Comments
by
Participants
in
the
Public
Meeting
on
the
Draft
Instruction
Manual
for
the
2006
Updating
of
the
TSCA
Chemical
Substance
Inventory
Meeting
Held
on
October
15,
2003
in
Chicago,
Illinois
A
public
meeting
was
held
by
the
Economics,
Exposure,
and
Technology
Division
of
EPA's
Office
of
Pollution
Prevention
and
Toxics
in
conjunction
with
a
Synthetic
Organic
Chemicals
Manufacturer's
Association
(
SOCMA)
meeting
on
October
15,
2003
in
Chicago,
Illinois.
The
purpose
of
the
meeting
was
to
receive
comments
on
the
clarity,
comprehensiveness,
and
utility
of
the
draft
Instruction
Manual
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database.
The
draft
Instruction
Manual
details
how
to
respond
to
the
information
collection
requirements
of
the
Inventory
Update
Rule,
40
CFR
Part
710,
which
was
substantially
modified
by
amendments
promulgated
on
January
7,
2003.
Thirty­
two
persons
representing
industry
and
trade
groups,
the
entities
affected
by
the
regulation,
attended
the
meeting.
In
addition
to
comments
received
at
the
meeting,
EPA
invited
participants
to
submit
written
comments
and
questions.
The
comments
received
at
the
meeting
are
listed
below.

Chapter
1:
Introduction
No
comments
or
questions
Chapter
2:
Reporting
Requirements
and
Chapter
3:
When
to
Report
1.
Are
minerals
naturally
occurring?
2.
Clarify
that
the
25,000
pound
threshold
is
per
site.
3.
What
is
the
threshold
for
hydrates?
4.
For
what
time
period
do
you
complete
Form
U
(
calendar
year
or
fiscal
year)?
5.
Does
the
small
manufacturer
threshold
increase
for
inflation?
6.
Clarify
the
small
manufacturer
exemption
and
the
100,000
pound
threshold.
7.
How
should
imports
be
reported?
What
is
the
site
of
import?
8.
How
do
companies
petition
for
a
partial
exemption?
9.
Mixtures
 
How
do
you
report
a
mixture
made
up
of
three
different
chemicals?
10.
Can
you
petition
for
a
category
of
chemicals
to
be
partially
exempt?
11.
What
type
of
information
should
be
included
in
requests
for
a
partial
exemption?
12.
How
do
you
report
if
you
are
importing
proprietary
chemicals?
13.
Clarify
the
partial
exemption
deadline
and
the
purpose
of
the
partial
exemption?
14.
Has
the
rationale
for
the
chemicals
that
are
currently
partially
exempt
been
explained?
15.
What
is
the
reporting
period?
16.
What
constitutes
`
control'
in
the
definition
of
importer?

Chapter
4:
Completing
Form
U
1.
What
are
the
qualifications
for
the
certifying
official?
2.
A
commenter
is
concerned
about
certifying
for
all
the
parts
of
the
form,
especially
Part
III.
What
are
the
repercussions?
More
information
is
needed
on
the
readily
obtainable
standard.
3.
The
certification
statement
is
different
in
this
version
of
the
manual.
The
commenter
is
concerned
about
the
statement
`
the
amounts
and
values
in
this
report
are
accurate
based
on
reasonable
estimates
using
data
available....'
What
is
meant
by
data
available?
Is
a
paper
trail
required
to
document
the
data
reported?
What
documentation
is
required?
4.
Is
the
technical
contact
for
the
parent
site
or
plant
site?
5.
Can
you
have
different
technical
contacts
for
different
sites?
6.
Why
isn't
Block
2.
A.
1
named
CAS
number?
7.
More
space
is
needed
to
report
chemical
name.
8.
Why
is
the
CAS
number
the
preferred
identifier.
The
submitter
stated
their
company
had
been
asked
to
revise
submitted
IUR
forms
to
use
the
PMN
number
used
on
submittals
from
previous
years.
9.
The
Instruction
Manual
has
examples
of
workers
likely
to
be
exposed
but
should
also
included
workers
that
are
not
likely
to
be
exposed
(
i.
e.
administrative
staff).
10.
Is
there
a
minimum
duration
for
the
exposures
to
be
reported
(
i.
e.
one
minute
of
exposure
does
not
need
to
be
reported)?
11.
Are
contractors
included
in
exposed
workers?
How
should
employee
turnover
be
counted?
12.
Does
the
maximum
concentration
question
include
lab
samples?
13.
Would
averages
be
a
better
way
to
report
concentrations?
14.
On
page
4­
11
the
first
paragraph
is
conflicting.
The
paragraph
states
readily
obtainable
information
may
include
estimates
that
use
your
best
professional
judgement....
The
paragraph
goes
on
to
say
that
readily
obtainable
information
is
information
known
by
management
and
supervisory
employees.
Are
estimates
required?
This
issue
needs
to
be
clarified.
15.
A
commenter
is
concerned
that
submitters
will
not
be
able
to
determine
the
top
10
type
of
process/
use,
NAICS,
and
IFC
combination
because
they
don't
know
the
production
volume
for
the
chemicals.
How
do
you
report
if
you
have
greater
than
10
combinations
but
do
not
have
information
about
the
relative
volumes
of
the
combinations.
16.
A
commenter
thinks
the
rule
will
lead
to
questionnaires
being
sent
to
suppliers.
Part
III
will
require
a
lot
of
effort.
Is
this
what
EPA
is
intending?
17.
Why
do
the
steps
leading
up
to
preparing
a
final
product
need
to
be
reported?
18.
A
commenter
stated
that
other
programs
such
as
Responsible
Care
will
not
have
all
the
information
required
for
downstream
reporting
and
therefore
can
not
be
relied
upon
for
help
with
submitting
Form
U.
19.
The
instructions
state
to
leave
the
blocks
blank
if
any
information
is
not
readily
obtainable.
How
can
the
form
be
certified
if
some
things
are
intentionally
left
blank.
An
additional
code
is
need
to
report
that
the
information
is
not
known.
20.
How
will
commenters
know
if
there
comments/
questions
about
the
IUR
Instruction
Manual
have
already
been
submitted
to
EPA.
21.
In
responding
to
the
children's
use
question,
is
an
answer
of
`
Y'
a
definitive
yes
or
is
it
a
`
it
may
be/
there
is
a
possibility
it
could.'
22.
Does
Part
III
only
apply
for
that
chemical
substance
and
not
if
it
is
changed
into
another
chemical
substance.
23.
How
do
you
complete
the
form
if
all
importing
is
done
through
a
parent
company.
24.
Most
companies
have
two
sides
 
the
regulatory
side
(
environmental,
TSCA)
and
the
commercial/
marketing
people.
It
will
be
a
tremendous
burden
to
complete
the
form
and
bring
everything
together
since
the
marketing
people
will
need
to
be
consulted
to
complete
Part
III.
25.
Many
EPA
forms
estimate
how
long
it
should
take
to
complete
the
form.
Will
this
be
included?
26.
Could
an
`
NA'
or
`
unknown'
be
added
to
the
tables
of
reporting
codes?

Appendix
G:
Case
Studies
1.
If
the
anhydrous
CuSO4
is
only
a
portion
of
the
hydrated
form.
How
can
the
maximum
concentration
code
be
>
93%.
2.
In
the
pigment
case
study,
the
pigment
is
suspended
in
a
solution.
Why
is
this
reported
as
a
liquid
in
the
physical
form
section.
3.
In
setting
up
the
case
studies,
EPA
gives
estimates
of
number
of
workers
exposed.
How
were
these
estimates
made.
4.
Exposures
will
be
overestimated
since
multiple
sites
may
be
sending
chemicals
to
the
same
downstream
site.
5.
Is
reporting
required
if
you
import
articles?

Chapter
5:
CBI
1.
The
portion
of
the
TRI
certification
statement
about
CBI
is
not
included
in
the
new
certification
statement.
