Instructions
for
Reporting
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
Economics,
Exposure
and
Technology
Division
October
2003
Instructions
for
Reporting
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
Economics,
Exposure
and
Technology
Division
September
2003
HIGHLIGHTS
OF
THE
2006
IUR
COLLECTION

Information
from
calendar
year
2005
must
be
reported
in
the
2006
IUR
(
40
CFR
710.53).


The
submission
period
is
from
August
25,
2006
to
December
23,
2006
(
40
CFR
710.53).


Reporting
is
required
for
all
chemical
substances,
both
organic
and
inorganic,
other
than
polymers,
microorganisms,
naturally
occurring
chemical
substances
and
certain
forms
of
natural
gas
(
40
CFR
710.46).


The
production
volume
threshold
which
triggers
reporting
has
been
raised
from
10,000
pounds
to
25,000
pounds
(
40
CFR
710.48(
a)).


For
chemicals
produced
in
amounts
equal
to
or
greater
than
300,000
pounds,
additional
reporting
of
processing
and
use
information
is
required
(
40
CFR
710.52(
c)(
4)).


A
partial
reporting
exemption
is
provided
for
certain
chemical
substances
termed
"
petroleum
process
streams"
and
for
specific
chemical
substances
where
EPA
has
identified
a
low
current
interest
in
processing
and
use
information
related
to
the
chemical.
Only
site
identification
and
manufacturing
information
is
required
to
be
reported
for
these
chemicals
(
40
CFR
710.46).


Chemical
substances
which
are
subject
to
a
proposed
or
final
TSCA
rule
or
order
are
not
eligible
for
an
exemption
from
reporting
requirements;
all
required
information
must
be
reported
for
these
chemical
substances
(
40
CFR
710.46).
Many
of
these
substances
are
listed
in
Appendix
C.


Reporting
of
additional
specific
information
is
required
to
assist
in
the
accurate
identification
of
plant
sites
reporting
under
the
IUR
(
40
CFR
710.52).


New
requirements
for
cleaning
information
submitted
under
the
IUR
as
confidential
are
included.
The
production
volume
of
a
chemical
and
the
range
in
which
it
falls
may
be
independently
claimed
to
be
confidential.
Additional
information
is
required
to
claim
the
chemical
identity
and
plant
site
identity
as
confidential
(
40
CFR
710.58).


A
current
version
of
the
non­
confidential
TSCA
Inventory
has
been
prepared
in
CD
ROM
and
computer
tape
formats.
Chapter
7
of
this
document
provides
additional
details
on
obtaining
a
copy
of
the
non­
confidential
TSCA
Inventory.


Companies
are
encouraged
to
report
to
EPA
using
the
2006
IUR
Electronic
Form.
There
is
no
minimum
number
of
chemical
substances
required
for
electronic
reporting.
Chapter
6
discusses
how
to
submit
your
Form
U
to
EPA.


For
questions
concerning
IUR
reporting
or
to
request
additional
forms,
contact
the
TSCA
Hotline,
Monday
through
Friday,
8:
30
am
to
5:
00
pm,
East
Coast
time
at
(
202)
554­
1404.
DRAFT
iv
TABLE
OF
CONTENTS
PREFACE
1.0
Introduction
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1­
1
1.1
Recent
Changes
to
IUR
Reporting
Requirements
.
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1­
1
1.2
Rationale
for
IUR
Changes
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1­
4
1.3
Use
of
IUR
Data
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1­
4
1.3.1
Use
of
Exposure­
Related
Information
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1­
5
1.3.2
Use
of
Processing
and
Use
Data
Elements
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1­
6
2.0
Reporting
Requirements
.
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2­
1
2.1
Criterion
I:
Is
Your
Chemical
Substance
Reportable
Under
the
IUR?
.
.
.
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.
.
2­
2
2.1.1
Is
Your
Chemical
Substance
in
the
TSCA
Inventory?
.
.
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.
.
2­
3
2.1.1.1
What
is
the
TSCA
Inventory?
.
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2­
3
2.1.1.2
How
Do
You
Determine
Whether
a
Chemical
Substance
is
Listed
on
the
TSCA
Chemical
Substance
Inventory?
.
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.
2­
3
2.1.1.3
What
Do
You
Do
if
You
Cannot
Find
Your
Chemical
Substance
in
the
TSCA
Chemical
Substance
Inventory?
.
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2­
4
2.1.2
Is
Your
Chemical
Substance
Excluded
from
Reporting?
.
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2­
6
2.1.2.1
Polymers
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2­
6
2.1.2.2
Microorganisms
.
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2­
7
2.1.2.3
Certain
Forms
of
Natural
Gas
.
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2­
7
2.1.2.4
Naturally
Occurring
Substances
.
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.
.
2­
7
2.1.3
Is
Your
Chemical
Subject
to
a
Special
Regulatory
Action
Under
TSCA?
.
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2­
8
2.1.4
When
is
the
Manufacture
or
Importation
of
Chemical
Substances
Subject
to
TSCA
but
not
Included
on
the
TSCA
Chemical
Substance
Inventory
(
40
CFR
720.22)?
.
.
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2­
8
2.2
Criterion
II:
Are
You
a
Manufacturer
Who
Is
Required
to
Report?
.
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.
.
2­
9
2.2.1
Did
You
Manufacture
the
Reportable
Substance
in
Quantities
of
25,000
Pounds
or
More?
.
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2­
9
2.2.1.1
Meeting
the
25,000­
Pound
Annual
Production
Volume
Threshold
.
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2­
9
2.2.2
Are
You
a
Small
Manufacturer?
.
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2­
12
2.2.3
Do
You
Qualify
for
Any
Additional
Reporting
Exemptions?
.
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.
2­
13
2.3
Criterion
III:
What
Information
Do
You
Need
to
Report?
.
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.
2­
15
2.3.1
Do
You
Manufacture
and/
or
Import
the
Reportable
Substance
in
Quantities
of
300,000
Pounds
or
More?
.
.
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2­
16
2.3.2
Does
Your
Reportable
Substance
Qualify
for
a
Partial
Exemption?
.
.
2­
17
TABLE
OF
CONTENTS
(
Continued)
DRAFT
v
2.3.2.1
Petroleum
Process
Streams
.
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2­
18
2.3.2.2
Partial
Exemption
for
Specific
Chemical
Substances.
.
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.
2­
18
2.3.2.3
Partial
Exemption
for
Inorganic
Substances
in
2006
.
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2­
18
3.0
When
You
Must
Report
.
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3­
1
4.0
Completing
Form
U
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4­
1
4.1
Form
of
Submission
.
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4­
1
4.2
Part
I
 
Section
I
Certification
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4­
1
4.2.1
Signature
(
Block
1.
A.
1)
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4­
1
4.2.2
Date
(
Block
1.
A.
2)
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4­
1
4.2.3
Name
and
Official
Title
(
Blocks
1.
A.
3
and
1.
A.
4)
.
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4­
1
4.3
Part
I
 
Section
II
Parent
Company
and
Technical
Contact
Information
.
.
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4­
2
4.3.1
Parent
Company
Name
(
Block
1.
B.
1)
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4­
2
4.3.2
Parent
Company
Dun
&
Bradstreet
Number
(
Block
1.
B.
2)
.
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4­
2
4.3.3
Technical
Contact
Name
(
Block
1.
B.
3)
.
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4­
2
4.3.4
Technical
Contact
Telephone
Number
and
E­
mail
Address
(
Blocks
1.
B.
4
and
1.
B.
5)
.
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4­
2
4.3.5
Technical
Contact
Mailing
Address
(
Blocks
1.
B.
6
through
1.
B.
10)
.
.
.
4­
2
4.4
Part
I
 
Section
III
Plant
Site
Identification
.
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.
4­
2
4.4.1
Plant
Site
Name
(
Block
1.
C.
1)
.
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.
4­
3
4.4.2
Plant
Site
Dun
&
Bradstreet
Number
(
Block
1.
C.
2)
.
.
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.
4­
3
4.4.3
Plant
Site
Street
Address
(
Blocks
1.
C.
3
through
1.
C.
8)
.
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4­
3
4.5
Part
II
 
Section
I
Chemical
Identification
.
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4­
3
4.5.1
Chemical
Identifying
Number
(
Block
2.
A.
1)
.
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.
4­
3
4.5.1.1
CAS
Registry
and
Other
Identifying
Numbers
.
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4­
4
EPA
Accession
Number
.
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.
4­
4
PMN
Number
.
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.
.
4­
4
4.5.1.2
Obtaining
CAS
Registry
and
Accession
Numbers
from
EPA
.
.
4­
4
4.5.2
ID
Code
(
Block
2.
A.
2)
.
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4­
5
4.5.3
Chemical
Name
(
Block
2.
A.
3)
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
4.6
Part
II
 
Section
II
Manufacturing
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
4.6.1
Company
Information
CBI
(
Block
2.
B.
1)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
4.6.2
Plant
Site
CBI
(
Block
2.
B.
2)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
7
4.6.3
Site
Limited
Status
(
Block
2.
B.
3)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
7
4.6.4
Activity
(
Manufacture
and/
or
Import)
(
Block
2.
B.
4)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
7
4.6.5
Production
Volume
(
Block
2.
B.
5)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
7
4.6.6
Production
Volume
Range
(
Block
2.
B.
6)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
7
4.6.7
Number
of
Workers
(
Block
2.
B.
7)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
8
4.6.8
Maximum
Concentration
(
Block
2.
B.
8)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
9
4.6.9
Physical
Form
and
Percentage
of
Production
Volume
(
Blocks
2.
B.
9
through
2.
B.
14)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
10
4.7
Part
III
 
Processing
and
Use
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
10
TABLE
OF
CONTENTS
(
Continued)
DRAFT
vi
4.7.1
Part
III
 
Section
I
Industrial
Processing
and
Use
Data
(
Blocks
3.
A.
1
through
3.
A.
10)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
11
4.7.1.1
Type
of
Process
or
Use
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
11
4.7.1.2
Five­
Digit
NAICS
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
12
4.7.1.3
Industrial
Function
Category
(
IFC)
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
12
4.7.1.4
Percentage
of
Production
Volume
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
13
4.7.1.5
Number
of
Sites
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
14
4.7.1.6
Number
of
Workers
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
15
4.7.2
Part
III
 
Section
II
Consumer
and
Commercial
End­
Use
Exposure­
Related
Data
(
Blocks
3.
B.
1
through
3.
B.
10)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
16
4.7.2.1
Consumer
and
Commercial
Product
Category
Code
.
.
.
.
.
.
.
4­
16
4.7.2.2
Use
in
Children's
Product
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
17
4.7.2.3
Percentage
of
Production
Volume
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
19
4.7.2.4
Maximum
Concentration
Code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
19
5.0
How
to
Assert
Confidentiality
Claims
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
1
5.1
Chemical
Identity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
2
5.2
Manufacturing
Plant
Site
Identity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
3
5.3
Chemical
Production
Volume
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
4
5.4
Additional
Data
Elements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
5
6.0
How
to
Submit
Your
Form
U
to
EPA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.1
Sending
Forms
to
EPA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.2
Correcting
Errors
in
Submissions
for
Original
Inventory
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.3
Recordkeeping
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
2
6.4
Special
Instructions
for
Importers
and
Foreign
Suppliers
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
3
7.0
How
To
Obtain
Copies
of
Documents
Cited
in
These
Instructions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.1
Obtaining
Copies
of
TSCA
Regulations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.2
Obtaining
Copies
of
the
Public
Inventory
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.2.1
Printed
Editions
of
the
Public
Inventory
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.2.2
Obtaining
the
Public
Inventory
in
Computer­
Readable
Format
.
.
.
.
.
.
.
7­
1
7.3
Obtaining
Copies
of
Form
U
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
2
8.0
How
To
Request
Assistance
with
Reporting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
1
Appendix
A
­
2006
Form
U
Appendix
B
­
Definitions
Appendix
C
­
Inventory
Chemical
Substances
Subject
to
Proposed
or
Final
TSCA
Rules
or
Orders
(
as
of
May
14,
2002)
Appendix
D
­
Instructions
for
Submitting
IUR
Forms
Electronically
Appendix
E
­
Partially
Exempt
Chemicals
Appendix
F
­
Explanation
of
Reporting
Codes
Used
in
Part
III
of
Form
U
Appendix
G
­
Case
Studies
DRAFT
vii
LIST
OF
FIGURES
2­
1.
Decision
Logic
Diagram
for
Determining
Your
Reporting
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
2­
1
2­
2.
Decision
Logic
Diagram
for
Determining
if
Your
Chemical
Substance
is
Reportable
.
.
.
2­
2
2­
3.
Decision
Logic
Diagram
for
Evaluating
Criterion
II
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
10
2­
4.
Decision
Logic
Diagram
for
Evaluating
Criterion
III
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
16
DRAFT
viii
LIST
OF
TABLES
1­
1.
Changes
Made
to
IUR
Reporting
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
2
2­
1.
Chemical
Substances
Covered
by
Natural
Gas
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
7
2­
2.
Examples
of
Evaluating
Substances
for
the
Naturally
Occurring
Exemption
(
40
CFR
710.4(
b))
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
8
2­
3.
Annual
Production
Volume
Threshold
Examples
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
11
2­
4.
Small
Manufacturer
Exemption
Examples
(
40
CFR
710.48)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
13
2­
5.
Examples
of
Reporting
Exemptions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
14
2­
6.
Examples
of
Reporting
Requirements
for
Form
U,
Part
III
(
40
CFR
710.52(
c)(
4))
.
.
.
2­
17
4­
1.
ID
Code
for
Chemical
Identifying
Numbers
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
4­
2.
Production
Volume
Ranges
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
8
4­
3.
Codes
for
Reporting
Number
of
Industrial
Workers
Potentially
Exposed
.
.
.
.
.
.
.
.
.
.
.
.
4­
9
4­
4.
Codes
for
Reporting
Maximum
Concentration
of
Chemical
Substance
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
9
4­
5.
Codes
Corresponding
to
Processing
or
Use
Operations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
11
4­
6.
Codes
for
Reporting
IFCs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
13
4­
7.
Examples
of
Reporting
Industrial
Processing
and
Use
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
14
4­
8.
Codes
for
Reporting
Numbers
of
Sites
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
15
4­
9.
Codes
for
Reporting
Number
of
Industrial
Workers
Potentially
Exposed
.
.
.
.
.
.
.
.
.
.
.
4­
15
4­
10.
Codes
for
Reporting
Commercial
and
Consumer
Product
Categories
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
17
4­
11.
Examples
of
Use
in
Children's
Product
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
18
5­
1.
Special
Considerations
for
Asserting
Confidentiality
Claims
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
1
5­
2.
Substantiation
Questions
To
Be
Answered
When
Making
Chemical
Identity
CBI
Claims
(
from
40
CFR
710.58(
b))
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
2
5­
3.
Substantiation
Questions
To
Be
Answered
When
Making
Plant
Site
Identity
CBI
Claims
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
4
5­
4.
Production
Volume
Ranges
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
4
DRAFT
ix
PREFACE
On
January
7,
2003,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
promulgated
a
final
rule
amending
the
Inventory
Update
Rule
(
IUR)
(
see
40
CFR
Part
710).
Sites
affected
by
this
rule
are
subject
to
the
revised
reporting
requirements
beginning
in
2006
for
manufacturing
and/
or
importing
activities
conducted
during
the
2005
calendar
year.
The
first
reports
are
due
by
December
26,
2006;
sites
are
to
use
the
revised
2006
Form
U
for
reporting
to
EPA,
and
are
encouraged
to
file
electronically.

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

nor
is
it
a
regulation
itself.
It
does
not
impose
legally
binding
requirements
on
the
regulated
community
or
on
EPA.
Determinations
regarding
compliance
with
the
IUR
requirements
will
be
based
solely
on
the
Toxic
Substances
Control
Act
15
U.
S.
C.
§
2607
and
the
IUR
regulations
(
40
CFR
Part
710).
Interested
parties
are
free
to
raise
questions
about
the
application
of
this
guidance
to
a
particular
situation.
Where
appropriate,
EPA
retains
the
discretion
to
accept
approaches
on
a
case­
by­
case
basis
that
differ
from
this
guidance,
to
the
extent
that
such
approaches
comply
with
TSCA
and
the
implementing
regulations.

This
guidance
document
contains
the
following
sections
and
appendices:


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


Chapter
2
­
Instructions
on
determining
which
chemical
substances
are
reportable,

who
must
report,
and
what
must
be
reported.


Chapter
3
­
When
you
must
report.


Chapter
4
­
Step­
by­
step
guidance
on
completing
Form
U.


Chapter
5
­
Asserting
and
reasserting
your
claims
of
Confidential
Business
Information
(
CBI).


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


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


Chapter
8
­
Requesting
assistance
with
IUR
reporting.


Appendix
A
­
2006
Form
U.


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

Appendix
C
­
List
of
CAS
numbers
of
chemicals
that
are
subject
to
a
special
regulatory
action
under
TSCA.


Appendix
D
­
Instructions
for
electronic
IUR
reporting.


Appendix
E
­
Partially
exempt
chemicals.


Appendix
F
­
Definitions
of
industrial
function
categories
and
commercial
and
consumer
end­
use
categories.


Appendix
G
­
Case
studies
illustrating
how
to
complete
2006
Form
U.
DRAFT:
Chapter
1.0
Introduction
1­
1
1.0
Introduction
In
1977,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
promulgated
a
rule
under
the
Toxic
Substances
Control
Act
(
TSCA)
section
8(
a),
15
U.
S.
C.
2607(
a),
to
compile
and
keep
current
an
inventory
of
chemical
substances
in
U.
S.
commerce.
This
inventory
is
called
the
TSCA
Chemical
Substance
Inventory
(
TSCA
Inventory).
In
1986,
EPA
promulgated
the
Inventory
Update
Rule
(
IUR),
also
under
TSCA
section
8(
a),
to
facilitate
the
periodic
updating
of
the
TSCA
Inventory
database
and
to
support
activities
associated
with
implementing
TSCA.
When
first
promulgated,
the
IUR
required
chemical
manufacturers
(
including
importers)
to
report
to
EPA
every
4
years
the
identity
of
chemical
substances
manufactured
(
including
imported)
annually
in
quantities
of
10,000
pounds
or
greater
at
each
plant
site
they
owned
or
controlled.
In
2003,
EPA
amended
the
IUR,
adjusting
the
universe
of
chemicals
and
plant
sites
reporting,
the
type
of
data
reported,
and
the
Confidential
Business
Information
(
CBI)
claim
procedures.

This
document
updates
the
2002
guidance
manual
(
EPA
749­
B­
02­
001)
to
incorporate
the
IUR
Amendments
(
IURA)
reporting
requirements
for
2006
reporting.
Manufacturers
and
importers
of
chemical
substances
are
encouraged
to
carefully
review
the
IUR
reporting
requirements
in
40
CFR
Part
710
to
determine
whether
they
are
subject
to
these
requirements
and
what
information
is
to
be
reported.

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

1.1
Recent
Changes
to
IUR
Reporting
Requirements
In
2003,
EPA
made
several
major
changes
to
the
IUR
reporting
requirements,
which
are
highlighted
in
Table
1­
1
and
explained
later
in
this
document.
In
addition,
Form
U
was
revised
to
incorporate
these
changes.
Appendix
A
contains
the
2006
Form
U.
DRAFT:
Chapter
1.0
Introduction
1­
2
Table
1­
1.
Changes
Made
to
IUR
Reporting
Requirements
Reporting
thresholds
increased
The
manufacture
and/
or
import
volume
reporting
threshold
was
raised
from
10,000
lbs/
yr
to
25,000
lbs/
yr
(
40
CFR
710.48(
a)).
A
larger­
volume
reporting
threshold
of
300,000
lbs/
yr
was
added
for
the
reporting
of
exposure­
related
processing
and
use
information
(
40
CFR
710.52(
c)(
4)).

Reporting
of
manufacturing
exposure­
related
information
added
New
data
elements
include:
(
1)
the
number
of
workers
(
in
ranges)
reasonably
likely
to
be
exposed
to
the
chemical
substance
at
the
site
of
manufacture
or
import,
(
2)
the
physical
form(
s)
of
the
substance
as
it
leaves
the
submitter's
possession,
(
3)
the
percentage
(
rounded
to
the
closest
10%)
of
the
total
production
volume
associated
with
each
physical
form,
and
(
4)
the
maximum
concentration
(
within
a
range)
of
the
chemical
substance
at
the
time
it
is
reacted
on­
site
to
produce
a
different
chemical
substance
or
as
it
leaves
the
submitter's
possession
(
40
CFR
710.52(
c)).

Reporting
of
industrial,
commercial,
and
consumer
exposure­
related
information
added
New
data
elements
to
be
reported
by
certain
larger­
volume
(
i.
e.,
300,000
lbs/
yr
or
more)
manufacturers
(
including
importers)
include:
Industrial
Processing
and
Use
Information
(
40
CFR
710.52(
c)(
4)(
i))


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

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

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

Information
associated
with
each
processing
or
use
operation/
NAICs/
industrial
function
category
combination:
 
Percentage
of
production
volume
 
Number
of
processing
and
use
sites
 
Number
of
workers
reasonably
likely
to
be
exposed
Commercial
and
Consumer
Use
Information
(
40
CFR
710.52(
c)(
4))


Commercial
and
consumer
product
uses
of
the
chemical
substance

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

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

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

Reporting
requirements
for
site
identity
added
Plant
site's
county
or
parish
and
an
email
address
for
the
technical
contact
must
now
be
reported
(
40
CFR
710.52(
c)(
2)(
i)).

Reporting
of
inorganic
chemical
substances
added
For
2006
reporting,
a
partial
reporting
exemption
for
inorganic
chemical
substances
is
in
place,
i.
e.,
no
reporting
of
industrial,
commercial,
and
consumer
exposure­
related
information
is
required
for
these
chemicals.
For
reporting
in
future
years,
manufacturers
must
fully
report
these
substances,
as
required
based
on
production
volume
(
40
CFR
710.46(
b)(
3)).

Natural
gas
exemption
added
A
full
exemption
from
IUR
reporting
for
certain
forms
of
natural
gas
was
added
(
40
CFR
710.46(
a)(
4)).
Table
1­
1
(
Continued)
DRAFT:
Chapter
1.0
Introduction
1­
3
Petroleum
process
stream
partial
exemption
added
A
partial
reporting
exemption
was
created
for
certain
listed
petroleum
process
streams
(
40
CFR
710.46(
b)(
1)).

Specific
chemical
substances
added
partial
exemption
added
A
partial
exemption
was
created
for
specific
chemical
substances
where
EPA
identified
that
there
is
a
low
current
interest
in
the
IUR
processing
and
use
information
related
to
the
chemical
(
40
CFR
710.46(
b)(
2)).

Records
retention
period
extended
The
records
retention
period
was
extended
from
4
to
5
years
(
40
CFR
710.57).

Reporting
changed
The
period
for
which
reporting
is
required
was
changed
from
a
corporate
fiscalyear
basis
to
a
calendar­
year
basis
(
40
CFR
710.52).

CBI
claims
for
production
volume
ranges
allowed
Submitters
can
now
claim
their
production
volume
ranges
as
CBI,
in
addition
to
the
existing
requirement
that
submitters
report
a
specific
production
volume
number
and
the
CBI
status
of
that
number
(
40
CFR
710.52(
3)(
v)).
This
change
allows
submitters
to
assert
a
confidentiality
claim
for
specific
production
volume
information
while
releasing
the
more
general
production
volume
range
as
public
information.

Up­
front
substantiation
for
plant
site
CBI
claims
required
Up­
front
substantiation
of
plant
site
confidentiality
claims
is
now
required
for
IUR
submissions
to
EPA
(
40
CFR
710.58(
c)).
This
requirement
is
similar
to
the
upfront
substantiation
requirement
for
chemical
identity
claims.
Clear
and
concise
substantiation
information
related
to
CBI
compliance
with
the
regulations
under
710.58(
c)
should
be
submitted.
See
Chapter
5.0
for
additional
costs.
DRAFT:
Chapter
1.0
Introduction
1­
4
1.2
Rationale
for
IUR
Changes
EPA
amended
the
IUR
on
January
7,
2003
for
three
primary
reasons:


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


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

To
improve
the
utility
of
the
information
reported.

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

1.3
Use
of
IUR
Data
In
the
past,
EPA
has
used
the
TSCA
Inventory
and
IUR
data
to
support
many
TSCA­
related
activities
and
to
provide
overall
support
for
a
number
of
EPA
and
other
federal
health,
safety,
and
environmental
protection
activities.
In
addition
to
the
past
uses,
EPA
will
use
the
processing
and
use
and
exposure
information
reported
in
2006
to
help
EPA,
other
agencies,
and
the
general
public
more
readily
screen
chemicals
for
exposure
and
risk.
The
information
collected
will
enable
EPA
to
develop
a
more
systematic
and
comprehensive
approach
to
the
chemical
prioritization
process.

EPA
will
use
the
information
to:

°
Support
priority
setting
and
risk­
based
screening
of
chemicals
(
e.
g.,
IUR
data
can
be
used
to
provide
a
risk­
based
context
for
hazard
information
being
submitted
under
the
HPV
Challenge
Program);

°
Empower
resource
allocation
decisions
by
enabling
EPA
to
make
science­
based
decisions
about
which
chemicals
to
focus
its
limited
resources;

°
Provide
a
first
place
to
look
when
a
new
concern
is
identified;
DRAFT:
Chapter
1.0
Introduction
1­
5
°
Provide
an
overview
of
chemical
use
and
exposure,
over
time,
in
a
unique
database;

°
Inform
a
variety
of
Agency
and
other
programs,
such
as
the
TSCA
testing
program
and
National
Institute
of
Occupational
Safety
and
Health
(
NIOSH)
and
Consumer
Product
Safety
Commission
(
CPSC)
programs;


Identify
and
manage
human
health
and
environmental
risks
by
providing
EPA
with
information
on
nationwide
chemical
manufacture
and/
or
importation
production
and
exposure
so
that
chemicals
in
commerce
can
be
screened;


Identify
chemicals
to
which
large
numbers
of
workers
may
be
exposed
 
to
the
benefit
of
EPA,
Occupational
Safety
and
Health
Administration,
National
Institute
of
Occupational
Safety
and
Health,
National
Institutes
of
Health,
organized
labor,
chemical
industry,
and
other
organizations'
risk
management
programs;
and

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

The
following
sections
discuss
the
use
of
the
specific
IUR
data
elements.
For
additional
information,
see
"
Inventory
Update
Rule
Amendments
Data
Use
Plan"
located
in
the
rulemaking
record
for
this
rule
(
OPPT­
2002­
0054).

1.3.1
Use
of
Exposure­
Related
Information
EPA
uses
exposure
information
in
a
wide
variety
of
analyses
and
decision­
making,
including
that
associated
with
projects
within
the
Existing
Chemicals
Program
and
Design
for
the
Environment
(
DfE).
(
Further
information
on
these
projects
can
be
found
at
http://
www.
epa.
gov/
opptintr/.)
Often
under
these
programs,
EPA
completes
an
initial
review
of
chemical
substances
to
identify
those
substances
that
raise
particular
concerns
as
to
the
potential
risks
they
present
to
human
health
and
the
environment.
The
new
IUR
reporting
requirements
for
exposure­
related
information
are
related
to,
or
are
indicative
of,
three
components
of
exposure:


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


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

The
frequency
and
duration
of
potential
exposures
(
e.
g.,
data
elements
concerning
industrial
function
categories
and
commercial
and
consumer
use
categories).
DRAFT:
Chapter
1.0
Introduction
1­
6
Effective
risk
screening
and
risk
management
depend
on
both
exposure
information
and
hazard
information.
The
IUR
will
provide
EPA
with
data
that
will
more
accurately
and
realistically
gauge
potential
exposure.
The
exposure­
related
information
reported
under
the
IUR
will
be
used
in
combination
with
hazard
information
such
as
that
developed
under
TSCA
section
4
test
rules
and
enforceable
consent
agreements/
orders,
through
voluntary
efforts
such
as
the
HPV
Challenge
Program,
and
other
sources.
Because
of
the
limitations
of
the
data
available
from
past
information
collections
such
as
the
one­
time
reporting
of
information
by
a
subset
of
the
manufacturers
of
a
small
number
of
selected
high
production
volume
chemicals,
as
was
included
in
EPA's
voluntary
Use
and
Exposure
Information
Project
(
UEIP),
EPA
is
collecting
the
information
necessary
to
develop
an
exposure
database.
The
new
data
elements
included
in
the
2006
IUR
collection
improve
EPA's
ability
to
evaluate
exposure.
This
new
exposure­
related
information
will
facilitate
a
more
efficient
and
effective
screening
of
chemical
substances
based
either
on
exposure
or
on
risk.

1.3.2
Use
of
Processing
and
Use
Data
Elements
Under
the
new
IUR
requirements,
manufacturers
and
importers
producing
300,000
pounds
or
greater
must
report
industrial
processing
and
use
and
commercial
and
consumer
enduse
information.

Submitters
must
report
the
following
industrial
processing
and
use
data:

°
Type
of
Process
or
Use;
°
North
American
Industrial
Classification
System
(
NAICS)
code;
°
Industrial
Function
Category;
°
Percent
Production
Volume;
°
Number
of
Sites;
and
°
Number
of
Workers.

This
information
provides
basic
information
to
EPA
to
develop
potential
exposure
scenarios.
These
data
elements
affect
EPA's
decision­
making
during
risk
screening
exercises.
For
example,
a
process
and
use
code
of
repackaging
potentially
indicates
lower
exposures
than
if
the
chemical
is
used
to
formulate
a
mixture.
The
number
of
sites
directly
affects
the
distribution
of
general
population
exposures.
Without
these
data,
EPA
would
have
to
conservatively
assume
that
chemicals
are
processed
and
used
in
operations
that
result
in
higher
exposures
and
releases.

Submitters
must
also
report
the
following
commercial
and
consumer
end­
use
data:

°
Commercial
and
Consumer
Product
Categories;
°
Use
in
Children's
Products;
°
Percent
Production
Volume
Associated
with
Each
Category;
and
°
Maximum
Concentration
Associated
with
Each
Category.

The
information
indicates
the
types
of
products
to
which
consumers
and
nonindustrial
workers
may
be
exposed.
Some
of
the
most
vulnerable
populations,
such
as
children,
could
be
exposed
to
chemicals
that
have
primarily
commercial
and
consumer
uses.
DRAFT:
Chapter
1.0
Introduction
1­
7
Specific
examples
of
the
type
of
reports
that
can
be
prepared
from
the
IUR
data
can
be
found
in
"
Inventory
Update
Rule
Amendments
Data
Use
Plan"
located
in
the
rulemaking
record
for
this
rule
(
OPPT­
2002­
0054).
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
1
2.0
Reporting
Requirements
This
chapter
explains
the
reporting
requirements
for
the
2006
IUR
reporting
cycle.
Reporting
requirements
have
changed
since
the
last
IUR
reporting
cycle
in
2002.
There
are
three
criteria
to
consider
in
determining
your
reporting
requirements
for
each
chemical
substance
that
you
manufacture
in
the
United
States
or
import
into
the
United
States:


Criterion
I:
Is
your
substance
reportable
under
the
IUR?


Criterion
II:
Are
you
a
manufacturer
(
or
importer)
who
is
required
to
report?


Criterion
III:
What
information
do
you
need
to
report?

Figure
2­
1
is
a
decision
tree
summarizing
reporting
criteria.

CRITERION
II:
Are
you
a
manufacturer
required
to
report?
YOU
DO
NOT
NEED
TO
REPORT.
CRITERION
I:
Is
your
chemical
substance
reportable?

YOU
MUST
REPORT.
Evaluate
CRITERION
III
to
determine
what
information
you
should
complete.
Yes
Yes
No
No
Figure
2­
1.
Decision
Logic
Diagram
for
Determining
Your
Reporting
Requirements
This
chapter
will
discuss
each
of
these
criteria
and
associated
reporting
obligations
in
more
detail.
Appendix
B
provides
definitions
of
terms
used
for
IUR
reporting.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
2
Is
your
chemical
substance
excluded
from
reporting
(
710.46a)?
YOU
DO
NOT
NEED
TO
REPORT.
Is
your
substance
on
the
TSCA
Inventory?
(
710.45
and
710.53)

EVALUATE
CRITERION
II.
Yes
Yes
No
No
CRITERION
I:
Is
your
chemical
substance
reportable
under
IUR?

Is
your
substance
subject
to
a
special
regulatory
action
under
TSCA?
(
710.46)

Yes
No
2.1
Criterion
I:
Is
Your
Chemical
Substance
Reportable
Under
the
IUR?

A
chemical
substance
is
reportable
under
the
IUR
if
it
is
in
the
TSCA
Inventory
as
of
August
25,
2006,
and
not
specifically
exempted
by
40
CFR
710.46.
To
determine
if
your
chemical
substance
is
reportable
under
the
IUR,
you
should
answer
the
following
three
questions:


Is
your
substance
on
the
TSCA
Inventory?


Is
your
substance
excluded
from
reporting
because
it
is
a
polymer,
a
microorganism,
a
natural
gas,
or
naturally
occurring?


Is
your
substance
subject
to
a
special
regulatory
action?

Figure
2­
2
presents
a
decision
logic
diagram
to
assist
you
in
answering
these
questions.
The
following
subsections
explain
each
question
in
greater
detail.

Figure
2­
2.
Decision
Logic
Diagram
for
Determining
if
Your
Chemical
Substance
is
Reportable
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
3
Hydrates
are
not
listed
in
the
TSCA
Inventory.
However,
you
are
required
to
report
the
CAS
registry
number
of
the
corresponding
anhydrous
form.
Adjust
the
reported
production
volume
to
exclude
water.
2.1.1
Is
Your
Chemical
Substance
in
the
TSCA
Inventory?

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

2.1.1.1
What
is
the
TSCA
Inventory?
Authorized
by
§
8(
b)
of
TSCA,
the
TSCA
Inventory
is
a
list
of
chemical
substances
manufactured,
imported,
or
processed
for
commercial
purposes
in
the
United
States.
The
TSCA
Inventory
was
originally
compiled
from
reports
submitted
in
1978
and
1979
by
manufacturers,
importers,
and
certain
processors
of
chemicals
in
commerce
during
those
years.
Subpart
A
of
40
CFR
Part
710
prescribes
criteria
for
including
a
substance
in
the
TSCA
Inventory.
New
chemical
substances
are
added
to
the
TSCA
Inventory
when
companies
that
have
submitted
Premanufacture
Notifications
(
PMNs)
to
EPA
under
section
5
of
TSCA
notify
EPA
that
they
have
begun
to
manufacture
or
import
the
chemical
substance
(
under
40
CFR
720.102).

EPA
keeps
a
Master
Inventory
File,
which
is
the
authoritative
list
of
all
the
eligible
chemical
substances
that
have
been
reported
to
EPA
for
inclusion
in
the
TSCA
Inventory.
EPA
also
makes
the
non­
confidential
portion
of
the
inventory
file,
commonly
referred
to
as
the
Public
Inventory,
available
to
the
general
public.
The
Public
Inventory
does
not
contain
the
specific
identities
of
chemical
substances
that
have
been
claimed
as
CBI;
it
only
contains
generic
chemical
names
for
these
confidential
business
information
chemical
substances.
See
Chapter
7
of
this
document
for
information
on
obtaining
copies
of
the
Public
Inventory.

2.1.1.2
How
Do
You
Determine
Whether
a
Chemical
Substance
is
Listed
on
the
TSCA
Chemical
Substance
Inventory?
The
following
methods
may
help
you
determine
if
your
chemical
substance
is
listed
in
the
TSCA
Inventory:


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


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


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

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

Several
commercial
databases
have
incorporated
the
Public
Inventory
(
which
excludes
substances
with
confidential
identities)
and
indicate
whether
a
given
chemical
substance
is
included
in
the
TSCA
Inventory.
Because
these
databases
are
not
generated
or
peer­
reviewed
by
EPA,
the
Agency
cannot
guarantee
the
accuracy
of
the
information
in
these
databases.
Thus,
there
is
no
penalty
for
reporting
a
substance
that
may
be
listed
on
a
commercial
database,
but
is
not
required
to
be
reported.
However,
if
a
commercial
database
that
you
use
fails
to
include
all
reportable
chemicals
and,
as
a
result,
you
fail
to
report
information
for
these
chemicals,
you
may
be
in
violation
of
TSCA
(
40
CFR
710.1(
c)).
Please
note
that
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
4
hydrates
are
not
listed
in
the
TSCA
Inventory;
however,
you
are
required
to
report
the
CAS
registry
number
of
the
corresponding
anhydrous
form
(
40
CFR
710.3).
You
should
adjust
the
reported
production
volume
to
exclude
water.

For
example,
Company
A
manufactures
50,000
pounds
of
copper
(
II)
sulfate
pentahydrate,
CuSO
4

5H
2
O.
This
chemical
should
be
reported
under
the
anhydrous
form
of
copper
(
II)
sulfate,
CuSO
4.
To
calculate
the
production
volume,
multiply
the
mass
of
hydrated
compound
by
the
weight
fraction
(
ratio
of
molecular
weights)
of
anhydrous
copper
(
II)
sulfate,
CuSO
4,
in
the
hydrated
copper
(
II)
sulfate,
CuSO
4

5H
2
O.
The
molecular
weights
of
CuSO
4
and
CuSO
4

5H
2
O
are
159.6
pounds
per
pound­
mole
and
249.7
pounds
per
pound­
mole,
respectively.
Company
A
should
report
31,958
pounds
of
anhydrous
copper
(
II)
sulfate
on
Form
U
based
on
the
following
calculation:

50,000
lbs.
CuSO
5H
O
159.6
lbs
/
lb
mole
CuSO
249.7
lbs
/
lb
mole
CuSO
5H
O
=
31,
958
lbs.
CuSO
4
2
4
4
2
4
 
×
 
 
 

Since
31,958
pounds
is
greater
than
or
equal
to
25,000
pounds
but
less
than
300,000
pounds,
Company
A
should
complete
Parts
I
and
II
of
Form
U.

2.1.1.3
What
Do
You
Do
if
You
Cannot
Find
Your
Chemical
Substance
in
the
TSCA
Chemical
Substance
Inventory?
If
after
having
checked
the
above
sources,
you
are
still
uncertain
as
to
whether
a
chemical
substance
is
listed
on
the
TSCA
Inventory,
write
a
letter
to
EPA
at
the
following
address:

ATTN:
Inventory
Update
Rule
OPPT
Document
Control
Officer
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7407M)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460.

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

In
communicating
with
EPA,
you
must
substantiate
the
fact
that
you
are
manufacturing
or
importing
the
substance
in
question
by
providing
the
following
information
(
40
CFR
720.25):


Company
identification,
address,
and
telephone
number;
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
5

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


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


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

An
elemental
analysis
of
the
substance.

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

If
you
claim
information
which
you
submit
to
EPA
as
CBI,
EPA
recommends
that
you
place
your
letter
and
any
accompanying
materials
in
a
double­
wrapped
package
for
maximum
security.
The
inner
wrapper
should
be
labeled
with
the
recipient's
name
and
the
statement
"
TSCA
Confidential
Business
Information."
The
outer
wrapper
should
be
labeled
only
with
the
name
and
address
of
the
recipient
and
your
return
address.
Nothing
on
the
outer
wrapper
should
indicate
that
the
package
contains
CBI.
This
package
should
be
sent
to
EPA
by
certified
or
registered
mail,
return
receipt
requested,
or
sent
by
courier
service
or
U.
S.
Postal
Service
Express
Mail.
Regular
first
class
mail
should
never
be
used
to
send
CBI
to
EPA.
Failure
to
follow
proper
procedures
regarding
CBI
materials
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
you.

After
processing
your
response,
EPA
will
inform
you
whether
the
chemical
substance
is
in
the
TSCA
Inventory
and
whether
the
substance
is
subject
to
reporting
under
the
IUR.
If
the
chemical
substance
is
found
on
the
confidential
TSCA
Inventory,
EPA
will
notify
the
person(
s)
who
originally
reported
the
substance
that
another
person
has
requested
information
pursuant
to
the
IUR
procedures
and
was
told
that
the
chemical
substance
is
in
the
TSCA
Inventory
and
that
it
is
subject
to
reporting.
Your
identity
will
not
be
revealed
to
the
person
originally
reporting
the
substance.

If
you
are
an
importer
and
cannot
provide
all
of
the
required
information
because
your
foreign
manufacturer/
supplier
is
maintaining
it
as
confidential,
the
manufacturer/
supplier
can
send
the
information
directly
to
EPA.
Be
advised
that
it
is
the
obligation
of
the
importer
to
ensure
that
the
foreign
manufacturer
complies
with
the
IUR
requirements
(
40
CFR
720.25(
b)).
See
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
6
Polymers,
certain
natural
gas
streams,
and
microorganisms
are
not
excluded
from
reporting
when
they
are
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.

The
"
XU"
Flag
and
Polymers
Please
note
that
a
few
of
the
polymerization
gases
that
are
not
considered
polymers
might
have
been
incorrectly
flagged
because
of
the
inclusion
of
the
word
fragment
"
polym"
in
the
chemical
name.
These
substances
are
reportable
under
the
IUR.
Chapter
6,
Section
6.4
of
this
document
for
more
details
related
to
foreign
manufacturers/
suppliers.

2.1.2
Is
Your
Chemical
Substance
Excluded
from
Reporting?

Four
categories
of
substances,
though
included
in
the
TSCA
Inventory,
are
largely
excluded
from
reporting
under
the
IUR.
These
categories
are
polymers,
certain
natural
gas
streams,
microorganisms,
and
naturally
occurring
substances.
Refer
to
section
710.46
of
the
IUR
and
to
the
preamble
of
the
Federal
Register
notice
announcing
the
rule
(
Federal
Register
Vol.
68
No.
4,
January
7,
2003)
for
precise
definitions
of
these
categories.
Polymers,
certain
natural
gas
streams,
and
microorganisms
are
not
excluded
from
reporting
when
they
are
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.

Certain
petroleum
process
streams
and
other
specifically
listed
substances
are
exempted
from
reporting
processing
and
use
information.
Inorganic
substances,
which
were
previously
excluded,
are
no
longer
excluded
from
IUR
reporting;
however,
inorganic
substances
are
exempted
from
reporting
processing
and
use
information
for
the
2006
submission
period.
See
Section
2.3.2
for
further
information.

To
help
identify
excluded
substances,
EPA
has
labeled
most
of
these
substances
in
the
printed
and
electronic
versions
of
the
TSCA
Inventory
with
an
"
XU"
flag.
Note
that
you
are
advised
to
use
the
flag
only
as
a
guide;
submitters
are
responsible
for
verifying
exemptions.
If
a
substance
does
not
bear
an
"
XU"
flag
and
section
710.46
of
the
IUR
does
not
provide
sufficient
guidance
to
determine
whether
the
substance
is
excluded,
contact
the
TSCA
Hotline
at
(
202)
554­
1404
for
assistance.

2.1.2.1
Polymers.
Polymers
are
exempt
from
IUR
reporting.
The
IUR
definition
of
polymer
is
sufficiently
broad
to
include
virtually
all
those
substances
that
are
generally
considered
polymers.
These
include
siloxanes
and
silicones,
rubber,
lignin,
polysaccharides
(
such
as
starch
and
gums),
proteins
(
such
as
gelatin
and
hemoglobin),
and
enzymes.
However,
substances
that
result
from
hydrolysis,
depolymerization,
or
chemical
modification,
regardless
of
the
extent
of
these
processes,
of
polymers
so
that
the
final
products
are
no
longer
polymeric
(
e.
g.,
a
mixture
of
amino
acids
that
is
the
result
of
hydrolysis
of
a
polypeptide)
are
not
considered
to
be
polymers
and
must
be
reported
if
not
otherwise
excluded
(
40
CFR
710.46(
a)(
1)).
For
reporting
purposes,
salts
of
polymers
are
also
considered
to
be
polymers.
Please
note
that
a
few
of
the
polymerization
gases
that
are
not
considered
polymers
might
have
been
incorrectly
flagged
with
"
XU"
because
of
the
inclusion
of
the
word
fragment
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
7
"
polym"
in
the
chemical
name.
These
substances
are
reportable
under
the
IUR.
See
40
CFR
710.46(
a)(
1)
for
the
regulatory
definition
of
polymers.

2.1.2.2
Microorganisms.
Microorganisms
are
exempt
from
IUR
reporting.
A
microorganism
is
any
combination
of
chemical
substances
that
is
a
living
organism
and
that
meets
the
definition
of
"
microorganism"
at
40
CFR
725.3.
Any
chemical
substance
produced
from
a
living
microorganism
is
reportable
unless
otherwise
excluded
(
40
CFR
710.46(
a)(
2)).

2.1.2.3
Certain
Forms
of
Natural
Gas.
Table
2­
1
identifies
certain
forms
of
natural
gas
that
are
exempt
from
IUR
reporting;
the
natural
gas
exemption
is
new
for
the
2006
reporting
cycle.

Table
2­
1.
Chemical
Substances
Covered
by
Natural
Gas
Exemption
Form
of
Natural
Gas
CAS
Number
Natural
gas
(
petroleum),
raw
liquid
mix
64741­
48­
6
Natural
gas
condensates
68919­
39­
1
Gasoline
natural
8006­
61­
9
Gasoline
(
natural
gas),
natural
68425­
31­
0
Natural
gas
8006­
14­
2
Natural
gas,
dried
68410­
63­
9
2.1.2.4
Naturally
Occurring
Substances.
Chemical
substances
that
are
described
in
40
CFR
710.4(
b)
of
the
TSCA
Inventory
Reporting
Regulations
are
considered
"
naturally
occurring"
and
are
automatically
on
the
TSCA
Inventory
but
are
not
reportable
under
IUR.
Examples
of
substances
that
are
typically
naturally
occurring
materials
are
raw
agricultural
commodities,
water,
air,
natural
gas,
crude
oil,
rocks,
ores,
and
minerals.
However,
since
the
section
710.4(
b)
exclusion
is
a
process­
specific
exclusion
rather
than
a
chemical­
specific
one,
if
you
produce
any
substance
in
a
manner
other
than
as
described
in
section
710.4(
b),
you
are
required
to
report
unless
otherwise
excluded
(
40
CFR
710.46(
a)(
3)).
For
this
reason
minerals
and
certain
agricultural
products
are
sometimes
considered
not
to
be
naturally
occurring
because
of
their
method
of
production.

Further,
section
710.46(
a)(
3)
intentionally
exempts
from
IUR
reporting
any
chemical
substance
that
is
isolated/
removed
from
nature
for
a
commercial
purpose
by
the
means
specified
in
section
710.4(
b).
It
also
exempts
any
other
chemical
substance
derived
or
separated
from
the
substance
originally
removed
from
nature,
provided
such
derivation
involved
only
the
means
specified
in
that
section
(
e.
g.,
being
obtained
by
aqueous
extraction
or
flotation
or
by
pressing).
Whether
a
substance
is
considered
"
naturally
occurring"
depends
on
the
manner
in
which
it
is
produced
and
isolated.
Table
2­
2
presents
some
examples
of
evaluating
the
naturally
occurring
substance
exemption.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
8
Table
2­
2.
Examples
of
Evaluating
Substances
for
the
Naturally
Occurring
Exemption
(
40
CFR
710.4(
b))

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

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

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

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

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

2.1.3
Is
Your
Chemical
Subject
to
a
Special
Regulatory
Action
Under
TSCA?

With
the
exception
of
naturally
occurring
substances,
a
chemical
substance
that
falls
into
one
of
the
excluded
categories
must
still
be
reported
if
it
is
the
subject
of
any
of
the
following:
a
rule
proposed
or
promulgated
under
sections
4,
5(
a)(
2),
5(
b)(
4),
or
6
of
TSCA;
an
order
issued
under
TSCA
sections
5(
e)
or
5(
f);
or
relief
that
has
been
granted
under
a
civil
action
under
TSCA
sections
5
or
7
(
40
CFR
710.46).
Appendix
C
lists
the
chemical
substances
that
fall
into
these
categories.
However,
if
you
are
unable
to
determine
whether
the
specific
chemical
substance
you
manufacture
or
import
is
listed
in
Appendix
C,
you
can
contact
EPA
to
see
if
the
specific
substance
is
reportable
(
see
Chapter
8
for
contact
information).

2.1.4
When
is
the
Manufacture
or
Importation
of
Chemical
Substances
Subject
to
TSCA
but
not
Included
on
the
TSCA
Chemical
Substance
Inventory
(
40
CFR
720.22)?

When
checking
the
chemical
substances
you
manufacture
or
import
against
the
TSCA
Inventory,
you
may
discover
that
you
are
manufacturing
or
importing
substances
that
are
not
in
the
TSCA
Inventory
but
should
be
listed.
Such
manufacture
or
importation
is
in
violation
of
section
15
of
TSCA
and
could
subject
you
to
administrative
or
criminal
penalties.
Similarly,
if
you
are
manufacturing
or
importing
a
substance
that
was
previously
in
the
TSCA
Inventory
but
has
subsequently
been
delisted,
then
you
are
also
in
violation
of
section
15
of
TSCA.
If
either
of
these
situations
applies
to
you,
you
should
send
a
letter
to
EPA
at
the
following
address:

Director
Toxics
and
Pesticides
Enforcement
Division
Office
of
Regulatory
Enforcement
(
2245)
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
9
Information
in
your
letter
may
be
claimed
as
confidential
by
circling
or
bracketing
the
text
to
be
protected
and
marking
the
page
"
Confidential."
Failure
to
so
mark
this
information
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
you.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

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

2.2
Criterion
II:
Are
You
a
Manufacturer
Who
Is
Required
to
Report?

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


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


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


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

Figure
2­
3
presents
a
decision
logic
diagram
to
assist
you
in
answering
these
questions.
The
following
subsections
explain
each
question
in
greater
detail.

2.2.1
Did
You
Manufacture
the
Reportable
Substance
in
Quantities
of
25,000
Pounds
or
More?

If
you
manufactured
(
including
imported)
25,000
pounds
or
more
of
a
reportable
chemical
substance
at
any
single
site
you
owned
or
controlled
during
the
calendar
year
immediately
preceding
the
submission
period,
you
are
subject
to
reporting
(
40
CFR
710.48(
a)).

Manufacture
means
to
import,
produce,
or
manufacture
with
the
purpose
of
obtaining
an
immediate
or
eventual
commercial
advantage.
This
includes,
for
example,
manufacturing
or
importing
any
amount
of
a
chemical
substance
for
commercial
distribution
(
including
test
marketing)
manufacturing
solely
for
export,
or
manufacturing
for
use
by
the
manufacturer,
including
use
for
product
research
and
development
or
as
an
intermediate
(
40
CFR
710.3)).

2.2.1.1
Meeting
the
25,000­
Pound
Annual
Production
Volume
Threshold.
You
must
report
a
chemical
substance
only
if
you
manufactured
(
including
imported)
25,000
pounds
or
more
of
the
substance
at
any
single
site
you
owned
or
controlled
during
the
calendar
year
immediately
preceding
the
submission
period.
Moreover,
if
during
the
year
you
manufactured
25,000
pounds
or
more
of
the
substance
at
some
sites
and
less
than
25,000
pounds
at
other
sites,
you
will
need
to
report
the
substance
only
for
those
sites
at
which
you
manufactured
(
including
imported)
25,000
pounds
or
more
(
40
CFR
710.48).
Some
companies
may
both
manufacture
and
import
the
same
substance.
These
companies
should
add
together
the
manufacturing
and
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
10
Do
you
qualify
as
a
small
manufacturer?
(
710.49)
YOU
DO
NOT
NEED
TO
REPORT.
Did
you
manufacture
25,000
pounds
or
more
of
the
substance?
(
710.48)

YOU
MUST
REPORT.
Evaluate
CRITERION
III
to
determine
what
parts
of
Form
U
you
should
complete.
Yes
Yes
No
No
CRITERION
II:
Are
you
a
manufacturer
required
to
report?

Is
your
substance
subject
to
a
special
regulatory
action
under
TSCA?
(
710.46)

Yes
No
Do
you
qualify
for
additional
reporting
exemptions
(
see
Section
2.2.3)?
(
710.50)
Yes
No
Figure
2­
3.
Decision
Logic
Diagram
for
Evaluating
Criterion
II
importation
volumes
at
each
site
to
determine
whether
they
meet
or
exceed
the
25,000­
pound
threshold,
based
on
the
definition
of
manufacture.

Table
2­
3
provides
some
examples
of
how
the
annual
production
volume
reporting
requirement
applies.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
11
Table
2­
3.
Annual
Production
Volume
Threshold
Examples
Description
2006
Reporting
Requirement
Company
A,
which
has
only
one
manufacturing
site,
manufactured
26,000
pounds
of
Chemical
X,
which
is
not
exempt
from
reporting,
at
its
site
in
2005.
Company
A
must
report
for
Chemical
X
because
it
manufactured
25,000
pounds
or
more
of
Chemical
X
in
2005.

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

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

Company
D
has
two
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
10,000
pounds
of
Chemical
X
and
Site
2
manufactured
150,000
pounds
of
Chemical
X.
Company
D
is
not
required
to
report
for
Chemical
X
for
Site
1
because
2005
production
was
less
than
25,000
pounds,
but
must
report
for
Chemical
X
at
Site
2
because
at
this
location
production
was
25,000
pounds
or
more
in
2005.

Company
E
has
one
site
where
it
imports
and
manufactures
Chemical
X.
Company
E
manufactured
21,000
pounds
of
Chemical
X
and
imported
5,000
pounds
of
Chemical
X
in
2005.
Company
E
must
report
for
Chemical
X
because
the
total
produced
and
imported
in
2005
was
25,000
pounds
or
more.

In
many
cases,
reportable
substances
are
contained
within
a
mixture.
Although
mixtures
are
not
reportable,
the
chemical
substances
making
up
a
mixture
are
reportable
(
40
CFR
710.3).
If
you
manufacture
the
substances
as
part
of
a
mixture,
you
should
determine
whether
the
production
volume
for
each
substance
in
the
mixture
was
25,000
pounds
or
more.
Similarly,
if
you
import
a
mixture,
you
should
determine
whether
its
importation
volume
for
each
substance
in
the
mixture
is
25,000
pounds
or
more.
Note,
however,
that
a
person
who
produces
a
mixture
by
combining
existing
substances
without
a
chemical
reaction
is
not
a
manufacturer
of
those
substances
and,
therefore,
does
not
have
to
report
those
substances
under
the
IUR.

2.2.1.2
Special
Provisions
for
Importers.
The
site
where
you
import
a
chemical
substance
is
considered
the
site
of
the
operating
unit
within
your
organization
that
is
directly
responsible
for
importing
the
substance
and
controls
the
import
transaction.
In
some
cases,
the
import
site
may
be
the
organization's
headquarters
in
the
United
States
(
40
CFR
710.48(
b)).

Example
2­
1.
The
headquarters
of
your
company
is
located
in
New
Town.
You
have
a
plant
site
located
in
Old
Town,
which
is
in
a
different
state.
A
headquarters
employee
purchases
and
arranges
to
have
500,000
pounds
of
Chemical
X
imported
from
Japan
to
your
Old
Town
plant
site.
An
Old
Town
employee
is
also
involved
with
making
arrangements
to
receive
Chemical
X.
The
headquarters
employee
should
report
for
IUR.

Example
2­
2.
The
headquarters
of
your
company
is
located
in
New
Town.
Your
company
controls
three
manufacturing
sites,
Sites
1,
2,
and
3,
all
located
in
different
states.
An
employee
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
12
Small
manufacturers
are
still
required
to
report
on
substances
subject
to
a
rule
proposed
or
promulgated
under
certain
sections
of
TSCA.
See
Section
2.1.3
for
more
details.
based
at
headquarters
purchases
and
arranges
to
have
500,000
pounds
of
Chemical
X
imported
from
Japan.
20,000
pounds
is
delivered
to
Site
1;
180,000
pounds
is
delivered
to
Site
2;
and
300,000
pounds
is
delivered
to
Site
3.
The
headquarters
in
New
Town
should
report
all
500,000
pounds
imported.

2.2.2
Are
You
a
Small
Manufacturer?

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


Your
total
annual
sales,
combined
with
those
of
your
parent
company,
domestic
or
foreign
(
if
any),
do
not
exceed
$
4
million
regardless
of
annual
production
volume
(
40
CFR
704.3).


Your
total
annual
sales,
combined
with
those
of
your
parent
company,
domestic
or
foreign
(
if
any),
are
less
than
$
40
million
and
you
annual
production
volume
of
that
substance
does
not
exceed
100,000
pounds
at
any
individual
plant
site
(
40
CFR
704.3).
If
the
annual
production
volume
of
the
substance
at
any
of
your
sites
is
over
100,000
pounds,
you
are
required
to
report
only
for
those
sites.
Note
that
it
is
possible
to
qualify
as
a
small
manufacturer
with
respect
to
some
substances
and
not
others
or
with
respect
to
some
plant
sites
and
not
others.

If
you
qualify
as
a
small
manufacturer,
you
must
still
report
if
you
produce
25,000
pounds
or
more
in
a
year
of
a
reportable
substance
that
is
the
subject
of
a
rule
proposed
or
promulgated
under
sections
4,
5(
b)(
4),
or
6
of
TSCA;
an
order
under
TSCA
section
5(
e);
or
relief
granted
under
a
civil
action
under
TSCA
sections
5
or
7
(
40
CFR
710.46).
Appendix
C
lists
all
substances
that
fall
into
these
categories.

Table
2­
4
provides
some
examples
of
how
the
small
manufacturing
exemption
applies.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
13
Table
2­
4.
Small
Manufacturer
Exemption
Examples
(
40
CFR
710.48)

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

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

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

Site
5,
which
is
one
of
several
sites
owned
by
Company
D,
had
a
production
volume
of
50,000
pounds
of
Chemical
X
in
2005.
The
total
annual
sales
of
Company
D
(
all
sites
combined)
were
$
100,000,000
in
2001.
Company
D
must
report
for
Chemical
X
at
Site
5
because
total
annual
sales
in
2005
exceeded
$
40
million.

Site
6,
which
is
one
of
several
sites
owned
by
Company
A,
had
a
production
volume
of
120,000
pounds
of
Chemical
X
in
2005.
The
total
annual
sales
of
Company
A
(
all
sites
combined)
were
$
1,250,000
in
2005.
Chemical
X
is
subject
to
a
test
rule
and
is
listed
in
Appendix
C
of
this
Guidance
document.
Site
6
is
required
to
report
for
Chemical
X.
Even
though
combined
sales
are
less
than
$
4
million,
this
chemical
is
subject
to
a
test
rule
and
therefore
must
be
reported.

2.2.3
Do
You
Qualify
for
Any
Additional
Reporting
Exemptions?

If
you
manufacture
or
import
reportable
substances
under
the
following
circumstances,
you
are
not
required
to
report
for
those
substances
under
the
IUR:


The
chemical
substance
is
imported
as
an
article
or
part
of
an
article.
An
article
is
defined
in
40
CFR
710.3(
d)
as
"
a
manufactured
item
(
1)
which
is
formed
to
a
specific
shape
or
design
during
manufacture,
(
2)
which
has
end­
use
function(
s)
dependent
in
whole
or
in
part
upon
its
shape
or
design
during
end
use,
and
(
3)
which
has
either
no
change
of
chemical
composition
during
its
end
use
or
only
those
changes
resulting
in
compositions
which
have
no
commercial
purpose
separate
from
that
of
the
article
and
that
may
occur
as
described
in
section
710.4(
d)(
5),
except
that
fluids
and
particles
are
not
considered
articles
regardless
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
14
of
shape
or
design."
EPA
considers
imported
items
as
articles
if
they
are
manufactured
in
a
specific
shape
or
design
for
a
particular
end­
use
application
and
this
design
is
maintained
as
an
essential
feature
in
the
finished
product.
Thus,
EPA
views
materials
such
as
metal
or
plastic
sheets,
wire,
coated
fabric,
rolled
carpet,
sheets
of
plywood,
and
other
similar
materials
as
articles,
even
if,
for
example,
subsequent
to
import
they
are
rolled
or
drawn
thinner,
cut,
printed,
laminated,
or
thermoformed,
so
long
as
they
meet
the
above
criteria.
Substances
that
are
part
of
such
articles
are
not
subject
to
reporting
under
the
IUR.
If
an
item
is
manufactured
in
a
particular
shape
for
the
purpose
of
shipping
convenience
and
the
shape
has
no
function
in
the
end
use,
it
would
not
be
considered
an
article.
Thus,
chemical
substances
that
are
part
of
items
such
as
metal
ingots,
billets,
and
blooms
are
subject
to
reporting
under
the
IUR.


The
chemical
substance
is
manufactured
as
an
impurity,
by­
product,
or
nonisolated
intermediate.
Sections
40
CFR
710.3(
d),
40
CFR
710.23,
and
40
CFR
720.30(
g)
provide
the
regulatory
definitions
of
these
terms.


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

Table
2­
5
shows
examples
of
these
reporting
exemptions.

Table
2­
5.
Examples
of
Reporting
Exemptions
Description
2006
Reporting
Requirement
Company
A
manufactures
400,000
pounds
of
a
chemical
intermediate
called
Chemical
X
during
the
production
of
a
polymer.
Chemical
X
is
manufactured
in
Reactor
1
and
is
subsequently
destroyed
when
reacted
with
other
chemicals.
Chemical
X
never
leaves
Reactor
1,
except
for
sampling
purposes.
Company
A
does
not
need
to
report
a
Form
U
for
Chemical
X
because
it
is
considered
to
be
a
non­
isolated
intermediate
and
is
therefore
fully
exempt.

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

Company
C
imports
10,000,000
pounds
of
Chemical
Z
in
the
form
of
thin
sheets.
Company
C
cuts
these
sheets
into
the
desired
size
and
shape,
which
are
sold
to
consumers.
Company
C
is
not
required
to
report
Chemical
Z
because
it
is
considered
to
be
an
article
and
therefore
exempt
from
reporting.
Table
2­
5
(
Continued)
DRAFT:
Chapter
2.0
Reporting
Requirements
Description
2006
Reporting
Requirement
2­
15
Company
D
imports
10,000,000
pounds
of
Chemical
W
in
the
form
of
pellets.
Company
D
subsequently
melts
and
molds
Chemical
W
into
the
desired
shape,
which
is
sold
directly
to
consumers.
Company
D
is
required
to
report
Chemical
W
because
they
imported
pellets
which
cannot
be
considered
articles.

Company
D
manufactures
10,000,000
pounds
of
Chemical
W.
Company
D
subsequently
sells
Chemical
W
to
Company
E
located
in
the
U.
S.
in
the
form
of
pellets.
Company
E
melts
and
molds
the
pellets.
Company
D
is
required
to
report.
Company
E
is
not
required
to
report
since
they
are
neither
manufacturing
nor
importing
Chemical
W.

2.3
Criterion
III:
What
Information
Do
You
Need
to
Report?

Now
that
you
have
determined
that
you
need
to
file
a
Form
U
for
a
chemical
substance,
you
should
determine
what
information
you
need
to
report.
All
persons
required
to
report
must
complete
and
submit
Parts
I
and
II
of
Form
U
(
see
Appendix
A
for
a
copy
of
the
form)
(
40
CFR
710.52(
c)).
Part
I
collects
basic
company
and
facility
identification
information.
Part
II
collects
chemical
identification
and
occupational
exposure
information
related
to
manufacturing
and
importing
chemical
substances.
Submitters
reporting
information
for
more
than
one
chemical
should
make
the
necessary
number
of
photocopies
of
Part
II
and
report
information
for
only
one
chemical
on
each
photocopy.
Submitters
using
electronic
forms
should
use
the
directions
provided
in
Appendix
D.

To
determine
if
you
need
to
complete
Part
III
of
Form
U,
you
should
answer
the
following
questions:


Did
you
manufacture
or
import
300,000
pounds
or
more
of
the
reportable
substance
at
any
single
site
during
the
reporting
year
(
e.
g.,
during
2005)?


Is
your
substance
inorganic,
listed
as
a
petroleum
process
stream,
or
listed
as
a
chemical
substance
partially
exempt
from
reporting?

Figure
2­
4
presents
a
decision
logic
diagram
to
assist
you
in
answering
these
questions.
The
following
subsections
explain
each
question
in
greater
detail.
Detailed
instructions
for
completing
Form
U
are
found
in
Chapter
4
of
this
document.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
16
Is
your
substance
inorganic
or
listed
as
a
petroleum
process
stream
or
listed
as
a
partial
exemption?
(
710.46)
Did
you
manufacture
300,000
pounds
or
more
of
the
substance?
(
710.52)

COMPLETE
PARTS
I,
II,
AND
III
OF
FORM
U.
Yes
No
No
CRITERION
III:
What
information
do
you
need
to
report?

Yes
COMPLETE
PARTS
I
AND
II
OF
FORM
U.

Figure
2­
4.
Decision
Logic
Diagram
for
Evaluating
Criterion
III
.

2.3.1
Do
You
Manufacture
and/
or
Import
the
Reportable
Substance
in
Quantities
of
300,000
Pounds
or
More?

If
you
produce
300,000
pounds
or
more
in
calendar
year
2005
of
a
reportable
substance
at
a
single
facility,
you
must
also
complete
Part
III
of
Form
U
for
each
chemical
meeting
the
300,000­
pound
threshold
(
40
CFR
710.52(
c)(
4)).
Part
III
collects
information
on
the
industrial,
commercial,
and
consumer
uses
of
the
chemical
substance
and
other
use­
related
exposure
information.
Submitters
reporting
information
for
more
than
one
chemical
should
make
the
necessary
number
of
photocopies
of
Part
III
and
report
information
for
only
one
chemical
on
each
photocopy.
Submitters
using
electronic
forms
should
use
the
directions
provided
in
Appendix
D.
Table
2­
6
provides
some
examples
of
when
Form
U,
Part
III
reporting
requirements
apply.
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
17
Table
2­
6.
Examples
of
Reporting
Requirements
for
Form
U,
Part
III
(
40
CFR
710.52(
c)(
4))

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

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

Company
C
has
two
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
130,000
pounds
of
Chemical
X
and
Site
2
manufactured
170,000
pounds
of
Chemical
X.
Company
C
is
not
required
to
complete
Part
III
for
Chemical
X
at
either
site
because
2005
production
was
less
than
300,000
pounds
at
each
site.
Company
C
should
complete
Parts
I
and
II
for
Chemical
X
at
both
sites.

Company
D
has
three
manufacturing
sites
for
Chemical
X.
In
2005,
Site
1
manufactured
10,000
pounds
of
Chemical
X,
Site
2
manufactured
30,000
pounds
of
Chemical
X,
and
Site
3
manufactured
350,000
pounds
of
Chemical
X.
Company
D
is
not
required
to
report
for
Chemical
X
for
Site
1
because
2005
production
was
less
than
25,000
pounds.
Company
D
must
complete
Parts
I
and
II
for
Chemical
X
at
Site
2
because
at
this
location
production
was
25,000
pounds
or
more
in
2005.
Company
D
must
complete
Parts
I,
II,
and
III
for
Chemical
X
at
Site
3
because
production
was
300,000
pounds
or
more
at
this
location.

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

In
2005,
Company
F
manufactured
700,000
pounds
of
a
liquid
that
contains
Chemical
X
at
50%
by
weight.
Company
F
manufactured
Chemical
X
via
a
chemical
reaction;
it
did
not
combine
existing
chemicals
to
form
a
mixture.
Company
F
must
complete
Parts
I,
II,
and
III
for
Chemical
X,
because
it
manufactured
350,000
pounds
of
Chemical
X
in
2005
and
Chemical
X
was
formed
by
a
chemical
reaction.

2.3.2
Does
Your
Reportable
Substance
Qualify
for
a
Partial
Exemption?

Three
categories
of
substances
are
exempt
from
this
reporting
requirement.
First,
manufacturers
and
importers
of
certain
petroleum
process
streams,
regardless
of
the
production
volume,
are
partially
exempt
and
do
not
need
to
complete
Part
III
of
Form
U
for
these
substances.
Second,
EPA
created
a
partial
exemption
for
specific
chemical
substances
where
EPA
has
identified
that
there
is
a
low
current
interest
in
the
IUR
processing
and
use
information
related
to
DRAFT:
Chapter
2.0
Reporting
Requirements
2­
18
the
chemical.
Third,
for
the
2006
submission
period
only,
inorganic
substances
are
also
partially
exempt.
These
three
categories
are
described
in
more
detail
below.

2.3.2.1
Petroleum
Process
Streams.
For
purposes
of
this
rule,
the
petroleum
process
streams
included
in
the
exemption
are
the
multicomponent
complex
chemical
substances
listed
by
CAS
Registry
Number
at
40
CFR
Part
710.46(
b)(
1)
and
in
Appendix
E.

The
chemical
substances
listed
as
petroleum
process
streams
were
derived
from
the
1983
publication
of
the
American
Petroleum
Institute
(
API)
entitled
Petroleum
Process
Stream
Terms
Included
in
the
Chemical
Substances
Inventory
Under
the
Toxic
Substances
Control
Act
(
TSCA).
Chemical
substances
listed
in
the
API
document
consisting
of
a
single­
component
chemical,
except
for
water,
are
not
considered
petroleum
process
streams
for
IUR
reporting
purposes
(
68FR
853,
January
7,
2003).
If
you
think
additional
petroleum
process
streams
should
be
added
to
the
list,
you
can
file
a
written
request
for
EPA
to
update
the
list.
Each
petition
should
only
address
petroleum
process
streams
that
have
a
CAS
Registry
Number.
A
petition
process
for
revising
the
list
of
exempted
chemical
substances
allows
anyone
to
submit
a
written
request
for
EPA
to
update
the
list
of
chemical
substances
covered
under
this
partial
exemption.
Additionally,
EPA
may
revise
the
list
on
its
own
initiative.

2.3.2.2
Partial
Exemption
for
Specific
Chemical
Substances.
EPA
created
a
partial
exemption
for
the
specific
chemical
substances
listed
at
40
CFR
710.46(
b)(
2)(
iv)
and
in
Appendix
E.
EPA
determined
there
is
a
low
current
interest
in
the
IUR
processing
and
use
information
related
to
these
chemicals.
Manufacturers
(
including
importers)
of
these
substances
are
exempt
from
reporting
the
information
requested
on
Part
III
of
Form
U
but
must
still
report
the
information
requested
on
Parts
I
and
II
of
Form
U
if
other
reporting
criteria
are
met
(
40
CFR
710.46(
b)).
A
petition
process
for
revising
the
list
of
exempted
chemical
substances
allows
anyone
to
submit
a
written
request
for
EPA
to
update
the
list
of
chemical
substances
covered
under
this
partial
exemption.
Additionally,
EPA
may
revise
the
list
on
its
own
initiative.

2.3.2.3
Partial
Exemption
for
Inorganic
Substances
in
2006.
For
the
2006
reporting
cycle,
manufacturers
(
including
importers)
of
inorganic
substances,
as
defined
in
40
CFR
710.46.(
b)(
3),
are
exempt
from
reporting
the
information
collected
by
Part
III
of
Form
U
for
those
substances.
Manufacturers
(
including
importers)
of
inorganic
substances
must
report
the
information
collected
by
Parts
I
and
II
of
Form
U
if
other
reporting
criteria
are
met
(
40
CFR
710.46(
b)).
You
must
complete
Part
III
for
inorganic
chemicals
you
manufacture
and/
or
import
in
quantities
equal
to
or
greater
than
300,000
pounds
for
all
reporting
cycles
following
the
2006
reporting
cycle
(
40
CFR
710.46(
b)(
3)).
DRAFT:
Chapter
3.0
When
You
Must
Report
3­
1
3.0
When
You
Must
Report
For
the
year
2006
reporting
cycle,
as
in
previous
reporting
cycles,
you
are
required
to
report
during
the
submission
period,
which
is
between
August
25
and
December
23
(
40
CFR
710.53).
However,
in
the
previous
reporting
cycles,
you
reported
information
from
the
latest
complete
corporate
fiscal
year
prior
to
the
submission
period.
EPA
has
changed
the
reporting
year
to
a
calendar­
year
basis.
This
means
that
the
information
to
be
reported
during
the
submission
period
from
August
25
to
December
23
in
the
year
2006
would
be
for
calendar
year
2005.
Subsequent
recurring
submission
periods
are
from
August
25
to
December
23
at
4­
year
intervals
after
the
first
submission
period
(
2010,
2014,
2018,
etc.)
(
40
CFR
710.53).

Your
submissions
must
be
postmarked
no
later
than
December
23,
2006
(
40
CFR
710.53).
If
you
are
required
to
report,
failure
to
file
your
report
during
this
period
is
a
violation
of
section
15
of
TSCA
and
may
subject
you
to
penalties
(
40
CFR
710.1(
c)).

Requests
for
searches
of
the
Master
Inventory
File
(
Section
2.1.1.3)
should
be
made
at
least
60
days
prior
to
the
close
of
the
submission
period
(
e.
g.,
October
25,
2006).
Otherwise,
EPA
cannot
guarantee
a
timely
response.
If
you
have
made
your
request
in
time,
you
will
be
allowed
15
business
days
from
the
date
of
receipt
of
EPA's
answer
or
until
the
end
of
the
submission
period,
whichever
is
later,
to
submit
the
report
for
the
substance
that
was
searched.
Any
other
reports
received
after
the
end
of
the
submission
period
will
be
considered
late
and
will
be
subject
to
enforcement
action.
DRAFT:
Chapter
4.0
Completing
Form
U
4­
1
4.0
Completing
Form
U
4.1
Form
of
Submission
Information
reported
for
the
IUR
must
be
submitted
either
on
electronic
media
(
not
email
or
on
a
printed
copy
of
Form
U
(
40
CFR
710.52).
Separate
forms
are
required
for
each
plant
site
(
40
CFR
710.52).
If
you
report
information
for
more
than
one
chemical
at
your
site,
you
should
make
the
necessary
number
of
photocopies
of
Parts
II
and
III
and
report
information
for
only
one
chemical
on
each
photocopy.
If
you
submit
electronically,
follow
the
instruction
in
Appendix
D.
Each
preprinted
copy
of
2006
Form
U
bears
an
individual
report
number.
EPA
will
assign
report
numbers
to
electronic
submissions
and
forms
obtained
from
the
Internet
when
they
are
received.
You
should
not
enter
any
information
in
the
report
number
box
in
the
upper
right
hand
corner
of
Form
U.
See
Chapter
7
for
information
on
obtaining
copies
of
Form
U.
Appendix
G
provides
sample
case
studies
to
illustrate
how
to
complete
Part
I
and
Part
II
of
Form
U.

4.2
Part
I
 
Section
I
Certification
4.2.1
Signature
(
Block
1.
A.
1)

The
certification
statement
must
be
signed
by
an
authorized
official
of
your
company
(
40
CFR
710.52(
1)(
a)).
This
statement
certifies
to
the
truth
and
accuracy
of
the
information
reported
and
of
the
confidentiality
claims
made
on
the
form.
By
certifying
to
the
truth
and
accuracy
of
the
information,
you
acknowledge
that
knowingly
providing
false
or
misleading
statements
may
be
punishable
by
fine
or
imprisonment
or
both
under
TSCA
section
15.
Signatures
should
be
made
in
black
ink
to
ensure
that
the
form
bears
a
legible
signature
that
can
be
microfiched
or
otherwise
archived.

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

4.2.2
Date
(
Block
1.
A.
2)

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

4.2.3
Name
and
Official
Title
(
Blocks
1.
A.
3
and
1.
A.
4)

Enter
the
name
and
title
of
the
person
who
signed
the
certification
in
the
respective
blocks.
DRAFT:
Chapter
4.0
Completing
Form
U
4­
2
4.3
Part
I
 
Section
II
Parent
Company
and
Technical
Contact
Information
4.3.1
Parent
Company
Name
(
Block
1.
B.
1)

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

4.3.2
Parent
Company
Dun
&
Bradstreet
Number
(
Block
1.
B.
2)

Dun
&
Bradstreet
assigns
separate
numbers
to
plant
sites
and
parent
companies;
make
sure
that
the
number
you
provide
EPA
belongs
to
the
parent
company
for
which
you
are
reporting.
If
the
parent
company
does
not
have
a
Dun
&
Bradstreet
number,
you
can
request
one
from
your
local
office
of
Dun
&
Bradstreet.
There
is
no
charge
for
this
service
and
you
are
not
required
to
disclose
sensitive
financial
information
to
get
a
number.
For
more
information
on
obtaining
a
Dun
&
Bradstreet
number,
see
www.
dnb.
com/
us.
If
you
are
already
listed
with
Dun
&
Bradstreet,
but
do
not
know
your
number,
you
can
call
1­
888­
814­
1435
for
assistance.

4.3.3
Technical
Contact
Name
(
Block
1.
B.
3)

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

4.3.4
Technical
Contact
Telephone
Number
and
E­
mail
Address
(
Blocks
1.
B.
4
and
1.
B.
5)

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

4.3.5
Technical
Contact
Mailing
Address
(
Blocks
1.
B.
6
through
1.
B.
10)

Enter
your
technical
contact
mailing
address,
using
standard
addressing
techniques
as
established
by
the
U.
S.
Postal
Service.
Post
office
box
numbers
are
acceptable
only
if
accompanied
by
a
street
address.
If
a
post
office
box
is
listed,
it
should
be
listed
after
the
street
address
in
Block
1.
B.
7
(
Address
Line
2).

4.4
Part
I
 
Section
III
Plant
Site
Identification
EPA
requires
the
following
information
to
be
reported
for
each
plant
site
at
which
a
reportable
chemical
substance
is
manufactured
(
including
imported)
in
amounts
greater
than
the
reporting
threshold:
the
plant
site
name,
plant
site
Dun
&
Bradstreet
number,
street
address,
city,
county
(
or
parish),
state,
and
zip
code.
The
site
for
a
chemical
substance
importer
is
the
site
of
the
operating
unit
within
the
importer's
organization
that
is
directly
responsible
for
importing
the
substance
and
that
controls
the
import
transaction;
in
some
cases,
it
may
be
the
organization's
DRAFT:
Chapter
4.0
Completing
Form
U
4­
3
headquarters
in
the
United
States.
EPA
will
assign
a
Facility
Identification
Number.
You
should
leave
this
part
blank.

4.4.1
Plant
Site
Name
(
Block
1.
C.
1)

Enter
the
full
name
of
the
plant
site.
Include
any
add­
on
terms
such
as
Inc.,
Ltd.,
L.
L.
C.,
etc.
In
some
cases,
this
information
may
be
the
same
as
that
reported
in
Block
1.
B.
1.

4.4.2
Plant
Site
Dun
&
Bradstreet
Number
(
Block
1.
C.
2)

Dun
&
Bradstreet
gives
separate
numbers
to
plant
sites
and
parent
companies;
make
sure
that
the
number
you
provide
EPA
belongs
to
the
individual
plant
site
for
which
you
are
reporting.
If
the
plant
site
does
not
have
a
Dun
&
Bradstreet
number,
you
can
request
one
from
your
local
office
of
Dun
&
Bradstreet.
There
is
no
charge
for
this
service
and
you
are
not
required
to
disclose
sensitive
financial
information
to
get
a
number.
For
more
information
on
obtaining
a
Dun
&
Bradstreet
number,
see
www.
dnb.
com/
us.
If
you
are
already
listed
with
Dun
&
Bradstreet,
but
do
not
know
your
number,
you
can
call
1­
888­
814­
1435
for
assistance.

4.4.3
Plant
Site
Street
Address
(
Blocks
1.
C.
3
through
1.
C.
8)

Enter
your
plant
site
mailing
address,
including
the
appropriate
county
or
parish,
using
standard
addressing
techniques
as
established
by
the
U.
S.
Postal
Service.
Post
office
box
numbers
are
acceptable
only
if
accompanied
by
a
street
address.
If
a
post
office
box
is
listed,
it
should
be
listed
after
the
street
address
in
Block
1.
C.
4
(
Address
Line
2).

4.5
Part
II
 
Section
I
Chemical
Identification
If
you
are
reporting
information
for
more
than
one
chemical,
make
the
necessary
number
of
photocopies
of
Part
II
and
report
information
for
only
one
chemical
on
each
photocopy.
If
you
are
using
electronic
forms,
follow
the
directions
provided
in
Appendix
D.

4.5.1
Chemical
Identifying
Number
(
Block
2.
A.
1)

The
IUR
currently
requires
manufacturers
(
including
importers)
to
report
both
the
specific
chemical
substance
name
and
the
CAS
Registry
Number
(
or
other
identifying
number)
of
each
reportable
chemical
substance
manufactured
(
including
imported)
in
amounts
over
25,000
pounds
per
year
(
40
CFR
710.52(
c)).

You
may
claim
the
identity
of
a
substance
that
is
listed
as
confidential
on
the
TSCA
Inventory
as
confidential
by
checking
the
CBI
box.
EPA
will
not
honor
a
chemical
identity
CBI
claim
for
a
substance
that
is
listed
on
the
nonconfidential
Public
Inventory.
No
CBI
claim
for
chemical
identity
will
be
accepted
unless
accompanied
by
a
separate
written
substantiation
for
each
chemical
substance
claimed
as
CBI;
see
Section
5.1
for
more
details
on
substantiating
CBI
claims.
Checking
this
box
does
not
protect
the
link
between
your
company
and
the
substance;
it
only
asserts
a
CBI
claim
for
the
specific
identity
of
the
substance.
To
claim
company
and/
or
plant
DRAFT:
Chapter
4.0
Completing
Form
U
4­
4
The
CAS
Registry
Number
is
the
preferred
identifier
for
chemical
substances
being
reported
as
part
of
the
IUR.
site
identities
as
CBI,
check
the
CBI
boxes
in
Part
II,
Section
II,
Blocks
2.
B.
1
and
2.
B.
2
(
see
Sections
4.6.1
and
4.6.2
below).

4.5.1.1
CAS
Registry
and
Other
Identifying
Numbers.
Every
chemical
substance
reported
on
Form
U
must
be
accompanied
by
its
CAS
Registry
Number
(
entered
into
Block
2.
A.
1
of
Part
II)
or
other
identifying
number
(
40
CFR
710.52(
c)(
3)).
The
printed
edition
of
the
TSCA
Inventory
contains
detailed
instructions
on
how
to
locate
the
CAS
Registry
Number
for
a
substance
listed.
When
you
report
a
CAS
Registry
Number,
please
verify
that
the
number
you
are
reporting
is
the
correct
number
for
your
substance.

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


EPA
Accession
Number;
or

PMN
Number.

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

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

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

4.5.1.2
Obtaining
CAS
Registry
and
Accession
Numbers
from
EPA.
If
you
previously
reported
on
a
chemical
to
EPA
but
are
unable
to
locate
an
identification
number
for
that
chemical
(
following
the
procedures
described
in
Chapter
2),
it
is
possible
that
the
chemical
is
DRAFT:
Chapter
4.0
Completing
Form
U
4­
5
no
longer
in
the
TSCA
Inventory.
In
this
case,
you
can
request
an
identifying
number
from
EPA.
Send
a
letter
to
the
following
address:

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

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

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

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

EPA
will
release
CAS
Registry
Numbers
or
Accession
Numbers
in
response
to
these
letters
only
for
substances
that
are
reportable
under
the
IUR.
Your
letter
should
be
received
no
later
than
November
12,
2006.
Otherwise,
EPA
cannot
guarantee
a
response
in
time
for
you
to
meet
your
reporting
obligations.

4.5.2
ID
Code
(
Block
2.
A.
2)

Enter
the
type
of
identifying
number
you
entered
in
Block
2.
A.
1,
as
shown
in
Table
4­
1.
DRAFT:
Chapter
4.0
Completing
Form
U
4­
6
Table
4­
1.
ID
Code
for
Chemical
Identifying
Numbers
If
the
Number
You
are
Reporting
in
Block
2.
A.
1
is
a(
n)
Enter
This
Code
in
Block
2.
A.
2
Accession
Number
A
CAS
Registry
Number
C
PMN
Number
P
4.5.3
Chemical
Name
(
Block
2.
A.
3)

Enter
the
specific
chemical
identity
of
the
chemical
substance
you
are
reporting
in
Block
2.
A.
3.
Enough
space
has
been
provided
so
that
the
chemical
name
should
fit.
Use
Chemical
Abstracts
Index/
Preferred
names
if
available.
You
can
find
names
of
nonconfidential
substances
in
the
Public
Inventory.
If
such
names
are
not
available,
use
nomenclature
that
completely
and
accurately
describes
the
chemical
substance.

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

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

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

4.6
Part
II
 
Section
II
Manufacturing
Information
The
following
subsections
describe
the
manufacturing
information
required
to
be
reported
for
each
chemical
substance.

4.6.1
Company
Information
CBI
(
Block
2.
B.
1)

Checking
the
CBI
box
in
this
block
asserts
a
confidentiality
claim
for
the
link
between
your
company
and
the
chemical
substance.
Checking
other
CBI
boxes
on
the
form
will
not
protect
this
link.
You
may
claim
this
connection
CBI
for
some
chemical
substances
for
which
you
are
reporting,
while
not
making
the
claim
for
others
(
each
chemical
substance
is
reported
on
a
separate
copy
of
Parts
II
and
III
of
the
Form).
DRAFT:
Chapter
4.0
Completing
Form
U
4­
7
4.6.2
Plant
Site
CBI
(
Block
2.
B.
2)

To
claim
the
link
between
the
site
of
manufacture/
import
and
the
chemical
identity
as
confidential,
check
the
"
Plant
Site
CBI"
box.
You
may
claim
this
connection
CBI
for
some
chemical
substances
for
which
you
are
reporting,
while
not
making
the
claim
for
others
(
each
chemical
substance
is
reported
on
a
separate
copy
of
Parts
II
and
III
of
the
form.
To
assert
a
claim
of
confidentiality
for
plant
site
information,
you
are
required
to
substantiate
the
claim
in
writing
for
each
Part
II
of
the
form
submitted
(
40
CFR
710.58(
c))
(
see
Section
5.2).
If
you
fail
to
substantiate
the
plant
site
CBI
claim
in
accordance
with
the
applicable
regulations,
EPA
may
make
the
information
available
to
the
public
without
further
notice
to
you.

4.6.3
Site
Limited
Status
(
Block
2.
B.
3)

If
you
manufacture
the
chemical
substance
at
the
plant
site
identified
and
do
not
distribute
the
chemical
substance
or
any
mixture
containing
that
substance
outside
the
plant
site
for
commercial
purposes,
enter
"
Y"
in
the
space
next
to
the
CBI
box.
Otherwise,
enter
"
N."
Note:
you
cannot
report
an
imported
chemical
substance
as
site­
limited
(
40
CFR
710.43).
To
claim
this
information
as
confidential
for
the
substance,
enter
"
X"
in
the
CBI
box.
You
may
claim
the
fact
that
a
substance
is
not
site­
limited
as
confidential,
if
appropriate.

4.6.4
Activity
(
Manufacture
and/
or
Import)
(
Block
2.
B.
4)

Check
all
boxes
that
describe
the
activities
at
your
site.
For
the
purpose
of
IUR,
manufacture
means
to
manufacture
or
produce
for
commercial
purposes.
Import
is
defined
as
bringing
any
chemical
substance
or
any
chemical
substance
as
part
of
a
mixture
or
article
into
the
customs
territory
of
the
United
States.
If
you
both
manufacture
and
import
the
same
chemical
substance,
please
check
both
boxes.
Check
the
CBI
box
to
claim
the
nature
of
the
activity
(
i.
e.,
manufacture
vs.
importation)
as
confidential
for
the
substance.
Claiming
activity
as
CBI
does
not
protect
the
link
between
your
company
and
the
substance;
that
link
will
not
be
protected
unless
you
check
the
CBI
box
next
to
the
company
name
(
see
Section
4.6.1).

4.6.5
Production
Volume
(
Block
2.
B.
5)

Enter
the
production
volume,
in
pounds.
If
you
both
manufacture
and
import
a
particular
substance,
add
the
manufacture
and
import
volumes
together
and
report
the
total
volume
(
40
CFR
710.52(
c)(
3)(
iv)).
Report
the
quantity
to
at
least
two
significant
figures;
it
should
be
accurate
to
the
extent
known
to
or
reasonably
ascertainable
by
you.
Production
volumes
should
be
reported
in
numeric
format
(
i.
e.,
50,000
or
6,352,000)
since
the
Agency's
automated
equipment
cannot
read
volumes
other
than
numeric
format.
For
example,"
2
million"
or
"
Ex10"
are
not
acceptable,
nor
are
abbreviations
such
as
M
(
12,000,000
=
12M)
or
K
(
50,000
=
50K).
Check
the
CBI
box
to
claim
production
volume
as
confidential.

4.6.6
Production
Volume
Range
(
Block
2.
B.
6)

If
you
made
a
CBI
claim
for
production
volume,
you
are
allowed
to
claim
the
production
volume
range
corresponding
to
the
reported
production
volume
number
as
CBI;
check
the
CBI
box
to
claim
this
range
as
CBI.
This
claim
is
separate
from
a
CBI
claim
for
the
specific
DRAFT:
Chapter
4.0
Completing
Form
U
4­
8
production
volume.
Table
4­
2
lists
the
production
volume
ranges.
EPA
will
assign
a
range
to
the
specific
production
volume
number
reported
in
Part
II,
Block
2.
B.
5.

Table
4­
2.
Production
Volume
Ranges
Production
Volume
Ranges
(
in
pounds)

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

4.6.7
Number
of
Workers
(
Block
2.
B.
7)

EPA
requires
that
you
report
your
estimate
of
the
total
number
of
workers
reasonably
likely
to
be
exposed
to
the
chemical
substance
at
each
reporting
site
(
40
CFR
710.52(
c)(
3)(
vi)).
For
Block
2.
B.
7,
report
the
total
number
of
workers
reasonably
likely
to
be
exposed
at
the
manufacturing
site.
For
each
substance,
report
the
range
code
that
corresponds
to
the
appropriate
number
of
workers
as
shown
in
Table
4­
3.
When
an
import
site
aggregates
and
reports
the
quantity
of
chemical
imported,
the
administrative
site
should
likewise
aggregate
and
report
the
number
of
exposed
workers.
For
imported
substances,
your
site
may
not
have
any
workers
reasonably
likely
to
be
exposed.
You
should
report
code
W1
to
reflect
fewer
than
ten
workers
exposed.

EPA
defines
"
reasonably
likely
to
be
exposed"
as
an
exposure
to
a
chemical
substance
that,
under
foreseeable
conditions
of
manufacture,
processing,
distribution
in
commerce,
or
use
of
the
chemical
substance,
is
more
likely
to
occur
than
not
to
occur
(
40
CFR
710.43).
Such
exposures
during
manufacturing
would
normally
include,
but
not
be
limited
to:
charging
reactor
vessels;
drumming;
bulk
loading;
cleaning
equipment;
maintenance
operations;
materials
handling
and
transfers;
sampling;
and
analytical
operations.
Covered
exposures
include
exposures
through
any
route
of
entry
(
inhalation,
ingestion,
skin
contact
or
absorption,
etc.),
but
exclude
accidental
exposures.
Workers
that
would
be
exposed
if
not
for
the
use
of
personal
protective
equipment
and
engineering
controls
should
be
included
in
the
reported
estimate.
For
example,
if
a
worker
wears
a
dust
mask
and
gloves
while
handling
a
powdered
chemical
substance,
then
that
worker
should
be
reported
as
a
worker
reasonably
likely
to
be
exposed.
Check
the
CBI
box
to
claim
the
number
of
workers
as
confidential.
DRAFT:
Chapter
4.0
Completing
Form
U
4­
9
Table
4­
3.
Codes
for
Reporting
Number
of
Industrial
Workers
Potentially
Exposed
Code
Range
of
Workers
Potentially
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
4.6.8
Maximum
Concentration
(
Block
2.
B.
8)

You
are
required
to
report
the
maximum
concentration,
measured
by
weight,
of
your
reportable
chemical
substance
at
the
time
it
is
reacted
on­
site
to
produce
a
different
chemical
substance
or
as
it
leaves
the
plant
site
(
40
CFR
710.52(
c)(
3)(
vii)).
The
quantity
should
be
accurate
to
the
extent
known
or
reasonably
obtainable
by
you.

For
each
substance,
select
the
maximum
concentration
of
the
substance
from
the
ranges
listed
in
Table
4­
4.
If
the
maximum
concentration
falls
between
two
ranges,
round
estimates
to
the
nearest
1
percent
using
standard
rounding
procedures.
Report
the
code
that
corresponds
to
the
appropriate
range.
Report
the
maximum
concentration
regardless
of
the
various
physical
forms
in
which
the
chemical
may
be
sent
off­
site.
Check
the
CBI
box
to
claim
the
maximum
concentration
as
confidential.

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

M1
Less
than
1%
by
weight
M2
From
1%
to
30%
by
weight
M3
From
31%
to
60%
by
weight
M4
From
61%
to
90%
by
weight
M5
Greater
than
90%
by
weight
DRAFT:
Chapter
4.0
Completing
Form
U
4­
10
Information
regarding
processing
or
use
activities
occurring
at
sites
not
under
your
control
must
be
reported
only
to
the
extent
that
it
is
readily
obtainable
by
you
(
40
CFR
710.52(
c)(
4)).
Readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgment
based
on
past
experience
for
similar
chemical
substances
in
the
same
or
similar
markets,
and/
or
any
reasonable
projections
of
likely
processing
and
use
scenarios
for
the
chemical
substance.
4.6.9
Physical
Form
and
Percentage
of
Production
Volume
(
Blocks
2.
B.
9
through
2.
B.
14)

You
are
required
to
report
all
physical
forms
of
the
chemical
substance
at
the
time
it
is
reacted
or
as
it
leaves
your
site
and
the
percentage
of
production
volume
for
each
physical
form
(
40
CFR
710.52(
c)(
3)).
The
six
types
of
physical
forms
are
listed
in
Example
4­
1
and
on
Form
U.
You
must
report
the
percentage
of
each
physical
form
reacted
on­
site
or
sent
off­
site
rounded
off
to
the
closest
10
percent
and
the
sum
of
all
percentages
must
not
add
up
to
greater
than
100
percent
(
40
CFR
710.52
(
c)(
3)(
ix)).
If
the
reported
chemical
substance
is
sent
off­
site
in
more
than
one
physical
form,
you
must
report
all
the
physical
forms
(
40
CFR
710.52(
c)(
3)(
viii)).
In
Section
"
a"
of
the
physical
form
question,
check
the
box
for
each
physical
form
that
applies
to
the
chemical
substance.
Check
the
CBI
box
to
claim
the
physical
form
as
confidential.
In
Section
"
b"
of
the
physical
form
question,
report
the
percentage
of
production
volume
for
each
physical
form
reported
in
Section
a.
Check
the
CBI
box
to
claim
the
percentage
of
production
volume
as
confidential.

Example
4­
1.
Determining
Percentage
of
Production
Volume
Company
A
manufactures
100,000
pounds
of
Chemical
X.
48%
of
the
production
volume
is
produced
as
dry
powder,
24%
is
produced
as
a
pellets,
24%
as
a
liquid
solution,
and
4%
as
a
water­
wet
solid.
Company
A
should
submit
the
following:

Dry
Powder
50%
Pellets
or
Large
Crystals
20%
Water
Wet
Solid
0%
Other
Solid
0%
Gas
or
Vapor
0%
Liquid
20%
Total
90%

4.7
Part
III
 
Processing
and
Use
Information
You
must
complete
Part
III
of
Form
U
for
reportable
chemical
substances
manufactured
(
including
imported)
for
commercial
purposes
in
an
amount
of
300,000
pounds
or
more
at
any
one
site
during
calendar
year
2005,
or
during
the
calendar
year
at
4­
year
intervals
thereafter
(
40
CFR
710.52(
c)(
4)).
If
you
manufacture
the
chemical
substance
in
an
amount
less
than
300,000
pounds,
you
do
not
need
to
complete
Section
III;
instead,
check
the
N/
A
box.
If
you
report
information
for
more
than
one
chemical,
make
the
necessary
number
of
photocopies
of
Part
III
and
report
information
for
only
one
chemical
on
each
photocopy.
You
must
report
industrial
processing
and
use
information
for
each
reportable
chemical
substance
at
sites
under
your
control,
and
at
sites
that
receive
a
reportable
chemical
substance
from
you
directly
or
indirectly
DRAFT:
Chapter
4.0
Completing
Form
U
4­
11
(
including
through
a
broker/
distributor,
from
a
customer
of
yours,
etc.)
(
40
CFR
710.52(
c)(
4)).
You
must
report
information
regarding
processing
or
use
activities
occurring
at
sites
not
under
your
control
only
to
the
extent
that
it
is
readily
obtainable
by
you
(
40
CFR
710.52(
c)(
4)).
Readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgment
based
on
past
experience
for
similar
chemical
substances
in
the
same
or
similar
markets,
and/
or
any
reasonable
projections
of
likely
processing
and
use
scenarios
for
the
chemical
substance.
EPA
defines
readily
obtainable
information
as
information
known
by
management
and
supervisory
employees
of
the
submitter
company
who
are
associated
with
manufacturing,
processing,
technical
services,
or
marketing
of
the
reportable
chemical
substance.
Extensive
file
searches
are
not
required.

4.7.1
Part
III
 
Section
I
Industrial
Processing
and
Use
Data
(
Blocks
3.
A.
1
through
3.
A.
10)

In
Section
I,
you
are
required
to
report
for
the
chemical
substance
up
to
10
unique
combinations
of
the
following
data
elements:
process
or
use
code
(
described
in
Section
4.7.1.1),
five­
digit
NAICS
code
(
described
in
Section
4.7.1.2),
and
industrial
function
category
code
(
IFC
code,
described
in
Section
4.7.1.3)
(
40
CFR
710.52(
c)(
4)(
i)(
C)).
Table
4­
7
provides
examples
of
reporting
these
codes.
A
processing
and
use
code,
NAICS
code,
and
industrial
function
category
code
combination
sufficiently
defines
a
potential
exposure
scenario
for
risk
screening
and
prioritysetting
purposes.
For
each
of
these
unique
combinations,
you
are
also
required
to
report
the
percentage
of
production
volume
(
described
in
Section
4.7.1.4),
a
number
of
sites
code
(
described
in
Section
4.7.1.5),
and
a
number
of
workers
code
(
described
in
Section
4.7.1.6)
for
each
specific
combination
(
40
CFR
710.52(
c)(
4)(
i)).
If
more
than
10
unique
combinations
apply
to
a
chemical
substance,
you
need
only
report
the
10
combinations
for
the
chemical
substance
that
cumulatively
represent
the
largest
percentage
of
production
volume,
measured
by
weight
(
40
CFR
710.52(
c)(
4)(
i)(
C)).
If
any
information
is
not
readily
obtainable,
the
block
corresponding
to
that
data
element
should
be
left
blank.

4.7.1.1
Type
of
Process
or
Use
Code.
To
the
extent
that
it
is
readily
obtainable,
report
the
process
or
use
code,
shown
in
Table
4­
5,
that
corresponds
to
the
appropriate
processing
or
use
operation
for
the
particular
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
Check
the
CBI
box
to
claim
the
process
or
use
code
as
confidential.

Table
4­
5.
Codes
Corresponding
to
Processing
or
Use
Operations
Code
Operation
PC
Processing
as
a
reactant
PF
Processing
 
incorporation
into
formulation,
mixture,
or
reaction
product
PA
Processing
 
incorporation
into
article
PK
Processing
 
repackaging
U
Use
 
nonincorporative
activities
DRAFT:
Chapter
4.0
Completing
Form
U
4­
12
The
definitions
of
the
codes
are
presented
below
and
in
Appendix
F:

PC:
Chemical
substance
is
used
in
chemical
reactions
for
the
manufacturing
of
another
chemical
substance
or
product.

PF:
Chemical
substance
is
added
to
a
product
(
or
product
mixture)
prior
to
further
distribution
of
the
product.

PA:
Chemical
substance
becomes
an
integral
component
of
an
article
distributed
for
industrial,
trade,
or
consumer
use.

PK:
Preparation
of
a
chemical
substance
for
distribution
in
commerce
in
a
different
form,
state,
or
quantity.
This
includes
transferring
the
substance
from
a
bulk
container
into
smaller
containers.
This
definition
does
not
apply
to
sites
that
only
relabel
or
redistribute
the
reportable
chemical
substance
without
removing
the
chemical
substance
from
the
container
in
which
it
is
received
or
purchased.

U:
Chemical
substance
is
otherwise
used.
For
example
as
a
chemical
processing
or
manufacturing
aid.

4.7.1.2
Five­
Digit
NAICS
Code.
The
North
American
Industry
Classification
System
(
NAICS)
codes
published
by
the
Office
of
Management
and
Budget
(
OMB)
have
superceded
the
1987
Standard
Industrial
Classification
(
SIC)
code
system.
Report
the
five­
digit
NAICS
code
that
corresponds
to
the
appropriate
industrial
setting
for
the
particular
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
The
NAICS
code
classification
system
is
being
used
to
describe
the
industrial
setting
in
which
chemical
exposures
may
occur.
You
are
required
to
report
the
five­
digit
NAICS
code(
s)
corresponding
to
your
sites,
as
well
as
at
the
sites
that
receive
a
reportable
chemical
substance
from
you
either
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer
of
yours,
etc.)
and
that
process
and
use
the
reportable
chemical
substance
to
the
extent
that
it
is
readily
obtainable
(
40
CFR
710.52(
c)(
4)(
i)(
B)).
However,
EPA
does
not
intend
for
you
to
survey
your
customers
or
distributors
to
precisely
identify
the
appropriate
NAICS
codes
at
your
"
downstream"
sites.
Check
the
CBI
box
to
claim
the
NAICS
code
as
confidential.

For
additional
information
on
NAICS
codes
and
tables
cross
referencing
the
NAICS
codes
and
SIC
codes,
refer
to
the
following
website:
http://
www.
census.
gov/
epcd/
www/
naics.
html.
The
NAICS
codes
can
contain
a
maximum
of
6
digits,
although
you
are
only
required
to
report
to
the
first
five
digits
for
the
IUR.

4.7.1.3
Industrial
Function
Category
(
IFC)
Code.
Report
the
IFC
code,
shown
in
Table
4­
6,
that
corresponds
to
the
appropriate
function
for
the
particular
combination
of
process/
use
code,
NAICS
code,
and
IFC
code
(
40
CFR
710.52(
c)(
4)(
i)(
C)).
Definitions
of
each
category
are
available
in
Appendix
F.
Check
the
CBI
box
to
claim
the
IFC
code
as
confidential.
DRAFT:
Chapter
4.0
Completing
Form
U
4­
13
Table
4­
6.
Codes
for
Reporting
IFCs
Codes
Industrial
Function
Categories
U01
Adsorbents
and
absorbents
U02
Adhesives
and
binding
agents
U03
Aerosol
propellants
U04
Agricultural
chemicals
(
nonpesticidal)
U05
Anti­
adhesive
agents
U06
Bleaching
agents
U07
Coloring
agents,
dyes
U08
Coloring
agents,
pigments
U09
Corrosion
inhibitors
and
antiscaling
agents
U10
Fillers
U11
Fixing
agents
U12
Flame
retardants
U13
Flotation
agents
U14
Fuels
U15
Functional
fluids
U16
Intermediates
U17
Lubricants
U18
Odor
agents
U19
Oxidizing
agents
U20
pH­
regulating
agents
U21
Photosensitive
chemicals
U22
Plating
agents
and
metal
surface
treating
agents
U23
Processing
aid,
not
otherwise
listed
U24
Process
regulators,
used
in
vulcanization
or
polymerization
processes
U25
Process
regulators,
other
than
polymerization
or
vulcanization
processes
U26
Reducing
agents
U27
Solvents
(
for
cleaning
or
degreasing)
U28
Solvents
(
which
become
part
of
product
formulation
or
mixture)
U29
Solvents
(
for
chemical
manufacture
and
processing
and
are
not
part
of
product
at
greater
than
1
percent
by
weight)
U30
Stabilizers
U31
Surface
active
agents
U32
Viscosity
adjustors
U33
Other
4.7.1.4
Percentage
of
Production
Volume.
Estimate
the
percentage
of
production
volume
that
is
attributable
to
each
unique
combination
of
process/
use
code,
NAICS
code,
and
IFC
code.
The
quantity
should
be
accurate
to
the
extent
known
or
readily
obtainable
by
you.
Round
the
estimates
to
the
nearest
10
percent
of
production
volume
(
40
CFR
710.52(
c)(
4)(
i)(
D)).
You
may
not
round
a
particular
combination
that
accounts
for
5
percent
or
less
of
the
total
production
volume
of
a
reportable
chemical
substance
to
0
percent
if
the
production
volume
attributable
to
that
combination
is
greater
than
or
equal
to
300,000
pounds
(
40
CFR
710.52(
c)(
4)(
i)(
D)).
In
such
cases,
you
must
report
the
percentage
of
production
volume
DRAFT:
Chapter
4.0
Completing
Form
U
4­
14
attributable
to
that
combination
to
the
nearest
1
percent
of
production
volume
(
40
CFR
710.52(
c)(
4)(
i)(
D)).
This
exception
to
the
general
rounding
rule
is
to
ensure
that
adequate
use
information
is
reported
for
gross
production
volumes
of
chemical
substances.
EPA
selected
the
300,000­
pound
level
for
consistency
with
the
proposed
threshold
for
reporting
exposure
and
use
data.
To
claim
this
information
as
confidential,
check
the
CBI
box.

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

Table
4­
7.
Examples
of
Reporting
Industrial
Processing
and
Use
Information
Description
2006
Reporting
Requirement
Site
1
manufactures
500,000
pounds
of
Chemical
X
for
processing
for
incorporation
into
a
mixture.
All
of
the
production
is
for
use
under
industrial
NAICS
code
32519.
67%
of
the
production
(
335,000
pounds)
is
used
as
a
dye
and
33%
(
165,000
pounds)
of
the
production
is
used
as
a
pigment.
On
line
2.
A.
1
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U07
for
IFC,
and
70%
for
production
volume.
On
line
2.
A.
2
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U08
for
IFC,
and
30%
for
production
volume.

Site
1
manufactures
500,000
pounds
of
Chemical
X
for
processing
for
incorporation
into
a
mixture.
All
of
the
production
is
for
use
under
NAICS
code
32519.
97%
of
the
production
(
485,000
pounds)
is
used
as
a
coloring
agent
for
dyes
and
3%
of
the
production
(
15,000
pounds)
is
used
as
a
coloring
agent
for
pigments.
On
line
2.
A.
1
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U07
for
IFC,
and
100%
for
production
volume.
The
3%
of
production
used
for
pigments,
IFC
U08,
does
not
need
to
be
reported
since
production
volume
because
that
case
is
less
than
300,000
pounds.

Site
1
manufactures
12,000,000
pounds
of
Chemical
X
for
processing
for
incorporation
into
a
mixture.
All
of
the
production
is
for
use
under
NAICS
code
32519.
97%
(
11,640,000
pounds)
of
the
production
is
used
as
a
coloring
agent
for
dyes
and
3%
of
the
production
(
360,000
pounds)
is
used
as
a
coloring
agent
for
pigments.
On
line
2.
A.
1
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U07
for
IFC,
and
100%
for
production
volume.
Since
the
use
in
pigments,
IFC
U08,
accounts
for
300,000
pounds
or
more,
on
line
2.
A.
2
of
Form
U,
enter
PF
for
type
of
process
or
use,
32519
for
NAICS
code,
U08
for
IFC,
and
3%
for
production
volume.

4.7.1.5
Number
of
Sites
Code.
Report
an
estimate
of
the
total
number
of
industrial
sites,
including
those
beyond
your
control,
that
process
or
use
each
reported
chemical
substance
manufactured
(
including
imported)
by
you,
as
described
by
each
unique
combination
of
process/
use
code,
NAICS
code,
and
IFC
code
to
the
extent
that
it
is
readily
obtainable
(
40
CFR
710.52(
c)(
4)(
i)(
E)).
In
the
event
you
both
manufacture
(
including
import)
and
process
or
use
the
same
reportable
chemical
substance
at
the
reporting
plant
site,
your
site
must
be
counted
as
both
a
manufacturing
site
in
Part
II
of
Form
U
and
a
processing
or
use
site
reported
in
Part
III
of
Form
U
(
40
CFR
710.52(
c)(
4)).
For
each
substance,
report
the
code
listed
in
Table
4­
8
that
DRAFT:
Chapter
4.0
Completing
Form
U
4­
15
corresponds
to
the
appropriate
number
range.
To
claim
this
information
as
confidential,
check
the
CBI
box.

Table
4­
8.
Codes
for
Reporting
Numbers
of
Sites
Codes
Range
S1
Less
than
10
S2
From
10
to
25
S3
From
26
to
100
S4
From
101
to
250
S5
From
251
to
1,000
S6
From
1,001
to
10,000
S7
Greater
than
10,000
4.7.1.6
Number
of
Workers
Code.
EPA
requires
that
you
report
your
estimate
of
the
total
number
of
workers,
including
those
at
sites
not
under
your
control,
that
are
reasonably
likely
to
be
exposed
to
the
chemical
substance
at
facilities
that
process
or
use
the
substance
in
a
manner
that
corresponds
to
each
unique
combination
of
process/
use
code,
NAICS
code,
and
IFC
code
(
40
CFR
710.52(
c)(
4)(
i)(
F)).
You
need
only
report
this
information
to
the
extent
that
it
is
readily
obtainable.
If
this
information
is
not
readily
obtainable,
leave
the
box
corresponding
to
this
data
element
blank.
For
each
substance,
report
the
range
code
listed
in
Table
4­
9
that
corresponds
to
the
appropriate
number
of
workers.

Table
4­
9.
Codes
for
Reporting
Number
of
Industrial
Workers
Potentially
Exposed
Code
Range
of
Workers
Potentially
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
EPA
defines
"
reasonably
likely
to
be
exposed"
as
an
exposure
to
a
chemical
substance
under
foreseeable
conditions
of
manufacture,
processing,
distribution
in
commerce,
or
use
of
the
chemical
substance
(
40
CFR
710.43).
Activities
in
which
a
worker
is
reasonably
likely
to
be
exposed
to
a
chemical
substance
include,
but
are
not
limited
to:
charging
reactor
vessels;
drumming;
bulk
loading;
cleaning
equipment;
maintenance
operations;
materials
handling
and
transfers;
sampling;
and
analytical
operations.
Such
exposures
during
industrial
uses
could
include,
but
not
be
limited
to,
inhalation
of
vapors,
deposition
of
chemicals
on
the
skin
during
spray
applications
of
the
chemical
(
paints,
coatings,
etc.),
and,
misting
during
roll
coating/
printing
DRAFT:
Chapter
4.0
Completing
Form
U
4­
16
operations.
Covered
exposures
include
exposures
through
any
route
of
entry
(
inhalation,
ingestion,
skin
contact
or
absorption,
etc.),
but
exclude
accidental
exposures.
Workers
that
would
be
exposed
if
not
for
the
use
of
personal
protective
equipment
and
engineering
controls
should
be
included
in
the
reported
estimate.
For
example,
if
a
worker
wears
a
dust
mask
and
gloves
while
handling
a
powdered
chemical
substance,
then
that
worker
should
be
reported
as
a
worker
reasonably
likely
to
be
exposed.
Check
the
CBI
box
to
claim
the
number
of
workers
as
confidential.

4.7.2
Part
III
 
Section
II
Consumer
and
Commercial
End­
Use
Exposure­
Related
Data
(
Blocks
3.
B.
1
through
3.
B.
10)

For
purposes
of
IUR
reporting,
a
commercial
use
means
the
use
of
a
chemical
substance
or
mixture
in
a
commercial
enterprise
providing
saleable
goods
or
a
service
(
such
as
painting
contractors
using
paint
products)
(
40
CFR
710.43).
A
consumer
use,
on
the
other
hand,
means
the
use
of
a
chemical
substance
that
is
directly,
or
as
part
of
a
mixture,
sold
to
or
made
available
to
consumers
for
their
own
use
in
or
around
a
permanent
or
temporary
household
or
residence
or
in
or
around
a
school
or
recreational
area
(
40
CFR
710.43).

You
are
required
to
report
information
concerning
the
commercial
and
consumer
end
uses
of
each
reportable
chemical
substance
manufactured
(
including
imported)
at
sites
you
control
and
at
sites
controlled
by
people
to
whom
you
have
either
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer,
etc.)
distributed
the
reportable
chemical
substance
(
40
CFR
710.52(
c)(
4)).
As
with
the
industrial
processing
and
use
information,
this
requirement
applies
only
to
each
chemical
substance
manufactured
(
including
imported)
in
annual
quantities
of
300,000
pounds
or
more,
and
you
are
required
only
to
report
information
to
the
extent
that
it
is
readily
obtainable.
If
this
information
is
not
readily
obtainable,
leave
the
box
corresponding
to
this
data
element
blank.

4.7.2.1
Consumer
and
Commercial
Product
Category
Code.
You
must
designate
up
to
10
commercial
and
consumer
product
categories
for
which
the
reportable
chemical
substance
is
used
by
selecting
from
the
codes
listed
in
Table
4­
10
(
40
CFR
710.52(
c)(
4)(
ii)(
A)).
The
definitions
of
these
categories
are
listed
in
Appendix
F.
Information
regarding
product
category
codes
at
sites
beyond
your
control
must
be
reported
only
to
the
extent
that
it
is
readily
obtainable
by
you
(
40
CFR
710.52(
c)(
4)(
ii)(
A)).
If
more
than
10
codes
apply,
you
need
report
only
the
codes
for
the
chemical
substance
that
cumulatively
represent
the
largest
percentage
of
production
volume,
measured
by
weight
(
40
CFR
710.52(
c)(
4)(
ii)(
A)).
To
claim
this
information
as
confidential,
check
the
CBI
box.
If
the
information
is
not
readily
obtainable
leave
the
box
corresponding
to
this
data
element
blank.
Readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgment
based
on
past
experience
for
similar
chemical
substances
in
the
same
or
similar
markets,
and/
or
any
reasonable
projections
of
likely
processing
and
use
scenarios
for
the
chemical
substance.
DRAFT:
Chapter
4.0
Completing
Form
U
4­
17
Table
4­
10.
Codes
for
Reporting
Commercial
and
Consumer
Product
Categories
Codes
Category
C01
Artists'
supplies
C02
Adhesives
and
sealants
C03
Automotive
care
products
C04
Electrical
and
electronic
products
C05
Glass
and
ceramic
products
C06
Fabrics,
textiles
and
apparel
C07
Lawn
and
garden
products
(
nonpesticidal)

C08
Leather
products
C09
Lubricants,
greases
and
fuel
additives
C10
Metal
products
C11
Paper
products
C12
Paints
and
coatings
C13
Photographic
chemicals
C14
Polishes
and
sanitation
goods
C15
Rubber
and
plastic
products
C16
Soaps
and
detergents
C17
Transportation
products
C18
Wood
and
wood
furniture
C19
Other
4.7.2.2
Use
in
Children's
Product.
You
must
determine,
within
each
commercial
and
consumer
product
category
reported,
whether
any
amount
of
each
reportable
chemical
substance
manufactured
(
including
imported)
by
you
is
present
in
or
on
any
consumer
products
intended
for
use
by
children
age
14
or
younger,
regardless
of
the
concentration
of
the
substance
remaining
in
or
on
the
product
(
40
CFR
710.52(
c)(
4)(
ii)(
B)).
If
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
a
consumer
product
intended
for
use
by
children,
then
you
would
report
a
"
Y"
in
the
appropriate
box
in
the
Children's
Product
column.
If
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
not
used
in
a
consumer
product
intended
for
use
by
children,
then
you
would
report
an
"
N"
in
the
appropriate
box
in
the
Children's
Product
column.
If
this
information
is
not
readily
obtainable,
please
enter
a
"?"
in
the
appropriate
box.
To
claim
this
information
as
confidential,
check
the
CBI
box.

EPA
defines
"
intended
for
use
by
children"
to
mean
the
chemical
substance
or
mixture
is
used
in
a
product
that
is
specifically
intended
for
use
by
children
age
14
or
younger
(
40
CFR
710.43).
Your
chemical
substance
or
mixture
is
intended
for
use
by
children
when
you
answer
"
yes"
to
at
least
one
of
the
following
questions
for
the
product
into
which
your
chemical
substance
or
mixture
is
incorporated:
DRAFT:
Chapter
4.0
Completing
Form
U
4­
18
(
1)
Is
the
product
commonly
recognized
(
i.
e.,
by
a
reasonable
person)
as
being
intended
for
children
age
14
or
younger;

(
2)
Does
the
manufacturer
of
the
product
state
through
product
labeling
or
other
written
materials
that
the
product
is
intended
or
will
be
used
by
children
age
14
or
younger;
or
(
3)
Is
the
advertising,
promotion,
or
marketing
of
the
product
aimed
at
children
age
14
or
younger?

Using
this
definition,
if
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
a
product
that
is
intended
to
be
used
by
children
age
14
or
younger,
you
must
report
this
on
the
Form
U.

Table
4­
11
illustrates
some
examples
of
"
Use
in
Children's
Product."
For
example,
EPA
believes
that
certain
products,
like
crayons,
coloring
books,
diapers,
and
toy
cars
­
to
name
a
few
­
are
typically
to
be
used
by
children
age
14
or
younger.
As
such,
if
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
crayons
and
toy
cars,
report
a
"
Y"
in
the
Children's
Product
column
for
categories
C01
and
C10.

Certain
products,
such
as
household
cleaning
products,
automotive
supplies,
and
lubricants,
are
not
typically
intended
to
be
used
by
children
age
14
or
younger.
As
such,
if
you
determine,
based
on
readily
obtainable
information,
that
your
chemical
substance
or
mixture
is
used
in
automotive
care
products
and
lubricants,
report
an
"
N"
in
the
Children's
Use
column
for
categories
C03
and
C09.

Table
4­
11.
Examples
of
Use
in
Children's
Product
Codes
Category
Examples
C01
Artists'
supplies
Crayons,
children's
markers
C02
Adhesives
and
sealants
Craft
glue,
model
glue
C03
Automotive
care
products
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C04
Electrical
and
electronic
products
Electronic
games,
remote
control
cars,
toys
C05
Glass
and
ceramic
products
Porcelain
dolls
C06
Fabrics,
textiles
and
apparel
Pajamas
C07
Lawn
and
garden
products
(
non­
pesticidal)
Lawn
&
gardening
tools
designed
specifically
for
children,
e.
g.,
kids
rake
C08
Leather
products
Shoes,
jackets,
baseball
gloves
C09
Lubricants,
greases
and
fuel
additives
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C10
Metal
products
Toy
trucks,
toy
cars,
wagon
C11
Paper
products
Diapers,
baby
wipes,
coloring
books
Table
4­
11
(
Continued)
DRAFT:
Chapter
4.0
Completing
Form
U
Codes
Category
Examples
4­
19
C12
Paints
and
coatings
Finger
paints,
water
color
kits
intended
for
children's
use
C13
Photographic
chemicals
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C14
Polishes
and
sanitation
goods
Typically
products
in
this
category
are
not
likely
to
be
intended
for
use
by
children
14
or
younger
C15
Rubber
and
plastic
products
Pacifiers,
action
figures,
balls
C16
Soaps
and
detergents
Baby
shampoo,
children's
bubble
bath
C17
Transportation
products
Child's
car
seat
C18
Wood
and
wood
furniture
Baby
cribs,
changing
tables,
wooden
toys
C19
Other
Other
items
specifically
intended
for
use
by
children
age
14
or
younger
4.7.2.3
Percentage
of
Production
Volume.
You
are
required
to
estimate
the
percentage
of
your
production
volume
for
each
reportable
chemical
substance
that
is
attributable
to
each
specific
commercial
and
consumer
end
use
carried
out
at
sites
under
your
control,
as
well
as
at
sites
that
receive
a
reportable
chemical
substance
from
you
either
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer
of
the
submitter,
etc.),
to
the
extent
that
such
information
is
readily
obtainable
(
40
CFR
710.52(
c)(
4)(
ii)(
C)).
Round
estimates
to
the
nearest
10
percent
of
production
volume
(
40
CFR
710.52(
c)(
4)(
ii)(
C)).
However,
you
may
not
round
a
commercial
and
consumer
product
category
that
accounts
for
5
percent
or
less
of
the
total
production
volume
of
a
reportable
chemical
substance
to
0
percent
if
the
production
volume
attributable
to
that
commercial
and
consumer
product
category
is
greater
than
or
equal
to
300,000
pounds
(
40
CFR
710.52(
c)(
4)(
ii)(
C)).
In
such
cases,
you
must
report
the
percentage
of
production
volume
attributable
to
that
commercial
and
consumer
product
category
to
the
nearest
1
percent
of
the
production
volume
(
40
CFR
710.52(
c)(
4)(
ii)(
C)).
This
exception
to
the
general
rounding
rule
will
ensure
that
adequate
use
information
is
reported
for
gross
production
volumes
of
chemical
substances.
EPA
selected
the
300,000­
pound
threshold
for
consistency
with
the
proposed
threshold
for
reporting
processing
and
use
data.
To
claim
this
information
as
confidential
for
this
substance,
check
the
CBI
box.

The
total
percentage
of
production
volumes
reported
may
add
up
to
more
than
100
percent,
given
that
you
are
reporting
production
volumes
to
the
nearest
10
percent.
The
total
percentage
of
production
volume
may
add
up
to
less
than
100
percent
if
you
cannot
readily
obtain
information
about
how
all
of
your
production
volume
is
used
in
commercial
and
consumer
products
or
there
are
more
than
10
commercial
or
consumer
product
categories
applicable
to
your
chemical
substance.

4.7.2.4
Maximum
Concentration
Code.
You
are
required
to
report
estimates,
in
ranges,
of
the
maximum
concentration
(
measured
by
weight)
of
each
reportable
chemical
DRAFT:
Chapter
4.0
Completing
Form
U
4­
20
substance
likely
to
be
present
in
commercial
and
consumer
products
manufactured
(
including
imported)
at
sites
under
your
control
and
at
sites
where
your
commercial
and
consumer
products
are
distributed
directly
or
indirectly
(
including
through
a
broker/
distributor,
from
a
customer,
etc.)
(
40
CFR
710.52(
c)(
4)(
ii)(
D)).
Such
information
is
required
only
to
the
extent
that
it
is
readily
obtainable
by
you;
otherwise
leave
the
box
corresponding
to
this
data
element
blank.
The
reporting
range
codes
are
the
same
as
those
listed
in
Table
4­
4.
To
claim
this
information
as
confidential,
check
the
CBI
box.
DRAFT:
Chapter
5.0
How
to
Assert
Confidentiality
Claims
5­
1
5.0
How
to
Assert
Confidentiality
Claims
Under
the
proper
circumstances,
information
submitted
to
EPA
under
the
IUR
can
be
claimed
confidential.
However,
such
claims
will
not
be
accepted
and
honored
if
they
are
not
asserted
at
the
time
information
is
submitted
to
EPA
or
if
they
are
submitted
in
a
manner
inconsistent
with
the
rule
and
reporting
instructions.

You
can
claim
certain
information
submitted
to
EPA
under
this
rule
as
confidential
if
you
believe
that
doing
so
is
warranted
under
the
substantive
criteria
for
determining
confidentiality
found
within
40
CFR
2.208.
EPA's
procedures
for
processing
and
reviewing
confidentiality
claims
are
set
forth
at
40
CFR
Part
2,
Subpart
B.
EPA
strongly
encourages
you
to
review
confidentiality
claims
carefully
to
ensure
that
the
information
in
question
falls
under
the
protection
of
TSCA
section
14
and
fully
meets
the
substantive
criteria
within
the
Part
2
regulations
referred
to
above.

To
claim
information
as
confidential,
you
must
check
the
appropriate
boxes
on
Form
U
and
have
an
authorized
official
sign
the
certification
statement
on
the
reporting
form
(
40
CFR
710.58(
a)).
If
you
fail
to
do
so,
EPA
could
release
the
information
to
the
public
without
further
notice
to
you.
As
reflected
in
the
regulations,
by
signing
the
certification
statement
you
certify
that
your
claims
of
confidentiality
are
made
in
good
faith.
Procedures
for
claiming
information
submitted
electronically
(
such
as
a
submission
on
diskette)
as
confidential
are
specified
in
Chapter
6.
CBI
must
not
be
submitted
by
e­
mail.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

Specific
procedures
for
CBI
claims
of
chemical
identity,
manufacturing
plant
and
plant
site
information,
and
chemical
production
volume
information
are
addressed
below.
Table
5­
1
summarizes
the
special
considerations
for
these
data
elements.

Table
5­
1.
Special
Considerations
for
Asserting
Confidentiality
Claims
Data
Element
Confidentiality
Claim
Requirement
Chemical
Identity
Check
CBI
box
in
Part
II
Section
A,
and
submit
answers
to
questions
in
Table
5­
2.
See
40
CFR
710.58(
b)(
1).

Manufacturing
Plant
Site
Identity
Check
CBI
box
in
Part
II
Block
2.
B.
2
and
submit
written
answers
to
questions
in
Table
5­
3.
See
40
CFR
710.58(
c)(
1).

Chemical
Production
Volume
Check
the
CBI
box
in
Part
II
Block
2.
B.
5
and
determine
if
CBI
protection
is
warranted
for
the
corresponding
range
listed
in
Table
5­
4.
If
the
range
also
warrants
CBI
protection,
check
the
CBI
box
in
Block
2.
B.
6.
DRAFT:
Chapter
5.0
How
to
Assert
Confidentiality
Claims
5­
2
5.1
Chemical
Identity
You
may
assert
a
confidentiality
claim
for
the
specific
identity
of
a
chemical
substance
only
if
EPA
treats
that
substance
identity
as
confidential
in
the
TSCA
Inventory
at
the
time
your
report
is
submitted
(
i.
e.,
the
substance
is
not
on
the
Public
Inventory)
(
40
CFR
710.58(
b)).
Both
confidential
and
nonconfidential
substances
can
be
included
in
the
same
submission.
Confidential
substances
can
be
included
in
diskette
submissions
(
see
Chapter
6
for
further
discussion
of
diskette
submission
procedures).

A
claim
of
confidentiality
for
the
identity
of
a
chemical
will
not
be
accepted
unless
accompanied
by
a
separate
written
substantiation
for
each
chemical
substance
claimed
as
CBI.
To
assert
a
claim
of
confidentiality
for
the
identity
of
a
reportable
chemical
substance,
you
must
submit
detailed
written
answers
to
the
questions
at
40
CFR
710.58(
b)(
1),
which
are
repeated
in
Table
5­
2.
In
addition,
an
authorized
official
from
your
company
must
sign
and
date
Form
U.
The
answers
must
be
complete
and
specific
to
the
chemical
substance
in
question.
If
any
of
the
information
contained
in
the
answers
to
these
questions
is
asserted
to
contain
CBI,
you
must
clearly
identify
the
information
that
is
claimed
confidential
by
marking
the
specific
information
on
each
page
with
a
label
such
as
"
confidential
business
information,"
"
proprietary,"
or
"
trade
secret"
(
40
CFR
720.25).
If
the
required
substantiation
does
not
accompany
your
Form
U,
EPA
may
make
the
chemical
identities
reported
on
the
form
available
to
the
public
without
further
notice
to
you.
See
Section
2.1.1.3
for
CBI
packing
instructions.

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

Table
5­
2.
Substantiation
Questions
To
Be
Answered
When
Making
Chemical
Identity
CBI
Claims
(
from
40
CFR
710.58(
b))

No.
Question
1.
What
harmful
effects
to
your
competitive
position,
if
any,
do
you
think
would
result
from
the
identity
of
the
chemical
substance
being
disclosed
in
connection
with
reporting
under
the
IUR?
How
could
a
competitor
use
such
information?
Would
the
effects
of
disclosure
be
substantial?
What
is
the
causal
relationship
between
the
disclosure
and
the
harmful
effects?

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

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

4.
Has
the
identity
of
the
chemical
substance
been
kept
confidential
to
the
extent
that
your
competitors
do
not
know
it
is
being
manufactured
or
imported
for
a
commercial
purpose
by
anyone?
Table
5­
2
(
Continued)
DRAFT:
Chapter
5.0
How
to
Assert
Confidentiality
Claims
No.
Question
5­
3
5.
Is
the
fact
that
the
chemical
substance
is
being
manufactured
(
including
imported)
for
a
commercial
purpose
available
to
the
public,
for
example,
in
technical
journals,
libraries,
or
State,
local,
or
Federal
agency
public
files?

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

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

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

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

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

11.
Has
EPA,
another
Federal
agency,
or
any
Federal
court
made
any
pertinent
confidentiality
determinations
regarding
this
chemical
substance?
If
so,
please
attach
copies
of
such
determinations.

5.2
Manufacturing
Plant
Site
Identity
Under
the
IUR,
you
may
assert
a
claim
of
confidentiality
for
the
identity
of
the
manufacturing
facility
if
release
of
that
identity
would
reveal
confidential
business
information
as
contemplated
under
Section
14
of
TSCA.
EPA
believes
claims
for
CBI
should
be
limited
to
circumstances
in
which
they
are
absolutely
necessary
and
legally
justified.

To
assert
a
claim
of
confidentiality,
you
are
required
to
check
the
CBI
box
at
Block
2.
B.
2
of
Part
II
on
the
reporting
form
indicating
a
confidentiality
claim
for
plant
site
identity
information
and
you
are
required
to
substantiate
that
claim
(
40
CFR
710.58(
c)).
To
do
this,
you
must
submit
with
Form
U
detailed
written
answers
to
the
two
questions
at
40
CFR
710.58(
c)(
1),
which
are
also
listed
in
Table
5­
3.
In
addition,
an
authorized
official
from
your
company
must
sign
and
date
Form
U
(
40
CFR
710.58(
c)(
1)).
This
upfront
substantiation
is
not
required
for
company
information
CBI
claims
(
Block
2.
B.
1
on
Form
U).
Please
note
that
both
plant
site
and
company
information
claims
are
to
be
made
in
conjunction
with
a
specific
chemical
substance
on
page
2
of
Form
U.
For
instance,
if
you
report
four
chemical
substances
on
one
Form
U
(
by
photocopying
additional
pages
of
Part
II
and
III)
you
are
able
to
claim
CBI
for
plant
site
identity
for
one
chemical
while
releasing
information
for
the
other
three.
DRAFT:
Chapter
5.0
How
to
Assert
Confidentiality
Claims
5­
4
Table
5­
3.
Substantiation
Questions
To
Be
Answered
When
Making
Plant
Site
Identity
CBI
Claims
No.
Question
1.
Has
site
information
been
linked
with
a
chemical
identity
in
any
other
Federal,
state,
or
local
reporting
scheme?
For
example,
is
the
chemical
identity
linked
to
a
facility
in
a
filing
under
the
EPCRA
section
311,
namely
through
a
Material
Safety
Data
Sheet
(
MSDS)?
If
so,
identify
all
such
schemes.
Was
the
linkage
claimed
as
confidential
in
any
of
these
instances?

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

If
you
assert
that
any
of
the
information
contained
in
the
answers
to
these
questions
contains
CBI,
you
must
clearly
identify
the
information
that
is
claimed
confidential
by
marking
the
specific
information
on
each
page
with
a
label
such
as
"
confidential
business
information,"
"
proprietary,"
or
"
trade
secret"
(
40
CFR
720.25).
If
no
claim
of
confidentiality
is
indicated
on
the
Form
U
submitted
to
EPA
under
this
part,
or
if
confidentiality
claim
substantiation
is
not
submitted
with
Form
U
,
EPA
may
make
the
information
available
to
the
public
without
further
notice
to
you.
See
Section
2.1.1.3
for
CBI
packaging
instructions.

5.3
Chemical
Production
Volume
Information
Under
the
IUR,
you
may
check
the
appropriate
box
on
Form
U
to
assert
a
claim
of
confidentiality
for
chemical
production
volume
information,
if
the
information
qualifies
as
confidential
under
Section
14
of
TSCA
and
the
substantive
criteria
under
40
CFR
Part
2.
Additionally,
if
you
do
assert
a
claim
of
confidentiality
for
your
specific
production
volume,
you
may
also
choose
to
determine
if
CBI
protection
is
warranted
for
production
volume
information
in
ranges.
The
ranges
are
similar
to
those
used
for
the
original
TSCA
Inventory
and
are
listed
in
Table
5­
4.
If
you
determine
that
your
production
volume
range
also
warrants
CBI
protection,
you
must
check
the
appropriate
box
on
Form
U
for
claiming
this
information
as
CBI
(
40
CFR
710.58(
a)).

Table
5­
4.
Production
Volume
Ranges
Production
Volume
Ranges
(
in
pounds)

At
least
25,000
but
less
than
300,000
At
least
300,000
but
less
than
1,000,000
At
least
1,000,000
but
less
than
10,000,000
At
least
10,000,000
but
less
than
50,000,000
At
least
50,000,000
but
less
than
100,000,000
At
least
100,000,000
but
less
than
500,000,000
At
least
500,000,000
but
less
than
1,000,000,000
DRAFT:
Chapter
5.0
How
to
Assert
Confidentiality
Claims
Production
Volume
Ranges
(
in
pounds)

5­
5
1,000,000,000
or
greater
5.4
Additional
Data
Elements
You
may
claim
the
information
reported
under
the
IUR
confidential.
Form
U
contains
confidential
business
information
(
CBI)
boxes
for
the
data
elements
requested
in
Parts
II
and
III
of
the
Form.
To
assert
a
claim
of
confidentiality
enter
an
"
X"
in
the
CBI
box
for
that
data
element
as
discussed
in
Section
4.0.
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
1
6.0
How
to
Submit
Your
Form
U
to
EPA
EPA
will
mail
a
reporting
package
(
consisting
of
a
copy
of
Form
U
and
a
copy
of
the
Instructions
for
Reporting
for
Partial
Updating
of
the
TSCA
Inventory
Data
Base)
to
those
companies
that
reported
in
the
IUR
reporting
period
that
occurred
immediately
prior
to
the
current
reporting
period.
If
you
did
not
receive
a
reporting
package
but
are
required
to
report,
you
may
request
a
copy
of
the
reporting
package
from
EPA
by
calling
the
EPA
TSCA
Hotline
at
(
202)
554­
1404
or
TDD
(
202)­
554­
0551,
or
you
may
send
an
e­
mail
message
to
the
EPA
TSCA
Hotline
at
TSCA­
Hotline@
epa.
gov.
If
you
wish
to
send
a
written
request
for
this
information,
write
to:

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

6.1
Sending
Forms
to
EPA
You
must
use
the
EPA
form
identified
as
"
Form
U"
to
submit
written
information
in
response
to
the
requirements
of
this
rule
(
40
CFR
710.59(
a)).
Section
7.3
presents
the
procedures
for
obtaining
copies
of
Form
U.

You
must
submit
your
completed
written
and/
or
electronic
reporting
form(
s),
along
with
the
accompanying
Certification
Letter
and
CBI
Substantiation
Letter,
to
EPA
at
the
following
address
(
40
CFR
710.59(
d)):

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


The
chemical
identity
originally
reported
was
incomplete
or
inaccurate;


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

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

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

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

6.3
Recordkeeping
Requirements
The
Inventory
regulations
require
you
to
retain
records
on
IUR
reports
for
5
years
after
the
effective
date
of
the
applicable
reporting
period
(
40
CFR
710.57).
For
example,
if
you
submit
an
IUR
report
in
reporting
year
2006,
you
would
be
required
to
retain
the
records
on
which
the
report
is
based
until
December
23,
2011.

As
long
as
the
records
are
maintained
in
a
manner
consistent
with
normal
business
practice,
you
may
determine
their
exact
format.
Required
records
include
those
that
show
the
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
3
production
volume,
plant
site,
and
site­
limited
status
of
each
substance
reported.
If
a
substance
is
not
reported
because
its
site­
specific
annual
production
is
less
than
25,000
pounds,
EPA
suggests
you
maintain
records
to
document
your
reasons
for
not
filing
Form
U.

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

6.4
Special
Instructions
for
Importers
and
Foreign
Suppliers
This
section
applies
to
importers
who
do
not
know
the
specific
chemical
identity
of
a
substance
because
the
foreign
supplier
chooses
to
keep
it
confidential.
If
you
are
such
an
importer,
you
are
still
responsible
for
ensuring
that
the
information
is
submitted
to
EPA
(
40
CFR
720.25).
You
can
accomplish
this
by
having
your
foreign
supplier
complete
some
of
the
information
on
Form
U,
as
follows:

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

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

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

4.
On
the
original
form,
sign
the
certification
statement,
enter
the
technical
contact,
and
complete
Parts
I
through
IV
for
each
chemical
substance.
In
Part
II,
Section
I,
Block
2.
A.
1,
instead
of
entering
the
identifying
number,
enter
the
trade
name
or
other
designation
by
which
you
know
each
chemical
substance.
Leave
Block
2.
A.
2
blank.
Check
the
"
Chemical
CBI"
box
only
if
you
wish
to
claim
the
identities
of
the
chemicals
identified
on
the
form
as
confidential
(
you
must
answer
the
substantiation
questions
described
in
Section
5.1).
Foreign
suppliers
are
responsible
for
their
own
CBI
claims.
Send
this
original
form
to
EPA.

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

6.
The
foreign
supplier
should
enter
technical
contact­
company
information
on
the
copy
(
the
technical
contact
listed
here
should
be
the
foreign
supplier),
complete
Parts
I
through
IV,
and
enter
the
appropriate
specific
chemical
identities
in
Part
II,
Section
I.
Make
sure
that
your
supplier
understands
which
chemical
identities
belong
with
each
copy
of
the
Form
U.
If
the
foreign
supplier
wishes
to
claim
the
chemical
identities
as
confidential,
the
supplier
should
check
the
"
CBI"
box
and
submit
a
substantiation
as
described
in
Section
5.1.
The
supplier
should
include
with
Form
U
a
letter
stating
that
this
information
is
being
submitted
by
a
foreign
DRAFT:
Chapter
6.0
How
to
Submit
Your
Report
to
EPA
6­
4
supplier
on
behalf
of
the
importer,
who
should
be
identified.
Information
in
the
letter
may
be
claimed
as
confidential
by
circling
or
bracketing
the
text
to
be
protected
and
marking
the
page
"
CONFIDENTIAL."
Failure
to
so
mark
this
information
may
result
in
EPA
making
the
information
available
to
the
public
without
further
notice
to
the
supplier.
The
foreign
supplier
should
then
send
the
form
and
letter
to
EPA.

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

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

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

7.2.2
Obtaining
the
Public
Inventory
in
Computer­
Readable
Format
The
Public
Inventory
is
available
on
computer
tape,
diskettes,
and
CD­
ROM.
These
can
be
obtained
from
the
National
Technical
Information
Service
(
703­
487­
4650).
The
computer
tape
version
consists
of
two
tapes.
The
first
tape,
the
Inventory
Preferred
Name
File,
is
sorted
by
CAS
Registry
Number.
It
contains
the
CAS
Registry
Number,
CA
Index/
Preferred
Name,
molecular
formula,
and
if
applicable,
the
substance
definition
and
appropriate
EPA
flags
(
including
the
"
XU"
flag
for
substances
exempt
from
reporting
under
the
Inventory
Update
Rule)
for
nonconfidential
substances.
The
second
tape,
the
Inventory
Synonym
Name
file,
contains
the
DRAFT:
Chapter
7.0
How
to
Obtain
Copies
of
Documents
Cited
in
These
Instructions
7­
2
same
data
elements
as
the
first
tape
but
differs
in
two
ways.
First,
it
is
sorted
by
chemical
name,
not
CAS
Registry
Number.
Second,
in
addition
to
the
CA
Index/
Preferred
names,
this
file
also
includes
valid
names
(
synonyms)
as
supplied
to
EPA
by
Inventory
submitters.
In
contrast
to
the
printed
version
of
the
Public
Inventory,
which
includes
CAS­
derived
synonyms,
the
synonyms
listed
on
this
tape
are
only
those
reported
to
EPA
by
Inventory
submitters.

The
CD
ROM
version
contains
the
information
on
both
computer
tapes
combined,
with
duplicate
information
removed.
CAS
Registry
Numbers
are
listed
in
numerical
order.

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

Contact
the
following
for
ordering
information
for
these
products:

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

TSCA
Hotline
U.
S.
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
(
7408M)
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Telephone:
(
202)
554­
1404
DRAFT:
Chapter
8.0
How
to
Request
Assistance
with
Reporting
8­
1
8.0
How
To
Request
Assistance
with
Reporting
Write
to
the
address
below
if
you
need
additional
information
on
or
assistance
with:


Determining
your
reporting
obligations;


Mechanics
of
completing
Form
U;


Entering
data
onto
a
computer
diskette
for
submission;
and

Determining
the
status
of
forms/
diskettes
you
have
submitted.

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

You
can
also
call
(
202)
554­
1404
for
assistance.
