Report
3­
1
3.0
When
You
Must
Report
For
the
year
2006
reporting
cycle,
as
in
previous
reporting
cycles,
you
are
required
to
report
during
the
reporting
period,
which
is
between
August
25
and
December
23.
However,
in
the
previous
reporting
cycles,
you
reported
information
from
the
latest
complete
corporate
fiscal
year
prior
to
the
reporting
period.
EPA
has
changed
the
reporting
period
to
a
calendar­
year
basis.
This
means
that
the
information
to
be
reported
during
the
reporting
period
from
August
25
to
December
23
in
the
year
2006
would
be
for
calendar
year
2005.
Subsequent
recurring
reporting
periods
are
from
August
25
to
December
23
at
4­
year
intervals
after
the
first
reporting
period
(
2010,
2014,
2018,
etc.).

Your
submissions
must
be
postmarked
no
later
than
December
23,
2006.
If
you
are
required
to
report,
failure
to
file
your
report
during
this
period
is
a
violation
of
section
15
of
TSCA.

Requests
for
searches
of
the
Master
Inventory
File
(
Section
2.1.1.3)
must
be
made
at
least
60
days
prior
to
the
close
of
the
reporting
period.
If
you
have
made
your
request
in
time,
you
will
be
allowed
15
business
days
from
the
date
of
receipt
of
EPA's
answer
or
until
the
end
of
the
reporting
period,
whichever
is
later,
to
submit
the
report
for
the
substance
that
was
searched.
Any
other
reports
received
after
the
end
of
the
reporting
period
will
be
considered
late
and
will
be
subject
to
enforcement
action.
DRAFT:
Chapter
4.0
How
to
Report
CBI
Information
4­
1
4.0
How
to
Report
CBI
Information
4.1
How
to
Assert
CBI
Claims
Information
submitted
to
EPA
under
the
IUR
can
be
claimed
as
CBI
by
checking
the
appropriate
"
CBI"
boxes
on
Form
U.
Claims
of
confidentiality
will
not
be
accepted
and
honored
if
they
are
not
asserted
at
the
time
information
is
submitted
to
EPA
or
if
they
are
submitted
in
a
manner
inconsistent
with
the
rule
and
reporting
instructions.

You
can
claim
certain
information
submitted
to
EPA
under
this
rule
as
confidential
if
you
have
reason
to
believe
that
release
of
the
information
would
reveal
trade
secrets
or
confidential
commercial
or
financial
information
(
as
provided
by
section
14
of
TSCA
and
40
CFR
Part
2).
EPA's
procedures
for
processing
and
reviewing
confidentiality
claims
are
set
forth
at
40
CFR
Part
2,
Subpart
B.
EPA
strongly
encourages
you
to
review
confidentiality
claims
carefully
to
ensure
that
the
information
in
question
falls
under
the
protection
of
TSCA
section
14,
and
to
limit
confidentiality
claims
as
much
as
possible.

To
claim
information
as
confidential,
you
must
check
the
appropriate
box
and
have
an
authorized
official
sign
the
certification
statement
on
the
reporting
form.
If
you
fail
to
do
so,
EPA
could
release
the
information
to
the
public
without
further
notice
to
you.
Thus,
it
is
important
that
you
follow
up
with
EPA
to
determine
if
your
claim
was
substantiated.
As
reflected
in
the
regulations,
by
signing
the
certification
statement
you
certify
that
your
claims
of
confidentiality
are
made
in
good
faith.
Procedures
for
claiming
information
submitted
electronically
(
such
as
a
submission
on
diskette)
as
confidential
are
specified
in
Chapter
6.
CBI
should
not
be
submitted
by
e­
mail.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

Specific
procedures
for
CBI
claims
of
chemical
identity,
manufacturing
plant
and
plant
site
information,
and
chemical
production
volume
information
are
addressed
below.

4.1.1
Chemical
Identity
You
may
assert
a
CBI
claim
for
the
specific
identity
of
a
chemical
substance
only
if
EPA
treats
that
substance
identity
as
confidential
in
the
TSCA
Inventory
at
the
time
your
report
is
submitted
(
i.
e.,
the
substance
is
not
on
the
Public
Inventory).
Both
confidential
and
nonconfidential
substances
can
be
reported
on
the
same
form.
Confidential
substances
can
be
included
in
diskette
submissions
(
see
Chapter
6
for
further
discussion
of
diskette
submission
procedures).
For
all
CBI
claims,
you
must
follow
up
with
EPA
to
make
sure
your
claim
was
substantiated.
DRAFT:
Chapter
4.0
How
to
Report
CBI
Information
4­
2
No
CBI
claim
for
chemical
identity
will
be
accepted
unless
accompanied
by
a
separate
written
substantiation
for
each
chemical
substance
claimed
as
CBI.
To
assert
a
claim
of
confidentiality
for
the
identity
of
a
reportable
chemical
substance,
you
must
submit
with
Form
U
detailed
written
answers
to
the
questions
in
Table
4­
1,
signed
and
dated
by
an
authorized
official
of
the
company.
The
answers
must
be
complete
and
specific
to
the
chemical
substance
in
question.
If
any
of
the
information
contained
in
the
answers
to
these
questions
is
asserted
to
contain
CBI,
you
must
clearly
identify
the
information
that
is
claimed
confidential
by
marking
the
specific
information
on
each
page
with
a
label
such
as
"
confidential
business
information,"
"
proprietary,"
or
"
trade
secret."
If
the
required
substantiation
does
not
accompany
your
Form
U,
EPA
may
make
the
chemical
identities
reported
on
the
form
available
to
the
public
without
further
notice
to
you.
Thus,
it
is
important
that
you
follow
up
with
EPA
to
determine
if
your
claim
was
substantiated.
See
section
2.1.1.3
for
CBI
packing
instructions.

If
you
are
manufacturing
or
importing
a
chemical
substance
that
is
currently
listed
in
the
TSCA
Inventory
as
confidential,
you
are
encouraged
not
to
assert
confidentiality
claims
if
circumstances
are
now
such
that
confidentiality
is
no
longer
necessary.
If
you
report
a
previously
confidential
substance
as
nonconfidential,
that
substance
will
subsequently
be
listed
in
the
TSCA
Inventory
as
nonconfidential.

4.1.2
Manufacturing
Plant
Site
Identity
Under
the
IUR,
you
may
assert
a
claim
of
confidentiality
for
the
specific
manufacturing
plant
site
identity
if
release
of
that
identity
would
reveal
trade
secrets
or
confidential
commercial
or
financial
information
as
provided
by
TSCA
section
14.
While
EPA
does
not
question
the
occasional
need
for
this
claim,
it
believes
that
these
claims
should
be
limited
only
to
those
circumstances
in
which
it
is
absolutely
necessary.

To
assert
a
claim
of
confidentiality,
you
are
required
to
check
the
CBI
box
at
block
2.2
of
Part
II
on
the
reporting
form
indicating
a
confidentiality
claim
for
plant
site
information
and
you
are
required
to
substantiate
that
claim.
To
do
this,
you
must
submit
with
Form
U
detailed
written
answers
to
the
two
questions
in
Table
4­
2,
signed
and
dated
by
an
authorized
official.
This
upfront
substantiation
is
not
required
for
company
information
CBI
claims
(
block
2.1
on
Form
U).

If
you
assert
that
any
of
the
information
contained
in
the
answers
to
these
questions
contains
CBI,
you
must
clearly
identify
the
information
that
is
claimed
confidential
by
marking
the
specific
information
on
each
page
with
a
label
such
as
"
confidential
business
information,"
"
proprietary,"
or
"
trade
secret."
If
no
claim
of
confidentiality
is
indicated
on
the
Form
U
submitted
to
EPA
under
this
part,
or
if
confidentiality
claim
substantiation
is
not
submitted
with
Form
U
,
EPA
may
make
the
information
available
to
the
public
without
further
notice
to
you.
Thus,
it
is
important
that
you
follow
up
with
EPA
to
determine
if
your
claim
was
substantiated.
See
Section
2.1.1.3
for
CBI
packaging
instructions.
DRAFT:
Chapter
4.0
How
to
Report
CBI
Information
4­
3
Table
4­
1.
Substantiation
Questions
To
Be
Answered
When
Making
Chemical
Identity
CBI
Claims
No.
Question
1.
What
harmful
effects
to
your
competitive
position,
if
any,
do
you
think
would
result
from
the
identity
of
the
chemical
substance
being
disclosed
in
connection
with
reporting
under
this
part?
How
could
a
competitor
use
such
information?
Would
the
effects
of
disclosure
be
substantial?
What
is
the
causal
relationship
between
the
disclosure
and
the
harmful
effects?

2.
How
long
should
confidential
treatment
be
given
 
by
a
specific
date,
the
occurrence
of
a
specific
event,
or
permanently?
Why?

3.
Has
the
chemical
substance
been
patented?
If
so,
have
you
granted
licenses
to
others
with
respect
to
the
patent
as
it
applies
to
the
chemical
substance?
If
the
chemical
substance
has
been
patented,
and
therefore
disclosed
through
the
patent,
why
should
it
be
treated
as
confidential?

4.
Has
the
identity
of
the
chemical
substance
been
kept
confidential
to
the
extent
that
your
competitors
do
not
know
it
is
being
manufactured
or
imported
for
a
commercial
purpose
by
anyone?

5.
Is
the
fact
that
the
chemical
substance
is
being
manufactured
(
including
imported)
for
a
commercial
purpose
available
to
the
public,
for
example,
in
technical
journals,
libraries,
or
state,
local,
or
federal
agency
public
files?

6.
What
measures
have
you
taken
to
prevent
undesired
disclosure
of
the
fact
that
the
chemical
substance
is
being
manufactured
(
including
imported)
for
a
commercial
purpose?

7.
To
what
extent
has
the
fact
that
this
chemical
substance
is
manufactured
(
including
imported)
for
commercial
purposes
been
revealed
to
others?
What
precautions
have
been
taken
regarding
these
disclosures?
Have
there
been
public
disclosures
or
disclosures
to
competitors?

8.
Does
this
particular
chemical
substance
leave
the
site
of
manufacture
(
including
import)
in
any
form
(
e.
g.,
as
product,
effluent,
emission)?
If
so,
what
measures
have
been
taken
to
guard
against
the
discovery
of
its
identity?

9.
If
the
chemical
substance
leaves
the
site
in
a
product
that
is
available
to
the
public
or
your
competitors,
can
the
substance
be
identified
by
analysis
of
the
product?

10.
For
what
purpose
do
you
manufacture
(
including
import)
the
substance?

11.
Has
EPA,
another
federal
agency,
or
any
federal
court
made
any
pertinent
confidentiality
determinations
regarding
this
chemical
substance?
If
so,
please
attach
copies
of
such
determinations.
DRAFT:
Chapter
4.0
How
to
Report
CBI
Information
4­
4
Table
4­
2.
Substantiation
Questions
To
Be
Answered
When
Making
Plant
Site
Identity
CBI
Claims
No.
Question
1.
Has
site
information
been
linked
with
a
chemical
identity
in
any
other
federal,
state,
or
local
reporting
scheme?
For
example,
is
the
chemical
identity
linked
to
a
facility
in
a
filing
under
the
EPCRA
section
311,
namely
through
a
Material
Safety
Data
Sheet
(
MSDS)?
If
so,
identify
all
such
schemes.
Was
the
linkage
claimed
as
confidential
in
any
of
these
instances?

2.
What
harmful
effect,
if
any,
to
your
competitive
position
do
you
think
would
result
from
the
identity
of
the
site
and
the
chemical
substance?
How
could
a
competitor
use
such
information?
Would
the
effects
of
disclosure
be
substantial?
What
is
the
causal
relationship
between
the
disclosure
and
the
harmful
effects?

4.1.3
Chemical
Production
Volume
Information
Under
the
IUR,
you
may
check
the
appropriate
box
on
Form
U
to
assert
a
claim
of
confidentiality
for
chemical
production
volume
information,
if
the
release
of
that
information
would
reveal
trade
secrets
or
confidential
commercial
or
financial
information
as
provided
by
section
14
of
TSCA.
Additionally,
if
you
do
assert
a
claim
of
confidentiality
for
your
specific
production
volume,
you
may
also
choose
to
determine
if
CBI
protection
is
warranted
for
production
volume
information
in
ranges.
The
ranges
are
similar
to
those
used
for
the
original
TSCA
Inventory
and
are
listed
in
Table
4­
3
.
If
you
determine
that
your
production
volume
range
also
warrants
CBI
protection,
you
must
check
the
appropriate
box
on
Form
U
for
claiming
this
information
as
CBI.

Table
4­
3.
Production
Volume
Ranges
Production
Volume
Ranges
(
in
pounds)

At
least
25,000
but
less
than
300,000
At
least
300,000
but
less
than
1,000,000
At
least
1,000,000
but
less
than
10,000,000
At
least
10,000,000
but
less
than
50,000,000
At
least
50,000,000
but
less
than
100,000,000
At
least
100,000,000
but
less
than
500,000,000
At
least
500,000,000
but
less
than
1,000,000,000
1,000,000,000
or
greater
DRAFT:
Chapter
5.0
Completing
Form
U
5­
1
5.0
Completing
Form
U
5.1
Form
of
Submission
Information
reported
for
the
IUR
must
be
submitted
either
electronically
or
on
a
preprinted
Form
U.
Separate
forms
are
required
for
each
plant
site.
If
you
report
information
for
more
than
one
chemical,
you
should
make
the
necessary
number
of
photocopies
of
Parts
II­
III
and
report
information
for
only
one
chemical
on
each
photocopy.
If
you
submit
electronically,
follow
the
instruction
is
Appendix
D.
Each
preprinted
copy
of
2006
Form
U
bears
an
individual
report
number.
EPA
will
assign
report
numbers
to
electronic
submissions
and
forms
obtained
from
the
Internet
or
via
fax­
on­
demand
when
they
are
received.
See
Chapter
7
for
information
on
obtaining
copies
of
Form
U.
Appendix
E
provides
sample
case
studies
to
illustrate
how
to
complete
Part
II
and
Part
II
of
Form
U.

5.2
Part
I
 
Section
I
Certification
5.2.1
Signature
(
Part
I,
Block
1.1)

The
certification
statement
must
be
signed
by
an
authorized
official
of
your
company.
This
statement
certifies
to
the
truth
and
accuracy
of
the
information
reported
and
of
the
confidentiality
claims
made
on
the
form.
By
certifying
to
the
truth
and
accuracy
of
the
information,
you
acknowledge
that
knowingly
false
or
misleading
statements
may
be
punishable
by
fine
or
imprisonment
or
both
under
TSCA
section
15.
Signatures
should
be
made
in
black
ink
to
ensure
that
the
form
bears
a
legible
signature
that
can
be
microfiched
or
otherwise
archived.

A
certification
statement
is
also
on
the
Form
U
diskette.
Appendix
D
provides
more
detail
on
how
to
sign
and
submit
all
electronic
documentation.

5.2.2
Date
(
Part
I,
Block
1.2)

Enter
the
month,
day,
and
year
that
the
form
was
signed.

5.2.3
Name
and
Official
Title
(
Part
I,
Blocks
1.3
and
1.4)

Enter
the
name
and
title
of
the
person
who
signed
the
certification
in
the
respective
blocks.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
2
5.3
Part
I
 
Section
II
Parent
Company
and
Technical
Contact
Information
5.3.1
Parent
Company
Name
(
Part
I,
Block
2.1)

Enter
the
full
name
of
the
parent
company.
Include
any
add­
on
terms
such
as
Inc.,
Ltd.,
L.
L.
C.,
etc.

5.3.2
Parent
Company
Dun
&
Bradstreet
Number
(
Part
I,
Block
2.2)

Dun
&
Bradstreet
assigns
separate
numbers
to
plant
sites
and
parent
companies;
make
sure
that
the
number
you
provide
EPA
belongs
to
the
parent
company
for
which
you
are
reporting.
If
the
parent
company
does
not
have
a
Dun
&
Bradstreet
number,
you
can
request
one
from
your
local
office
of
Dun
&
Bradstreet.
There
is
no
charge
for
this
service
and
you
are
not
required
to
disclose
sensitive
financial
information
to
get
a
number.

5.3.3
Technical
Contact
Name
(
Part
I,
Block
2.3)

Enter
the
name
of
the
person
whom
EPA
may
contact
for
clarification
of
information
submitted
on
Form
U.
The
technical
contact
need
not
be
located
at
the
site
for
which
information
is
reported,
but
should
be
located
in
the
United
States.
The
technical
contact
also
need
not
be
the
person
that
signed
the
certification
statement.
If
you
wish
to
identify
more
than
one
person
as
a
technical
contact,
please
include
the
extra
name(
s)
in
a
separate
cover
letter
along
with
title(
s),
telephone
number(
s),
and
e­
mail
address(
es).

5.3.4
Technical
Contact
Telephone
Number
and
E­
mail
Address
(
Part
I,
Blocks
2.4
and
2.5)

Enter
the
technical
contact's
telephone
number,
including
the
area
code,
and
their
e­
mail
address
(
if
one
is
available).

5.3.5
Technical
Contact
Mailing
Address
(
Part
I,
Blocks
2.11
through
2.15)

Enter
your
technical
contact
mailing
address,
using
standard
addressing
techniques
as
established
by
the
U.
S.
Postal
Service.
Post
office
box
numbers
are
acceptable
only
if
accompanied
by
a
street
address.
If
a
post
office
box
is
listed,
it
should
be
listed
after
the
street
address
in
Block
2.12
(
Address
Line
2).

5.4
Part
I
 
Section
III
Plant
Site
Identification
EPA
requires
the
following
information
to
be
reported
for
each
plant
site
at
which
a
reportable
chemical
substance
is
manufactured
(
including
imported)
in
amounts
greater
than
the
reporting
threshold:
the
plant
site
name,
plant
site
Dun
&
Bradstreet
number,
street
address,
city,
county
(
or
parish),
state,
and
zip
code.
The
site
for
a
chemical
substance
importer
is
the
site
of
the
operating
unit
within
the
importer's
organization
that
is
directly
responsible
for
importing
the
substance
and
that
controls
the
import
transaction;
in
some
cases,
it
may
be
the
organization's
headquarters
in
the
United
States.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
3
5.4.1
Plant
Site
Name
(
Part
I,
Block
3.1)

Enter
the
full
name
of
the
plant
site.
Include
any
add­
on
terms
such
as
Inc.,
Ltd.,
L.
L.
C.,
etc.
In
some
cases,
this
information
may
be
the
same
as
that
reported
in
Block
2.1.

5.4.2
Plant
Site
Dun
&
Bradstreet
Number
(
Part
I,
Block
3.2)

Dun
&
Bradstreet
gives
separate
numbers
to
plant
sites
and
parent
companies;
make
sure
that
the
number
you
provide
EPA
belongs
to
the
individual
plant
site
for
which
you
are
reporting.
If
the
plant
site
does
not
have
a
Dun
&
Bradstreet
number,
you
can
request
one
from
your
local
office
of
Dun
&
Bradstreet.
There
is
no
charge
for
this
service
and
you
are
not
required
to
disclose
sensitive
financial
information
to
get
a
number.

5.4.3
Plant
Site
Street
Address
(
Part
I,
Blocks
3.3
through
3.8)

Enter
your
plant
site
mailing
address,
including
the
appropriate
county
or
parish,
using
standard
addressing
techniques
as
established
by
the
U.
S.
Postal
Service.
Post
office
box
numbers
are
acceptable
only
if
accompanied
by
a
street
address.
If
a
post
office
box
is
listed,
it
should
be
listed
after
the
street
address
in
Block
3.4
(
Address
Line
2).

5.5
Part
II
 
Section
1
Chemical
Identification
If
you
are
reporting
information
for
more
than
one
chemical,
make
the
necessary
number
of
photocopies
of
Part
II
and
report
information
for
only
one
chemical
on
each
photocopy.
If
you
are
using
electronic
forms,
follow
the
directions
provided
in
Appendix
D.

5.5.1
Chemical
Identifying
Number
(
Part
II,
Block
1.1)

The
IUR
currently
requires
manufacturers
(
including
importers)
to
report
both
the
specific
chemical
substance
name
and
the
CAS
Registry
Number
(
or
other
identifying
number)
of
each
reportable
chemical
substance
manufactured
(
including
imported)
in
amounts
over
25,000
pounds
per
year.

You
may
claim
the
identity
of
a
substance
that
is
listed
as
confidential
on
the
TSCA
Inventory
as
confidential
by
checking
the
CBI
box.
EPA
will
not
honor
a
chemical
identity
CBI
claim
for
a
substance
that
is
listed
on
the
nonconfidential
Public
Inventory.
No
CBI
claim
for
chemical
identity
will
be
accepted
unless
accompanied
by
a
separate
written
substantiation
for
each
chemical
substance
claimed
as
CBI;
see
Section
4.1.1
for
more
details
on
substantiating
CBI
claims.
Checking
this
box
does
not
protect
the
link
between
your
company
and
the
substance;
it
only
asserts
a
CBI
claim
for
the
specific
identity
of
the
substance.
If
you
wish
to
claim
company
and/
or
plant
site
identities
as
CBI,
check
the
CBI
boxes
in
Part
II,
Section
II,
Blocks
2.1
and
2.2
(
see
Sections
5.6.1
and
5.6.2
below).

5.5.1.1
CAS
Registry
and
Other
Identifying
Numbers.
Every
chemical
substance
reported
on
Form
U
must
be
accompanied
by
its
CAS
Registry
Number
(
entered
into
Block
1.1
of
Part
II)
or
other
identifying
number.
The
printed
edition
of
the
TSCA
Inventory
contains
detailed
DRAFT:
Chapter
5.0
Completing
Form
U
5­
4
The
CAS
Registry
Number
is
the
preferred
identifier
for
chemical
substances
being
reported
as
part
of
the
IUR.
instructions
on
how
to
locate
the
CAS
Registry
Number
for
a
substance
listed.
When
you
report
a
CAS
Registry
Number,
please
verify
that
the
number
you
are
reporting
is
the
correct
number
for
your
substance.

The
CAS
Registry
Number
is
the
preferred
identifier
for
chemical
substances
being
reported
as
part
of
the
IUR.
If
you
are
unable
to
find
a
CAS
Registry
Number
in
the
Public
Inventory,
then
the
substance
was
not
in
the
TSCA
Inventory
as
of
the
date
of
printing
or
the
substance
is
listed
as
confidential
(
in
which
case
the
specific
identity
is
not
listed
and
the
chemical
substance
has
an
Accession
Number
rather
than
a
CAS
Registry
Number).
If
this
is
the
case,
you
can
use
one
of
the
following
acceptable
identifying
numbers:


EPA
Accession
Number;
or

PMN
Number.

EPA
Accession
Number.
If
the
identity
of
a
chemical
substance
in
the
TSCA
Inventory
is
confidential,
the
printed
Inventory
lists
an
Accession
Number
for
that
substance
and
uses
a
generic
name
rather
than
a
specific
identity.
You
can
use
an
Accession
Number
as
an
identifying
number
only
if
EPA
has
communicated
the
appropriate
Accession
Number
to
you
(
e.
g.,
following
your
report
for
the
original
Inventory
in
1978
or
1979,
or
following
commencement
of
manufacture
or
import
of
a
substance
for
which
you
filed
a
PMN).
You
may
be
reporting
for
the
wrong
substance
if
you
find
a
generic
chemical
identity
in
the
printed
Inventory
that
you
think
belongs
to
your
substance
and
report
using
the
Accession
Number
that
pertains
to
that
substance.
An
Accession
Number
may
not
be
used
for
a
nonconfidential
chemical
substance.
A
typical
Accession
Number
is
a
5­
digit
number
such
as
"
29735."

PMN
Number.
If
you
filed
a
PMN
for
a
substance
that
is
now
reportable
under
the
IUR
and
that
PMN
was
assigned
a
PMN
number,
you
can
use
that
as
an
identifying
number.
A
typical
PMN
number
looks
like
this:
"
P­
85­
0243"
or
"
P­
83­
0001A."

Please
be
aware
that
a
chemical
substance
that
has
a
PMN
number
is
not
automatically
reportable
under
the
IUR.
A
PMN
substance
is
reportable
under
the
IUR
only
if
it
is
included
in
the
TSCA
Inventory.
A
PMN
substance
is
included
in
the
TSCA
Inventory
only
if
a
Notice
of
Commencement
was
received
by
EPA
for
the
substance.

5.5.1.2
Obtaining
CAS
Registry
and
Accession
Numbers
from
EPA.
If
you
previously
reported
on
a
chemical
to
EPA
but
are
unable
to
locate
an
identification
number
for
that
chemical
(
following
the
procedures
described
in
Chapter
2),
it
is
possible
that
the
chemical
is
no
longer
in
the
TSCA
Inventory.
In
this
case,
you
can
request
an
identifying
number
from
EPA.
Send
a
letter
to
the
following
address:

ATTN:
Inventory
Update
Rule
OPPT
Document
Control
Officer
DRAFT:
Chapter
5.0
Completing
Form
U
5­
5
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7407)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
The
letter
must
include
the
specific
identity
of
the
chemical
substance,
must
be
signed
by
an
officer
of
the
company,
and
must
designate
a
technical
contact
(
include
name,
title,
address,
and
telephone
number).
You
should
provide
the
structure
of
the
substance,
if
available.
You
can
use
this
procedure
only
when
you
have
previously
reported
the
substance
to
the
Agency.
If
you
need
EPA
to
tell
you
whether
the
substance
is
in
the
TSCA
Inventory,
you
must
follow
the
procedures
outlined
in
Chapter
2.

You
can
claim
information
in
this
letter
itself
as
confidential
by
circling
or
bracketing
the
text
to
be
protected
and
marking
the
page
"
CONFIDENTIAL."
Failure
to
so
mark
this
information
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
you.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

EPA
will
release
information
in
response
to
these
letters
only
to
the
company
that
originally
submitted
the
information.
If
company
ownership
has
changed
or
the
technical
contact
authorized
to
receive
CBI
has
changed
since
you
reported
the
substance
to
EPA
between
1978
and
1980,
you
must
include
a
notarized
letter
by
an
officer
of
the
current
surviving
company
certifying
to
the
change
and
designating
the
new
technical
contact.

EPA
will
send
the
technical
contact
a
CAS
Registry
Number
(
if
the
substance
is
listed
as
nonconfidential
in
the
TSCA
Inventory)
or
an
EPA
Accession
Number
(
if
the
substance
is
confidential).

EPA
will
release
CAS
Registry
Numbers
or
Accession
Numbers
in
response
to
these
letters
only
for
substances
that
are
reportable
under
the
IUR.
Your
letter
must
be
received
no
later
than
November
12,
2002.
Otherwise,
EPA
cannot
guarantee
a
response
in
time
for
you
to
meet
your
reporting
obligations.

5.5.2
ID
Code
(
Part
II,
Block
1.2)

Enter
the
type
of
identifying
number
you
entered
in
Block
1.1,
as
shown
in
Table
5­
1.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
6
Table
5­
1.
ID
Code
for
Chemical
Identifying
Numbers
If
the
Number
You
are
Reporting
in
Block
1.1
is
a(
n)
Enter
This
Code
in
Block
1.2
Accession
Number
A
CAS
Registry
Number
C
PMN
Number
P
5.5.3
Chemical
Name
(
Part
II,
Block
1.3)

Enter
the
specific
chemical
identity
of
the
chemical
substance
you
are
reporting
in
Block
1.3.
Enough
space
has
been
provided
so
that
the
chemical
name
should
fit.
Use
Chemical
Abstracts
Index
or
preferred
names
if
available.
You
can
find
names
of
nonconfidential
substances
in
the
Public
Inventory.
If
such
names
are
not
available,
use
nomenclature
that
completely
and
accurately
describes
the
chemical
substance.

Trade
names
may
not
be
used
except
where
a
trade
name
describes
a
chemical
in
which
part
of
the
identity
is
a
chemical
substance
you
are
reporting
and
your
supplier
will
not
disclose
to
you
the
specific
identity
of
the
trade
name
reactant.
Report
all
such
chemical
substances
on
a
separate
form,
entering
the
specific
identities
of
chemical
where
you
know
them
and
the
trade
names
where
you
do
not.
You
must
also
submit
along
with
Form
U
a
letter
certifying
that
your
supplier
will
not
disclose
to
you
the
specific
identity
of
the
trade
name
reactant
and
identifying
the
supplier
of
each
trade
name
reactant
reported.

You
may
claim
information
in
this
letter
as
confidential
by
circling
or
bracketing
the
text
to
be
protected
and
marking
the
page
"
CONFIDENTIAL."
Failure
to
so
mark
this
information
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
you.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

If
you
are
an
importer
whose
foreign
supplier
will
not
reveal
to
you
the
identity
of
the
substance
you
are
reporting,
follow
the
procedures
in
Section
6.4.

5.6
Part
II
 
Section
II
Manufacturing
Information
The
following
subsections
describe
the
manufacturing
information
required
to
be
reported
for
each
chemical
substance.

5.6.1
Company
Information
CBI
(
Part
II,
Block
2.1)

Checking
the
CBI
box
in
this
block
asserts
a
confidentiality
claim
for
the
link
between
your
company
and
the
chemical
substance.
Checking
other
CBI
boxes
on
the
form
will
not
protect
this
link.
You
may
claim
this
connection
CBI
for
some
chemical
substances
for
which
you
are
reporting,
while
not
making
the
claim
for
others
(
each
chemical
substance
is
reported
on
a
separate
copy
of
the
form).
DRAFT:
Chapter
5.0
Completing
Form
U
5­
7
5.6.2
Plant
Site
CBI
(
Part
II,
Block
2.2)

If
you
wish
to
claim
the
site
of
manufacture/
import
as
confidential,
check
the
"
Plant
Site
CBI"
box.
You
may
claim
this
connection
CBI
for
some
chemical
substances
for
which
you
are
reporting,
while
not
making
the
claim
for
others
(
each
chemical
substance
is
reported
on
a
separate
copy
of
the
form).
To
assert
a
claim
of
confidentiality
for
plant
site
information,
you
are
required
to
substantiate
the
claim
in
writing
(
see
Section
4.1.2).
If
you
fail
to
substantiate
the
plant
site
CBI
claim
in
accordance
with
the
applicable
regulations,
EPA
may
make
the
information
available
to
the
public
without
further
notice
to
you.
Thus,
it
is
important
that
you
follow
up
with
EPA
to
determine
if
your
claim
was
substantiated.

5.6.3
Site
Limited
(
Y/
N)
(
Part
II,
Block
2.3)

If
you
manufacture
the
chemical
substance
at
the
plant
site
identified
and
do
not
distribute
the
chemical
substance
or
any
mixture
containing
that
substance
outside
the
plant
site
for
commercial
purposes,
enter
"
Y"
in
the
space
next
to
the
CBI
box.
Otherwise,
enter
"
N."
Note:
you
cannot
report
an
imported
chemical
substance
as
site­
limited.
If
you
wish
to
claim
this
information
as
confidential
for
the
substance,
enter
"
X"
in
the
CBI
box.
You
may
claim
the
fact
that
a
substance
is
not
site­
limited
as
confidential,
if
appropriate.

5.6.4
Activity
(
M
=
Manufacture
or
I
=
Import)
(
Part
II,
Block
2.4)

If
you
manufacture
the
substance,
enter
"
M"
in
the
Activity
box;
enter
"
I"
if
you
import
the
substance.
If
you
both
manufacture
and
import
the
substance
at
the
same
site,
enter
"
B"
in
the
Activity
box.
Check
the
CBI
box
if
you
wish
to
claim
the
nature
of
the
activity
(
i.
e.,
manufacture
vs.
importation)
as
confidential
for
the
substance.
Claiming
activity
as
CBI
does
not
protect
the
link
between
your
company
and
the
substance;
that
link
will
not
be
protected
unless
you
check
the
CBI
box
next
to
the
company
name
(
see
Section
5.6.1).

5.6.5
Production
Volume
Range
(
Part
II,
Block
2.5)

Enter
one
of
the
production
volume
ranges
listed
in
Table
5­
2.
You
are
allowed
to
claim
the
production
volume
range
corresponding
to
the
reported
production
volume
number
as
CBI;
check
the
CBI
box
if
you
wish
to
claim
this
range
as
CBI.
This
claim
is
separate
from
a
CBI
claim
for
the
specific
production
volume.

5.6.6
Production
Volume
(
Part
II,
Block
2.6)

Enter
the
production
volume,
in
pounds.
If
you
both
manufacture
and
import
a
particular
substance,
add
the
manufacture
and
import
volumes
together
and
report
the
total
volume.
Report
the
quantity
to
at
least
two
significant
figures;
it
should
be
accurate
to
the
extent
known
or
reasonably
ascertainable
by
you.
Production
volumes
must
be
reported
in
numeric
format
since
the
Agency's
automated
equipment
cannot
read
volumes
other
than
numeric
format.
For
example,"
2
million"
or
"
Ex10"
are
not
acceptable,
nor
are
abbreviations
such
as
M
(
12,000,000
=
12M)
or
K
(
50,000
=
50K).
Check
the
CBI
box
if
you
wish
to
claim
production
volume
as
confidential.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
8
Table
5­
2.
Production
Volume
Ranges
Code
Production
Volume
Ranges
(
in
pounds)

P1
At
least
25,000
but
less
than
300,000
P2
At
least
300,000
but
less
than
1,000,000
P3
At
least
1,000,000
but
less
than
10,000,000
P4
At
least
10,000,000
but
less
than
50,000,000
P5
At
least
50,000,000
but
less
than
100,000,000
P6
At
least
100,000,000
but
less
than
500,000,000
P7
At
least
500,000,000
but
less
than
1,000,000,000
P8
1,000,000,000
or
greater
Note:
These
ranges
are
similar
to
those
used
in
developing
the
original
TSCA
Inventory;
however,
the
new
ranges
start
at
the
proposed
IUR
reporting
threshold
of
25,000
pounds
rather
than
the
old
10,000­
pound
threshold.

5.6.7
Number
of
Workers
(
Part
II,
Block
2.7)

EPA
requires
that
you
report
your
estimate
of
the
total
number
of
workers
reasonably
likely
to
be
exposed
to
the
chemical
substance
at
each
reporting
plant
site.
For
Block
2.7,
report
the
total
number
of
workers
reasonably
likely
to
be
exposed
at
the
manufacturing
site
only.
For
each
substance,
report
the
range
code
that
corresponds
to
the
appropriate
number
of
workers
as
shown
in
Table
5­
3.

EPA
defines
"
reasonably
likely
to
be
exposed"
as
an
exposure
to
a
chemical
substance
which,
under
foreseeable
conditions
of
manufacture,
processing,
distribution
in
commerce,
or
use
of
the
chemical
substance.
Such
exposures
during
manufacturing
would
normally
include,
but
not
be
limited
to:
charging
reactor
vessels;
drumming;
bulk
loading;
cleaning
equipment;
maintenance
operations;
materials
handling
and
transfers;
sampling;
and
analytical
operations.
Covered
exposures
include
exposures
through
any
route
of
entry
(
inhalation,
ingestion,
skin
contact
or
absorption,
etc.),
but
exclude
accidental
exposures.
Workers
that
would
be
exposed
if
not
for
the
use
of
personal
protective
equipment
and
engineering
controls
should
be
included
in
the
reported
estimate.
For
example,
if
a
worker
wears
a
dust
mask
and
gloves
while
handling
a
powdered
chemical
substance,
then
that
worker
should
be
reported
as
an
worker
reasonably
likely
to
be
exposed.
Check
the
CBI
box
if
you
wish
to
claim
the
number
of
workers
as
confidential.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
9
Table
5­
3.
Codes
for
Reporting
Number
of
Workers
Exposed
Code
Range
of
Workers
Exposed
W1
Fewer
than
10
W2
At
least
10
but
fewer
than
25
W3
At
least
25
but
fewer
than
50
W4
At
least
50
but
fewer
than
100
W5
At
least
100
but
fewer
than
500
W6
At
least
500
but
fewer
than
1,000
W7
At
least
1,000
but
fewer
than
10,000
W8
10,000
or
greater
5.6.8
Maximum
Concentration
(
Part
II,
Block
2.8)

You
are
required
to
report
the
maximum
concentration,
measured
by
weight,
of
your
reportable
chemical
substance
at
the
time
it
is
reacted
on
site
to
produce
a
different
chemical
substance
or
as
it
leaves
the
plant
site.
Report
the
code
that
corresponds
to
the
appropriate
maximum
concentration,
according
to
Table
5­
4.
Report
the
maximum
concentration
regardless
of
the
various
physical
forms
in
which
the
chemical
may
be
sent
off
site.
The
quantity
should
be
accurate
to
the
extent
known
or
reasonably
obtainable
by
you.
Round
estimates
to
the
nearest
1
percent,
when
possible,
using
standard
rounding
procedures.
Check
the
CBI
box
if
you
wish
to
claim
the
maximum
concentration
as
confidential.

Table
5­
4.
Codes
for
Reporting
Maximum
Concentration
of
Chemical
Substance
Codes
Concentration
Range
(
weight
percent)

M1
Less
than
1%
by
weight
M2
From
1%
to
30%
by
weight
M3
From
31%
to
60%
by
weight
M4
From
61%
to
90%
by
weight
M5
Greater
than
90%
by
weight
5.6.9
Physical
Form
and
Percentage
of
Production
Volume
(
Part
II,
Blocks
2.9
through
2.14)

You
are
required
to
report
all
physical
forms
of
the
chemical
substance
at
the
time
it
is
reacted
or
as
it
leaves
your
site
and
the
percentage
of
production
volume
for
each
physical
form.
You
must
report
the
percentage
rounded
off
to
the
closest
10
percent.
If
the
reported
chemical
substance
is
sent
off
site
in
more
than
one
physical
form,
you
must
report
all
the
physical
forms.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
10
Information
regarding
processing
or
use
activities
occurring
at
sites
not
under
your
control
must
be
reported
only
to
the
extent
that
it
is
readily
obtainable
by
you;
readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgment
based
on
past
experience
for
similar
chemical
substances
in
the
same
or
similar
markets,
and/
or
any
reasonable
projections
of
likely
processing
and
use
scenarios
for
the
chemical
substance.
If
the
required
information
is
not
readily
obtainable,
the
submitter
is
not
required
to
respond
to
the
requirement.
In
Section
a
of
the
physical
form
question,
check
the
box
for
each
physical
form
that
applies
to
the
chemical
substance.
Check
the
CBI
box
if
you
wish
to
claim
the
physical
form
as
confidential.
In
Section
b
of
the
physical
form
question,
report
the
percentage
of
production
volume
for
each
physical
form
reported
in
Section
a.
Check
the
CBI
box
if
you
wish
to
claim
the
percentage
of
production
volume
as
confidential.

Example
5­
1.
Determining
Percentage
of
Production
Volume
Company
A
manufactures
100,000
pounds
of
Chemical
X.
48%
of
the
production
volume
is
produced
as
dry
powder,
24%
is
produced
as
a
pellets,
24%
as
a
liquid
solution,
and
4%
as
a
water­
wet
solid.
Company
A
would
submit
the
following:
Dry
Powder
50%
Pellets
or
Large
Crystals
20%
Water
Wet
Solid
0%
Liquid
20%
Total
90%

Example
5­
2.
Determining
Percentage
of
Production
Volume
Company
A
manufactures
100,000
pounds
of
Chemical
X.
43%
of
the
production
volume
is
produced
as
dry
powder,
27%
is
produced
as
a
pellets,
25%
as
a
liquid
solution,
and
5%
as
a
water­
wet
solid.
Company
A
would
submit
the
following:
Dry
Powder
40%
Pellets
or
Large
Crystals
30%
Water
Wet
Solid
10%
Liquid
30%
Total
110%

5.7
Part
III
 
Processing
and
Use
Information
You
must
complete
Part
III
of
Form
U
for
reportable
chemical
substances
manufactured
(
including
imported)
for
commercial
purposes
in
an
amount
of
300,000
pounds
or
more
at
any
one
site
during
calendar
year
2005,
or
during
the
calendar
year
at
4­
year
intervals
thereafter.
If
you
manufacture
the
chemical
substance
in
an
amount
less
than
300,000
pounds,
you
do
not
need
to
complete
Section
III;
instead,
check
the
N/
A
box.
If
you
report
information
for
more
than
one
chemical
make
the
necessary
number
of
photocopies
of
Part
III
and
report
information
for
only
one
chemical
on
each
photocopy.
You
must
report
industrial
processing
and
use
information
for
each
reportable
chemical
substance
at
sites
under
your
control,
and
at
sites
that
receive
a
reportable
chemical
substance
from
you
directly
or
indirectly
(
including
through
a
DRAFT:
Chapter
5.0
Completing
Form
U
5­
11
broker/
distributor,
from
a
customer
of
yours
,
etc.).
You
must
report
information
regarding
processing
or
use
activities
occurring
at
sites
not
under
your
control
only
to
the
extent
that
it
is
readily
obtainable
by
you;
readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgment
based
on
past
experience
for
similar
chemical
substances
in
the
same
or
similar
markets,
and/
or
any
reasonable
projections
of
likely
processing
and
use
scenarios
for
the
chemical
substance.
If
the
required
information
is
not
readily
obtainable,
you
are
not
required
to
respond
to
the
requirement.

5.7.1
Part
III
 
Section
I
Industrial
Processing
and
Use
Exposure­
Related
Data
(
Part
III,
Blocks
1.1
through
1.10)

In
Section
I,
you
are
required
to
report
for
the
chemical
substance
up
to
10
unique
combinations
of
the
following
data
elements:
process
or
use
code
(
described
in
Section
5.7.1.1),
five­
digit
NAICS
code
(
described
in
Section
5.7.1.2),
and
industrial
function
category
code
(
IFC
code,
described
in
Section
5.7.1.3).
Table
5­
7
provides
examples
of
reporting
these
codes.
A
processing
and
use
code,
NAICS
code,
and
industrial
function
category
code
combination
sufficiently
defines
a
potential
exposure
scenario
for
risk
screening
and
priority­
setting
purposes.
For
each
of
these
unique
combinations,
you
are
also
required
to
report
the
percentage
of
production
volume
(
described
in
Section
5.7.1.4),
a
number
of
sites
code
(
described
in
Section
5.7.1.5),
and
a
number
of
workers
code
(
described
in
Section
5.7.1.6)
for
each
specific
combination.
If
more
than
10
unique
combinations
apply
to
a
chemical
substance,
you
need
only
report
the
10
combinations
for
the
chemical
substance
that
cumulatively
represent
the
largest
percentage
of
production
volume,
measured
by
weight.

5.7.1.1
Type
of
Process
or
Use
Code.
To
the
extent
that
it
is
readily
obtainable,
report
the
process
or
use
code,
shown
in
Table
5­
5,
that
corresponds
to
the
appropriate
processing
or
use
operation
for
the
particular
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
Check
the
CBI
box
if
you
wish
to
claim
the
process
or
use
code
as
confidential.

Table
5­
5.
Codes
Corresponding
to
Processing
or
Use
Operations
Code
Operation
PC
Processing
as
a
reactant
PF
Processing
 
incorporation
into
formulation,
mixture,
or
reaction
product
PA
Processing
 
incorporation
into
article
PK
Processing
 
repackaging
U
Use
 
nonincorporative
activities
Repackaging
is
defined
as
the
physical
transfer
of
a
chemical
substance
or
mixture
(
as
is)
from
one
container
to
another
container
or
containers
in
preparation
for
distributing
the
chemical
substance
or
mixture
in
commerce.
This
definition
does
not
apply
to
sites
that
only
relabel
or
DRAFT:
Chapter
5.0
Completing
Form
U
5­
12
redistribute
the
reportable
chemical
substance
without
removing
the
chemical
substance
from
the
container
in
which
it
is
received
or
purchased.

5.7.1.2
Five­
Digit
NAICS
Code.
To
the
extent
that
it
is
readily
obtainable,
report
the
five­
digit
NAICS
code
that
corresponds
to
the
appropriate
industrial
setting
for
the
particular
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
The
NAICS
code
classification
system
is
being
used
to
describe
the
industrial
setting
in
which
chemical
exposures
may
occur.
You
are
required
to
report
the
five­
digit
NAICS
code(
s)
corresponding
to
your
sites,
as
well
as
at
the
sites
that
receive
a
reportable
chemical
substance
from
you
either
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer
yours,
etc.)
and
that
process
and
use
the
reportable
chemical
substance.
However,
EPA
does
not
intend
for
you
to
survey
your
customers
or
distributors
to
precisely
identify
the
appropriate
NAICS
codes
at
your
"
downstream"
sites.
Check
the
CBI
box
if
you
wish
to
claim
the
NAICS
code
as
confidential.

The
NAICS
codes,
published
by
the
Office
of
Management
and
Budget
(
OMB),
have
superseded
OMB's
prior
system
of
Standard
Industrial
Classification
(
SIC)
codes.
For
additional
information
on
NAICS
codes
and
tables
cross
referencing
the
NAICS
codes
and
SIC
codes,
refer
to
the
following
website:
http://
www.
census.
gov/
epcd/
www/
naics.
html.
The
NAICS
codes
can
contain
a
maximum
of
6
digits,
although
you
are
only
required
to
report
to
five
digits
for
the
IUR.

5.7.1.3
Industrial
Function
Category
(
IFC)
Code.
To
the
extent
that
it
is
readily
obtainable,
report
the
IFC
code,
shown
in
Table
5­
6,
that
corresponds
to
the
appropriate
function
for
the
particular
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
Definitions
of
each
category
are
available
in
Table
B­
1,
located
in
Appendix
B.
Check
the
CBI
box
if
you
wish
to
claim
the
IFC
code
as
confidential.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
13
Table
5­
6.
Codes
for
Reporting
IFCs
Codes
Industrial
Function
Categories
U01
Adsorbents
and
absorbents
U02
Adhesives
and
binding
agents
U03
Aerosol
propellants
U04
Agricultural
chemicals
(
nonpesticidal)
U05
Anti­
adhesive
agents
U06
Bleaching
agents
U07
Coloring
agents,
dyes
U08
Coloring
agents,
pigments
U09
Corrosion
inhibitors
and
antiscaling
agents
U10
Fillers
U11
Fixing
agents
U12
Flame
retardants
U13
Flotation
agents
U14
Fuels
U15
Functional
fluids
U16
Intermediates
U17
Lubricants
U18
Odor
agents
U19
Oxidizing
agents
U20
pH­
regulating
agents
U21
Photosensitive
chemicals
U22
Plating
agents
and
metal
surface
treating
agents
U23
Processing
aid,
not
otherwise
listed
U24
Process
regulators,
used
in
vulcanization
or
polymerization
processes
U25
Process
regulators,
other
than
polymerization
or
vulcanization
processes
U26
Reducing
agents
U27
Solvents
(
for
cleaning
or
degreasing
and
are
part
of
product
at
1
percent
or
greater
by
weight)
U28
Solvents
(
which
become
part
of
product
formulation
or
mixture
and
are
part
of
product
at
1
percent
or
greater
by
weight)
U29
Solvents
(
for
chemical
manufacture
and
processing
and
are
not
part
of
product
at
greater
than
1
percent
by
weight)
U30
Stabilizers
U31
Surface
active
agents
U32
Viscosity
adjustors
U33
Other
DRAFT:
Chapter
5.0
Completing
Form
U
5­
14
5.7.1.4
Percentage
of
Production
Volume.
To
the
extent
that
it
is
readily
obtainable,
estimate
the
percentage
of
production
volume
that
is
attributable
to
each
unique
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
The
quantity
should
be
accurate
to
the
extent
known
or
reasonably
obtainable
by
you.
Round
the
estimates
to
the
nearest
10percent
of
production
volume
However,
you
may
round
a
particular
combination
that
accounts
for
5
percent
or
less
of
the
total
production
volume
of
a
reportable
chemical
substance
to
0
percent,
unless
the
production
volume
attributable
to
that
combination
is
greater
than
or
equal
to
300,000
pounds.
In
such
cases,
you
must
report
the
percentage
of
production
volume
attributable
to
that
combination
to
the
nearest
1
percent
of
production
volume.
This
exception
to
the
general
rounding
rule
is
to
ensure
that
adequate
use
information
is
reported
for
gross
production
volumes
of
chemical
substances.
EPA
selected
the
300,000­
pound
level
for
consistency
with
the
proposed
threshold
for
reporting
exposure
and
use
data.
If
you
wish
to
claim
this
information
as
confidential,
check
the
CBI
box.

The
total
percentage
of
production
volumes
associated
with
the
NAICS
code/
IFC
combinations
may
add
up
to
more
than
100
percent,
given
that
you
are
reporting
on
distribution
of
a
chemical
to
sites
in
your
control
as
well
as
downstream
sites,
some
of
which
are
not
immediate
purchasers
from
your
original
manufacturing
site.
Additionally,
the
total
percentage
of
production
volume
may
add
up
to
less
than
100
percent
if
you
cannot
readily
obtain
information
about
how
all
of
your
production
volume
is
processed
or
used
by
industry.

Table
5­
7.
Examples
of
Reporting
Industrial
Processing
and
Use
Information
Description
2006
Reporting
Requirement
Site
1
manufactures
500,000
pounds
of
Chemical
X
for
processing
for
incorporation
into
a
mixture.
All
of
the
production
is
for
use
under
industrial
NAICS
code
32519.
67%
of
the
production
(
335,000
pounds)
is
used
as
a
coloring
agent
for
dyes
and
33%
(
165,000
pounds)
of
the
production
is
used
as
a
coloring
agent
for
pigments.
On
line
1.1
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U07
for
IFC,
and
70%
for
production
volume.
On
line
1.2
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U08
for
IFC,
and
30%
for
production
volume.

Site
1
manufactures
500,000
pounds
of
Chemical
X
for
processing
for
incorporation
into
a
mixture.
All
of
the
production
is
for
use
under
NAICS
code
32519.
97%
of
the
production
(
485,000
pounds)
is
used
as
a
coloring
agent
for
dyes
and
3%
of
the
production
(
15,000
pounds)
is
used
as
a
coloring
agent
for
pigments.
On
line
1.1
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U07
for
IFC,
and
100%
for
production
volume.
The
3%
of
production
used
for
pigments,
IFC
U08,
does
not
need
to
be
reported
since
production
volume
because
that
case
is
less
than
300,000
pounds.
DRAFT:
Chapter
5.0
Completing
Form
U
Description
2006
Reporting
Requirement
5­
15
Site
1
manufactures
12,000,000
pounds
of
Chemical
X
for
processing
for
incorporation
into
a
mixture.
All
of
the
production
is
for
use
under
NAICS
code
32519.
97%
(
11,640,000
pounds)
of
the
production
is
used
as
a
coloring
agent
for
dyes
and
3%
of
the
production
(
360,000
pounds)
is
used
as
a
coloring
agent
for
pigments.
On
line
1.1
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U07
for
IFC,
and
97%
for
production
volume.
Since
the
use
in
pigments,
IFC
U08,
accounts
for
300,000
pounds
or
more,
on
line
1.2
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U08
for
IFC,
and
3%
for
production
volume.

5.7.1.5
Number
of
Sites
Code.
To
the
extent
that
it
is
readily
obtainable,
you
are
required
to
report
an
estimate
of
the
total
number
of
industrial
sites,
including
those
beyond
your
control,
that
process
or
use
each
reported
chemical
substance
manufactured
(
including
imported)
by
you,
as
described
by
each
unique
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
In
the
event
you
both
manufacture
(
including
import)
and
process
or
use
the
same
reportable
chemical
substance
at
the
reporting
plant
site,
your
site
should
be
counted
as
both
a
manufacturing
site
in
Part
II
of
Form
U
and
a
processing
or
use
site
reported
in
Part
III
of
Form
U.
For
each
substance,
report
the
code
listed
in
Table
5­
8
that
corresponds
to
the
appropriate
number
range.
If
you
wish
to
claim
this
information
as
confidential,
check
the
CBI
box.

Table
5­
8.
Codes
for
Reporting
Numbers
of
Sites
Codes
Range
S1
Less
than
10
S2
From
10
to
25
S3
From
26
to
100
S4
From
101
to
250
S5
From
251
to
1,000
S6
From
1,001
to
10,000
S7
Greater
than
10,000
5.7.1.6
Number
of
Workers
Code.
EPA
requires
that
you
report
your
estimate
of
the
total
number
of
workers,
including
those
at
sites
not
under
your
control,
that
are
reasonably
likely
to
be
exposed
to
the
chemical
substance
at
facilities
that
process
or
use
the
substance
in
a
manner
that
corresponds
to
each
unique
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
You
need
only
report
this
information
to
the
extent
that
it
is
readily
obtainable.
For
each
substance,
report
the
range
code
listed
in
Table
5­
9
that
corresponds
to
the
appropriate
number
of
workers.

EPA
defines
"
reasonably
likely
to
be
exposed"
as
an
exposure
to
a
chemical
substance
which,
under
foreseeable
conditions
of
manufacture,
processing,
distribution
in
commerce,
or
use
of
the
chemical
substance.
Such
exposures
would
normally
include,
but
not
be
limited
to:
DRAFT:
Chapter
5.0
Completing
Form
U
5­
16
charging
reactor
vessels;
drumming;
bulk
loading;
cleaning
equipment;
maintenance
operations;
materials
handling
and
transfers;
sampling;
and
analytical
operations.
Such
exposures
during
industrial
uses
could
include,
but
not
be
limited
to,
spray
applications
of
the
chemical
(
paints,
coatings,
etc.)
and
misting
during
roll
coating/
printing.
Covered
exposures
include
exposures
through
any
route
of
entry
(
inhalation,
ingestion,
skin
contact
or
absorption,
etc.),
but
exclude
accidental
exposures.
Workers
that
would
be
exposed
if
not
for
the
use
of
personal
protective
equipment
and
engineering
controls
should
be
included
in
the
reported
estimate.
For
example,
if
a
worker
wears
a
dust
mask
and
gloves
while
handling
a
powdered
chemical
substance,
then
that
worker
should
be
reported
as
an
worker
reasonably
likely
to
be
exposed.
Check
the
CBI
box
if
you
wish
to
claim
the
number
of
workers
as
confidential.

Typically,
at
least
two
workers
per
site
are
"
reasonably
likely
to
be
exposed"
due
to
the
activities
mentioned
in
the
previous
paragraph.
Some
operations
will
involve
more
workers,
depending
upon
the
number
of
shifts
per
day,
the
number
of
operating
days
per
year,
the
number
of
worker
activities,
and
type
of
process
equipment
(
e.
g.,
open
or
closed
vessels).

Table
5­
9.
Codes
for
Reporting
Number
of
Workers
Exposed
Code
Range
of
Workers
Exposed
W1
Fewer
than
10
W2
At
least
10
but
fewer
than
25
W3
At
least
25
but
fewer
than
50
W4
At
least
50
but
fewer
than
100
W5
At
least
100
but
fewer
than
500
W6
At
least
500
but
fewer
than
1,000
W7
At
least
1,000
but
fewer
than
10,000
W8
10,000
or
greater
5.7.2
Part
III
 
Section
II
Consumer
and
Commercial
End­
Use
Exposure­
Related
Data
(
Part
III,
Blocks
2.1
through
2.10)

For
purposes
of
IUR
reporting,
a
commercial
use
means
the
use
of
a
chemical
substance
or
mixture
in
a
commercial
enterprise
providing
saleable
goods
or
a
service
(
such
as
painting
contractors
using
paint
products).
A
consumer
use,
on
the
other
hand,
means
the
use
of
a
chemical
substance
that
is
directly,
or
as
part
of
a
mixture,
sold
to
or
made
available
to
consumers
for
their
own
use
in
or
around
a
permanent
or
temporary
household
or
residence
or
in
or
around
a
school
or
recreational
area.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
17
You
are
required
to
report
information
concerning
the
commercial
and
consumer
end
uses
of
each
reportable
chemical
substance
manufactured
(
including
imported)
at
sites
you
control
and
at
sites
controlled
by
people
to
whom
you
have
either
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer,
etc.)
distributed
the
reportable
chemical
substance.
As
with
the
industrial
processing
and
use
information,
this
requirement
applies
only
to
each
chemical
substance
manufactured
(
including
imported)
in
annual
quantities
of
300,000
pounds
or
more,
and
you
are
required
only
to
report
information
to
the
extent
that
it
is
readily
obtainable.

5.7.2.1
Consumer
and
Commercial
Product
Category
Code.
You
must
designate
up
to
10
commercial
and
consumer
product
categories
for
which
the
reportable
chemical
substance
is
used
by
selecting
from
the
codes
listed
in
Table
5­
10.
Information
regarding
product
category
codes
at
sites
beyond
your
control
must
be
reported
only
to
the
extent
that
it
is
readily
obtainable
by
you.
If
more
than
10
codes
apply,
you
need
report
only
the
codes
for
the
chemical
substance
that
cumulatively
represent
the
largest
percentage
of
production
volume,
measured
by
weight.
If
you
wish
to
claim
this
information
as
confidential,
check
the
CBI
box.

Table
5­
10.
Codes
for
Reporting
Commercial
and
Consumer
Product
Categories
Codes
Category
C01
Artists'
supplies
C02
Adhesives
and
sealants
C03
Automotive
care
products
C04
Electrical
and
electronic
products
C05
Glass
and
ceramic
products
C06
Fabrics,
textiles
and
apparel
C07
Lawn
and
garden
products
(
nonpesticidal)

C08
Leather
products
C09
Lubricants,
greases
and
fuel
additives
C10
Metal
products
C11
Paper
products
C12
Paints
and
coatings
C13
Photographic
chemicals
C14
Polishes
and
sanitation
goods
C15
Rubber
and
plastic
products
Readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgment
based
on
past
experience
for
similar
chemical
substances
in
the
same
or
similar
markets,
and/
or
any
reasonable
projections
of
likely
processing
and
use
scenarios
for
the
chemical
substance.
If
the
required
information
is
not
readily
obtainable,
the
submitter
is
not
required
to
respond
to
the
requirement.
DRAFT:
Chapter
5.0
Completing
Form
U
Codes
Category
5­
18
C16
Soaps
and
detergents
C17
Transportation
products
C18
Wood
and
wood
furniture
C19
Other
5.7.2.2
Use
in
Children's
Product.
You
must
determine,
within
each
commercial
and
consumer
product
category
reported,
whether
any
amount
of
each
reportable
chemical
substance
manufactured
(
including
imported)
by
you
is
present
in
or
on
any
consumer
products
intended
for
use
by
children
age
14
or
younger,
regardless
of
the
concentration
of
the
substance
remaining
in
or
on
the
product.
If
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
a
consumer
product
intended
for
use
by
children,
then
you
would
report
a
"
Y"
in
the
appropriate
box
in
the
Children's
Product
column.
If
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
not
used
in
a
consumer
product
intended
for
use
by
children,
then
you
would
report
an
"
N"
in
the
appropriate
box
in
the
Children's
Product
column.
If
this
information
is
not
readily
obtainable,
please
leave
the
box
blank.
If
you
wish
to
claim
this
information
as
confidential,
check
the
CBI
box.

EPA
defines
"
intended
for
use
by
children"
to
mean
the
chemical
substance
or
mixture
is
used
in
a
product
that
is
specifically
intended
for
use
by
children
age
14
or
younger.
Your
chemical
substance
or
mixture
is
intended
for
use
by
children
when
you
answer
"
yes"
to
at
least
one
of
the
following
questions
for
the
product
into
which
your
chemical
substance
or
mixture
is
incorporated:
(
1)
Is
the
product
commonly
recognized
(
i.
e.,
by
a
reasonable
person)
as
being
intended
for
children
age
14
or
younger;
(
2)
Does
the
manufacturer
of
the
product
state
through
product
labeling
or
other
written
materials
that
the
product
is
intended
or
will
be
used
by
children
age
14
or
younger;
or
(
3)
Is
the
advertising,
promotion,
or
marketing
of
the
product
aimed
at
children
age
14
or
younger?
Using
this
definition,
if
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
a
product
that
is
intended
to
be
used
by
children
age
14
or
younger,
you
must
report
this
on
the
Form
U.

To
illustrate
some
examples
of
"
Use
in
Children's
Product,"
please
refer
to
Table
5­
10.
For
example,
EPA
believes
that
certain
products,
like
crayons,
coloring
books,
diapers,
and
toy
cars
­
to
name
a
few
­
are
typically
to
be
used
by
children
age
14
or
younger.
As
such,
if
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
crayons
and
toy
cars,
report
a
"
Y"
in
the
Children's
Product
column
for
categories
C01
and
C11.

On
the
other
hand,
EPA
believes
that
certain
products,
like
household
cleaning,
automotive,
and
lubricants
­
to
name
a
few
­
are
typically
not
intended
to
be
used
by
children
age
14
or
younger.
As
such,
if
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
automotive
care
products
and
lubricants,
report
an
"
N"
in
the
Children's
Use
column
for
categories
C03
and
C09.
DRAFT:
Chapter
5.0
Completing
Form
U
5­
19
Table
5­
11.
Examples
of
Use
in
Children's
Product
Codes
Category
Examples
C01
Artists'
supplies
Crayons,
children's
markers
C02
Adhesives
and
sealants
Craft
glue,
model
glue
C03
Automotive
care
products
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C04
Electrical
and
electronic
products
Electronic
games,
remote
control
cars,
toys
C05
Glass
and
ceramic
products
Porcelain
dolls
C06
Fabrics,
textiles
and
apparel
Pajamas
C07
Lawn
and
garden
products
(
non­
pesticidal)
Lawn
&
gardening
tools
designed
specifically
for
children,
e.
g.,
kids
rake
C08
Leather
products
Shoes,
jackets,
baseball
gloves
C09
Lubricants,
greases
and
fuel
additives
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C10
Metal
products
Toy
trucks,
toy
cars,
wagon
C11
Paper
products
Diapers,
baby
wipes,
coloring
books
C12
Paints
and
coatings
Finger
paints,
water
color
kits
intended
for
children's
use
C13
Photographic
chemicals
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C14
Polishes
and
sanitation
goods
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C15
Rubber
and
plastic
products
Pacifiers,
action
figures,
balls
C16
Soaps
and
detergents
Baby
shampoo,
children's
bubble
bath
C17
Transportation
products
Child's
car
seat
C18
Wood
and
wood
furniture
Baby
cribs,
changing
tables,
wooden
toys
C19
Other
Other
items
specifically
intended
for
use
by
children
age
14
or
younger
5.7.2.3
Percentage
of
Production
Volume.
You
are
required
to
estimate
the
percentage
of
your
production
volume
for
each
reportable
chemical
substance
that
is
attributable
to
each
specific
commercial
and
consumer
end
use
carried
out
at
sites
under
your
control,
as
well
as
at
sites
that
receive
a
reportable
chemical
substance
from
you
either
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer
of
the
submitter,
etc.),
to
the
extent
that
such
information
is
readily
obtainable.
Round
estimates
to
the
nearest
10
percent
of
production
volume.
However,
you
may
not
round
a
commercial
and
consumer
product
category
that
accounts
for
5
percent
or
less
of
the
total
production
volume
of
a
reportable
chemical
substance
to
0
percent
if
the
production
volume
attributable
to
that
commercial
and
consumer
product
DRAFT:
Chapter
5.0
Completing
Form
U
5­
20
category
is
greater
than
or
equal
to
300,000
pounds.
In
such
cases,
you
must
report
the
percentage
of
production
volume
attributable
to
that
commercial
and
consumer
product
category
to
the
nearest
1
percent
of
the
production
volume.
This
exception
to
the
general
rounding
rule
will
ensure
that
adequate
use
information
is
reported
for
gross
production
volumes
of
chemical
substances.
EPA
selected
the
300,000­
pound
threshold
for
consistency
with
the
proposed
threshold
for
reporting
processing
and
use
data.
If
you
wish
to
claim
this
information
as
confidential
for
this
substance,
check
the
CBI
box.

The
total
percentage
of
production
volumes
reported
may
add
up
to
more
than
100
percent,
given
that
you
are
reporting
the
distribution
of
a
chemical
to
sites
in
your
control
as
well
as
downstream
sites,
some
of
which
are
not
immediate
purchasers
from
the
original
manufacturing
site.
Additionally,
the
total
percentage
of
production
volume
may
add
up
to
less
than
100
percent
if
you
cannot
readily
obtain
information
about
how
all
of
your
production
volume
is
used
in
commercial
and
consumer
products.

5.7.2.4
Maximum
Concentration
Code.
You
are
required
to
report
estimates,
in
ranges,
of
the
maximum
concentration
(
measured
by
weight)
of
each
reportable
chemical
substance
likely
to
be
present
in
commercial
and
consumer
products
manufactured
(
including
imported)
at
sites
under
your
control
and
at
sites
where
your
commercial
and
consumer
products
are
distributed
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer,
etc.).
Such
information
is
required
only
to
the
extent
that
it
is
readily
obtainable
by
you.
The
reporting
range
codes
are
the
same
as
those
listed
in
Table
5­
4.
If
you
wish
to
claim
this
information
as
confidential,
check
the
CBI
box.
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
1
6.0
How
to
Submit
Your
Form
U
to
EPA
EPA
will
mail
a
reporting
package
(
consisting
of
a
copy
of
Form
U
and
a
copy
of
the
Instructions
for
Reporting
for
Partial
Updating
of
the
TSCA
Inventory
Data
Base)
to
those
companies
that
reported
in
the
IUR
reporting
period
that
occurred
immediately
prior
to
the
current
reporting
period.
If
you
did
not
receive
a
reporting
package
but
are
required
to
report,
you
may
request
a
copy
of
the
reporting
package
from
EPA
by
calling
the
EPA
TSCA
Hotline
at
(
202)
554­
1404
or
TDD
(
202)­
554­
0551,
or
you
may
send
an
e­
mail
message
to
the
EPA
TSCA
Hotline
at
TSCA­
Hotline@
epa.
gov.
If
you
wish
to
send
a
written
request
for
this
information,
write
to:

TSCA
Hotline
Mail
Code
7408
ATTN:
Inventory
Update
Rule
Office
of
Pollution
Prevention
and
Toxics
Environmental
Protection
Agency
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460.

6.1
Sending
Forms
to
EPA
You
must
use
the
EPA
form
identified
as
"
Form
U"
to
submit
written
information
in
response
to
the
requirements
of
this
rule.
Section
7.3
presents
the
procedures
for
obtaining
copies
of
Form
U.

You
must
submit
your
completed
reporting
form(
s)
and/
or
electronic
forms,
along
with
the
accompanying
Certification
Letter
and
CBI
Substantiation
Letter,
to
EPA
at
the
following
address:

Document
Control
Officer
Mail
Code
7407
ATTN:
Inventory
Update
Rule
Office
of
Pollution
Prevention
and
Toxics
Environmental
Protection
Agency
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460.
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
2
Note:
The
act
of
correcting
errors
in
submissions
to
the
Original
Inventory
does
not
grant
the
person
making
the
correction
immunity
from
enforcement
action
for
any
possible
violations
of
the
Original
Inventory
Reporting
Rule.
6.2
Correcting
Errors
in
Submissions
for
Original
Inventory
In
reporting
under
the
IUR,
you
may
find
that
an
error
was
made
when
you
reported
for
the
original
Inventory
in
1978
or
1979.
That
error
may
fall
into
one
of
the
following
categories:


The
chemical
identity
originally
reported
was
incomplete
or
inaccurate;


An
isolated
intermediate
occurring
during
the
manufacture
of
a
substance
was
not
recognized
when
previously
reported
for
the
Inventory;
and

EPA
informed
your
company
of
a
reporting
error
and
requested
a
correction
from
you,
to
which
you
did
not
respond.

If
an
error
occurred,
you
should
file
an
Inventory
Correction,
following
the
procedures
outlined
in
the
Federal
Register
notice
of
July
29,
1980
(
45
FR
50544).
Reference
the
original
Inventory
report
form
and
line
number
(
if
appropriate)
when
you
file
a
correction.
For
copies
of
the
Federal
Register
notice
or
further
assistance
with
an
Inventory
Correction,
you
may
contact:

TSCA
Hotline
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7408)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Telephone:
(
202)
554­
1404
Submit
your
Inventory
Correction
requests
to
EPA
with
your
copies
of
Form
U.
Your
Form
U
should
report
the
chemical
substance
you
are
actually
manufacturing
or
importing.
Explain
the
correction
in
a
cover
letter
that
specifically
references
the
number
of
the
correction
form,
the
Form
U
number,
and
the
Form
U
report
line
number.
Please
note
that
the
act
of
correcting
errors
in
submissions
to
the
Original
Inventory
does
not
grant
the
person
making
the
correction
immunity
from
enforcement
action
for
any
possible
violations
of
the
Original
Inventory
Reporting
Rule.

6.3
Recordkeeping
Requirements
The
Inventory
regulations
require
you
to
retain
records
on
IUR
reports
for
5
years
after
the
effective
date
of
the
applicable
reporting
period.
For
example,
if
you
submit
an
IUR
report
in
reporting
year
2006,
you
would
be
required
to
retain
the
records
on
which
the
report
is
based
until
December
23,
2011.
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
3
As
long
as
the
records
are
maintained
in
a
manner
consistent
with
normal
business
practice,
you
may
determine
their
exact
format.
Required
records
include
those
that
show
the
production
volume,
plant
site,
and
site­
limited
status
of
each
substance
reported.
If
a
substance
is
not
reported
because
its
site­
specific
annual
production
is
less
than
25,000
pounds,
only
the
sitespecific
production
records
for
that
substance
need
to
be
kept.

If
you
qualify
as
an
exempt
small
manufacturer,
you
need
to
keep
records
only
for
those
chemical
substances
that
you
are
required
to
report;
however,
in
claiming
an
exemption,
you
bear
the
burden
of
documenting
that
you
qualify
for
the
exemption.

6.4
Special
Instructions
for
Importers
and
Foreign
Suppliers
This
section
applies
to
importers
who
do
not
know
the
specific
chemical
identity
of
a
substance
because
the
foreign
supplier
chooses
to
keep
it
confidential.
If
you
are
such
an
importer,
you
are
still
responsible
for
ensuring
that
the
information
is
submitted
to
EPA.
You
can
accomplish
this
by
having
your
foreign
supplier
complete
some
of
the
information
on
Form
U,
as
follows:

1.
Include
a
cover
letter
with
your
Form
U,
stating,
"
The
identifying
numbers
and
specific
chemical
identities
for
the
substances
on
this
form
and
the
technical
contact
will
be
submitted
by
our
foreign
supplier."

2.
Use
a
separate
Form
U
for
each
foreign
supplier
who
does
not
inform
you
of
the
identity
of
the
chemical
substances
you
are
importing.
Do
not
report
by
diskette.
Do
not
use
the
same
report
form
for
substances
the
for
which
you
know
the
specific
identity.

3.
Photocopy
a
blank
Form
U
before
entering
any
information
on
the
form.

4.
On
the
original
form,
sign
the
certification
statement,
enter
the
technical
contact,
and
complete
Parts
I
through
IV
for
each
chemical
substance.
In
Part
II,
Section
I,
Block
1.1,
instead
of
entering
the
identifying
number,
enter
the
trade
name
or
other
designation
by
which
you
know
each
chemical
substance.
Leave
Block
1.2
blank.
Check
the
"
Chemical
CBI"
box
only
if
you
wish
to
claim
the
identities
of
the
chemicals
identified
on
the
form
as
confidential
(
you
must
answer
the
substantiation
questions
described
in
Section
4.1).
Foreign
suppliers
are
responsible
for
their
own
CBI
claims.
Send
this
original
form
to
EPA.

5.
On
the
photocopy
of
the
blank
form,
enter
only
the
plant
site
information.
Send
this
copy
to
your
foreign
supplier
to
complete
and
forward
to
EPA.

6.
The
foreign
supplier
should
enter
technical
contact­
company
information
on
the
copy
(
the
technical
contact
listed
here
should
be
the
foreign
supplier),
complete
Parts
I
through
IV,
and
enter
the
appropriate
specific
chemical
identities
in
Part
II,
Section
I.
Make
sure
that
your
supplier
understands
which
chemical
identities
belong
with
each
copy
of
the
Form
U.
If
the
foreign
supplier
wishes
to
claim
the
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
4
chemical
identities
as
confidential,
the
supplier
should
check
the
"
CBI"
box
and
submit
a
substantiation
as
described
in
Section
4.1.
The
supplier
should
include
with
Form
U
a
letter
stating
that
this
information
is
being
submitted
by
a
foreign
supplier
on
behalf
of
the
importer,
who
should
be
identified.
Information
in
the
letter
may
be
claimed
as
confidential
by
circling
or
bracketing
the
text
to
be
protected
and
marking
the
page
"
CONFIDENTIAL."
Failure
to
so
mark
this
information
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
the
supplier.
The
foreign
supplier
should
then
send
the
form
and
letter
to
EPA.

Note
that
it
is
your
responsibility
to
ensure
that
your
foreign
supplier
understands
how
to
complete
the
copy
of
Form
U
(
including
any
relevant
CBI
claims)
and
that
the
supplier
sends
the
information
to
EPA
by
the
end
of
the
reporting
period.
If
the
supplier
fails
to
submit
the
information,
your
company
may
be
subject
to
an
enforcement
action.
DRAFT:
Chapter
7.0
How
to
Obtain
Copies
of
Documents
Cited
in
These
Instructions
7­
1
7.0
How
To
Obtain
Copies
of
Documents
Cited
in
These
Instructions
7.1
Obtaining
Copies
of
TSCA
Regulations
To
obtain
copies
of
TSCA
regulations,
write
to:

TSCA
Hotline
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7408)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Or
call
(
202)
554­
1404
for
assistance.

7.2
Obtaining
Copies
of
the
Public
Inventory
7.2.1
Obtaining
Copies
of
Printed
Editions
of
the
Public
Inventory
The
nonconfidential
Public
Inventory
listing
can
be
found
in
the
TSCA
Chemical
Substance
Inventory:
1985
Edition
(
a
complete
version
of
the
Public
Inventory
current
as
of
July
1985)
and
in
the
TSCA
Chemical
Substance
Inventory:
1990
Supplement,
a
supplement
to
the
1985
edition
current
as
of
February
1,
1990.
These
printed
versions
contain
the
CAS
Registry
Number,
Preferred
CA
Index
Name,
molecular
formula,
and,
if
applicable,
the
substance
definition
and
appropriate
EPA
flags
(
including
the
"
XU"
flag
for
substances
exempt
from
reporting
under
the
IUR)
for
nonconfidential
substances.
For
chemical
substances
the
chemical
identity
of
which
has
been
claimed
as
confidential,
generic
chemical
names
and
EPA
accession
numbers
are
listed.
Copies
can
be
purchased
from:

Superintendent
of
Documents
Government
Printing
Office
Washington,
D.
C.
20402
Order
Desk:
(
202)
783­
3238
The
price
for
the
1985
edition
is
$
161.00
in
the
United
States
and
Canada,
$
201.25
elsewhere;
the
price
for
the
1990
supplement
is
$
15.00
in
the
United
States,
and
$
18.75
outside
the
United
States.
If
ordering
by
mail,
use
the
above
address.
GPO
will
also
take
orders
by
telephone;
MasterCard
and
Visa
are
accepted.
Refer
to
stock
number
055­
000­
00254­
1
for
the
DRAFT:
Chapter
7.0
How
to
Obtain
Copies
of
Documents
Cited
in
These
Instructions
7­
2
1985
edition
and
055­
000­
00254­
1
for
the
1990
supplement.
Please
allow
4
to
6
weeks
for
delivery
(
longer
outside
the
United
States).

7.2.2
Obtaining
the
Public
Inventory
in
Computer­
Readable
Format
The
Public
Inventory
is
available
on
computer
tapes
or
PC
diskettes.
Both
can
be
obtained
from
the
National
Technical
Information
Service
(
1­
800­
553­
NTIS).
The
computer
tape
version
consists
of
two
tapes.
The
first
tape,
the
Inventory
Preferred
Name
File,
is
sorted
by
CAS
Registry
Number.
It
contains
the
CAS
Registry
Number,
Preferred
CA
Index
Name,
molecular
formula,
and
if
applicable,
the
substance
definition
and
appropriate
EPA
flags
(
including
the
"
XU"
flag
for
substances
exempt
from
reporting
under
the
Inventory
Update
Rule)
for
nonconfidential
substances.
The
second
tape,
the
Inventory
Synonym
Name
file,
contains
the
same
data
elements
as
the
first
tape
but
differs
in
two
ways.
First,
it
is
sorted
by
chemical
name,
not
CAS
Registry
Number.
Second,
in
addition
to
the
Preferred
CA
Index
names,
this
file
also
includes
valid
names
(
synonyms)
as
supplied
to
EPA
by
Inventory
submitters.
In
contrast
to
the
printed
version
of
the
Public
Inventory,
which
includes
CAS­
derived
synonyms,
the
synonyms
listed
on
this
tape
are
only
those
reported
to
EPA
by
Inventory
submitters.

The
PC
diskette
version
is
a
set
of
diskettes
containing
the
information
on
both
computer
tapes
combined,
with
duplicate
information
removed.
CAS
Registry
Numbers
are
listed
in
numerical
order.

The
tapes
and
diskettes
only
contain
information
on
nonconfidential
chemical
substances.
They
do
not
refer
in
any
way
to
chemicals
on
the
TSCA
Inventory
claimed
as
confidential.

Contact
the
following
for
ordering
information
for
these
products:

National
Technical
Information
Service
5285
Port
Royal
Road
Springfield,
VA
22161
Telephone:
(
703)
487­
4650
or
(
800)
553­
NTIS
7.3
Obtaining
Copies
of
Form
U
Electronic
and
printed
copies
of
Form
U
can
be
obtained
from:

TSCA
Hotline
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7408)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Telephone:
(
202)
554­
1404
Printed
copies
of
Form
U
can
also
be
obtained
from:
DRAFT:
Chapter
7.0
How
to
Obtain
Copies
of
Documents
Cited
in
These
Instructions
7­
3
Internet:
http://
www.
epa.
gov/
opptintr/
iur98
[
Is
this
the
correct
website
for
2002?]
FAX
ON
DEMAND:
(
202)
401­
0527;
Item:
5119
DRAFT:
Chapter
8.0
How
to
Request
Assistance
with
Reporting
8­
1
8.0
How
To
Request
Assistance
with
Reporting
Write
to
the
address
below
if
you
need
additional
information
on
or
assistance
with:


Determining
your
reporting
obligations;


Mechanics
of
completing
Form
U;


Entering
data
onto
computer
diskette
for
submission;
and

Determining
the
status
of
forms/
diskettes
you
have
submitted.

TSCA
Hotline
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7408)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Attn:
Inventory
Update
Rule.

You
can
also
call
(
202)
554­
1404
for
assistance.
DRAFT:
Appendix
A
Forms
A­
1
Appendix
A
2002
Form
U
DRAFT:
Appendix
B
Definition
Changes
B­
1
Appendix
B
Definitions
Articles
are
any
manufactured
item
that:
(
1)
is
formed
to
a
specific
shape
or
design
during
manufacture,
(
2)
has
end
use
function(
s)
dependent
in
whole
or
in
part
upon
its
shape
or
design
during
end
use,
and
(
3)
has
either
no
change
of
chemical
composition
during
its
end
use
or
only
those
changes
of
composition
that
have
no
commercial
purpose
separate
from
that
of
the
article
and
that
may
occur
as
described
in
40
CFR
711.4(
d)(
5);
fluids
and
particles
are
not
considered
articles
regardless
of
shape
or
design.

By­
product
is
a
chemical
substance
produced
without
separate
commercial
intent
during
the
manufacture
or
processing
of
another
chemical
substance(
s)
or
mixture(
s).

Chemical
substance
is
any
organic
or
inorganic
substance
of
a
particular
molecular
identity,
including
any
combination
of
such
substances
occurring
in
whole
or
in
part
as
a
result
of
a
chemical
reaction
or
occurring
in
nature,
and
any
chemical
element
or
uncombined
radical;
"
chemical
substance"
does
not
include:
(
1)
Any
mixture;
(
2)
Any
pesticide
when
manufactured,
processed,
or
distributed
in
commerce
for
use
as
a
pesticide;
(
3)
Tobacco
or
any
tobacco
product,
but
not
including
any
derivative
products;
(
4)
Any
source
material,
special
nuclear
material,
or
byproduct
material;
(
5)
Any
pistol,
firearm,
revolver,
shells,
and
cartridges;
and
(
6)
Any
food,
food
additive,
drug,
cosmetic,
or
device,
when
manufactured,
processed,
or
distributed
in
commerce
for
use
as
a
food,
food
additive,
drug,
cosmetic,
or
device.

Commercial
use
is
the
use
of
a
chemical
substance
or
mixture
in
a
commercial
enterprise
providing
saleable
goods
or
services
(
e.
g.,
dry
cleaning
establishment,
painting
contractor).

Consumer
use
is
the
use
of
a
chemical
substance
that
is
directly,
or
as
part
of
a
mixture,
sold
or
made
available
to
consumers
for
their
use
in
or
around
a
permanent
or
temporary
household
or
residence,
in
or
around
a
school,
or
in
or
around
recreational
areas.

Importer
is
any
person
who
imports
any
chemical
substance
or
any
chemical
substance
as
part
of
a
mixture
or
article
into
the
customs
territory
of
the
United
States
and
includes:
(
1)
The
person
primarily
liable
for
the
payment
of
any
duties
on
the
merchandise,
or
(
2)
An
authorized
agent
acting
on
his/
her
behalf
(
as
defined
in
19
CFR
1.11)
DRAFT:
Appendix
B
Definition
Changes
B­
2
Impurity
is
a
chemical
substance
which
is
unintentionally
present
with
another
chemical
substance.

Industrial
Function
Categories
include
categories
defined
in
Table
B­
1.

Industrial
use
is
use
at
a
site
at
which
one
or
more
chemical
substances
or
mixtures
are
manufactured
(
including
imported)
or
processed.

Inorganic
Substances
is
any
chemical
substance
which
does
not
contain
carbon
or
contains
carbon
only
in
the
form
pf
carbonato
[=
CO3],
cyano
[
 
CN],
cyanato
[
 
OCN],
isocyano
[
 
NC],
or
isocyanato
[
 
NCO]
groups,
or
the
chalcogen
analogues
of
such
groups.

Intended
for
use
by
children
means
the
chemical
substance
or
mixture
is
used
in
a
product
that
is
specifically
intended
for
use
by
children
age
14
or
younger.
A
chemical
substance
or
mixture
is
intended
for
use
by
children
when
the
submitter
answers
"
yes"
to
at
least
one
of
the
following
questions
for
the
product
into
which
the
submitter's
chemical
substance
or
mixture
is
incorporated:
(
1)
Is
the
product
commonly
recognized
(
i.
e.,
by
a
reasonable
person)
as
being
intended
for
children
age
14
or
younger;
(
2)
Does
the
manufacturer
of
the
product
state
through
product
labeling
or
other
written
materials
that
the
product
is
intended
or
will
be
used
by
children
age
14
or
younger;
or
(
3)
Is
the
advertising,
promotion,
or
marketing
of
the
product
aimed
at
children
age
14
or
younger?

Intermediate
is
any
chemical
substance:
(
1)
Which
is
intentionally
removed
from
the
equipment
in
which
it
is
manufactured,
and
(
2)
Which
either
is
consumed
in
whole
or
in
part
in
chemical
reaction(
s)
used
for
the
intentional
manufacture
of
other
chemical
substance(
s)
or
mixture(
s),
or
is
intentionally
present
for
the
purpose
of
altering
the
rate
of
such
chemical
reaction(
s).
NOTE:
The
equipment
in
which
it
was
manufactured
includes
the
reaction
vessel
in
which
the
chemical
substance
was
manufactured
and
other
equipment
that
is
strictly
ancillary
to
the
reaction
vessel,
and
any
other
equipment
through
which
the
chemical
substance
may
flow
during
a
continuous
flow
process,
but
does
not
include
tanks
or
other
vessels
in
which
the
chemical
substance
is
stored
after
its
manufacture.

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

Manufacture
or
import
for
commercial
purposes
means
to
import,
produce,
or
manufacture
with
the
purpose
of
obtaining
an
immediate
or
eventual
commercial
advantage
and
includes,
for
example,
the
manufacture
or
import
of
any
amount
of
a
chemical
substance
or
mixture
for
commercial
distribution,
including
for
test
marketing,
or
for
use
by
the
manufacturer,
including
use
for
product
research
and
development,
or
as
an
intermediate.

Master
Inventory
File
is
EPA's
comprehensive
list
of
chemical
substances
that
constitute
the
Chemical
Substances
Inventory
compiled
under
section
8(
b)
of
TSCA
.
It
includes
substances
reported
under
Subpart
B
of
this
part
and
substances
reported
under
Part
720
of
this
DRAFT:
Appendix
B
Definition
Changes
B­
3
chapter
for
which
a
Notice
of
Commencement
of
Manufacture
or
Import
has
been
received
under
section
720.120
of
this
chapter.

Microorganisms
is
any
combination
of
chemical
substances
that
is
a
living
organism
and
that
meets
the
definition
of
microorganism
at
40
CFR
725.3.
Any
chemical
substance
produced
from
a
living
microorganism
is
reportable
unless
otherwise
excluded.

Mixture
is
any
combination
of
two
or
more
chemical
substances
if
the
combination
does
not
occur
in
nature
and
is
not,
in
whole
or
in
part,
the
result
of
a
chemical
reaction;
"
mixture"
does
include:
(
1)
Any
combination
that
occurs,
in
whole
or
in
part,
as
a
result
of
a
chemical
reaction
if
the
combination
could
have
been
manufactured
for
commercial
purposes
without
a
chemical
reaction
at
the
time
the
chemical
substances
comprising
the
combination
were
combined
and
if,
after
the
effective
date
or
premanufacture
notification
requirements,
none
of
the
chemical
substances
comprising
the
combination
is
a
new
chemical
substance,
and
(
2)
Hydrates
of
a
chemical
substance
or
hydrated
ions
formed
by
association
of
a
chemical
substance
with
water.

Natural
Gases
Excluded
From
the
Reporting
include
the
following
chemical
substances:
CAS
No.
64741­
48­
6,
Natural
gas
(
petroleum),
raw
liquid
mix;
CAS
No.
68919­
39­
1,
Natural
gas
condensates;
CAS
No.
8006­
61­
9,
Gasoline
natural;
CAS
No.
68425­
31­
0,
Gasoline
(
natural
gas),
natural;
CAS
No.
8006­
14­
2,
Natural
gas;
and
CAS
No.
68410­
63­
9,
Natural
gas,
dried.
These
substances
are
also
listed
in
Table
2­
2
of
this
document.

Naturally
Occurring
Substances
are
chemical
substances
manufactured
according
to
the
conditions
in
40
CFR
711.4(
b)
of
the
Inventory
Reporting
Regulations
and
are
not
reportable
under
TSCA.
Examples
of
substances
that
are
typically
naturally
occurring
materials
are
raw
agricultural
commodities,
water,
air,
natural
gas,
crude
oil,
rocks,
ores,
and
minerals.
However,
since
40
CFR
711.4(
b)
exclusion
is
a
process­
specific
exclusion
rather
than
a
chemical­
specific
one,
the
persons
who
produce
any
substance
in
a
manner
other
than
as
described
in
40
CFR
711.4(
b)
are
required
to
report
unless
otherwise
excluded.
For
this
reason,
water,
minerals,
and
certain
agricultural
products,
etc.,
are
sometimes
considered
not
to
be
naturally
occurring
because
of
their
method
of
production.

New
chemical
substance
is
any
chemical
substance
that
is
not
included
in
the
inventory
compiled
and
published
under
subsection
8(
b)
of
TSCA
.

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

Petroleum
Process
Streams
refers
to
the
multicomponent
complex
chemical
substances
listed
at
40
CFR
711.26(
b)(
1).
DRAFT:
Appendix
B
Definition
Changes
B­
4
Polymers.
The
IUR
definition
of
polymer
is
sufficiently
broad
to
include
virtually
all
those
substances
that
are
generally
considered
polymers.
These
include
polysaccharides,
such
as
sugar
and
gums,
and
all
classes
of
proteins,
enzymatic
or
structural.
However,
substances
that
result
from
hydrolysis,
depolymerization,
or
chemical
modification,
regardless
of
the
extent
of
these
processes,
of
polymers
so
that
the
final
products
are
no
longer
polymeric
(
e.
g.,
a
mixture
of
amino
acids
that
is
the
result
of
hydrolysis
of
a
polypeptide)
are
not
considered
to
be
polymers
and
must
be
reported
if
not
otherwise
excluded.
For
reporting
purposes,
salts
of
polymers
are
also
considered
to
be
polymers.

Process
is
the
preparation
of
a
chemical
substance
or
mixture,
after
its
manufacture,
for
distribution
in
commerce
(
1)
in
the
same
form
or
physical
state
as,
or
in
a
different
form
or
physical
state
from,
that
in
which
it
was
received
by
the
person
so
preparing
such
substance
or
mixture;
or
(
2)
as
part
of
a
mixture
or
article
containing
the
chemical
substance
or
mixture.

Process
for
"
commercial
purposes"
means
to
process
(
1)
for
distribution
in
commerce,
including
for
test
marketing
purposes;
or
(
2)
for
use
as
an
intermediate.

Readily
obtainable
information
is
information
known
by
management
and
supervisory
employees
of
the
submitter
company
who
are
associated
with
research,
development,
distribution,
technical
services,
or
marketing
of
the
reportable
chemical
substance.
Extensive
file
searches
are
not
required.

Reasonably
likely
to
be
exposed
is
an
exposure
to
a
chemical
substance
that,
under
foreseeable
conditions
of
manufacture
(
including
import),
processing,
distribution
in
commerce,
or
use
of
the
chemical
substance,
is
more
likely
to
occur
than
not
to
occur.
Such
exposures
would
normally
include,
but
not
be
limited
to,
activities
such
as
charging
reactor
vessels,
drumming,
bulk
loading,
cleaning
equipment,
maintenance
operations,
materials
handling
and
transfers,
and
analytical
operations.
Covered
exposures
include
exposures
through
any
route
of
entry
(
e.
g.,
inhalation,
ingestion,
skin
contact,
absorption).
Accidental
or
theoretical
exposures
are
excluded.

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

Reportable
chemical
substance
is
a
chemical
substance
described
in
40
CFR
711.25.

Site
is
a
contiguous
property
unit.
Property
divided
only
by
a
public
right­
of­
way
will
be
considered
one
site.
There
may
be
more
than
one
manufacturing
plant
on
a
single
site.
For
the
purposes
of
imported
chemical
substances,
the
site
will
be
the
business
address
of
the
importer.

Site­
limited
is
a
chemical
substance
is
manufactured
and
processed
only
within
a
site
and
is
not
distributed
for
commercial
purposes
as
a
substance
or
as
part
of
a
mixture
or
article
outside
the
site.
Imported
substances
are
never
site­
limited.
Although
a
site­
limited
chemical
substance
is
not
distributed
for
commercial
purposes
outside
the
site
at
which
it
is
manufactured
and
DRAFT:
Appendix
B
Definition
Changes
B­
5
processed,
the
substance
is
considered
to
have
been
manufactured
and
processed
for
commercial
purposes.

Technically
qualified
individual
is
a
person:
(
1)
Who
because
of
his/
her
education,
training,
or
experience,
or
a
combination
of
these
factors,
is
capable
of
appreciating
the
health
and
environmental
risks
associated
with
the
chemical
substance
that
is
used
under
his/
her
supervision,
(
2)
Who
is
responsible
for
enforcing
appropriate
methods
of
conducting
scientific
experimentation,
analysis,
or
chemical
research
in
order
to
minimize
such
risks,
and
(
3)
Who
is
responsible
for
the
safety
assessments
and
clearances
related
to
the
procurement,
storage,
use,
and
disposal
of
the
chemical
substance
as
may
be
appropriate
or
required
within
the
scope
of
conducting
the
research
and
development
activity.
The
responsibilities
in
this
paragraph
may
be
delegated
to
another
individual,
or
other
individuals,
as
long
as
each
meets
the
criteria
in
paragraph
(
1)
of
this
definition.

Use
is
any
use
of
a
chemical
substance
or
mixture
that
is
not
otherwise
covered
by
the
terms
"
manufacture"
or
"
process."
Relabeling
or
redistributing
a
container
holding
a
chemical
substance
or
mixture
where
no
repackaging
of
the
chemical
substance
or
mixture
occurs
does
not
constitute
use
or
processing
of
the
chemical
substance
or
mixture.
DRAFT:
Appendix
B
Definition
Changes
B­
6
Table
B­
1.
Definition
of
Industrial
Function
Categories
Industrial
Function
Categories
Definition
Adsorbents
and
absorbents
Substances
that
hold
another
substance
by
allowing
it
to
penetrate
into
its
inner
structure.
Examples
of
absorbents
include
straw
oil,
alkaline
solutions,
and
kerosene.
Examples
of
adsorbents
include
silica
gel,
bauxite,
activated
carbon,
and
activated
alumina.
Adhesives
and
binding
agents
Substances
that
promote
bonding
between
other
substances
by
surface
attachment.
Aerosol
propellants
Substances
(
usually
compressed
gases
or
liquids)
used
to
dissolve
or
suspend
other
substances
and
to
expel
those
substances
from
a
container
in
the
form
of
aerosols.
Agricultural
chemicals
(
nonpesticidal)
Compounds
or
mixtures
used
to
increase
the
productivity
and
quality
of
farm
crops.
Examples
include
fertilizers
and
soil
conditioners.
Anti­
adhesive
agents
Substances
that
prevent
bonding
between
substances
by
discouraging
surface
attachment.
Examples
include
adherents,
antiblock
agents,
detackifiers,
dusting
agents,
and
parting
agents.
Bleaching
agents
Substances
that
lighten
or
whiten
a
substrate
through
chemical
reaction,
usually
an
oxidative
or
reductive
process
which
degrades
the
color
system.
The
most
common
bleaching
agents
belong
to
one
of
two
groups:
chlorinecontaining
bleaching
agents
(
e.
g.,
chlorine,
hypochlorites,
Nchloro
compounds,
and
chlorine
dioxide)
and
peroxygen
bleaching
agents
(
e.
g.,
hydrogen
peroxide
and
sodium
perorate).
Coloring
agents,
dyes
Substances
that
impart
color
to
other
materials
or
mixtures
(
i.
e.
substrates)
by
penetrating
into
the
surface
of
the
substrate.
Examples
of
types
of
dyes
include
azo,
anthraquinone,
amino
azo,
aniline,
eosin,
stilbene,
acid,
basic
or
cationic,
reactive,
disperse,
and
natural
dyes.
Coloring
agents,
pigments
Substances
that
impart
color
to
other
materials
or
mixtures
(
i.
e.
substrates)
by
attaching
themselves
to
the
surface
of
the
substrate
through
binding
or
adhesion.
The
Pigments
category
includes
fluorescent
agents,
luminescent
agents,
whitening
agents,
pearlizing
agents,
and
opacifiers.
Examples
of
pigments
include
metallic
oxides
of
iron,
titanium,
zinc,
cobalt,
and
chromium;
metal
powder
suspensions;
lead
chromates;
vegetable
and
animal
products;
and
synthetic
organic
pigments.
Corrosion
inhibitors
and
antiscaling
agents
Agents
which
prevent
or
retard
corrosion
or
the
formation
of
scale.
Examples
include
aniline
and
pyridine.
DRAFT:
Appendix
B
Definition
Changes
Industrial
Function
Categories
Definition
B­
7
Fillers
Substances
that
are
incorporated
into
a
matrix
to
provide
bulk;
increase
strength,
hardness,
or
resistance
to
impact;
and
reduce
production
costs
by
minimizing
the
amount
of
more
expensive
raw
materials
used
in
the
production
process.
Example
include
calcium
carbonate,
barium
sulfates,
silicates,
soft
clays,
and
zinc
oxides.
Fixing
agents
Substances
that
are
used
to
permanently
fix
another
material
onto
a
substrate
within
a
wet
process.
Examples
of
fixing
agents
include
albumin,
trivalent
chromium
complexes,
metallic
hydroxides,
tannic
acid,
rosin
size,
alum,
and
glycerol.
Flame
retardants
Substances
that
are
applied
to
the
surface
of
or
incorporated
into
combustible
materials
to
reduce
or
eliminate
their
tendency
to
ignite
when
exposed
to
heat
or
a
flame
for
a
short
period
of
time.
Examples
of
flame
retardants
include
inorganic
salts,
chlorinated
or
brominated
organic
compounds,
or
organic
phosphates/
phosphonates.
Flotation
agents
Chemical
additives
which
are
used
to
aid
in
the
process
of
flotation
by
increasing
the
degree
of
aggregation
in
a
suspension.
Examples
include
xanthates,
sulfonates,
thiophosphates,
primary
and
secondary
alcohols,
and
ethers.
Fuels
Substances
that
evolve
energy
in
controlled
chemical
reactions;
the
most
common
type
of
reaction
is
combustion.
Examples
of
types
of
fuels
include
fossil,
nuclear,
and
synthetic
fuels.
Functional
fluids
Liquid
or
gaseous
substances
that
are
used
for
one
or
more
operational
properties.
Examples
of
functional
fluids
include:
antifreezes
and
deicing
fluids,
heat
transfer
agents
(
e.
g.,
coolants
and
refrigerants),
and
dielectric
fluids.
This
category
does
not
include
fluids
used
as
lubricants
and
hydraulic/
transmission
fluids.
Intermediates
Substances
that
are
formed
during
the
production
of
a
chemical,
but
are
consumed
in
a
subsequent
chemical
reaction.
Lubricants
Substances
that
reduce
friction
between
two
adjacent
solid
surfaces
and
prevent
the
wear
and
seizing
of
the
surfaces.
Examples
include
greases,
oils,
and
solid
film
lubricants.
Odor
agents
Substances
used
to
control
odors,
remove
odors,
mask
odors,
or
impart
odors.
Examples
include
deodorants
and
fragrances.
DRAFT:
Appendix
B
Definition
Changes
Industrial
Function
Categories
Definition
B­
8
Oxidizing
agents
Substances
that
oxidize
a
chemical
compound,
usually
by
accepting
electrons
from
that
compound.
Examples
include
ozone,
nitric
acid,
chromium
trioxide,
and
vanadium
pentoxide.
pH­
regulating
agents
Substances
used
to
maintain
or
change
the
pH
level
of
a
given
solution.
A
pH
regulating
agent
tends
to
fall
into
one
of
three
categories:
an
acid,
an
alkali
(
base),
or
a
buffer.

Photosensitive
chemicals
Substances
that
alter
their
physical
or
chemical
structure
through
absorption
of
light
resulting
in
the
emission
of
light,
dissociation,
discoloration,
or
other
chemical
reaction.
Examples
include
sensitizers,
fluorescents,
photovoltaic
agents,
ultraviolet
absorbers,
and
ultraviolet
stabilizers.
Plating
agents
and
metal
surface
treating
agents
Substances
that
are
deposited
on
the
surface
of
a
substrate
to
change
its
physical
or
chemical
properties.
Metal
surface
treating
agents
are
typically
used
in
aqueous
solutions
for
metal
surface
treatment
operations
such
as
electroplating,
electroless
plating,
anodizing,
and
chemical
conversion
coating
(
e.
g.,
phosphate
conversion).
Also
included
are
non­
aqueous
metal
deposition
operations
such
as
vapor
deposition,
ion
beam
implantation,
and
sputtering.
Processing
aid,
not
otherwise
listed
Substance
that,
when
added
to
a
process
or
to
a
substance
or
mixture
to
be
processed,
improves
the
processing
characteristics
or
the
operation
of
the
process
equipment.
Processing
aids
are
not
intended
to
become
part
of
the
finished
product
formulation
or
article.
Process
regulators,
used
in
vulcanization
or
polymerization
processes
Substances
that
change
the
rate
of
a
chemical
reaction,
start
or
stop
the
reaction,
or
otherwise
influence
the
course
of
the
reaction.
Process
regulators
do
not
become
part
of
the
reaction
product
and
are
therefore
not
considered
to
be
reactants.
Process
regulators,
other
than
polymerization
or
vulcanization
processes
Substances
that
change
the
rate
of
a
chemical
reaction,
start
or
stop
the
reaction,
or
otherwise
influence
the
course
of
the
reaction.
Process
regulators
do
not
become
part
of
the
reaction
product
and
are
therefore
not
considered
to
be
reactants.
Reducing
agents
Substances
that
reduce
a
chemical
compound,
usually
be
donating
electrons.
Reduction
generally
occurs
by
the
donation
of
one
or
more
electrons
by
an
atom
of
the
reducing
agent,
the
removal
of
oxygen
from
a
compound,
or
the
addition
of
hydrogen
to
a
compound.
DRAFT:
Appendix
B
Definition
Changes
Industrial
Function
Categories
Definition
B­
9
Solvents
(
for
cleaning
or
degreasing
and
are
part
of
product
at
1
percent
or
greater
by
weight)
Substances
that
are
capable
of
dissolving
another
substance
(
solute)
to
form
a
uniformly
dispersed
mixture
(
solution)
at
the
molecular
level.
The
category
includes
diluents
used
to
reduce
the
concentration
of
an
active
material
to
achieve
a
specified
effect,
or
low­
gravity
materials
used
primarily
to
reduce
cost.
Solvents
(
which
become
part
of
product
formulation
or
mixture
and
are
part
of
product
at
1
percent
or
greater
by
weight)
Substances
that
are
capable
of
dissolving
another
substance
(
solute)
to
form
a
uniformly
dispersed
mixture
(
solution)
at
the
molecular
level.
The
category
includes
diluents
used
to
reduce
the
concentration
of
an
active
material
to
achieve
a
specified
effect,
or
low­
gravity
materials
used
primarily
to
reduce
cost.
Solvents
(
for
chemical
manufacture
and
processing
and
are
not
part
of
product
at
greater
than
1
percent
by
weight)
Substances
that
are
capable
of
dissolving
another
substance
(
solute)
to
form
a
uniformly
dispersed
mixture
(
solution)
at
the
molecular
level.
The
category
includes
diluents
used
to
reduce
the
concentration
of
an
active
material
to
achieve
a
specified
effect,
or
low­
gravity
materials
used
primarily
to
reduce
cost.
Stabilizers
Substances
that
function
to
keep
a
compound,
mixture,
or
solution
from
changing
its
form
or
chemical
structure.
Stabilizers
typically
act
to
retard
a
reaction
rate,
preserve
a
chemical
equilibrium,
act
as
antioxidants,
keep
pigments
and
other
components
in
emulsion
form,
or
prevent
particles
in
a
colloidal
suspension
from
precipitating
and
settling
out.
Examples
of
stabilizers
include
antihydrolysis
agents,
antioxidants,
antiozonants,
and
heat
stabilizers.
Surface
active
agents
Compounds
that
reduce
surface
tension
when
dissolved
in
water
or
water
solutions,
or
which
reduce
interfacial
tension
between
two
liquids
or
between
a
liquid
and
a
solid.
Examples
include
carboxylates,
sulfonates,
phosphates,
carboxylic
acid,
esters,
and
quaternary
ammonium
salts.
Viscosity
adjustors
Substances
that
alter
the
viscosity
of
another
substance.
Examples
include:
viscosity
index
(
VI)
improvers,
pour
point
depressants,
and
thickeners.
Other
Substances
that
cannot
be
defined
by
any
other
category
listed
in
this
table.
DRAFT:
Appendix
C
Chemical
List
C­
1
Appendix
C
Chemical
List
To
view
an
electronic
version
of
this
appendix
(
for
EPA
review
purposes),
go
to
the
following
Internet
address
for
Appendix
A
from
the
1998
IUR
Guidance
Manual.

http://
www.
epa.
gov/
opptintr/
iur98/
blubook.
pdf
[
Is
"
iur98"
in
the
web
address
correct
for
2002?]
DRAFT:
Appendix
D
Instructions
for
Submitting
IUR
Forms
Electronically
D­
1
Appendix
D
Instructions
for
Submitting
IUR
Forms
Electronically
To
view
an
electronic
version
of
this
appendix
(
for
EPA
review
purposes),
go
to
the
following
Internet
address
for
Appendix
B
from
the
1998
IUR
Guidance
Manual.

http://
www.
epa.
gov/
opptintr/
iur98/
blubook.
pdf
[
Is
"
iur98"
in
the
web
address
correct
for
2002?]
E­
1
Appendix
E
Case
Studies
INTRODUCTION
This
Appendix
presents
seven
sample
case
studies
to
illustrate
how
to
report
information
on
Form
U.
EPA
designed
the
case
studies
to
cover
a
variety
of
reporting
scenarios.
These
case
studies
are
not
based
on
actual
data,
but
are
hypothetical
situations
generated
to
assist
submitters.
Each
case
study
is
divided
into
the
following
four
sections:

°
Scenario
­
This
section
presents
a
sample
manufacturing
scenario
for
a
single
chemical
including
processing
and
use
information.
For
some
cases,
a
figure
is
included
to
clarify
the
manufacture,
process,
and
use
information;

°
Key
Points
­
This
section
summarizes
the
information
from
the
previous
section
and
addresses
which
information
should
or
should
not
be
reported;

°
Completing
the
Form
­
This
section
discusses
the
responses
which
should
be
entered
on
Form
U
for
each
manufacturing
scenario.
This
section
explains
the
basis
and
rationale
for
the
reported
information;
and
°
Sample
Form
U
­
A
completed
Form
U
for
each
scenario
is
included.
Part
I
of
Form
U
was
not
completed
for
these
case
studies
because
that
information
pertains
strictly
to
site
identification.

EPA
created
case
studies
to
cover
the
following
frequently
asked
questions:

1.
How
do
I
know
if
my
chemical
is
site
limited?
A
chemical
is
site
limited
if
it
is
manufactured
at
your
plant
site
and
you
do
not
distribute
the
substance
or
any
mixture
containing
the
substance
outside
the
plant
site
for
commercial
purposes.
See
Section
5.6.3
and
Case
Study
A
for
additional
guidance.

2.
What
if
my
site
only
imports
a
chemical?
Manufacturers
and
importers
are
required
to
report
under
the
IURA.
Importers
should
enter
"
I"
in
Block
2.4
in
Part
II,
Section
II
of
Form
U.
Sections
2.2.2.1
and
5.6.4
and
Case
Study
B
of
this
document
provide
additional
guidance
for
reporting
this
information.

3.
What
if
my
site
exports
the
entire
volume
of
the
manufactured
chemical?
E­
2
If
you
manufacture
an
IUR­
reportable
chemical
substance
solely
for
export,
you
are
required
to
report
and
otherwise
comply
with
all
IUR
requirements
applicable
to
manufacturers
of
all
IUR
reportable
chemicals.
Reporting
this
information
is
not
addressed
directly
in
this
document,
therefore
a
case
study
was
generated
to
illustrate
a
possible
submission.
Case
Study
C
illustrates
how
to
complete
Form
U
for
a
chemical
that
is
exported.

4.
What
if
my
site
both
manufactures
and
imports
the
same
chemical?
Sites
both
manufacturing
and
importing
a
chemical
substance
should
enter
"
B"
in
Block
2.4
in
Part
II,
Section
II
of
Form
U.
The
total
volume
of
chemical
(
both
manufactured
and
imported)
should
be
reported
in
Parts
II
and
III
of
Form
U.
See
Sections
2.2.2.1
and
5.6.4
and
Case
Study
G
for
additional
guidance.

5.
How
do
I
report
the
number
of
workers
at
my
site
and
at
downstream
sites?
Estimates
for
the
number
of
workers
reasonably
likely
to
be
exposed
are
required
for
both
the
manufacturing
and
industrial
processing
sections
of
Form
U.
Sections
5.6.7
and
5.7.1.6
of
this
document
describe
how
to
report
these
codes
and
give
examples
of
worker
activities
that
could
potentially
result
in
exposure.
All
case
studies
provide
examples
of
how
to
report
the
number
of
potentially
exposed
workers
along
with
the
basis
and
rationale
for
selecting
the
reported
code.

6.
How
do
I
report
the
maximum
concentration
of
my
chemical?
You
are
required
to
report
the
maximum
concentration,
by
weight,
of
your
chemical
at
the
time
it
sent
off­
site
from
each
site.
If
a
chemical
is
site­
limited,
report
the
maximum
concentration
when
it
is
reacted
on­
site
to
produce
a
different
chemical
substance.
Section
5.6.8
of
this
document
provides
guidance
for
reporting
this
information.
Case
Study
B
illustrates
how
to
complete
Block
2.8
in
Part
II,
Section
II
and
Block
2.1.
d
in
Part
III,
Section
II.

7.
What
if
I
manufacture
my
chemical
in
more
than
one
physical
form?
You
are
required
to
report
all
physical
forms
of
the
chemical
substance
at
the
time
it
leaves
your
site
and
the
percent
of
production
volume
for
each
form.
The
percentage
must
be
rounded
off
to
the
nearest
10%;
the
sum
of
the
percentages
for
each
form
must
not
add
up
to
more
than
100%.
Section
5.6.9
of
this
document
provides
guidance
for
reporting
the
physical
form
and
the
percent
production
volume
in
each
physical
form.
Case
Study
F
provides
a
scenario
and
illustrates
how
to
complete
Blocks
2.9
though
2.14
in
Part
II,
Section
II.

8.
What
if
there
are
multiple
NAICS,
IFC,
and
"
Types
of
Process
or
Use"
code
combinations
for
my
chemical?
You
are
required
to
report
up
to
ten
unique
combinations
of
codes.
If
more
than
10
unique
combinations
apply,
you
need
only
report
the
ten
combinations
that
represent
the
largest
percentage
of
production
volume.
Section
5.7.1
and
Case
Studies
F
and
G
provide
additional
guidance.

9.
What
if
my
percent
production
volume
is
less
than
5%
for
the
a
process/
use,
NAICS,
and
IFC
code
combination
and
the
total
production
volume
is
less
than
300,000
pounds?
E­
3
As
discussed
in
section
5.7.1.4
of
this
document,
if
a
particular
combination
accounts
for
less
than
5%
of
the
percent
production
volume
and
is
less
than
300,000
pounds,
then
you
may
report
the
percent
production
volume
as
0%.
Case
Study
G
illustrates
this
how
to
report
this
information.

10.
What
if
my
percent
production
volume
is
less
than
5%
for
the
a
process/
use,
NAICS,
and
IFC
code
combination
but
the
total
production
volume
is
greater
than
300,000
pounds?
As
discussed
in
Section
5.7.1.4
of
this
document,
if
a
particular
combination
accounts
for
less
than
5%
of
the
percent
production
volume
and
is
300,000
pounds
or
greater,
then
you
must
report
the
percent
production
volume
to
the
nearest
1%
of
production
volume.
Case
Study
G
illustrates
this
how
to
report
this
information
11.
What
if
the
values
I
report
for
percent
production
volume
for
each
end
use
add
up
to
more
than
100%?
As
discussed
in
Section
5.7.1.4,
the
total
percent
production
volumes
may
add
up
to
more
than
100%
since
you
are
reporting
on
the
distribution
of
the
chemical
to
downstream
sites.
The
values
may
add
up
to
less
than
100%
if
the
information
on
production
volume
is
not
readily
obtainable.
Case
Studies
F
and
G
illustrate
how
to
report
this
information.

12.
What
if
my
chemical
has
multiple
commercial
and
consumer
uses?
You
must
report
up
to
10
commercial
and
consumer
product
categories
for
which
your
chemical
is
used.
Section
5.7.2.1
and
Case
Studies
F
and
G
provide
additional
guidance
for
completing
Column
a
in
Part
III,
Section
II.

13.
What
if
my
substance
is
used
in
children's
products?
You
must
determine,
within
each
commercial
and
consumer
product
category
reported,
whether
any
amount
of
each
reportable
chemical
substance
is
present
in
consumer
products
intended
for
use
by
children
age
14
or
younger.
Section
5.7.2.2
of
this
document
provides
guidance
for
completing
Column
b
in
Part
III
­
Section
II
of
Form
U.
Case
Study
F
presents
a
scenario
to
illustrate
how
to
complete
this
part
of
Form
U.

14.
How
do
I
report
chemicals
that
are
intermediates?
Definitions
for
"
intermediate"
and
"
non­
isolated
intermediate"
are
provided
in
Appendix
B.
Section
2.2.2.3
of
this
document
states
that
impurities,
byproducts,
and
non­
isolated
intermediates
are
exempt
from
reporting.
However,
reporting
the
manufacture
of
an
isolated
intermediate
is
required.
Case
Study
A
provides
a
possible
scenario
for
reporting
an
isolated
intermediate.
Additional
examples
are
available
in
section
2.2.2.3
of
this
document.

15.
How
do
I
report
hydrates
of
a
chemical
substance?
You
are
required
to
complete
Form
U
for
the
corresponding
anhydrous
form.
Section
2.1.1.2
of
this
document
specifically
addresses
how
to
report
a
hydrate
of
a
chemical
substance
and
provides
an
example.
Furthermore,
Case
Study
D
presents
another
example
of
how
to
report
a
hydrate
of
a
chemical
substance.

16.
How
do
I
report
inorganic
chemical
substances?
E­
4
Inorganic
chemical
substances
are
partially
exempt
from
reporting
for
the
2006
reporting
period
and
will
not
be
exempt
for
subsequent
reporting
periods.
For
the
2006
reporting
period,
you
only
need
to
complete
Parts
I
and
II
of
Form
U.
Section
2.3.2
of
this
document
provides
additional
guidance
on
this
subject.
Case
Study
D
illustrates
how
to
report
an
inorganic
chemical
substance
for
the
2006
reporting
period.

17.
What
if
my
chemical
is
listed
on
the
"
specific
exempted
chemical
substances"
list?
EPA
generates
a
list
of
chemicals
for
which
manufacturers
are
exempt
from
reporting
Part
III
of
Form
U.
Additional
information
about
these
chemicals
can
be
found
in
section
2.3.2.3
of
this
document.
Case
Study
E
illustrates
how
to
report
a
chemical
that
is
listed
as
a
"
specific
exempted
chemical
substance."
E­
5
CASE
STUDY
A
This
example
illustrates
how
to
report:
°
site­
limited
chemicals;
°
intermediates.

Scenario:
Company
A
manufactures
1,100,000
lbs/
yr
of
an
intermediate
called
UV
Inhibitor
#
1
(
PMN#
P­
99­
9999)
that
the
site
will
later
use
in
the
manufacture
of
a
polyvinyl
chloride
(
PVC).
UV
Inhibitor
#
1
is
only
used
on
this
site.
UV
Inhibitor
#
1
is
produced
as
part
of
a
liquid
solution
at
89.6%
concentration
and
transferred
to
an
on­
site
storage
tank
for
future
use.
UV
Inhibitor
#
1
is
subsequently
destroyed
during
the
reaction
to
produce
the
PVC.
Twelve
workers
are
exposed
during
the
manufacture
of
UV
Inhibitor
#
1
for
sampling,
equipment
cleaning,
and
transfer
operations.
Two
workers
are
used
to
transfer
UV
Inhibitor
#
1
from
the
storage
tank
to
the
reactor
that
produces
PVC.
Four
administrative
workers
are
on­
site
but
not
directly
involved
with
the
manufacture
of
any
chemicals.

Key
Points:
Polymers
are
excluded
from
reporting,
so
reporting
for
the
manufacture
of
PVC
is
not
required.
However,
the
details
on
the
manufacture
and
use
of
the
intermediate
must
be
reported.
The
intermediate
is
considered
to
be
site­
limited
because
it
is
not
imported
to
the
site
and
does
not
leave
the
site.
The
intermediate
is
defined
as
isolated
because
the
transfer
operation
from
the
reactor
to
the
storage
tank
isolates
UV
Inhibitor
#
1.

Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
P­
99­
9999
Chemical
PMN
number.

1.2
ID
Code
P
Code
for
PMN
Number.

1.3
Chemical
Name
UV
Inhibitor
#
1
Chemical
Abstracts
Index
name.
Note:
if
this
were
a
real
chemical,
the
chemical
name
should
be
reported.

2.3
Site
limited
Y
UV
Inhibitor
#
1
is
site
limited
because
it
is
not
imported
and
it
never
leaves
the
site
because
it
is
destroyed
during
the
reaction
to
produce
PVC.

2.4
Activity
M
UV
Inhibitor
#
1
is
manufactured
by
Company
A
and
not
imported.

2.5
Production
Volume
Range
P3
At
least
1,000,000
but
less
than
10,000,000
pounds.

2.6
Production
Volume
(
lbs)
1,100,000
Amount
manufactured.
Block
Block
Title
Report
Basis/
Rationale
E­
6
2.7
Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
A
estimates
14
exposed
workers
from
sampling,
equipment
cleaning,
and
transfer
operations
during
manufacture
of
UV
Inhibitor
#
1.
The
administrative
workers
are
not
included
in
this
total
because
they
are
not
likely
to
be
exposed
to
this
chemical.

2.8
Maximum
Concentration
M4
From
61%
to
90%
by
weight.
The
maximum
concentration
is
89.6%,
rounding
to
the
nearest
percent
results
in
90%.

2.14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
a
liquid.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PC
32619
U16
100
S1
W1
Processing
as
a
reactant.
Other
plastics
product
manufacturing.
Intermediate.
All
product
is
used
as
an
intermediate.
Fewer
than
10.
Only
one
site
uses
this
chemical.
Fewer
than
10.
Company
A
estimates
2
workers
are
exposed
during
transfer
operations
during
the
reaction
that
produces
PVC.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
The
intermediate
is
destroyed
during
the
production
of
PVC
and
therefore
never
leaves
this
site
for
further
processing
or
use.
E­
7
E­
8
E­
9
CASE
STUDY
B
This
example
illustrates
how
to
report:
°
a
chemical
substance
that
is
imported
only;
°
TSCA­
exempt
uses
(
such
as
soaps
and
detergents
for
consumer
use).

Scenario:
Company
B
imports
400,000
pounds
of
2­
propanol
(
IPA)
(
CAS#
67­
63­
0)
to
its
only
site
during
a
reporting
year
as
part
of
a
liquid
solution
at
95%
concentration.
The
company
incorporates
the
IPA
into
mixtures
and
formulations
ranging
from
10%
to
50%
in
concentration.
Half
the
production
volume
(
200,000
pounds)
is
incorporated
into
industrial
solvents
and
cleaners
and
is
sold
to
hundreds
of
sites.
Company
B
estimates
3
workers
are
exposed
at
each
of
these
sites.
200,000
pounds
of
IPA
is
used
in
soaps
and
skin
cleaners,
half
of
which
is
used
commercially
and
half
by
consumers
(
25%
of
production
volume
for
each
use).
These
products
are
used
at
thousands
of
sites.

Key
Points:
Since
IPA
is
imported,
no
exposed
workers
are
reported
for
the
manufacturing
section
in
Part
II.
Use
of
soaps
and
skin
cleaners
by
consumers
is
exempt
from
TSCA
reporting,
but
the
manufacture
and
processing
of
these
products
is
not
exempt.
Therefore,
the
consumer
use
of
soaps
and
cleaners
is
not
required
in
Part
III
of
Form
U.
However,
reporting
the
commercial
use
of
soaps
and
skin
cleaners
is
required,
if
information
is
readily
obtainable.

Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
67­
63­
0
CAS
Number.

1.2
ID
Code
C
Code
for
CAS
Number.

1.3
Chemical
Name
2­
propanol
Chemical
Abstracts
Index
name.

2.3
Site
limited
N
Imported
chemicals
cannot
be
claimed
as
site
limited
and
IPA
leaves
the
site
of
manufacture.

2.4
Activity
I
IPA
is
imported
only
(
not
domestically
manufactured).

2.5
Production
Volume
Range
P2
At
least
300,000
but
less
than
1,000,000
pounds.

2.6
Production
Volume
(
lbs)
400,000
Amount
pf
IPA
imported.

2.7
Number
of
Workers
W1
Fewer
than
10.
Since
the
product
is
imported,
no
workers
are
exposed
during
the
manufacture
of
IPA.

2.8
Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
leaving
the
site
is
50%.
The
imported
concentration
of
95%
is
not
included
in
this
assessment.

2.14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
liquid
formulations
and
mixtures.
E­
10
Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PF
32519
U27
50
S5
W7
Incorporation
into
formulations
and
mixtures.
Other
basic
organic
chemical
manufacturing.
Solvents
for
cleaning
and
degreasing.
Half
of
the
product
is
used
in
industrial
solvents.
From
251
to
1,000.
Company
B
estimates
hundreds
of
sites.
At
least
1,000
but
fewer
than
10,000.
Company
B
estimates
3
exposed
workers
for
each
industrial
processing
site
during
transfer
and
use
operations.
3
workers
per
site
x
1,000
sites
=
3,000
workers.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Related
Data
Block
Block
Title
Report
Basis/
Rationale
2.1
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C16
Y
30
M3
Soaps
and
detergents.

Some
soaps
and
detergents
may
be
used
by
children.
Of
the
400,000
lbs
imported,
100,000
lbs
(
25%)
is
used
in
commercial
soaps
and
detergents.
From
31%
to
60%
by
weight.
The
maximum
concentration
used
in
formulations
is
50%.
E­
11
400,000
lbs.
of
IPA
is
imported
to
Company
B
at
95%
conc.

Company
B
incorporates
the
IPA
into
liquid
formulations
and
solutions
at
concentrations
of
10­
50%

200,000
lbs.
IPA
sold
as
industrial
solvents
and
cleaners
200,000
lbs.
IPA
sold
as
soaps
and
skin
cleaners
100,000
lbs.
IPA
used
commercially
100,000
lbs.
IPA
used
by
consumers
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
COMMERICAL
AND
CONSUMER
END
USE
CASE
STUDY
B
­
Flow
Diagram
E­
12
E­
13
CASE
STUDY
C
This
example
illustrates
how
to
report:
°
a
chemical
substance
that
is
exported
only
(
production
volume
is
300,000
lbs/
yr
or
more).

Scenario:
Company
C
manufactures
400,000
pounds
of
liquid
cyclohexane
(
CAS#
110­
82­
7)
in
solution
at
90%
concentration
during
a
reporting
year.
The
manufacturer
exports
the
entire
production
volume.
Since
cyclohexane
is
extremely
volatile,
steps
are
taken,
including
the
addition
of
engineering
controls,
to
minimize
releases
and
worker
exposures
during
manufacturing
operations.
However,
Company
C
estimates
4
workers
will
be
exposed
during
transfer
operations
and
4
workers
will
be
exposed
during
maintenance
operations.

Key
Points:
Reporting
the
industrial,
commercial,
and
processing
use
information
of
this
chemical
is
not
required
for
activities
outside
the
United
States.

Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
110­
82­
7
CAS
Number
1.2
ID
Code
C
Code
for
CAS
Number
1.3
Chemical
Name
Cylcohexane
Chemical
Abstracts
Index
name
2.3
Site
limited
N
Cyclohexane
is
distributed
off­
site
for
commercial
purposes.

2.4
Activity
M
Cyclohexane
is
manufactured
and
not
imported.

2.5
Production
Volume
Range
P2
At
least
300,000
but
less
than
1,000,000
pounds.

2.6
Production
Volume
(
lbs)
400,000
Amount
manufactured.

2.7
Number
of
Workers
W1
Fewer
than
10.
Company
C
estimates
8
workers
exposed
during
the
manufacturing
process.

2.8
Maximum
Concentration
M4
From
61%
to
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
90%.

2.14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
liquid
formulations
and
mixtures.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
E­
14
E­
15
CASE
STUDY
D
This
example
illustrates
how
to
report:
°
a
hydrate
of
a
chemical
substance;
°
inorganic
chemical
substances
(
partial
exemption
for
2006
reporting
year).

Scenario:
Company
D
produces
800,000
lbs/
yr
of
copper
sulfate
hydrate
(
CuSO
4
·
5H
2
O)
crystals
at
93%
purity.
70%
of
the
production
volume
is
used
for
metal
electroplating
and
30%
is
used
in
pesticides.
This
site
employs
60
workers
in
the
manufacturing
area.

Key
Points:
This
material
is
a
hydrate,
therefore
only
the
weight
fraction
of
the
anhydrous
copper
sulfate
(
CuSO
4)
(
CAS#
7758­
98­
7)
should
be
reported.
To
determine
the
weight
fraction,
multiply
the
production
volume
by
the
mass
fraction
of
copper
sulfate
(
CuSO
4)
in
the
hydrate
(
CuSO
4
·
5H
2
O).
The
molecular
weight
of
CuSO
4
is
159.5
and
the
molecular
weight
of
CuSO
4
·
5H
2
O
is
249.5.
Calculation:

800,000
lbs
CuSO4
5H2O
yr
159.5
lbs
CuSO4
249.5
lbs
CuSO
4
5H
2
O
511,423
lbs
CuSO4
 
×
 
=

The
use
of
pesticides
is
exempt
from
TSCA­
regulations,
but
the
manufacture
and
processing
of
pesticides
is
not
exempt.
Therefore,
the
portion
of
the
production
volume
used
in
pesticides
does
not
need
to
be
reported
for
Part
III.
Additionally,
copper
sulfate
is
an
inorganic
substance.
For
the
2006
reporting
year,
inorganic
substances
are
partially
exempt,
so
only
Parts
I
and
II
need
to
be
reported.
E­
16
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
7758­
98­
7
CAS
Number
1.2
ID
Code
C
Code
for
CAS
Number
1.3
Chemical
Name
Copper
(
II)
sulfate
Chemical
Abstracts
Index
name
2.3
Site
limited
N
Copper
sulfate
is
distributed
off­
site
for
commercial
purposes.

2.4
Activity
M
Copper
sulfate
is
manufactured
and
not
imported.

2.5
Production
Volume
Range
P2
At
least
300,000
but
less
than
1,000,000
pounds.

2.6
Production
Volume
(
lbs)
511,423
Calculated
amount
of
anhydrous
copper
sulfate
produced.

2.7
Number
of
Workers
W4
At
least
50
but
fewer
than
100.
Company
D
estimates
60
workers
exposed
during
the
manufacturing
process,
mostly
due
to
cleaning,
sampling,
handling,
and
transfer
operations.

2.8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
93%.

2.10
Physical
Form
Percent
of
PV
a.
Large
crystals;
b.
100
100%
of
the
product
is
produced
as
large
crystals.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
E­
17
Company
D
produces
800,000
lbs.
of
copper
sulfate
hydrate
crystals
at
93%
purity
560,000
lbs.
is
used
for
metal
electroplating
240,000
lbs.
is
used
in
pesticide
formulations
(
pesticides
are
exempt
from
reporting)
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
CASE
STUDY
D
­
Flow
Diagram
E­
18
E­
19
CASE
STUDY
E
This
example
illustrates
how
to
report:
°
a
chemical
listed
on
the
"
specific
exempted
chemical
substances"
list.

Scenario:
Company
E
produces
500,000
lbs/
yr
of
a
D­
glucose
(
50­
99­
7)
liquid
solution
at
concentrations
between
10%
and
40%.
Half
of
this
chemical
is
used
by
twelve
food
processing
companies,
the
other
half
is
sold
to
a
distributor
for
use
by
medical
facilities
at
roughly
2000
sites.
Company
E
has
two
production
lines
on
this
site
that
produce
D­
glucose.
Each
line
employs
20
workers
to
operate
and
maintain
equipment
during
manufacture
of
D­
glucose,
including
sampling,
handling,
and
equipment
cleaning.

Key
Points:
D­
glucose
is
partially
exempt
from
reporting,
therefore
only
Sections
I
and
II
need
to
be
completed.
The
processing
and
use
information
in
Section
III
does
not
need
to
be
completed.

Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
50­
99­
7
CAS
Number
1.2
ID
Code
C
Code
for
CAS
Number
1.3
Chemical
Name
D­
glucose
Chemical
Abstracts
Index
name
2.3
Site
limited
N
D­
glucose
is
distributed
off­
site
for
commercial
purposes.

2.4
Activity
M
D­
glucose
is
manufactured
and
not
imported.

2.5
Production
Volume
Range
P2
At
least
300,000
but
less
than
1,000,000
pounds.

2.6
Production
Volume
(
lbs)
500,000
Reported
to
amount
reasonably
obtainable.

2.7
Number
of
Workers
W3
At
least
25
but
fewer
than
50.
Company
E
estimates
40
workers
exposed
during
the
manufacturing
process
(
20
workers
per
line
x
2
lines
=
40
workers).

2.8
Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
leaving
the
site
is
40%.

2.14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
produced
as
liquid
formulations
and
mixtures.

Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
°
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
E­
20
500,000
lbs.
of
D­
glucose
solution
produced
at
10­
40%
concentration
250,000
lbs.
D­
glucose
is
sold
to
12
food
processing
companies
250,000
lbs.
sold
to
a
distributor
for
use
by
medical
facilities
at
2,000
sites
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
CASE
STUDY
E
­
Flow
Diagram
E­
21
E­
22
CASE
STUDY
F
This
example
illustrates
how
to
report:
°
when
two
different
physical
forms
are
manufactured;
°
the
use
in
a
children's
product;
°
Children's
Product
Use
as
"
not
readily
obtainable";
°
when
the
sum
of
the
percent
production
volume
is
greater
than
100%.

Scenario:
At
one
site,
Company
F
manufacturers
a
total
of
800,000
lb/
yr
of
C.
I.
Pigment
Yellow
100
(
CAS#
12225­
21­
7)
in
both
powdered
and
liquid
forms.
Company
F
manufactures
and
sells
300,000
lb/
yr
of
powdered
C.
I.
Pigment
Yellow
100
(
100%
concentration)
to
6
sites
that
incorporate
it
into
plastic
articles
at
less
than
1%
concentration.
The
remaining
500,000
pounds
of
C.
I.
Pigment
Yellow
100
is
sold
as
a
liquid
at
concentrations
between
1%
and
30%
as
a
coloring
agent
to
approximately
50
paint
manufacturers.
The
paint
manufacturers
then
sell
60%
of
this
paint
(
300,000
lbs.)
directly
to
the
consumer
and
the
other
40%
to
about
10
toy
manufacturers
that
paint
wooden
toys
(
200,000
lbs.).
The
furniture
and
toys
are
then
sold
to
consumers,
including
children.

Company
F
employs
25
workers
to
manufacture
C.
I.
Pigment
Yellow
100
as
a
powder
and
an
additional
20
workers
to
manufacture
the
liquid
formulations.
Company
F
estimates
that
5
workers
are
exposed
to
C.
I.
Pigment
Yellow
100
at
each
plastic
manufacturing
site
and
5
workers
are
exposed
at
each
paint
manufacturing
site.
Company
F
estimates
5
workers
are
exposed
at
to
C.
I.
Pigment
Yellow
100
at
each
wooden
toy
manufacturer
site.
E­
23
Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
12225­
21­
7
CAS
Number
1.2
ID
Code
C
Code
for
CAS
Number
1.3
Chemical
Name
C.
I.
Pigment
Yellow
100
Chemical
Abstracts
Index
name
2.3
Site
limited
N
C.
I.
Pigment
Yellow
100
is
distributed
off­
site
for
commercial
purposes.

2.4
Activity
M
C.
I.
Pigment
Yellow
100
is
manufactured
and
not
imported.

2.5
Production
Volume
Range
P2
At
least
300,000
but
less
than
1,000,000
pounds.

2.6
Production
Volume
(
lbs)
800,000
Reported
to
amount
reasonably
obtainable.

2.7
Number
of
Workers
W3
At
least
25
but
fewer
than
50.
Company
E
employs
45
workers
to
produce
C.
I.
Pigment
Yellow
100
(
25
for
powder
form
and
20
for
liquid
form).

2.8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
100%.

2.9
Physical
Form
Percent
of
PV
a.
Powder;
b.
40
300,000
of
the
total
800,000
pounds
(
37.5%)
of
product
is
produced
as
a
powder.
Round
up
to
40%.

2.14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
60
500,000
of
the
total
800,000
pounds
(
62.5%)
of
product
is
produced
as
a
liquid.
Round
down
to
40%.
E­
24
Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PA
32619
U08
40
S1
W3
Incorporation
into
an
article.
This
accounts
for
the
powder
form
being
incorporated
into
plastics.
Other
plastics
product
manufacturing.
Coloring
agents,
pigments.
37.5%
of
the
production
volume
is
used
for
this
use.
Round
up
to
40%.
Less
than
10.
Company
F
has
6
customer
sites.
At
least
25
but
fewer
than
50.
Company
B
estimates
5
exposed
workers
for
each
of
6
processing
sites.
5
workers
per
site
x
6
sites
=
30
workers
1.2
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PF
32551
U08
60
S3
W5
Incorporation
into
formulations
and
mixtures.
Paint
and
coating
manufacturing.
Coloring
agents,
pigments.
62.5%
of
the
production
volume
is
used
for
this
use.
Round
down
to
60%.
From
26
to
100.
Company
F
estimates
50
paint
manufacturers
use
their
product.
At
least
100
but
fewer
than
500.
Company
F
estimates
5
exposed
workers
per
site
for
50
processing
sites
=
250
of
workers.

1.3
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PF
32199
U08
30
S2
W4
Incorporation
into
formulations
and
mixtures.
All
other
wood
product
manufacturing..
Coloring
agents,
pigments.
25%
of
the
PV(
200,000
lbs.)
is
used
by
wooden
toy
manufacturers.
Round
up
to
30%.
From
10
to
25.
Company
F
estimates
10
sites
paint
toys
using
C.
I.
Pigment
Yellow
100.
At
least
50
but
fewer
than
100.
Company
F
estimates
5
workers
per
site
x
10
sites
=
50
workers.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Block
Block
Title
Report
Basis/
Rationale
2.1
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C01
Y
40
M2
Artist's
supplies.
Paint
is
classified
as
an
artists
supply.

Some
paints,
such
as
finger
paints
and
watercolor,
may
be
used
by
children.
37.5%
of
PV
(
300,000
lbs.)
is
used
in
paint
which
is
not
used
by
wooden
toy
makers.
Round
up
to
40%.
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.
Block
Block
Title
Report
Basis/
Rationale
E­
25
2.2
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C12
N
60
M2
Paints
and
coatings.

Paints
sold
directly
to
consumer
are
not
expected
to
be
used
by
children.
60%
of
C.
I.
Pigment
Yellow
100
manufactured
by
Company
F
is
used
in
paint.
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.

2.3
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C15
?
40
M1
Rubber
and
plastics
products.

Information
not
readily
obtainable.
40%
of
C.
I.
Pigment
Yellow
100
manufactured
by
Company
F
is
used
in
polymers/
plastics.
Less
than
1%
by
weight.

2.4
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C18
Y
30
M2
Wood
and
wood
furniture.

Wooden
toys
are
expected
to
be
used
by
children.
25%
of
PV
(
200,000
lbs.)
is
used
in
paint
for
wooden
toys.
Round
up
to
30%.
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.
E­
26
Company
F
produces
300,000
lbs.
of
powdered
CI
Pigment
Yellow
100
at
100%
concentration
500,000
lbs.
of
CI
Pigment
Yellow
100
is
sold
to
50
paint
manufacturers
as
a
coloring
agent
and
is
blended
into
paint
formulations
at
concentrations
of
1­
30%
300,000
lbs.
CI
Pigment
Yellow
100
sold
to
6
sites
that
incorporate
it
into
plastic
articles.

300,000
lbs.
is
sold
directly
to
the
consumer
as
a
component
in
paint
200,000
lbs.
is
sold
to
10
toy
manufacturers
for
painting
wooden
toys
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
COMMERICAL
AND
CONSUMER
END
USE
Company
F
produces
500,000
lbs.
of
powdered
CI
Pigment
Yellow
in
liquid
solution
at
1
­
30%
concentration
CASE
STUDY
F
­
Flow
Diagram
E­
27
E­
28
CASE
STUDY
G
This
example
illustrates
how
to
report:
°
a
chemical
substance
that
is
both
manufactured
and
imported
at
the
same
site;
°
multiple
Types
of
Process
or
Use
codes;
°
multiple
NAICS
codes;
°
multiple
IFC
codes;
°
when
the
sum
of
the
percent
production
volume
for
Industrial
Processing
is
greater
than
100%;

Scenario:
Company
G
produced
19,000,000
pounds
of
xylene,
mixed
isomers
(
CAS#
1330­
20­
7)
(
referred
to
as
xylene
throughout
this
case
study)
and
imported
an
additional
1,000,000
pounds
during
the
same
reporting
year
to
the
same
site.
The
xylene
is
manufactured
at
100%
concentration.
Company
G
estimates
8
exposed
workers
during
the
manufacture
of
xylene
for
sampling
and
maintenance,
in
addition
to
6
exposed
workers
during
the
drumming
of
product.

Company
G
distributes
4,000,000
pounds
of
xylene
directly
to
3
chemical
manufacturing
facilities
at
100%
concentration
to
be
used
as
a
chemical
reactant.
The
remaining
16,000,000
pounds
of
xylene
is
shipped
to
15
different
distributors
for
repackaging.
The
distributors
repackage
4,000,000
pounds
of
xylene
and
sell
it
as
a
metal
degreaser
at
95%
concentration
to
200
hardware
manufacturers.
The
repackager
dilutes
the
remaining
12,000,000
pounds
such
that
xylene
is
present
at
a
concentration
ranging
between
0.5%
and
95%
and
places
the
final
product
into
smaller
containers.
Of
the
12,000,000
pounds
of
xylene
that
is
processed,
6,000,000
pounds
is
used
in
automotive
care
products
(
35%
max.
conc.)
used
both
commercially
and
by
consumers.
3,200,000
pounds
will
be
used
in
paint
formulations
(
15%
max.
conc.),
of
which
80%
(
2,560,000
lbs.)
will
be
used
commercially
and
20%
(
640,000
lbs.)
by
consumers.
2,200,000
pounds
is
sold
for
use
in
pesticides
(
95%
max
conc.).
400,000
pounds
is
sold
as
a
wood
preservative
(
20%
conc.).
200,000
pounds
is
sold
as
a
component
of
solvents
on
the
consumer
market
(
95%
max
conc.).

Key
Points:
The
use
of
pesticides
is
exempt
under
TSCA
regulations,
so
the
use
of
xylene
for
this
purpose
does
not
need
to
be
included
in
Form
U.
The
200,000
lbs.
of
xylene
used
as
a
component
of
solvents
sold
to
consumers
should
not
be
reported
in
Part
III
because
it
is
less
than
5%
of
the
total
production
volume
and
less
than
the
300,000
pounds
threshold.
The
percent
production
volumes
for
use
as
wood
preservatives
and
paint
used
by
consumers
should
be
reported
to
the
nearest
percentage
point
because
it
is
less
than
5%
of
the
production
volume
and
totals
300,000
lbs.
or
more.

Completing
the
Form:
Part
II
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
E­
29
1.1
Chemical
ID
Number
1330­
20­
7
CAS
Number
1.2
ID
Code
C
Code
for
CAS
Number
1.3
Chemical
Name
Xylene,
mixed
isomer
Chemical
Abstracts
Index
name
2.3
Site
limited
N
Xylene
is
distributed
off­
site
for
commercial
purposes.

2.4
Activity
B
Xylene
is
both
manufactured
and
imported.

2.5
Production
Volume
Range
P4
At
least
10,000,000
but
less
than
50,000,000
lbs.

2.6
Production
Volume
(
lbs)
20,000,000
Combined
manufacture
and
import
volumes.

2.7
Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
G
reports
14
workers
are
exposed
during
the
manufacture
of
xylene.

2.8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
100%.

2.14
Physical
Form
Percent
of
PV
a.
Liquid;
b.
100
100%
of
the
product
is
manufactured
in
liquid
form.
E­
30
Part
III
­
Section
I.
Industrial
Processing
and
Use
Information.

Block
Block
Title
Report
Basis/
Rationale
1.1
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PC
33519
U16
20
S1
W2
Processing
as
a
reactant.
Other
basic
organic
chemical
manufacturing.
Intermediates.
20%
PV
of
xylene
is
distributed
directly
to
3
chemical
manufacturers.
4,000,000
lbs.
/
20,000,000
lbs.
total
=
20%.
Less
than
10.
3
industrial
sites.
At
least
10
but
fewer
than
25.
Company
B
estimates
4
exposed
workers
for
each
of
3
industrial
sites.
4
workers
per
site
x
3
sites
=
12
workers
1.2
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PK
32519
U27
80
S2
W4
Repackaging
xylene.
Other
basic
organic
chemical
manufacturing.
Solvents
(
for
cleaning
or
degreasing).
80%
PV(
16,000,000
lbs.)
is
repackaged.
From
10
to
25.
Company
G
distributes
xylene
to
15
distributor/
repackaging
centers.
At
least
50
but
fewer
than
100.
Company
F
estimates
6
exposed
workers
per
site
x
15
sites
=
90
workers.

1.3
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
U
33251
U27
20
S4
W6
Industrial
grade
solvent.
Use
as
a
metal
degreaser.
Hardware
manufacturing.
Solvents
(
for
cleaning
or
degreasing).
20%
PV
of
xylene
is
distributed
from
distribution/
repackaging
centers
to
200
hardware
manufacturers
for
use
as
a
metal
degreaser.
From
101
to
250.
200
hardware
manufacturers
use
xylene
as
a
metal
degreaser.
At
least
500
but
fewer
than
1000.
Company
B
estimates
3
exposed
workers
for
each
of
200
sites.
3
workers
per
site
x
200
sites
=
600
workers
1.4
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PF
32551
U28
20
Incorporation
into
formulations
and
mixtures.
Paint
and
coating
manufacturing.
Solvents
(
which
become
part
of
product
formulation
or
mixture).
16%
PV
of
xylene
(
3,200,000
lbs.)
is
used
in
paint
formulations.
Round
to
20%.
Company
G
has
determined
that
this
information
is
not
readily
obtainable.
Company
G
has
determined
that
this
information
is
not
readily
obtainable.
Block
Block
Title
Report
Basis/
Rationale
E­
31
1.5
Type
of
Process
or
Use
NAICS
IFC
Percent
PV
Number
of
Sites
Number
of
Workers
PF
32111
U28
2
Incorporation
into
formulations
and
mixtures.
Sawmills
and
wood
preservation.
Solvents
(
which
become
part
of
product
formulation
or
mixture).
2%
PV
(
400,000
lbs.)
of
xylene
is
used
as
a
component
in
wood
preservatives.
This
percentage
is
rounded
to
the
nearest
percentage
point
because
it
is
less
than
5%
and
volume
is
300,000
lbs.
or
greater.
Company
G
has
determined
that
this
information
is
not
readily
obtainable.
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
Block
Block
Title
Report
Basis/
Rationale
2.1
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C03
N
30
M3
Automotive
care
products.

Not
expected
to
be
used
by
children.
30%
PV
(
6,000,000
lbs.)
is
used
in
the
formulation
of
automotive
care
products.
From
31%
to
60%
by
weight.
The
maximum
concentration
used
in
formulations
is
35%.

2.2
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C12
N
10
M2
Paints
and
coatings
(
commercial
use).

Not
expected
to
be
used
by
children.
12.8%
PV
(
2,560,000
lbs.)
of
xylene
is
used
in
paints
for
commercial
use.
Round
down
to
10%.
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
15%.

2.3
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C12
?
3
M2
Paints
and
coatings
(
consumer
use).

Not
readily
obtainable.
3.2%
PV
(
640,000
lbs.)
of
xylene
is
used
in
paints
used
by
consumers.
Since
this
percentage
is
less
than
5%
and
totals
300,000
pounds
or
greater,
round
to
the
nearest
percentage
point
(
3%).
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
15%.
Block
Block
Title
Report
Basis/
Rationale
E­
32
2.4
Commercial
and
Consumer
Product
Category
Use
in
Children's
Product
Percent
PV
Maximum
Concentration
C18
N
2
M2
Wood
and
wood
furniture.

Not
expected
to
be
used
by
children.
2%
PV
(
400,000
lbs.
)
of
xylene
is
used
as
a
component
in
wood
preservatives.
Since
this
percentage
is
less
than
5%
and
totals
300,000
pounds
or
greater,
round
to
the
nearest
percentage
point
(
2%).
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
20%.
E­
33
19,000,000
lbs.
xylene
produced
by
Company
A
at
100%
concentration
16,000,000
lbs.
shipped
to
15
different
distributors/
packaging
centers
to
be
repackaged
at
0.5%
­
95%
4,000,000
lbs.
shipped
directly
to
3
chemical
manufactures
at
100%
concentration
for
use
as
a
chemical
reactant.

2,560,000
lbs.
used
in
paints
for
commercial
applications
640,000
lbs.
used
in
paints
for
use
by
consumers
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
COMMERICAL
AND
CONSUMER
END
USE
1,000,000
lbs.
xylene
imported
by
Company
A
at
100%
concentration
Company
A
reports
20,000,000
lb.
manufactured
at
100%
concentration
4,000,000
lbs.
used
at
95%
maximum
concentration
as
a
metal
degreaser
at
200
hardware
manufacturers
400,000
lbs.
sold
as
a
component
in
wood
preservatives
at
20%
maximum
concentration
2,200,000
lbs.
used
in
pesticide
formulations
at
95%
concentration
3,200,000
lbs.
used
in
paint
formulations
at
15%
maximum
concentration
6,000,000
lbs.
used
as
a
component
in
automotive
care
products
at
35%
maximum
concentration
200,000
lbs.
used
as
a
component
of
solvents
sold
to
consumers
at
95%
maximum
concentration
CASE
STUDY
G
­
Flow
Diagram
E­
34
