Inorganic
Chemicals:
Sources
of
Information
Suggested
by
Commenters
to
the
Proposed
Inventory
Update
Rule
Amendments
Economic
and
Policy
Analysis
Branch
Economics,
Exposure,
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
U.
S.
Environmental
Protection
Agency
June
2000
­
1­
1.
Sources
of
Information
for
Inorganic
Chemicals
Several
of
the
commenters
suggested
specific
sources
of
information
for
inorganic
chemicals.
Table
1
summarizes
the
sources
of
information
suggested,
the
frequency
and
type
of
collected
information,
and
the
reporting
entity
or
source
of
information.
The
following
sources
of
information
are
collected
on
a
regular,
ongoing
basis:


EPA
Toxics
Release
Inventory
(
TRI)


EPCRA
Tier
II
­
Hazardous
Chemical
Inventory
Report

Bureau
of
Labor
Statistics

USGS
Mineral
Commodity
Summaries

USGS
Mineral
Industry
Surveys

Census
of
Manufacturers
°
U.
S.
Securities
and
Exchange
Commission
Form
10­
K
Of
these,
TRI,
EPCRA
Tier
II,
USGS
Mineral
Commodity
Summaries,
and
the
USGS
Mineral
Industry
Surveys
contain
information
related
to
chemical
use
and/
or
exposure.
The
Bureau
of
Labor
Statistics
conducts
many
surveys,
but
they
are
related
to
employment
and
productivity
and
do
not
contain
chemical
exposure
information.
The
U.
S.
Census
conducts
periodic
surveys
on
manufacturer's
shipments,
inventories,
and
orders,
but
these
surveys
do
not
appear
to
contain
information
useful
for
the
TSCA
Inventory
Update
Rule.
The
Form
10­
K
reports
submitted
by
all
public
companies
to
the
U.
S.
Securities
and
Exchange
Commission
contain
financial
data
and
are
not
useful
for
screening
risks
to
public
health
and
the
environment.

The
TRI
reports
on
the
annual,
site­
specific
amounts
of
toxic
chemicals
released
to
air,
water,
and
land,
and
that
are
transferred
off­
site
for
disposal,
treatment,
etc.
The
focus
of
this
reporting
is
on
chemicals
in
waste,
not
on
chemicals
in
products.
Therefore,
the
TRI
information
is
different
than
that
requested
for
the
TSCA
Inventory
Update
Rule
which
consists
of
the
average
and
maximum
concentration,
measured
by
weight,
of
the
reportable
chemical
substance
as
it
leaves
the
site
in
a
commercial
product.

The
EPCRA
Tier
II
data
consists
of
the
Hazardous
Chemical
Inventory
Report
required
under
section
312
of
EPCRA.
(
See
http://
es.
epa.
gov/
program/
exec/
qa­
tri2.
html
for
further
information
on
EPRCA
requirements).
These
data
are
submitted
annually
to
three
different
groups:
local
fire
departments,
local
emergency
planning
committees,
and
State
emergency
response
commissions.
The
data
are
not
submitted
to
the
Federal
government
and
therefore,
there
is
no
comprehensive
listing
or
database
of
the
reported
information
on
the
Internet.
This
law
applies
to
hazardous
chemicals
as
defined
by
the
Occupational
Safety
and
Health
Administration
(
OSHA)
as
chemicals
that
are
a
physical
or
health
hazard.
These
hazards
are
defined
in
29
CFR
Part
1910.1200(
c).
Although
many
chemical
substances
can
meet
the
OSHA
definition
of
a
physical
or
health
hazard,
there
is
no
comprehensive
list
of
all
OSHA
hazardous
chemicals.
Tier
II
reporting
facilities
should
submit
forms
for
most
chemicals
for
which
they
are
required
by
OSHA
to
maintain
a
Material
Safety
Data
Sheet
(
MSDS)
and
for
Extremely
Hazardous
­
2­
Substances
(
EHSs)
that
are
defined
and
listed
in
Appendices
A
and
B
of
Title
40
CFR
Part
355
(
rules
promulgated
under
EPCRA).
There
are
currently
362
listed
EHSs
(
www.
afcee.
brooks.
af.
mil/
pro_
act/
fact/
Oct98d.
htm).
The
completed
Tier
II
inventory
form
contains
the
following
information
(
42
U.
S.
C.
11022(
d)(
2)):

1.
The
chemical
name
or
the
common
name
of
the
chemical
as
provided
on
the
material
safety
data
sheet
and
the
CAS
number.
2.
An
estimate,
in
ranges,
of
the
maximum
amount
of
the
hazardous
chemical
present
at
the
facility
at
any
time
during
the
preceding
year.
3.
An
estimate,
in
ranges,
of
the
average
daily
amount
of
the
hazardous
chemical
present
at
the
facility
during
the
preceding
year.
4.
A
brief
description
of
the
manner
of
storage
of
the
hazardous
chemical.
5.
The
location
of
the
hazardous
chemical
at
the
facility.
6.
An
indication
of
whether
the
owner
elects
to
withhold
location
information
or
other
information
about
a
specific
hazardous
chemical
from
disclosure
to
the
public
as
a
trade
secret.

The
USGS
Mineral
Commodity
Summaries
provide
annual
information
on
the
total
production
of
a
chemical,
in
thousands
of
metric
tons,
in
the
United
States
.
This
information
is
presented
in
aggregate
and
it
is
not
broken
down
by
facility;
in
contrast,
the
TSCA
Inventory
Update
Rule
gathers
this
information
for
each
facility
required
to
report
under
the
Rule.
Similarly,
the
USGS
Mineral
Industry
Surveys
provide
data
on
total
production,
imports,
and
consumption
of
each
chemical.
However,
this
information
is
also
presented
as
an
aggregate
and
would
not
be
of
use
for
facility­
specific
information,
does
not
contain
specific
location
information,
does
not
indicate
a
tie­
in
to
any
parent
company,
and
does
not
contain
a
certification
of
accuracy
of
the
information.
An
example
of
the
type
of
information
that
is
included
in
the
USGS
reports
for
aluminum
and
can
be
seen
at
http://
minerals.
usgs.
gov/
minerals/
pubs/
commodity/
aluminum/
index.
html.
Information
on
all
of
the
chemicals
listed
on
Attachment
1
would
also
be
available
at
this
site.
Attachment
2
provides
additional
information
on
the
USGS
survey.

In
summary,
the
commenters
have
presented
many
excellent
data
sources
on
inorganic
chemicals.
However,
many
of
these
data
sources
are
documents
which
consist
of
literature
reviews
and
are
not
updated
regularly.
Other
sources
of
data
do
not
contain
information
in
a
format
that
would
be
readily
useable
for
the
IUR
and
do
not
contain
the
information
that
will
be
collected
through
the
IURA.
­
3­
Table
1.
Sources
of
Information
From
Comments
Sources
of
Information
Frequency
of
collected
information
Type
of
information
collected
Reporting
entity
or
source
of
information
Toxics
Release
Inventory
(
TRI)

(
http://
www.
epa.
gov/
tri
/)
Annual
The
amounts
of
toxic
chemicals
released
to
air,
water,
land,
and
injected
underground
and
amount
transferred
off­
site
for
recycling,
energy
recovery,
treatment,
and
disposal.
Facilities
with
10
or
more
employees,
which
manufacture
or
process
more
than
25,000
lbs
or
otherwise
use
more
than
10,000
lbs
of
any
listed
chemical
during
the
calender
yr.

EPCRA
Tier
II
­
Hazardous
Chemical
Inventory
Report
(
http://
es.
epa.
gov/
p
rogram/
exec/
qa­
tri2
.
html)
Annual
The
maximum
and
average
daily
amount
of
hazardous
chemicals
and
extremely
hazardous
substances
present
at
a
facility.
Facility
using
10,000
lbs
or
more
of
hazardous
chemical
or
facilities
that
exceed
either
the
threshold
planning
quantity
or
500
lbs,
(
whichever
is
lower)
for
extremely
hazardous
substances.

Material
Safety
Data
Sheets
(
MSDS)
Once
One
sheet
per
chemical
­­
contains:
chemical
identity,
hazardous
ingredients,
physical
data,
fire
and
explosion
hazard
data,
health
hazard
data,
reactivity
data,
spill
or
leak
procedures,
special
protection
information,
&
special
precautions.
Employers
must
have
a
MSDS
for
each
chemical
substance
used
in
the
workplace.

Bureau
of
Mines
(
http://
www.
cdc.
gov/
ni
osh/
mining/)
Unclear
what
commenter
was
referring
to
here.
The
Bureau
of
Mines
closed
in
1996.
A
few
parts
survived,
such
as
the
Office
for
Mine
Safety
and
Health
Research
in
NIOSH,
and
the
Mine
Safety
and
Health
Admin
Dept.
of
Labor.
Perhaps
some
older
publications
from
the
Bureau
of
Mines
contained
exposure
information
but
it
would
be
out­
of­
date.
NA
­
4­
Bureau
of
Labor
Statistics
(
http://
stats.
bls.
gov/
bls
home.
htm)
Surveys
(
some
monthly,
some
annual)
Employment
and
unemployment,
prices
and
living
conditions,
compensation
and
working
conditions,
productivity
and
technology,
employment
projections,
international
programs.
Survey
data
USGS
Mineral
Commodity
Summaries
(
http://
minerals.
usgs.
g
ov/
minerals/
pubs/
mcs/
#
A)
Annual­
not
facility
specific
Information
on
the
domestic
industry
structure,
govt.
programs,
tariffs,
and
5­
year
statistics
including
production
(
thousands
of
metric
tons),
imports,
exports,
consumption,
price,
employment,
for
more
than
90
minerals
and
materials.*
Survey
data
USGS
Mineral
Industry
Surveys
(
http://
minerals.
usgs.
g
ov/
minerals/
pubs/
com
modity/
mis.
html)
Monthly,
quarterly,
or
at
other
regular
interval
 
not
facility
specific
Production
(
thousands
of
metric
tons),
distribution,
stocks,
and
consumption
of
approx.
90
minerals.*
Survey
data
Census
of
Manufacturers
(
http://
www.
census.
gov
/
econ/
www/
ma0100.
ht
ml)
Periodic
Reports
on
manufacturers
shipments,
inventories,
and
orders
in
dollars
Survey
data
ATSDR
Toxicological
Profiles
(
http://
www.
atsdr.
cdc.
g
ov/)
One
per
chemical,
updated
as
needed,
approx.
every
4
years
 
not
facility
specific
Information
on
production,
import/
export,
use,
potential
for
human
exposure
including
levels
measured
in
air,
water,
and
soil
and
general
population
and
occupational
exposure
(
majority
of
document
toxicology
data)
Literature
and
databases
NTP
reports
(
http://
ntp­
server.
niehs.
nih.
gov/)
One
per
chemical
 
not
facility
specific
Toxicology
and
carcinogenesis
studies
of
specific
chemicals.
Small
section
on
chemical
properties,
production,
and
exposure.
Literature
and
databases
IARC
monographs
(
http://
193.51.164.11/
d
efault.
html)
Each
volume
contains
approx.
15
individual
chemical
monographs
 
not
facility
specific
Information
on
chemical
and
physical
data,
production,
use,
occurrence,
and
analysis
(
rest
of
monograph
contains
carcinogenicity
data)
Literature
and
databases
­
5­
Federal
OSHA
(
http://
www.
osha.
gov/)
periodic
Information
on
worker
exposure,
accidents,
injuries
and
deaths.
Facilities
EPA
1986
Health
Assessment
Document
on
Nickel
Once
Information
on
chemical/
physical
properties,
environmental
cycling,
and
levels
of
Ni
in
air,
water,
food,
and
soils
(
majority
of
document
toxicology
data)
Literature
and
databases
ATSDR
Toxicological
Profile
on
Nickel
Updated
in
1997
Information
on
Ni
production,
import/
export,
use,
potential
for
human
exposure
including
levels
measured
in
air,
water
,
and
soil
and
general
population
and
occupational
exposure
(
majority
of
document
toxicology
data)
Literature
and
databases
TERA's
1999
Toxicological
Review
of
Soluble
Nickel
Salts
Once
Chemical
and
physical
properties,
exposure,
occupational
exposure,
Ni
speciation
(
majority
of
document
toxicology
data)
Literature
and
databases.

U.
S.
Securities
and
Exchange
Commission
Form
10­
K
(
http://
www.
sec.
gov/
in
dex.
html)
Annually
 
by
company,
not
individual
facility
Information
on
business
operations
similar
to
what
is
included
in
a
company's
annual
report
to
its
shareholders
Company
records
Occupational
Exposure
Limits
Criteria
Document
for
Nickel
­
European
Commission
Once
Chemical
and
physical
properties,
occurrence,
production,
use,
analytical
methods,
exposure
data,
health
effects
Literature
and
databases
NiDI
­
Trade
Association
­
data
on
intermediate
and
end
uses
of
Nickel
(
http://
www.
nidi.
org)
Once
End­
use
distribution
into
products
NA
*
See
Attachment
1
for
a
list
of
chemicals
and
materials
which
have
mineral
commodity
summaries
and
mineral
industry
surveys.
­
6­
2.
Summary
of
Comments
Comment:
Several
commenters
stated
that
data
on
inorganic
chemicals
that
EPA
needs
to
conduct
screening­
level
risk
assessments
is
already
available
from
the
following
sources:
Toxics
Release
Inventory,
EPCRA
Tier
II,
Material
Safety
Data
Sheets,
Bureau
of
Mines,
Bureau
of
Labor
Statistics,
U.
S.
Geological
Survey's
annual
reports
on
mineral
production
and
uses,
the
Census
of
Manufacturers,
U.
S.
Securities
and
Exchange
Commission,
ATSDR
data,
the
NTP
reports,
OSHA
and
the
International
Agency
for
Research
on
Cancer
monographs.
In
particular,
lime
production
volume
information
is
already
available
from
USGS'
annual
lime
industry
survey.
(
Commenters
44,
54)

Comment:
A
commenter
stated
that
the
hazard
potential
of
aluminum
is
well
established
and
sufficient
information
is
available
from
other
sources
on
this
compound.
(
Commenter
13)

Comment:
A
commenter
stated
that
there
are
several
lengthy
toxicological
reviews
of
nickel,
there
is
sufficient
data
available
for
EPA
to
conduct
a
screening­
level
risk
assessment
and,
therefore,
this
chemical
should
not
be
included
in
the
rule.
(
Commenter
22)

Comment:
Two
commenters
felt
that
many
chemicals
moving
through
commerce,
such
as
iron
oxides,
zinc,
aluminas,
naturally
occurring
clays,
zeolites,
and
complex
inorganic
color
pigments,
do
not
present
risks
to
human
health
or
the
environment.
Because
the
hazards
are
so
low
for
these
compounds,
EPA
should
not
be
focusing
its
risk
screening
efforts
on
such
low­
priority
chemicals.
In
addition,
requiring
reporting
for
these
chemicals
would
result
in
large
burdens
to
industry
and
large
quantities
of
unnecassary
data.
(
Commenters
38,
54)

3.
Chemical
Specific
Data
Many
of
the
sources
identified
in
Table
1
contain
data
on
the
specific
chemicals
that
were
mentioned
by
the
commenters
(
lime,
aluminum,
nickle,
iron
oxide,
zinc,
naturally
occurring
clays,
zeolites,
and
inorganic
color
pigments).
For
example
all
of
theses
chemicals
(
with
the
exception
of
inorganic
color
pigments)
are
included
on
Attachment
1­­
chemicals
in
the
USGS
surveys.
In
the
text
above,
I
provided
the
specific
Internet
links
for
the
USGS
information
for
aluminum.
Additional
Internet
links
are
provided
in
Table
1
for
the
other
information
sources.
Most
of
these
sources
are
extensive
and
contain
information
on
the
chemicals
in
question.
However,
the
information
provided
by
these
websites
does
not
appear
to
duplicate
the
information
that
would
be
provided
by
the
IUR.

Attachment
1
Chemicals
and
Materials
in
both
the
USGS
Mineral
Commodity
Summaries
and
Mineral
Industry
Surveys
­
7­

Abrasives

Aluminum

Antimony

Arsenic

Asbestos

Barite

Bauxite
and
Alumina

Beryllium

Bismuth

Boron

Bromine

Cadmium

Cement

Cesium

Chromium

Clays

Cobalt

Columbium
(
Niobium)


Copper

Diamond,
Industrial

Diatomite

Feldspar

Fluorspar

Gallium

Garnet

Gemstones

Germanium

Gold

Graphite

Gypsum

Helium

Indium

Iodine

Iron
and
Steel

Iron
and
Steel
Scrap

Iron
and
Steel
Slag

Iron
ore

Kyanite

Lead

Lime

Lithium

Magnesium

Manganese

Manufactured
Abrasives

Mercury

Mica

Molybdenum

Nickel

Nitrogen

Peat

Perlite

Phosphate
Rock

Platinum

Potash

Rare
earths

Rhenium

Salt

Sand
and
Gravel

Selenium

Silicon

Silver

Soda
Ash

Stone

Sulfur

Talc

Thorium

Tin

Titanium

Tungsten

Vanadium

Vermiculite

Zinc

Zirconium
Chemicals
and
Materials
in
the
Mineral
Commodity
Summaries
Only

Ilmenite

Pumice

Quartz
Crystal,
Industrial

Rubidium

Rutile

Scandium
­
8­

Sodium
Sulfate

Strontium

Tantalum

Tellerium

Thallium

Yttrium
Chemicals
and
Materials
in
the
Mineral
Industry
Surveys
Only

Coal
Combustion
Byproducts

Crushed
Stone
and
Sand
and
Gravel

Construction
sand
and
Gravel

Dimension
stone

Explosives

Ferroalloys

Iron
oxide
pigments

Precious
Metals

Recycling
materials

Silica

Wollastonite

Zeolites
­
9­
Attachment
2
U.
S.
Geological
Survey
The
following
are
the
responses
to
the
questions
asked
by
EPA.
I
obtained
this
information
from
the
USGS
Internet
site
and
from
a
discussion
with
one
USGS
employee.
The
address
for
the
Internet
site
is
included
in
the
response
to
question
#
1.
I
believe
that
all
of
the
information
that
you
need
is
contained
on
the
Internet
but
I
cut­
and­
pasted
the
answers
to
your
specific
questions
below.
I
have
put
the
information
that
has
come
directly
from
the
USGS
site
in
quotes.

Through
this
process,
I
have
learned
that
the
USGS
Mineral
Industry
Surveys
and
the
USGS
Mineral
Commodity
Summaries
are
both
based
on
the
survey
form
that
is
located
on
the
Internet.
The
main
differences
between
these
two
documents
are
that
the
industry
survey
data
comes
out
on
a
monthly
basis
and
is
mineral
specific
while
the
commodity
summaries
are
annual
reports
with
summary
information
on
the
entire
list
of
chemicals
and
minerals
that
was
included
in
Attached
1
of
Supplemental
Analysis
#
3.

2.
What
does
the
USGS
minerals
survey
form
look
like?

Go
to
http://
minerals.
usgs.
gov/
minerals/
pubs/
commodity/
survey_
methods/
,
click
on
the
link
to
the
survey
methods
for
1998.
See
page
four
of
the
attached
file.
It
is
an
example
form
for
rolled
zinc.
I
expect
that
other
forms
are
similar.

3.
How
are
facilities
that
will
receive
the
survey
identified?

"
After
the
survey
form
has
been
designed,
a
list
of
the
appropriate
establishments
to
be
canvassed
is
developed.
Many
sources
are
used
to
determine
which
companies,
mines,
plants,
and
other
operations
should
be
included
on
the
survey
mailing
list.
State
geologists,
Federal
organizations
(
e.
g.,
Mine
Safety
and
Health
Administration),
trade
associations,
industry
representatives,
and
trade
publications
and
directories
are
some
of
the
sources
that
are
used
to
develop
and
update
survey
listings.
With
few
exceptions,
a
complete
canvass
of
the
list
of
establishments
is
used
rather
than
a
sample
survey.
The
iron
and
steel
scrap
industry
is
one
of
the
exceptions
where
a
sample
survey
is
conducted."

"
The
USGS
surveys
approximately
18,000
establishments.
Each
year,
the
USGS
mails
about
40,000
forms
for
141
different
surveys."

4.
Are
facilities
required
to
complete
the
survey?
What
happens
if
they
don't?

As
stated
in
the
fine
print
at
the
top
of
the
sample
survey
form,
"
the
USGS
relies
on
your
voluntary
and
timely
response...."
Therefore
it
appears
that
response
by
a
specific
date
is
not
required.
Procedures
that
the
USGS
uses
to
get
data
are
as
follows
­
10­
"
To
produce
reliable
aggregated
data,
the
USGS
uses
efficient
procedures
for
handling
instances
of
nonresponse.
Failure
to
return
the
initial
survey
form
results
in
a
second
mailing
of
the
form.
If
the
second
form
is
not
returned,
then
telephone
calls
are
made
to
the
nonrespondents.
The
follow­
up
calls
provide
the
necessary
data
to
complete
the
survey
forms
and/
or
to
verify
questionable
data
entries.
Periodic
visits
to
minerals
establishments
also
are
made
by
USGS
mineral
commodity
specialists
to
gather
missing
data
and
to
explain
the
importance
of
the
establishment's
reporting.
By
describing
the
use
of
the
published
statistics
and
showing
the
impact
of
nonresponse,
the
USGS
strives
to
encourage
respondents
to
give
a
complete
and
accurate
reply."

"
The
OMB
publication
"
Guidelines
for
Reducing
Reporting
Burden"
stipulates
that
the
minimum
acceptable
response
rate
shall
be
75%
of
the
panel
surveyed.
In
addition,
the
USGS
strives
for
a
minimum
reporting
level
of
75%
of
the
quantity
produced
or
consumed
(
depending
on
the
survey)
for
certain
key
statistics.
Response
rates
are
periodically
reviewed.
For
those
surveys
not
meeting
the
minimum
reporting
level,
procedures
are
developed
and
implemented
to
improve
response
rates."

5.
Does
the
form
require
a
certifying
signature
to
ensure
accuracy
of
the
data?

The
form
has
a
line
at
the
bottom
for
the
signature
of
a
contact
person
at
the
facility.
There
is
no
wording
next
to
this
block
that
implies
that
a
signature
indicates
that
the
information
is
accurate.
In
the
fine
print
at
the
top
of
the
form
it
states
that
"
the
USGS
relies
on
your
response
to
assure
that
its
information
is
complete
and
accurate."
The
USGS
conducts
extensive
QA
on
the
data
as
described
in
the
following
paragraphs.

"
Each
completed
survey
form
returned
to
the
USGS
undergoes
extensive
analysis
to
ensure
the
highest
possible
accuracy
of
the
mineral
data.
The
statistical
staff
monitors
all
surveys
to
ensure
that
errors
are
not
created
by
reporting
in
physical
units
different
from
the
units
requested
on
the
form.
Relations
between
related
measures,
such
as
produced
crude
ore
and
marketable
crude
ore,
are
analyzed
for
consistency.
Engineering
relations,
such
as
recovery
factors
from
ores
and
concentrates,
also
are
used.
The
totals
for
each
form
are
verified,
and
currently
reported
data
are
checked
against
prior
reports
to
detect
possible
errors
or
omissions."

"
For
the
majority
of
the
surveys,
which
are
automated,
the
forms
are
reviewed
to
ensure
that
data
are
complete
and
correct
before
entering
into
the
computer.
The
computer
is
programmed
to
conduct
a
series
of
automated
checks
to
verify
mathematical
consistency
and
to
identify
discrepancies
between
the
data
reported
and
logically
acceptable
responses."

6.
Is
the
reported
data
considered
CBI
and
therefore
not
available
to
the
public
or
other
government
agencies?
­
11­
The
data
submitted
by
the
forms
is
treated
as
confidential
unless
the
reporting
facility
gives
permission
for
it
to
be
disclosed.
The
USGS
was
contacted
to
discuss
this
issue
and
to
see
if
arrangements
could
be
made
to
share
the
data
with
other
firms
or
government
agencies.
I
spoke
with
Gail
James
(
703­
648­
4915).
She
stated
that
she
thought
that
arrangements
had
been
made
in
the
past
for
information
sharing.
Her
supervisor
is
Kenneth
Mlynarski
(
703­
648­
4919)
and
should
be
the
one
contacted
for
more
information.

"
The
USGS
relies
on
the
cooperation
of
the
U.
S.
minerals
industry
to
provide
the
mineral
data
that
are
presented
in
this
and
other
USGS
publications.
Without
a
strong
response
to
survey
requests,
the
USGS
would
not
be
able
to
present
reliable
statistics.
The
USGS,
in
turn,
respects
the
proprietary
nature
of
the
data
received
from
the
individual
companies
and
establishments.
To
ensure
that
proprietary
rights
will
not
be
violated,
the
USGS
analyzes
each
of
the
aggregated
statistics
to
determine
if
the
data
reported
by
an
individual
establishment
can
be
deduced
from
the
aggregated
statistics.
If,
for
example,
only
two
significant
producers
of
a
commodity
are
in
a
given
State,
then
the
USGS
will
not
publish
the
State
total
because
either
producer
could
readily
estimate
the
production
of
the
other.
It
is
this
obligation
to
protect
proprietary
information
that
results
in
the
withheld,
or
W,
entries
in
the
published
tables.
If
a
company
gives
permission
in
writing,
however,
then
the
USGS
will
publish
the
data
as
long
as
the
data
from
other
respondents
are
protected
from
disclosure."
