DRAFT:
Appendix
G
Case
Studies
G­
1
Appendix
G
Case
Studies
INTRODUCTION
This
Appendix
presents
seven
hypothetical
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
identifies
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
completed
for
Case
Study
A
only.
Parts
II
and
III
of
Form
U
were
completed
for
all
cases,
as
necessary.

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
4.6.3
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
4.6.4
and
Case
Study
B
of
this
document
provide
additional
guidance
for
reporting
this
information.
DRAFT:
Appendix
G
Case
Studies
G­
2
3.
What
if
my
site
exports
the
entire
volume
of
the
manufactured
chemical?
If
you
manufacture
an
IUR­
reportable
chemical
substance
solely
for
export,
you
are
required
to
report
and
otherwise
comply
with
all
IUR
requirements
for
Parts
I
and
II
of
Form
U.
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
4.6.4
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
4.6.7
and
4.7.1.6
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
before
it
is
reacted
on­
site
to
produce
a
different
chemical
substance.
Section
4.6.8
of
this
document
provides
guidance
for
reporting
this
information.
Case
Study
A
illustrates
how
to
complete
Block
2.8
in
Part
II,
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
4.6.9
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
4.7.1
and
Case
Studies
F
and
G
provide
DRAFT:
Appendix
G
Case
Studies
G­
3
additional
guidance.

9.
What
if
my
percent
production
volume
is
less
than
5%
for
a
process/
use,
NAICS,
and
IFC
code
combination
and
the
total
production
volume
is
less
than
300,000
pounds?
As
discussed
in
Section
4.7.1.4
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
how
to
report
this
information.

10.
What
if
my
percent
production
volume
is
less
than
5%
for
a
process/
use,
NAICS,
and
IFC
code
combination
but
the
total
production
volume
is
greater
than
300,000
pounds?
As
discussed
in
Section
4.7.1.4
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
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
4.7.1.4,
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
4.7.2.1
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
4.7.2.2
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
2.2.3
of
this
document
states
that
impurities,
byproducts,
and
non­
isolated
intermediates
are
exempt
from
reporting.
However,
reporting
the
manufacture
of
an
DRAFT:
Appendix
G
Case
Studies
G­
4
isolated
intermediate
is
required.
Case
Study
A
provides
a
possible
scenario
for
reporting
an
isolated
intermediate.
Additional
examples
are
available
in
section
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?
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
2.3.2.2
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
"
partially
exempt
chemical
substance."
DRAFT:
Appendix
G
Case
Studies
G­
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
Monomer
#
1
(
Accession
#
99999)
at
the
Big
Lot
site.
Monomer
#
1
is
used
for
the
manufacture
of
a
polyamide
and
is
sitelimited
meaning
it
is
only
used
at
the
Big
Lot
site.
Monomer
#
1
is
produced
as
part
of
a
liquid
solution
at
89.6%
concentration
and
transferred
to
an
on­
site
storage
tank
for
future
use.
Monomer
#
1
is
subsequently
consumed
during
the
reaction
to
produce
the
polyamide.
Twelve
workers
are
exposed
during
the
manufacture
of
Monomer#
1
during
sampling
and
equipment
cleaning.
Two
additional
workers
transfer
Monomer
#
1
from
the
storage
tank
to
the
reactor
that
produces
the
polyamide.
Four
administrative
workers
are
on­
site
but
not
directly
involved
with
the
manufacture
of
any
chemicals.

John
Doe
is
the
plant
manager
for
the
Company
A's
Big
Lot
site.
The
mailing
address
for
this
site
is
100
John
Doe
Highway,
Richmond,
VA
23222.
The
Dun
&
Bradstreet
number
for
the
site
is
099999999.
The
mailing
address
for
Company
A's
headquarters
is
100
First
Street,
Suite
100,
New
York,
NY
10001.
The
Dun
&
Bradstreet
number
for
this
office
is
999999999.

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

Completing
the
Form:
Part
II.
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Chemical
ID
Number
99999
Accession
number.

1.2
ID
Code
A
Code
for
accession
number.

1.3
Chemical
Name
Monomer
#
1
Chemical
Abstracts
Index/
Preferred
name.
Note:
if
this
were
a
real
chemical,
the
chemical
name
should
be
reported.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
G­
6
2.3
Site
limited
Y
Monomer
#
1
is
site
limited
because
it
is
not
imported
and
it
never
leaves
the
site
because
it
is
destroyed
during
the
reaction
to
produce
polyamide.

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

2.5
Production
Volume
(
lbs)
1,100,000
Amount
manufactured.

2.7
Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
A
estimates
12
exposed
workers
from
sampling
and
equipment
cleaning
during
manufacture
of
Monomer
#
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
PC
Processing
as
a
reactant.

NAICS
32619
Other
plastics
product
manufacturing.

IFC
U16
Intermediate.

Percent
PV
100
100%
of
the
PV
is
used
as
an
intermediate.

Number
of
Sites
S1
Fewer
than
10.
Only
one
site
uses
this
chemical.

Number
of
Workers
W1
Fewer
than
10.
Company
A
estimates
2
workers
are
exposed
during
transfer
operations
during
the
reaction
that
produces
polyamide.

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
polyamide
and
therefore
never
leaves
this
site
for
further
processing
or
use.
DRAFT:
Appendix
G
Case
Studies
G­
7
Report
Number
Mark
"
X"
here
if
this
is
a
revision
to
the
previous
report
Previous
Report
Number
Form
U
­
CASE
STUDY
A
PAGE
1
of
2
(
IMPORTANT:
Type
only,
read
instructions
before
completing
form)

U.
S.
Environmental
Protection
Agency
Washington,
DC
20460
Partial
Updating
of
TSCA
Inventory
Data
Base
Production
and
Site
Report
(
Section
8(
a)
Toxic
Substances
Control
Act,
15
U.
S.
C.
2607)

PART
I.
SITE
IDENTIFICATION
INFORMATION
SECTION
I.
CERTIFICATION
Certification
Statement:
I
hereby
certify
to
the
best
of
my
knowledge
and
belief
that
(
1)
all
information
entered
on
this
form
is
complete
and
accurate;
and
(
2)
the
confidentiality
statements
at
the
end
of
this
form
are
true
and
correct
as
to
that
information
for
which
I
have
asserted
a
confidentiality
claim.

1.1
Signature
1.2
Date
signed
1.3
Name
John
Doe
1.4
Official
Title
Plant
Manager
SECTION
II.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION
2.1
Parent
Company
Name
Company
A,
Inc.

2.2
Parent
Company
Dun
&
Bradstreet
Number
999999999
2.3
Technical
Contact
Name
John
Doe
2.4
Technical
Contact
Telephone
(
w/
Area
Code)
555­
555­
5555
2.5
Technical
Contact
Email
Address
john.
doe@
companya.
com
Technical
Contact
Mailing
Address
2.6
Technical
Contact
Address
(
Line1)
100
First
Street
2.7
Technical
Contact
Address
(
Line
2)
Suite
100
2.8
City
New
York
2.9
State
NY
2.10
Zip
Code
10001
SECTION
III.
PLANT
SITE
IDENTIFICATION
3.1
Plant
Site
Name
Company
A,
Inc.

3.2
Plant
Site
Dun
&
Bradstreet
Number
099999999
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)
LEAVE
BLANK
3.3
Street
Address
(
Line
1)
100
John
Doe
Highway
3.4
Street
Address
(
Line
2)

3.5
City
Richmond
3.6
County/
Parish
Chesterfield
3.7
State
VA
3.8
Zip
Code
23222
FORM
U
2006
DRAFT:
Appendix
G
Case
Studies
G­
8
EPA
Form
Number
<
XXXX­
X>
(
Rev
7/
11/
02)
­
Previous
editions
are
obsolete
Form
Approved
OMG
Number
:
XX/
X­
XXXX
DRAFT:
Appendix
G
Case
Studies
G­
9
Form
U
­
CASE
STUDY
A
(
continued)
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
99999
1.2
ID
Code
A
1.3
Chemical
Name
Monomer
#
1
SECTION
II.
MANUFACTURING
INFORMATION
2.1
Company
Information
CBI
2.2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.3
Site
Limited
(
Y/
N)
Y
CBI
2.9
Dry
Powder
2.4
Activity
(
M,
I
or
both)
M
CBI
2.10
Pellets
or
Large
Crystals
2.5
Production
Volume
(
LB)
1,100,000
CBI
2.11
Water
or
Solvent
Wet
Solid
2.6
Production
Volume
Range
CBI
2.12
Other
Solid
2.7
Number
of
Workers
(
code)
W2
CBI
2.13
Gas
or
Vapor
2.8
Maximum
Concentration
(
code)
M4
CBI
2.14
Liquid

100
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II,
Block
2.5
is
greater
than
or
equal
to
3,000,000
lb/
year
SECTION
I.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
1.1
PC
32619
U16
100
S1
W1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10
SECTION
II.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A

a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
REPORT
NUMBER
DRAFT:
Appendix
G
Case
Studies
G­
10
CASE
STUDY
B
This
example
illustrates
how
to
report:
°
a
chemical
substance
that
is
imported
only;
°
TSCA­
exempt
uses
(
cosmetic
lotions).

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.
Company
B
employs
15
workers
to
incorporate
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.
100,000
pounds
of
IPA
is
used
in
soaps
and
cleaners.
The
remaining
100,000
pounds
is
incorporated
into
cosmetic
lotions.
The
soap
and
lotion
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
cosmetic
lotions
is
exempt
from
TSCA
reporting
because
it
is
regulated
by
the
Food
and
Drug
Administration
(
FDA),
but
the
manufacture
and
processing
of
these
products
is
not
exempt.
Therefore,
the
consumer
use
of
cosmetic
lotions
is
not
required
in
Part
III
of
Form
U.
DRAFT:
Appendix
G
Case
Studies
G­
11
400,000
lbs.
of
IPA
is
imported
to
Company
B
at
95%
concentration
200,000
lbs.
IPA
sold
as
industrial
solvents
and
cleaners.
(
Block
1.2)

200,000
lbs.
IPA
sold
as
soaps
and
skin
cleaners
100,000
lbs.
IPA
used
commercially
(
Block
2.1)
100,000
lbs.
IPA
used
by
consumers
(
Exempt)
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
COMMERICAL
AND
CONSUMER
END
USE
Company
B
incorporates
the
IPA
into
liquid
formulations
and
solutions
at
concentrations
of
10­
50%.
(
Block
1.1)
CASE
STUDY
B
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
G­
12
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/
Preferred
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
(
lbs)
400,000
Amount
of
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
pertinent
to
this
assessment.

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
Block
Block
Title
Report
Basis/
Rationale
1.1
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U28
Solvent
(
which
becomes
part
of
product
formulation
or
mixture).

Percent
PV
100
All
of
the
production
volume
is
formulated
into
a
mixture.

Number
of
Sites
S1
Less
than
10
sites.
Company
B
imports
IPA
to
a
single
site.

Number
of
Workers
W2
At
least
10
but
fewer
than
25.
Company
B
employs
15
workers
to
formulate
the
IPA.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
G­
13
1.2
Type
of
Process
or
Use
U
Use
as
an
industrial
solvent
and
cleaner.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U27
Solvents
for
cleaning
and
degreasing.

Percent
PV
50
Half
of
the
production
volume
(
200,000
lbs.)
is
used
in
industrial
solvents.

Number
of
Sites
S5
From
251
to
1,000.
Company
B
estimates
hundreds
of
sites.

Number
of
Workers
W7
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
C16
Soaps
and
detergents.

Use
in
Children's
Product
Y
Some
soaps
and
detergents
may
be
used
by
children.

Percent
PV
30
Of
the
400,000
lbs
imported,
100,000
lbs
(
25%)
is
used
in
soaps
and
detergents.

Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
used
in
formulations
is
50%.
DRAFT:
Appendix
G
Case
Studies
G­
14
Form
U
­
CASE
STUDY
B
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
67­
63­
0
1.2
ID
Code
C
1.3
Chemical
Name
2­
Propanol
SECTION
II.
MANUFACTURING
INFORMATION
2.1
Company
Information
CBI
2.2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.3
Site
Limited
(
Y/
N)
N
CBI
2.9
Dry
Powder
2.4
Activity
(
M,
I
or
both)
I
CBI
2.10
Pellets
or
Large
Crystals
2.5
Production
Volume
(
LB)
400,000
CBI
2.11
Water
or
Solvent
Wet
Solid
2.6
Production
Volume
Range
CBI
2.12
Other
Solid
2.7
Number
of
Workers
(
code)
W1
CBI
2.13
Gas
or
Vapor
2.8
Maximum
Concentration
(
code)
M3
CBI
2.14
Liquid

100
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II,
Block
2.5
is
greater
than
or
equal
to
3,000,000
lb/
year
SECTION
I.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
1.1
PF
32519
U28
100
S1
W2
1.2
U
32519
U27
50
S5
W7
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10
SECTION
II.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
2.1
C16
Y
30
M3
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
REPORT
NUMBER
DRAFT:
Appendix
G
Case
Studies
G­
15
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,
all
manufacturing
operations
occur
in
closed
systems
with
engineering
controls
to
minimize
releases
and
worker
exposures.
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/
Preferred
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
(
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.
DRAFT:
Appendix
G
Case
Studies
G­
16
Form
U
­
CASE
STUDY
C
Page
___
of
___

PART
II.
MANUFACTURING
INFORMATION
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
110­
82­
7
1.2
ID
Code
C
1.3
Chemical
Name
Cyclohexane
SECTION
II.
MANUFACTURING
INFORMATION
2.1
Company
Information
CBI
2.2
Plant
Site
Identity*
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.3
Site
Limited
(
Y/
N)
N
CBI
2.9
Dry
Powder
2.4
Activity
(
M,
I
or
both)
M
CBI
2.10
Pellets
or
Large
Crystals
2.5
Production
Volume
(
LB)
400,000
CBI
2.11
Water
or
Solvent
Wet
Solid
2.6
Production
Volume
Range
CBI
2.12
Other
Solid
2.7
Number
of
Workers
(
code)
W1
CBI
2.13
Gas
or
Vapor
2.8
Maximum
Concentration
(
code)
M4
CBI
2.14
Liquid

100
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II,
Block
2.5
is
greater
than
or
equal
to
3,000,000
lb/
year
SECTION
I.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A

a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10
SECTION
II.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A

a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
*
Substantiation
required
for
CBI
claims
on
chemical
identity
and
plant
site
identity.
REPORT
NUMBER
DRAFT:
Appendix
G
Case
Studies
G­
17
