CASE
STUDY
D
This
example
illustrates
how
to
report:
1.
a
hydrate
of
a
chemical
substance;
2.
inorganic
chemical
substances
(
partial
exemption
for
2006
reporting
year);
3.
TSCA­
exempt
use
(
as
a
pesticide).

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

Key
Points:
This
material
is
a
hydrate,
therefore
only
the
weight
fraction
of
the
non­
hydrated
form
of
copper
sulfate
(
CuSO
4)
(
CAS#
7758­
98­
7)
should
be
reported.
To
determine
the
weight
fraction,
multiply
the
production
volume
of
the
copper
sulfate
pentahydrate
by
the
molecular
weight
of
copper
sulfate
(
CuSO
4)
divided
by
the
molecular
weight
of
the
copper
sulfate
pentrahydrate
(
CuSO
4
·
5H
2
O).
The
molecular
weight
of
CuSO
4
is
159.6
lbs/
lb
·
mole
and
the
molecular
weight
of
CuSO
4
·
5H
2
O
is
249.7
lbs/
lb
·
mole.
Calculation:

800,000
lbs
CuSO
4
5H
2
O
yr
159.6
lbs
/
lb
mole
CuSO
4
249.7
lbs
/
lb
mole
CuSO
4
5H
2
O
511,386
lbs
CuSO
4
/
yr
 
×
 

 
 
=

The
manufacture
and
use
of
pesticides
is
exempt
from
TSCA­
regulations,
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.
Company
D
produces
800,000
lbs.
of
copper
sulfate
pentahydrate
crystals
(
511,386
lbs.
CuSO4)
at
93%
purity
560,000
lbs.
of
copper
sulfate
pentahydrate
(
357,970
lbs.
CuSO4)
is
used
for
metal
electroplating.
240,000
lbs.
of
copper
sulfate
pentahydrate
(
153,416
lbs.
CuSO4)
is
used
as
a
pesticide.
(
Exempt)
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
CASE
STUDY
D
­
Flow
Diagram
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/
Preferred
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
(
lbs)
357,970
Calculated
amount
of
anhydrous
copper
sulfate
produced
for
non­
pesticidal
uses.
511,386
lbs
x
70%
PV
=
357,970
lbs.

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
4.
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.

Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
5.
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
DRAFT:
Appendix
G
Case
Studies
Form
U
­
CASE
STUDY
D
Page
___
of
___

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

1.1
Chemical
Identifying
Number
7758­
98­
7
1.2
ID
Code
C
1.3
Chemical
Name
Copper
(
II)
Sulfate
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

100
2.5
Production
Volume
(
LB)
357,970
CBI
2.11
Water
or
Solvent
Wet
Solid
2.6
Production
Volume
Range
CBI
2.12
Other
Solid
2.7
Number
of
Workers
(
code)
W4
CBI
2.13
Gas
or
Vapor
2.8
Maximum
Concentration
(
code)
M5
CBI
2.14
Liquid
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
CASE
STUDY
E
This
example
illustrates
how
to
report:
6.
a
chemical
listed
on
the
"
partially
exempt
chemical
substances"
list.

Scenario:
Company
E
produces
500,000
lbs/
yr
of
a
benzene,
mono­
C14­
16­
alkyl
derivs.
(
129813­
60­
1)
liquid
solution
at
concentrations
up
to
95%.
Company
E
distributes
500,000
lbs
to
twelve
companies
for
formulation
into
laundry
detergents.
These
detergents
are
intended
for
use
by
approximately
200
commercial
companies.
Company
E
has
two
production
lines
on
this
site
that
produce
benzene,
mono­
C14­
16­
alkyl
derivs.
Each
line
employs
20
workers
to
operate
and
maintain
equipment
during
manufacturing
operations,
including
sampling,
handling,
and
equipment
cleaning.

Key
Points:
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
partially
exempt
from
reporting
(
see
40
CFR
710.46(
b)(
2)(
iv)
and
Appendix
E),
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
129813­
60­
1
CAS
Number
1.2
ID
Code
C
Code
for
CAS
Number
1.3
Chemical
Name
Benzene,
mono­
C14­
16­
alkyl
derivs.
Chemical
Abstracts
Index/
Preferred
name
2.3
Site
limited
N
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
distributed
off­
site.

2.4
Activity
M
Benzene,
mono­
C14­
16­
alkyl
derivs.
is
manufactured
and
not
imported.

2.5
Production
Volume
(
lbs)
500,000
Reported
to
amount
reasonably
obtainable.

2.7
Number
of
Workers
W2
At
least
25
but
fewer
than
50.
Company
E
estimates
40
workers
exposed
(
20
workers
per
line
x
2
lines
=
40
workers).

2.8
Maximum
Concentration
M5
Greater
than
90%
by
weight.
The
maximum
concentration
leaving
the
site
is
95%.

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
7.
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
DRAFT:
Appendix
G
Case
Studies
Part
III
­
Section
II.
Commercial
and
Consumer
End­
Use
Exposure
Related
Data
8.
Check
the
"
N/
A"
box
in
the
upper
right­
hand
corner.
DRAFT:
Appendix
G
Case
Studies
Form
U
­
CASE
STUDY
E
Page
___
of
___

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

1.1
Chemical
Identifying
Number
129813­
60­
1
1.2
ID
Code
C
1.3
Chemical
Name
Benzene,
Mono­
C14­
16­
Alkyl
Derivs.

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)
500,000
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)
M5
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
CASE
STUDY
F
This
example
illustrates
how
to
report:
9.
when
two
different
physical
forms
are
manufactured;
10.
the
use
in
a
children's
product;
11.
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
pellets
at
less
than
1%
concentration.
These
pellets
are
then
molded
into
plastic
articles
which
are
sold
to
consumers.
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.
DRAFT:
Appendix
G
Case
Studies
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%.
(
Block
1.2)
300,000
lbs.
of
CI
Pigment
Yellow
100
sold
to
6
sites
that
incorporate
it
into
plastic
pellets.

(
Block
1.1)

300,000
lbs.
is
sold
directly
to
the
consumer
as
a
component
in
paint.
(
Block
2.2)
200,000
lbs.
is
sold
to
10
toy
manufacturers
for
painting
wooden
toys.
(
Block
2.3)
MANUFACTURING
COMMERICAL
AND
CONSUMER
END
USE
Company
F
produces
500,000
lbs.
of
powdered
CI
Pigment
Yellow
in
liquid
solution
at
1
­
30%
concentration.
Company
F
produces
300,000
lbs.
of
powdered
CI
Pigment
Yellow
100
at
100%
concentration.

Plastic
pellets
containing
CI
Pigment
Yellow
100
are
molded
into
articles.
(
Block
2.1)
INDUSTRIAL
PROCESSING
AND
USE
CASE
STUDY
F
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
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/
Preferred
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
(
lbs)
800,000
Reported
to
amount
reasonably
obtainable.

2.7
Number
of
Workers
W3
At
least
25
but
fewer
than
50.
Company
F
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
60%.
DRAFT:
Appendix
G
Case
Studies
Part
III
­
Section
I.
Industrial
Processing
and
Use
Information
Block
Block
Title
Report
Basis/
Rationale
1.1
Type
of
Process
or
Use
PA
Incorporation
into
an
article.
This
accounts
for
the
powder
form
being
incorporated
into
plastic
pellets.

NAICS
32619
Other
plastics
product
manufacturing.

IFC
U08
Coloring
agents,
pigments.

Percent
PV
40
37.5%
of
the
production
volume
is
used
for
this
use.
Round
up
to
40%.

Number
of
Sites
S1
Less
than
10.
Company
F
has
6
customer
sites.

Number
of
Workers
W3
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
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32551
Paint
and
coating
manufacturing.

IFC
U08
Coloring
agents,
pigments.

Percent
PV
60
62.5%
of
the
production
volume
is
used
for
this
use.
Round
down
to
60%.

Number
of
Sites
S3
From
26
to
100.
Company
F
estimates
50
paint
manufacturers
use
their
product.

Number
of
Workers
W5
At
least
100
but
fewer
than
500.
Company
F
estimates
5
exposed
workers
per
site
for
50
processing
sites
=
250
of
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
C15
Rubber
and
plastics
products.

Use
in
Children's
Product
?
Information
not
readily
obtainable.

Percent
PV
40
40%
of
C.
I.
Pigment
Yellow
100
manufactured
by
Company
F
is
used
in
polymers/
plastics.

Maximum
Concentration
M1
Less
than
1%
by
weight.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
2.2
Commercial
and
Consumer
Product
Category
C12
Paints
and
coatings.

Use
in
Children's
Product
N
Paints
sold
directly
to
consumer
are
not
expected
to
be
used
by
children.

Percent
PV
40
37.5%
of
C.
I.
Pigment
Yellow
100
manufactured
by
Company
F
is
used
in
paint.
Round
up
to
40%.

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.

2.3
Commercial
and
Consumer
Product
Category
C18
Wood
and
wood
furniture.

Use
in
Children's
Product
Y
Wooden
toys
are
expected
to
be
used
by
children.

Percent
PV
30
25%
of
PV
(
200,000
lbs.)
is
used
in
paint
for
wooden
toys.
Round
up
to
30%.

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
30%.
DRAFT:
Appendix
G
Case
Studies
Form
U
­
CASE
STUDY
F
Page
___
of
___

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

1.1
Chemical
Identifying
Number
12225­
21­
7
1.2
ID
Code
C
1.3
Chemical
Name
C.
I.
Pigment
Yellow
100
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

40
2.4
Activity
(
M,
I
or
both)
M
CBI
2.10
Pellets
or
Large
Crystals
2.5
Production
Volume
(
LB)
800,000
CBI
2.11
Water
or
Solvent
Wet
Solid
2.6
Production
Volume
Range
CBI
2.12
Other
Solid
2.7
Number
of
Workers
(
code)
W3
CBI
2.13
Gas
or
Vapor
2.8
Maximum
Concentration
(
code)
M5
CBI
2.14
Liquid

60
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
PA
32619
U08
40
51
W3
1.2
PF
32551
U08
60
53
W5
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
C15
?
40
M1
2.2
C12
N
40
M2
2.3
C18
Y
30
M2
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
CASE
STUDY
G
This
example
illustrates
how
to
report:
12.
a
chemical
substance
that
is
both
manufactured
and
imported
at
the
same
site;
13.
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%;
°
TSCA­
exempt
use
(
as
a
pesticide)

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
formulation
of
products.
The
distributors
formulate
4,000,000
pounds
of
xylene
and
sell
it
as
a
metal
degreaser
at
95%
concentration
to
200
hardware
manufacturers.
The
formulator
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.)
which
are
then
sold
for
commercial
and
consumer
applications.
2,200,000
pounds
is
formulated
into
pesticides
(
10%
max
conc.)
which
is
then
sold
for
commercial
use.
400,000
pounds
is
sold
for
formulation
of
a
wood
preservative
(
20%
conc.)
to
be
used
on
furniture
for
residential
use.
200,000
pounds
is
sold
as
a
component
of
solvents
on
the
consumer
market
(
95%
max
conc.).

Key
Points:
Pesticides
are
exempt
from
regulation
under
TSCA,
therefore
the
use
of
xylene
for
the
preparation
of
a
commercial
pesticide
formulation
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.
DRAFT:
Appendix
G
Case
Studies
19,000,000
lbs.
xylene
produced
by
Company
A
at
100%
concentration
16,000,000
lbs.
shipped
to
15
different
formulators
for
formulation
and
packaging
at
0.5%
­
95%.
(
Block
1.2)
4,000,000
lbs.
shipped
directly
to
3
chemical
manufactures
at
100%
concentration
for
use
as
a
chemical
reactant.
(
Block
1.1)

Paint
sold
for
commercial
and
consumer
applications.
(
Block
2.2)
Pesticides
sold
for
commercial
and
consumer
applications.
(
Exempt)
MANUFACTURING
INDUSTRIAL
PROCESSING
AND
USE
COMMERICAL
AND
CONSUMER
END
USE
1,000,000
lbs.
xylene
imported
by
Company
A
at
100%
concentration
4,000,000
lbs.
used
at
95%
concentration
as
a
metal
degreaser
at
200
hardware
manufacturers.
(
Block
1.3)

400,000
lbs.
sold
as
a
component
in
wood
preservatives
at
20%
maximum
concentration.
(
Block
1.5)
2,200,000
lbs.
reformulated
into
pesticides
at
10%
concentration.

(
Exempt)

3,200,000
lbs.
reformulated
into
paint
15%
maximum
concentration.
(
Block
1.4)

6,000,000
lbs.
used
as
a
component
in
automotive
care
products
at
35%
maximum
concentration.
(
Block
2.1)
200,000
lbs.
used
as
a
component
of
solvents
sold
to
consumers
at
95%
maximum
concentration.
(
Exempt:
Less
than
300,000
lbs.
and
5%
PV)
Company
A
reports
20,000,000
lb.
manufactured
at
100%
concentration.

Applied
to
residential
furniture.

(
Block
2.3)
CASE
STUDY
G
­
Flow
Diagram
DRAFT:
Appendix
G
Case
Studies
Completing
the
Form:
Part
II
­
Manufacturing
Information
Block
Block
Title
Report
Basis/
Rationale
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/
Preferred
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
(
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.
DRAFT:
Appendix
G
Case
Studies
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
32519
Other
basic
organic
chemical
manufacturing.

IFC
U16
Intermediates.

Percent
PV
20
20%
PV
(
4,000,000
lbs)
is
distributed
directly
to
3
chemical
manufacturers.
4,000,000
lbs.
/
20,000,000
lbs.
total
=
20%.

Number
of
Sites
S1
Less
than
10
sites.

Number
of
Workers
W2
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
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32519
Other
basic
organic
chemical
manufacturing.

IFC
U27
Solvents
(
for
cleaning
or
degreasing).

Percent
PV
80
80%
PV
(
16,000,000
lbs.)
is
repackaged.

Number
of
Sites
S2
From
10
to
25.
Company
G
distributes
xylene
to
15
distributor/
repackaging
centers.

Number
of
Workers
W4
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
U
Industrial
grade
solvent.
Used
as
a
metal
degreaser.

NAICS
33251
Hardware
manufacturing.

IFC
U27
Solvents
(
for
cleaning
or
degreasing).

Percent
PV
20
20%
PV
(
4,000,000
lbs)
is
distributed
from
distribution/
repackaging
centers
to
200
hardware
manufacturers
for
use
as
a
metal
degreaser.

Number
of
Sites
S4
From
101
to
250.
200
hardware
manufacturers
use
xylene
as
a
metal
degreaser.

Number
of
Workers
W6
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.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
1.4
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32551
Paint
and
coating
manufacturing.

IFC
U28
Solvents
(
which
become
part
of
product
formulation
or
mixture).

Percent
PV
20
16%
PV
of
xylene
(
3,200,000
lbs.)
is
used
in
paint
formulations.
Round
to
20%.

Number
of
Sites
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

Number
of
Workers
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

1.5
Type
of
Process
or
Use
PF
Incorporation
into
formulations
and
mixtures.

NAICS
32111
Sawmills
and
wood
preservation.

IFC
U28
Solvents
(
which
become
part
of
product
formulation
or
mixture).

Percent
PV
2
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.

Number
of
Sites
Company
G
has
determined
that
this
information
is
not
readily
obtainable.

Number
of
Workers
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
C03
Automotive
care
products.

Use
in
Children's
Product
N
Not
expected
to
be
used
by
children.

Percent
PV
30
30%
PV
(
6,000,000
lbs.)
is
used
in
the
formulation
of
automotive
care
products.

Maximum
Concentration
M3
From
31%
to
60%
by
weight.
The
maximum
concentration
used
in
formulations
is
35%.
DRAFT:
Appendix
G
Case
Studies
Block
Block
Title
Report
Basis/
Rationale
2.2
Commercial
and
Consumer
Product
Category
C12
Paints
and
coatings
(
commercial
use).

Use
in
Children's
Product
N
Not
expected
to
be
used
by
children.

Percent
PV
20
16%
PV
(
3,200,000
lbs.)
is
used
in
paints
for
commercial
use.
Round
up
to
20%.

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
15%.

2.3
Commercial
and
Consumer
Product
Category
C18
Wood
and
wood
furniture.

Use
in
Children's
Product
N
Not
expected
to
be
used
by
children.

Percent
PV
2
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%).

Maximum
Concentration
M2
From
1%
to
30%
by
weight.
The
maximum
concentration
used
in
formulations
is
20%.
DRAFT:
Appendix
G
Case
Studies
Form
U
­
CASE
STUDY
G
Page
___
of
___

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

1.1
Chemical
Identifying
Number
1330­
20­
7
1.2
ID
Code
C
1.3
Chemical
Name
Xylene,
Mixed
Isomers
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)
B
CBI
2.10
Pellets
or
Large
Crystals
2.5
Production
Volume
(
LB)
20,000,000
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)
M5
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
32519
U16
20
S1
W2
1.2
PF
32519
U27
80
S2
W4
1.3
U
33251
U27
20
S4
W6
1.4
PF
32551
U28
20
1.5
PF
32111
U28
2
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
C03
N
30
M3
2.2
C12
N
20
M2
2.3
C18
N
2
M2
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
