1
Instructions
for
Reporting
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database
Susan
Sharkey
Economics
and
Policy
Analysis
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
IUR
Public
Meeting
August
1,
2003
Washington,
DC
2
What
is
TSCA?


The
Toxic
Substances
Control
Act
(
TSCA)

became
effective
on
Jan
1,
1977;
it
gives
EPA
broad
authority
to:

°
gather
information
on
chemical
health,
safety,

and
exposure
°
require
testing,
and
°
control
exposure
based
on
"
unreasonable"

risks

for
the
over
76,000
industrial
or
commercial
chemicals
produced
or
imported
into
the
U.
S.
3
What
was
the
Inventory
Update
Rule
(
IUR)?
(
prior
to
2003
amendments)


Updated
TSCA
Chemical
Substances
Inventory
by
providing
a
"
snapshot"
of
organic
chemical
manufacturing
every
4
years

Collected
information
from:

°
Sites
manufacturing
or
importing
10,000
lbs/
yr
or
more
°
Exemptions
for
inorganic
chemicals,
polymers,
and
others

Collected
information
on:

°
Company
name,
facility
location,
D&
B
number
°
Chemical
name,
site
limited
status,

production
volume
4
What
is
the
IUR
now?

(
since
the
amendments)


Updates
TSCA
Chemical
Substances
Inventory
by
providing
a
"
snapshot"
of
chemical
manufacturing
every
4
years

Collects
information
from:

°
Sites
manufacturing
or
importing
25,000
lbs/
yr
or
more
(
includes
inorganic
chemicals)

°
Full
&
partial
exemptions

Collects
information
on:

°
Company
and
facility
identification
°
Chemical
identification,
site
limited
status,
production
volume
°
Manufacturing
exposure­
related
information
°
Processing
and
use
exposure­
related
information
5
Who
needs
to
report
under
the
IUR?


Chemical
manufacturers
and
importers
with:

°
Production
volume
of
25,000
lbs
or
greater
(
annual,
per
site)

report
site
and
manufacturing
data
°
Production
volume
of
300,000
lbs
or
greater
(
annual,
per
site)
report
processing
and
use
data

Inorganic
chemical
manufacturers
and
importers:

°
Partial
exemption
for
first
reporting
cycle,
and
only
report
site
and
manufacturing
data
°
After
first
reporting
cycle,
report
as
described
for
chemical
manufacturers
and
importers
above
6
Exemptions
to
Reporting

Full
exemptions
(
no
reporting
unless
otherwise
specified)

°
Small
businesses
(
as
defined
by
TSCA)

°
Total
annual
sales,
including
parent
company,
less
than
$
40
million
and
annual
site
production
volume
100,000
lbs
or
lower
OR
°
Total
annual
sales,
including
parent
company,
less
than
$
4
million.

°
Natural
gas
streams
(
specifically
identified)


Partial
exemptions
(
report
only
site
and
manufacturing
data)

°
Inorganic
chemicals
(
for
first
reporting
cycle
only)

°
Certain
petroleum
streams
(
specifically
identified)

°
Specifically
listed
chemical
substances
for
which
there
is
a
low
current
need
for
processing
and
use
information
7
What
manufacturing
data
is
reported?


Current
IUR
information
still
reported:

°
Chemical
name
°
Numerical
identification
°
Production
volume
°
Site
limited
status
°
Manufacturing
or
Import
activity

Exposure­
related
information
added:

°
Number
of
potentially
exposed
workers
(
range)

°
Physical
form,
w/
associated
percent
production
volume
°
Maximum
concentration
(
range)


Report
"
known
to
or
reasonably
ascertainable
by"

information
8
What
industrial
processing
and
use
data
is
reported?


Up
to
10
unique
combinations
of
°
Type
of
process
or
use
°
NAICS
code
°
Industrial
function
category
(
bleaching
agent,
filler,
lubricant,

etc)


For
each
unique
combination,
report
°
Percent
production
volume
(
range)

°
Number
of
sites
(
range)

°
Number
of
potentially
exposed
workers
(
range)


Report
"
readily
obtainable"
information
9
What
consumer
and
commercial
use
data
is
reported?


Use
category
(
automotive
care
product,
lawn
&
garden
product,
soaps
&
detergents,
etc)


For
each
use
category,
report:

°
Indication
of
intention
of
use
by
children
°
Maximum
chemical
concentration
°
Percent
of
production
volume

Report
"
readily
obtainable"
information
10
What
other
changes
were
made
by
the
amendments?


Modified
CBI
requirements
°
Added
ability
to
claim
production
volume
range
as
CBI
°
Added
upfront
substantiation
requirement
for
site
identity
claims

Adjusted
administrative
reporting
details
°
Changed
to
calendar
year
reporting
from
fiscal
year
reporting
°
Adjusted
recordkeeping
requirements
from
4
years
to
5
years

Modified
company
and
site
identifier
data
°
Added
county
of
the
plant
site
°
Added
technical
contact
email
address
11
Benefits
of
IUR
Exposure­
Related
Information

enabling
a
"
first
look"
at
a
chemical,
industry,
or
use
by
providing
needed
information
not
otherwise
available

enabling
a
more
effective
early
screening
of
chemicals
and
uses
to
identify
priorities
for
resources

allowing
the
Agency
to
be
proactive
rather
than
reactive
by
providing
information
needed
to
identify
trends
and
upcoming
issues
or
concerns

providing
a
starting
point
for
more
in­
depth
analyses
and
identifying
where
additional
information
may
be
needed

allowing
the
Agency
and
others
to
put
hazard
information
into
context,

such
as
information
collected
through
the
HPV
Challenge
and
similar
programs
Congress
has
charged
EPA
through
TSCA
with
protecting
human
health
and
the
environment
from
commercial
chemicals.
The
amended
IUR
collection
will
provide
basic
information
needed
to
fulfill
our
mandate
by
providing
a
starting
point
of
basic
exposure
information.

Benefits
include:
12
Chapter
2:
Reporting
Requirements
Chapter
3:
When
You
Must
Report
and
Fred
Arnold
Chemical
Engineering
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
IUR
Public
Meeting
August
1,
2003
Washington,
DC
13
Overview
of
Chapters
2
and
3

Reporting
requirements
°
Who
must
report?

°
What
chemicals
must
be
reported?

°
Determining
what
parts
of
Form
U
to
complete
°
Exemptions
°
Examples

When
to
report

Discussion
14
Determining
Reporting
Requirements
Is
the
substance
reportable?
Are
you
a
manufacturer
required
to
report?

CRITERIA
I
CRITERIA
II
15
CRITERIA
I
YES
YES
EVALUATE
CRITERIA
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
reportable?

Is
the
substance
exempt
from
reporting?

(
710.46a)
Is
the
substance
subject
to
a
special
action?(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
16
Is
the
substance
on
the
TSCA
Inventory?


Chemical
substances
reportable
under
IUR
must
appear
on
the
TSCA
Inventory
at
the
beginning
of
the
submission
period

Hydrates
are
not
listed
on
the
TSCA
Inventory.
You
must
report
for
the
corresponding
anhydrous
form
(
40
CFR
710.3)


See
2.1.1
for
additional
details
YES
YES
EVALUATE
CRITERIA
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
exempt
from
reporting?

(
710.46a)
Is
the
substance
subject
to
a
special
action?

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
17
What
is
the
TSCA
Inventory?


EPA
classifies
all
chemicals
as
"
existing"
or
"
new"


All
existing
chemicals
are
compiled
in
a
list
called
the
Toxic
Substances
Control
Act
Chemical
Substance
Inventory
or
TSCA
Inventory

Originally
compiled
in
1978
and
1979

EPA
adds
new
chemicals
to
the
Inventory
when
companies
submit
a
Notice
of
Commencement

~
75,000
chemicals
are
listed
18
Is
the
substance
exempt?


Polymers,
certain
natural
gas
streams,
microorganisms,
and
naturally
occurring
substances
are
largely
exempt
from
reporting.


Some
groups
of
chemicals
are
partially
exempt
from
reporting.


See
Section
2.1.2
for
additional
details.

YES
YES
EVALUATE
CRITERIA
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
exempt
from
reporting?

(
710.46a)
Is
the
substance
subject
to
a
special
action?

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
19
Is
the
substance
subject
to
a
special
action?


Polymers,
certain
natural
gas
streams,
and
microorganisms
are
not
exempt
when
they
are
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.


See
Section
2.1.3,
40
CFR
710.46,
and
Appendix
C
for
additional
details.
YES
YES
EVALUATE
CRITERIA
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
exempt
from
reporting?

(
710.46a)
Is
the
substance
subject
to
a
special
action?

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
20
YES
YES
EVALUATE
CRITERIA
II
YES
NO
NO
NO
Is
the
substance
exempt
from
reporting?

(
710.46a)
Is
the
substance
subject
to
a
special
action?

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)

Is
the
substance
reportable?

CRITERIA
I
YOU
DO
NOT
NEED
TO
REPORT
21
Do
you
qualify
as
a
small
manufacturer?

(
710.49)
Did
you
manufacture
25,000
pounds
or
more?

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

YES
YOU
MUST
REPORT
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
CRITERIA
II
Is
the
substance
subject
to
a
special
action?

(
710.46)

YES
NO
YES
22
Do
you
qualify
as
a
small
manufacturer?

(
710.49)
Did
you
manufacture
25,000
pounds
or
more?

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

YES
YOU
MUST
REPORT
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
subject
to
a
special
action?

(
710.46)

YES
NO
YES
Do
you
manufacture
in
quantities
over
25,000
pounds?


Only
report
a
chemical
substance
manufactured
and/
or
imported
25,000
pounds
or
more
at
any
single
site.


Report
the
substance
for
all
sites
at
which
you
manufactured
and/
or
imported
25,000
pounds
or
more.
23
Annual
Production
Volume
Threshold
Example
Green
Chemical
Company
Annual
Sales
$
50
Million
Pennsylvania
Site
21,000
pounds
propylene
manufactured
5,000
pounds
imported
New
York
Site
50,000
pounds
of
a
50%
acetylene
mixture
Which
sites
need
to
report?

BOTH
Both
sites
exceed
the
25,000
pound
threshold
24
Do
you
qualify
as
a
small
manufacturer?


Total
annual
sales
<
$
4
million
OR

Total
annual
sales
<
$
40
million
(
company
wide);
and
Production
volume
<
100,000
lbs.
(
for
a
chemical
substance
at
a
single
plant
site)

NOTE:
Small
manufacturers
are
still
required
to
report
on
substances
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA
(
710.46).

Do
you
qualify
as
a
small
manufacturer?

(
710.49)
Did
you
manufacture
25,000
pounds
or
more?

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

YES
YOU
MUST
REPORT
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
subject
to
a
special
action?

(
710.46)

YES
NO
YES
25
Small
Manufacturer
Exemption
Example
AAA
Chemical
Company
Annual
Sales
$
30
Million
New
Jersey
Site
200,000
pounds
xylene
Delaware
Site
75,000
pounds
xylene
Which
sites
need
to
report?

AAA
Chemical
Company
is
not
required
to
report
for
the
Delaware
site
since
annual
production
volume
did
not
exceed
100,000
pounds
and
total
annual
sales
were
less
than
$
40
million.

New
Jersey
Site
26
Is
the
substance
subject
to
a
special
action?


Substances
must
be
reported
if
they
are
subject
to
a
special
action.


See
Section
2.1.3,
40
CFR
710.46,
and
Appendix
C
for
additional
details.

Do
you
qualify
as
a
small
manufacturer?

(
710.49)
Did
you
manufacture
25,000
pounds
or
more?

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

YES
YOU
MUST
REPORT
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
subject
to
a
special
action?

(
710.46)

YES
NO
YES
27
Do
you
qualify
for
additional
exemptions?


If
you
manufacture
or
import
under
the
following
circumstances
you
are
not
required
to
report:

°
Substance
is
imported
as
an
article
(
710.50).

°
Substance
is
manufactured
as
an
impurity,
by­
product,
or
non­
isolated
intermediate
(
710.50,
720.30(
g)
and
(
h)).

°
All
IUR
information
was
submitted
in
response
to
another
TSCA
Section
8(
a)
rule
within
the
last
year
(
CFR
710.55).

Do
you
qualify
as
a
small
manufacturer?

(
710.49)
Did
you
manufacture
25,000
pounds
or
more?

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

YES
YOU
MUST
REPORT
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
subject
to
a
special
action?

(
710.46)

YES
NO
YES
28
What
information
do
you
need
to
report?
Part
III
Complete
for
all
reportable
substances.
Complete
if
you
produce
greater
than
300,000
pounds
per
year
except
for
the
following:

1)
Petroleum
process
streams
listed
in
40
CFR
710.46(
b)(
1).

2)
Specific
chemical
substances
listed
in
40
CFR
710.46(
b)(
2)(
iv)
and
in
Appendix
E.

3)
Inorganic
substances
as
defined
in
40
CFR
710.46(
b)(
3).

Parts
I
and
II
29
Reporting
Requirements
Example
What
does
this
company
submit?

CA
Site
­
No
report
required
AZ
Site
­
Parts
I
and
II
NM
Site
­
Parts
I,
II,
and
III
Zero
Pollution
Chemical
Company
Annual
Sales
$
50
Million
CA
Site
10,000
pounds
pigment
NM
Site
350,000
pounds
pigment
AZ
Site
30,000
pounds
pigment
30
CRITERIA
II
Do
you
qualify
as
a
small
manufacturer?

(
710.49)
Did
you
manufacture
25,000
pounds
or
more?

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

YES
YOU
MUST
REPORT
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
subject
to
a
special
action?

(
710.46)

YES
NO
YES
31
When
do
you
report?


Information
for
calendar
year
2005
must
be
submitted
to
EPA
during
the
submission
period
which
is
currently
from
August
25
to
December
23,
2006
(
40
CFR
710.53)


Information
must
be
submitted
for
all
chemicals
that
are
on
the
TSCA
Inventory
at
the
beginning
of
the
submission
period
(
currently
August
25,
2006),
which
are
otherwise
subject
to
reporting
(
40
CFR
710.45)
32
Summary

Form
U
must
be
submitted
if
°
The
chemical
is
on
the
TSCA
chemical
substance
inventory
°
Manufactured
or
imported
in
an
amount
greater
than
25,000
pounds

Exemptions
°
Polymers,
certain
natural
gas
streams,
microorganisms,

naturally
occurring
substances
°
Small
manufacturers
°
Substance
is
manufactured
as
an
impurity,
by­
product,
or
nonisolated
intermediate
°
Substance
is
imported
as
a
component
of
an
article
33
Summary

Information
that
must
be
reported
°
All
reportable
chemicals:
chemical
identification
(
Part
I)

and
manufacturing
information
(
Part
II)

°
Chemicals
produced
in
amounts
greater
than
300,000
lbs
at
a
single
site:
processing
and
use
information
(
Part
III)
34
Chapter
4:
Completing
Form
U
Franklyn
Hall
Chemical
Engineering
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
IUR
Public
Meeting
August
1,
2003
Washington,
DC
35
Overview
of
Chapter
4

General
requirements

Overview
of
completing
Form
U
°
Part
I
­
Company
Information
°
Part
II
­
Manufacturing
Information
°
Part
III
­
Processing
and
End
Use
Information

Discussion
36
General
Requirements

Separate
forms
are
required
for
each
plant
site
(
40
CFR
710.52)


If
you
are
reporting
for
more
than
one
chemical,
you
should
make
the
required
number
of
copies
of
Parts
II
and
III

Information
can
be
submitted
either
on
electronic
disk
(
not
email)
or
a
printed
version
of
Form
U
(
40
CFR
710.52)
37
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
1.4
Official
Title
Part
I,
Section
I:
Certification
Must
be
signed
by
an
authorized
official
of
your
company.
38
SECTION
II.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION
2.1
Parent
Company
Name
2.2
Parent
Company
Dun
&

Bradstreet
Number
2.3
Technical
Contact
Name
2.4
Technical
Contact
Telephone
(
w/
Area
Code)
2.5
Technical
Contact
Email
Address
Technical
Contact
Mailing
Address
2.6
Technical
Contact
Address
(
Line1)

2.7
Technical
Contact
Address
(
Line
2)

2.8
City
2.9
State
2.10
Zip
Code
Part
I,
Section
II:

Parent
Company
Information
Make
sure
you
enter
the
parent
company
Dun
&
Bradstreet
number.
39
Part
I,
Section
III:

Plant
Site
Identification
SECTION
III.
PLANT
SITE
IDENTIFICATION
3.1
Plant
Site
Name
3.2
Plant
Site
Dun
&

Bradstreet
Number
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)
LEAVE
BLANK
3.3
Street
Address
(
Line
1)

3.4
Street
Address
Line
2)

3.5
City
3.6
County/

Parish
3.7
State
3.8
Zip
Code
Make
sure
you
enter
the
plant
site
Dun
&
Bradstreet
number.

EPA
will
assign
a
facility
identification
number.
40
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
1.2
ID
Code
1.3
Chemical
Name
Part
II,
Section
I:

Chemical
Identification

If
you
are
reporting
information
for
more
than
one
chemical,
make
the
necessary
number
of
copies.

Use
Chemical
Abstracts
Index/
Preferred
names
if
available.
Trade
names
may
not
be
used
except
if
the
supplier
will
not
disclose
the
specific
identity
of
the
trade
name
reactant.
You
cannot
claim
CBI
for
a
substance
on
the
nonconfidential
Public
Inventory.

The
CAS
Registry
number
is
the
preferred
identifier.
41
Add
the
manufacture
and
import
volumes
together
and
report
the
total
volume.

You
cannot
report
an
imported
chemical
as
site­
limited.

EPA
will
assign
a
production
volume
range.
You
may
claim
the
range
CBI.

Part
II,
Section
II:

Manufacturing
Information
(
cont'd)

SECTION
II.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.1
Company
Information
2.2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.3
Site
Limited
(
Y/
N)
2.9
Dry
Powder
CBI
2.4
Activity
(
M,
I
or
both)
2.10
Pellets
or
Large
Crystals
CBI
2.5
Production
Volume
(
LB)
2.11
Water
or
Solvent
Wet
Solid
CBI
2.6
Production
Volume
Range
2.12
Other
Solid
CBI
2.7
Number
of
Workers
(
code)
2.13
Gas
or
Vapor
CBI
2.8
Maximum
Concentration
(
code)
2.14
Liquid
42
Number
of
Workers

EPA
requires
that
you
report
your
estimate
of
the
total
number
of
workers
"
reasonably
likely
to
be
exposed"

(
40
CFR
710.52(
c)(
3)(
vi
))


Include
exposures
through
any
route
of
entry
 
inhalation,

ingestion,
skin
contact.


Include
workers
wearing
personal
protective
equipment

Reasonably
likely
to
be
exposed
 
Exposure
to
a
chemical
substance
under
foreseeable
conditions
of
manufacture,
processing,
distribution
in
commerce
43
Number
of
Workers

Use
the
range
code
listed
in
Table
4­
3
of
the
IUR
instruction
manual
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
44
Maximum
Concentration

Report
the
maximum
concentration,
measured
by
weight,
at
the
time
the
chemical
is
reacted
on­
site
or
as
it
leaves
the
plant
site
(
40
CFR
710.52(
c)(
3)(
vii))


Round
estimates
to
the
nearest
1%
using
standard
rounding
procedures

Use
the
range
code
listed
in
Table
4­
4
of
the
IUR
instruction
manual
45
Physical
Form

Report
all
physical
forms
of
the
chemical
at
the
time
it
is
reacted
or
as
it
leaves
your
site
and
the
percentage
of
production
volume
for
each
physical
form
(
40
CFR
710.52(
c)(
3)(
viii)).


Round
estimates
to
the
nearest
10%.
The
sum
of
percentages
must
not
add
up
to
more
than
100%.

a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
Check
All
That
Apply
CBI
Percent
CBI
2.9
Dry
Powder
2.10
Pellets
or
Large
Crystals
2.11
Water
or
Solvent
Wet
Solid
2.12
Other
Solid
2.13
Gas
or
Vapor
2.14
Liquid
46
Part
III:
Processing
and
Use
Information

Complete
Part
III
for
chemical
substances
manufactured
in
quantities
of
300,000
pounds
or
more
(
40
CFR
710.52(
c)(
4))


If
you
are
reporting
for
more
than
one
chemical,
make
the
necessary
number
of
copies

Report
readily
obtainable
information
about
the
industrial
processing
and
use
for
each
chemical
substance:

°
Sites
under
your
control
°
Sites
that
receive
a
reportable
substance
47
Part
III,
Section
I:

Industrial
Processing
and
Use
Report
up
to
10
unique
combinations
of
the
following
codes:

Process
or
use;
NAICS;
and
IFC
SECTION
I.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)

NAICS
c.
Industrial
Function
Category
d.
Percent
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
48
SECTION
I.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)

NAICS
c.
Industrial
Function
Category
d.
Percent
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
Part
III,
Section
I:
Industrial
Processing
and
Use
(
cont'd)

Estimate
the
percent
production
volume,

number
of
sites,
and
number
of
workers
for
each
unique
combination
of
process
or
use,
NAICS,
and
IFC
codes.
49
Percentage
of
Production
Volume

Round
estimates
to
nearest
10%

(
40
CFR
710.52(
c)(
4)(
i))


The
total
percentage
production
volume
may
add
up
to
more
than
100%
since
you
are
reporting
for
sites
in
your
control
and
downstream
sites
50
Number
of
Sites

Report
an
estimate
of
the
total
number
of
sites.
Use
the
codes
listed
in
Table
4­
8
corresponding
to
the
appropriate
range.


If
you
both
manufacture
and
process
or
use
a
chemical,
your
site
should
be
counted
as
both
a
manufacturing
site
in
Part
II
and
a
processing
or
use
site
in
Part
III.

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
51

Report
an
estimate
of
the
total
number
of
workers
including
those
at
sites
not
under
your
control.
Use
the
codes
listed
in
Table
4­
9
corresponding
to
the
appropriate
range.

Number
of
Workers
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
52
Part
III,
Section
II:
Commercial
and
Consumer
End
Use
Commercial
Use
­
Use
of
a
chemical
substance
or
mixture
in
a
commercial
enterprise
providing
saleable
goods
or
a
service.

Consumer
Use
­
Use
of
a
chemical
substance
that
is
directly,
or
as
part
of
a
mixture,
sold
to
a
consumer
for
their
own
use.

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
53
Consumer
and
Commercial
Product
Category
Designate
up
to
10
commercial
and
consumer
product
categories
defined
in
Table
4­
10
of
the
instruction
manual.

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
54
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
Use
in
Children's
Products
Determine
if
the
chemical
is
present
in
or
on
any
consumer
product
intended
for
use
by
children.
55
Percent
Production
Volume
and
Maximum
Concentration
Use
same
rules
for
reporting
as
in
Part
III
Section
I
and
Part
II
Section
II.

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
56
Summary

Overview
of
completing
Form
U
°
Part
I
­
Company
Information
°
Part
II
­
Manufacturing
Information
°
Part
III
­
Processing
and
End
Use
Information

Unique
combinations
of
Type
of
process
or
use,
NAICS,

and
IFC
codes

Commercial
and
consumer
use
codes

Use
in
children's
products

Rounding
methods
for
percentages
57
57
Case
Studies
Franklyn
Hall
Chemical
Engineering
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
IUR
Public
Meeting
August
1,
2003
Washington,
DC
58
Overview
of
Case
Studies

Hydrate
compounds
°
Show
how
to
complete
Form
U

Pigment
°
Show
how
to
complete
Form
U

Discussion
59
Case
Study
­
Hydrate
Compounds

Company
D
produces
800,000
lbs/
yr
of
copper
sulfate
pentahydrate
(
CuSO
4°
5H
2
O)
crystals
at
93%
purity.
560,000
lbs/
yr
(
70%)
of
the
production
volume
is
used
for
metal
electroplating
and
240,000
lbs/
yr
(
30%)
is
used
as
pesticides.
This
site
employs
60
workers
in
the
manufacturing
area.


Key
Points:

°
Copper
sulfate
is
an
inorganic
substance
­
Report
for
only
Parts
I
and
II
°
Manufacture
and
use
of
pesticides
is
exempt
from
TSCA
regulations,
therefore
the
production
volume
associated
with
pesticide
use
should
not
be
reported
°
Report
only
the
weight
fraction
of
the
anhydrous
copper
sulfate
560,000
lbs
CuSO
4
5H
2
O
yr
159.61
lbs
CuSO
4
249.69
lbs
CuSO
4
5H
2
O
357,970
lbs
CuSO4
 
×
 
=
60
SECTION
II.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.1
Company
Information
2.2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.3
Site
Limited
(
Y/
N)
2.9
Dry
Powder
CBI
2.4
Activity
(
M,
I
or
both)
2.10
Pellets
or
Large
Crystals
CBI
2.5
Production
Volume
(
LB)
2.11
Water
or
Solvent
Wet
Solid
CBI
2.6
Production
Volume
Range
2.12
Other
Solid
CBI
2.7
Number
of
Workers
(
code)
2.13
Gas
or
Vapor
CBI
2.8
Maximum
Concentration
(
code)
2.14
Liquid
Case
Study
­
Hydrate
Compounds
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
1.2
ID
Code
1.3
Chemical
Name
7758­
98­
7
C
Copper
(
II)
Sulfate
M
N
X
100
357,970
Amount
of
anhydrous
form
used
for
metal
electroplating.

W4
At
least
50
workers
but
fewer
than
100
M5
Greater
than
90%
by
weight
61
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
Case
Study
­
Hydrate
Compounds
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II.
2.6
is
greater
than
or
equal
to
300,000
lb/
year
X
X
62
Case
Study
­
Pigment
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
at
concentrations
less
than
1%.
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
The
plastic
articles
are
sold
directly
for
commercial
and
consumer
use
63

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
the
following:

°
5
workers
are
exposed
to
C.
I.
Pigment
Yellow
100
at
each
plastic
manufacturing
site;

°
5
workers
are
exposed
at
each
paint
manufacturing
site;

and
°
5
workers
are
exposed
at
each
wooden
toy
manufacturer
site.

Case
Study
­
Pigment
64
SECTION
II.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.1
Company
Information
2.2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.3
Site
Limited
(
Y/
N)
2.9
Dry
Powder
CBI
2.4
Activity
(
M,
I
or
both)
2.10
Pellets
or
Large
Crystals
CBI
2.5
Production
Volume
(
LB)
2.11
Water
or
Solvent
Wet
Solid
CBI
2.6
Production
Volume
Range
2.12
Other
Solid
CBI
2.7
Number
of
Workers
(
code)
2.13
Gas
or
Vapor
CBI
2.8
Maximum
Concentration
(
code)
2.14
Liquid
Case
Study
­
Pigment
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
1.2
ID
Code
1.3
Chemical
Name
C.
I.
Pigment
Yellow
100
12225­
21­
7
C
N
M
60
X
40
X
M5
Greater
than
90%
by
weight
W3
At
least
25
workers
but
fewer
than
50
800,000
Total
amount
of
C.
I.
Pigment
100
produced
65
Case
Study
­
Pigment
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II.
2.6
is
greater
than
or
equal
to
300,000
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
PA
S1
40
W3
U08
32619
PF
S3
60
W5
U08
32551
C15
40
M1
?

C12
40
M2
N
C18
30
M2
Y
C15
=
Rubber
and
plastics
products
C12
=
Paints
and
coatings
C18
=
Wood
and
wood
furniture
M1
=
Less
than
1
wt%

M2
=
From
1
wt%
to
30
wt%

32619
=
Other
plastics
product
mfg.

32551
=
Paint
and
coating
mfg.

U08
=
Coloring
agents,
pigments
S1
=
Less
than
10
sites
S3
=
From
26
to
100
sites
66
Chapter
5:

Claiming
Confidential
Business
Information
(
CBI)

Fred
Arnold
Chemical
Engineering
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
IUR
Public
Meeting
August
1,
2003
Washington,
DC
67
Overview
of
Chapter
5

Claiming
CBI
for:

°
Chemical
identity
°
Manufacturing
plant
site
identity
°
PV
and
PV
range

Example

Discussion
68
To
claim
confidentiality
on
Form
U:


Mark
the
appropriate
boxes
on
Form
U

An
authorized
official
must
sign
Part
I,
Section
I

Must
file
a
written
substantiation
for:

°
Chemical
Identity
°
Manufacturing
Plant
Site
Identity

Production
Volume
and
Production
Volume
Range

Note:
CBI
should
not
be
submitted
by
email
69
Chemical
Identity

Must
file
a
separate
written
substantiation,
signed
and
dated
by
an
authorized
official,
for
each
chemical
substance

Only
assert
a
confidentiality
claim
if
EPA
treats
the
identity
as
confidential
in
the
TSCA
Inventory

Address
all
questions
in
Table
5­
1
°
Harmful
effects
to
competitive
position
°
Length
of
time
information
must
remain
confidential
°
Patent
and
licensing
status
°
Publication
in
technical
journals
or
trade
literature
°
Ability
of
others
to
analyze
products
or
wastes
70
Manufacturing
Plant
Site
Identity

Check
the
CBI
box
next
to
Block
2.2

Submit
a
written
substantiation,
signed
and
dated
by
an
authorized
official,
answering
the
questions
in
Table
5­
2.

°
Has
site
information
been
linked
with
a
chemical
identity
in
any
other
reporting
scheme?
Ex.
Through
an
MSDS.

°
What
harmful
effect
to
your
competitive
advantage
would
result
from
the
identity
of
the
site
and
chemical
substance?


Upfront
substantiation
is
not
required
for
company
information
CBI
claims
(
Block
2.1)
71
SECTION
II.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.1
Company
Information
2.2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.3
Site
Limited
(
Y/
N)
2.9
Dry
Powder
CBI
2.4
Activity
(
M,
I
or
both)
2.10
Pellets
or
Large
Crystals
CBI
2.5
Production
Volume
(
LB)
2.11
Water
or
Solvent
Wet
Solid
CBI
2.6
Production
Volume
Range
2.12
Other
Solid
CBI
2.7
Number
of
Workers
(
code)
2.13
Gas
or
Vapor
CBI
2.8
Maximum
Concentration
(
code)
2.14
Liquid
Company
Identity
versus
Plant
Site
Identity
Checking
this
box
asserts
a
confidentiality
claim
for
the
link
between
your
plant
site
and
the
chemical
substance.

Checking
this
box
asserts
a
confidentiality
claim
for
the
link
between
your
company
and
the
chemical
substance.
72
Production
Volume
vs.

Production
Volume
Range

To
claim
production
volume
as
CBI,
check
the
CBI
box
next
to
Block
2.5

To
claim
production
volume
range
as
CBI,
check
the
CBI
box
next
to
Block
2.6

EPA
wants
to
provide
as
much
information
to
the
public
as
possible

If
you
claim
the
production
volume
as
CBI,
you
are
not
required
to
claim
the
production
volume
range
as
CBI.


The
production
volume
ranges
listed
in
Table
4­
2
of
the
Reporting
Instructions
are
assigned
by
EPA
73
SECTION
II.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.1
Company
Information
2.2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.3
Site
Limited
(
Y/
N)
2.9
Dry
Powder
CBI
2.4
Activity
(
M,
I
or
both)
2.10
Pellets
or
Large
Crystals
CBI
2.5
Production
Volume
(
LB)
2.11
Water
or
Solvent
Wet
Solid
CBI
2.6
Production
Volume
Range
2.12
Other
Solid
CBI
2.7
Number
of
Workers
(
code)
2.13
Gas
or
Vapor
CBI
2.8
Maximum
Concentration
(
code)
2.14
Liquid
SECTION
I.
CHEMICAL
IDENTIFICATION
CBI*

1.1
Chemical
Identifying
Number
1.2
ID
Code
1.3
Chemical
Name
C.
I.
Pigment
Yellow
100
12225­
21­
7
C
N
M
60
X
40
X
M5
W3
800,000
Example:
Claiming
CBI
on
Form
U
X
X
X
X
X
X
X
X
X
X
X
X
X
74
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Section
I
and
II
only
if
the
production
volume
noted
in
Part
II,
Section
II.
2.6
is
greater
than
or
equal
to
300,000
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
PA
S1
40
W3
U08
32619
PF
S3
60
W5
U08
32551
C15
40
M1
?

C12
40
M2
N
C18
30
M2
Y
Example:
Claiming
CBI
on
Form
U
(
cont'd)

X
X
X
X
X
X
X
X
X
X
X
X
XX
X
XXX
XX
X
XX
X
75
Summary

Written
substantiation
for:

°
Chemical
identity
°
Manufacturing
plant
site
identity

Claiming
CBI
for:

°
Company
identity
versus
manufacturing
site
identity
°
Production
volume
°
Production
volume
range
76
Amendments,

Partial
Exemptions,
and
Other
Future
Activities
Fred
Arnold
Chemical
Engineering
Branch
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
IUR
Public
Meeting
August
1,
2003
Washington,
DC
77
Future
Amendments
to
IUR

Change
the
reporting
period
°
4
years

5
years

Change
the
record
keeping
period
°
5
years

6
years

Move
the
reporting
period
°
August
­
December

January
­
May

Clarify
reporting
requirements
for
importers
78
Developing
a
Procedure
for
Reviewing
Partial
Exemptions
Draft
procedure:

1
EPA
will
receive
and
validate
the
request
2
EPA
will
identify
interest
in
IUR
processing
and
use
information
for
the
chemical
3
EPA
will
notify
potentially
interested
parties
4
An
EPA
workgroup
will
review
the
request
and
prepare
a
decision
document
for
management
review
5
EPA
management
will
review
the
decision
document
6
EPA
will
disseminate
a
decision
7
EPA
will
publish
a
proposed
rule
and
request
for
comment
79
Developing
a
Procedure
for
Reviewing
Partial
Exemptions
(
cont'd)


EPA's
decision
to
grant
or
deny
a
request
will
be
based
on
the
following
considerations
(
40
CFR
710.46(
b)(
2)(
ii)):

A
Production
volume
(
especially
if
>
300,000
pounds)

B
Chemical
and
physical
properties
(
potential
for
persistence,

bioaccumulation,
health
and
environmental
effects)

C
Information
needs
of
EPA,
other
federal
agencies,
and
the
public
D
Availability
of
complementary
risk
screening
information
E
Availability
of
comparable
processing
and
use
information
F
Whether
the
potential
risks
are
adequately
managed
by
EPA
or
other
agency
80
Development
of
a
Training
Materials
and
Training
Workshops

EPA
will
be
developing
a
manual
with
examples
to
assist
IUR
reporters

EPA
will
conduct
workshops
to
educate
EPA
regional
personnel
and
industry
on
IUR
reporting
