1
Instructions
for
Reporting
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database
Franklyn
Hall,
EPA
Economics,
Exposure
and
Technology
Division
Office
of
Pollution
Prevention
and
Toxics
Chris
Hibshman,
ERG
Lori
Weiss,
ERG
Dallas,
Texas
March
7,
2005
2

Background
Information

Reporting
Requirements

Completing
Form
U

CBI

Submitting
Information
to
EPA

Case
Study
1
 
Ammonia
Phosphate

Special
Topics
°
Mixtures,
Impurities,
By­
products,
Wastes
°
Importers/
Exporters
°
TSCA/
non­
TSCA
Use

Case
Study
2
 
Acetone

Case
Study
3
 
Xylene

Case
Study
4
 
EDTA

Revisions
Rule
Training
Agenda
3
Background
Information
4
If
you 
manufacture
or
import
a
chemical
at
a
single
site
in
volumes
of
25,000
pounds
or
more
during
calendar
year
2005,
you
may
need
to
report
under
the
Inventory
Update
Rule
(
IUR)
40
CFR
Part
710.
5
What
is
the
IUR?


The
TSCA
Inventory,
initiated
in
1977,
lists
over
80,000
TSCA
chemicals
in
commerce
in
the
U.
S.


The
Inventory
Update
Rule
(
IUR)
updates
production,

processing,
and
use
information
for
a
subset
of
chemicals
on
the
TSCA
Inventory.


The
next
submission
occurs
in
2006
and
will
include
TSCA
chemicals
manufactured
or
imported
in
2005.
6

Manufacturers
and
importers
of
chemicals
listed
on
the
TSCA
Inventory:

°
If
your
production
volume
is
25,000
lbs
or
greater
(
annual,
per
site),
then
report
site
identification
and
manufacturing
information
(
Parts
I
and
II
of
Form
U).

°
If
your
production
volume
is
300,000
lbs
or
greater
(
annual,
per
site),
also
report
downstream
processing
and
use
information
(
Part
III
of
Form
U).

Who
needs
to
report
under
the
IUR
in
2006?

Applicability
and
reporting
exemptions
will
be
covered
in
greater
detail
in
the
next
section.
7
Available
IUR
Information

The
IUR
Web
site
will
be
updated
to
include
the
2006
IUR
reporting
requirements
and
all
supporting
documents
(
www.
epa.
gov/
oppt/
iur).


Please
direct
any
general
questions
or
comments
on
the
IUR
requirements
to
Susan
Sharkey
at
sharkey.
susan@
epa.
gov.


If
you
need
additional
assistance
when
completing
Form
U,
call
the
TSCA
hotline
at
202­
554­
1404.
8
Reporting
Requirements
9
Reporting
Requirements

Determining
your
reporting
requirements

Determining
if
your
chemical
is
listed
on
the
TSCA
Inventory

Full
exemptions

Partial
exemptions

Determining
if
you
are
a
manufacturer
required
to
report

Meeting
the
reporting
thresholds

Determining
which
Parts
of
Form
U
to
complete
10
Determining
Reporting
Requirements
CRITERION
II:

Are
you
a
manufacturer
(
or
importer)

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
11
CRITERION
I
YES
YES
EVALUATE
CRITERION
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
exempt
from
reporting?

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

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
12
Is
the
substance
on
the
TSCA
Inventory?


Chemical
substances
reportable
under
IUR
must
appear
on
the
TSCA
Inventory
at
the
beginning
of
the
submission
period
(
August
25,
2006).
YES
YES
EVALUATE
CRITERION
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
exempt
from
reporting?

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

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
13
What
is
the
TSCA
Inventory?


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


All
existing
chemicals
are
compiled
in
a
list
called
the
Toxic
Substances
Control
Act
Chemical
Substance
Inventory
or
TSCA
Inventory.


The
Inventory
was
originally
compiled
in
1978
and
1979.


EPA
adds
new
chemicals
to
the
Inventory
when
companies
submit
a
Notice
of
Commencement
following
completion
of
Premanufacture
Notification
procedures.


Over
80,000
chemicals
are
listed.
14
How
do
you
obtain
a
copy
of
the
Inventory?


You
can
obtain
the
Public
Inventory
in
hardcopy
or
electronic
format
from
the
National
Technical
Information
Service.
Phone
number
703­
487­
4650
or
800­
553­
NTIS.


Organizations
outside
of
EPA
have
published
versions
of
the
Inventory
on
the
Internet.
Please
use
caution
if
you
rely
on
these
Web
sites.
EPA
is
not
responsible
for
the
content
of
these
pages
and
cannot
verify
the
accuracy
and
completeness
of
the
lists.
15
How
do
you
determine
if
your
substance
is
on
the
TSCA
Inventory?


Locate
the
substance
in
the
Public
Inventory.


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


Search
company
records
for
a
Notice
of
Commencement
of
manufacture
or
import
for
a
PMN
substance.
16
Hydrates
and
Mixtures

Hydrates
are
not
listed
in
the
TSCA
Inventory.
You
are
required
to
report
using
the
corresponding
anhydrous
form.


Mixtures
are
not
reportable
under
TSCA.
You
are
required
to
report
for
the
chemical
substances
making
up
the
mixture.

Examples
related
to
hydrates
and
mixtures
will
be
presented
in
later
sections.
17

You
can
request
that
EPA
search
the
Master
Inventory
File,
including
confidential
substances.


Because
searches
are
labor­
intensive,
you
should
request
a
search
only
if
your
search
of
the
Public
Inventory
and
company
records
fails
to
resolve
your
question.


EPA
can
not
guarantee
a
response
for
requests
received
after
the
beginning
of
the
submission
period.


Follow
the
instructions
listed
in
Section
2.1.1.3
of
the
Instructions
for
Reporting
for
submitting
your
request.

What
if
you
cannot
find
your
chemical
in
the
Inventory?
18

Contact
EPA
at
the
address
listed
in
Section
2.1.1.4
of
the
Instructions
for
Reporting.


Significant
reductions
in
penalties
are
given
for
people
who
voluntarily
disclose
such
information.

What
if
you
manufacture
a
substance
subject
to
TSCA
that
is
not
listed
in
the
Inventory?
19
Is
the
substance
exempt?


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


Exempt
substances
are
noted
with
an
`
XU'
flag
in
the
TSCA
Inventory.
YES
YES
EVALUATE
CRITERION
II
YES
NO
YOU
DO
NOT
NEED
TO
REPORT
NO
NO
Is
the
substance
exempt
from
reporting?

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

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
20
Polymers
(
40
CFR
710.46(
a)(
1))


The
IUR
definition
of
polymer
is
sufficiently
broad
to
include
all
those
substances
that
are
generally
considered
polymers.
These
include
polysaccharides,
such
as
starches
and
gums,
and
all
classes
of
proteins.
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.
For
reporting
purposes,
salts
of
polymers
are
also
considered
to
be
polymers.
21
Microorganisms
(
40
CFR
710.46(
a)(
2))


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
organism
is
reportable
unless
otherwise
excluded.

40
CFR
725.3
defines
microorganism
as
an
organism
classified,
using
the
5­
kingdom
classification
system
of
Whittacker,
in
the
kingdoms
Monera
(
or
Procaryotae),
Protista,
Fungi,
and
the
Chlorophyta
and
the
Rhodophyta
of
the
Plantae,

and
a
virus
or
virus­
like
particle.
22
Natural
Gas
(
40
CFR
710.46(
a)(
4))


Certain
forms
of
natural
gas
are
exempt
for
IUR
reporting.
These
forms
are
listed
in
40
CFR
710.46(
a)(
4),
Table
2­
1
of
the
Instructions
for
Reporting,
and
below:

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
23
Naturally
Occurring
Substances
(
40
CFR
710.46(
a)(
3))


A
naturally
occurring
substances
is
any
chemical
substance
which
is
naturally
occurring
and:

(
1)
Which
is
(
i)
unprocessed
or
(
ii)
processed
only
by
manual,
mechanical,
or
gravitational
means;
by
dissolution
in
water;
by
flotation;
or
by
heating
solely
to
remove
water;

(
2)
Which
is
extracted
from
air
by
any
means.

Examples
of
such
substances
are:
raw
agricultural
commodities;
water,
air,
natural
gas,
and
crude
oil;

and
rocks,
ores,
and
minerals.
24
Naturally
Occurring
Substances

Whether
a
substance
is
naturally
occurring
depends
on
the
manner
in
which
it
is
produced
and
isolated.

For
this
reason,
minerals
and
certain
agricultural
products
are
sometimes
considered
not
to
be
naturally
occurring
because
of
their
method
of
production.

Examples:

1.
Removing
small
particles
by
electrostatic
precipitation
is
treated
similarly
to
a
filtration
or
gravitation
separation.
Processing
a
naturally
occurring
substance
by
this
means
does
not
negate
the
exemption.

2.
Using
a
solvent
to
extract
a
naturally
occurring
substance
is
not
a
natural
means,
therefore
the
substance
would
need
to
be
reported.
25
Example
#
1
 
Naturally
Occurring
Substances
Georgia
Rock
Products
(
GRP)
extracts
phosphate
rock
from
the
earth
for
production
of
phosphoric
acid.
During
benefication,
the
phosphate
rock
is
separated
from
its
matrix
by
non­
chemical
means,
i.
e.
crushing,
screening,
gravitational
separation,
and
flotation.
What
chemical
substances
manufactured
by
GRP
are
subject
to
reporting
requirements
under
IUR?
26
Is
the
substance
subject
to
a
special
action?


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


See
Section
2.1.3,
40
CFR
710.46,
and
Appendix
C
of
the
Instructions
for
Reporting
for
additional
details.

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

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

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
27
CRITERION
I
YES
YES
EVALUATE
CRITERION
II
YES
NO
NO
NO
Is
the
substance
exempt
from
reporting?

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

(
710.46)

Is
the
substance
on
the
TSCA
Inventory?

(
710.45
and
710.53)
YOU
DO
NOT
NEED
TO
REPORT
28
Do
you
qualify
as
a
small
manufacturer?

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

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

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

(
710.46)

YES
NO
YES
29
Definition
of
Manufacture

Manufacture
means
to
manufacture,
produce,
or
import
for
commercial
purposes
(
40
CFR
710.3).

Note
the
definition
of
manufacture
includes
import.

Day
2
will
cover
special
topics
related
to
manufacturing
and
will
review
the
reporting
requirements
for
importers.
30
Do
you
qualify
as
a
small
manufacturer?

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

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

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

(
710.46)

YES
NO
YES
Do
you
manufacture
quantities
of
25,000
pounds
or
more?


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


Report
the
substance
for
all
sites
at
which
you
manufactured
and/
or
imported
25,000
pounds
or
more.
Form
U
should
be
completed
for
each
site.
31
Example
#
2
­
Annual
Production
Volume
Threshold
Green
Chemical
Company
Annual
Sales
$
50
Million
Pennsylvania
Site
Manufactures
21,000
pounds
and
imports
5,000
pounds
of
acetylene
Which
sites
need
to
report?

New
Jersey
Site
Manufacturers
50,000
pounds
of
a
50%
acetylene
mixture
New
York
Site
Manufactures
30,000
pounds
of
a
50%
acetylene
mixture
and
5,000
pounds
of
100%
acetylene
32
Example
#
3
­
Mixtures
Company
A
purchases
25,000
pounds
of
Chemical
X
and
25,000
pounds
of
Chemical
Y
from
Domestic
Manufacturer
B.
Company
A
mixes
the
two
chemicals
to
form
Mixture
Z
with
no
chemical
reaction
which
they
sell
directly
to
consumers.
Does
company
A
meet
the
IUR
reporting
requirements?
33
Example
#
4
 
Imported
Mixtures
Company
A
imports
50,000
pounds
of
Mixture
Z
which
contains
20,000
pounds
of
Chemical
X
and
30,000
pounds
of
Chemical
Y.
Company
A
sells
Mixture
Z
directly
to
consumers.
Does
company
A
meet
the
IUR
reporting
requirements?
34
Do
you
qualify
as
a
small
manufacturer?


Total
annual
sales
<
$
4
million
(
company
wide)

OR

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

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

Do
you
qualify
as
a
small
manufacturer?

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

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

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

(
710.46)

YES
NO
YES
35
Example
#
5
­
Small
Manufacturer
Exemption
AAA
Chemical
Company
Annual
Sales
$
30
Million
Which
sites
need
to
report?

New
Jersey
Site
200,000
pounds
of
xylene
Delaware
Site
75,000
pounds
of
xylene
36
Is
the
substance
subject
to
a
special
action?


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


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

Do
you
qualify
as
a
small
manufacturer?

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

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

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

(
710.46)

YES
NO
YES
37
Do
you
qualify
for
additional
exemptions?


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

°
Substance
is
imported
as
part
of
an
article
(
710.50).

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

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

Do
you
qualify
as
a
small
manufacturer?

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

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

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

(
710.46)

YES
NO
YES
38
Article
Exemption

"
An
article
is
any
manufactured
item
that:

(
1)
is
formed
to
a
specific
shape
or
design
during
manufacture,

(
2)
has
end­
use
function(
s)
dependent
in
whole
or
in
part
upon
its
shape
or
design
during
its
end
use,

and
(
3)
has
either
no
change
of
chemical
composition
during
its
end
use
or
only
those
changes
of
composition
that
have
no
commercial
purpose
separate
from
that
of
the
article."
(
40
CFR
710.3)
39
By­
product,
impurities,
and
non­
isolated
intermediates

"
By­
product
is
a
chemical
substance
produced
without
separate
commercial
intent
during
the
manufacture
or
processing
of
another
chemical
substance(
s)
or
mixture(
s)."
(
40
CFR
710.3)


"
Impurity
is
a
chemical
substance
which
is
unintentionally
present
with
another
chemical
substance."
(
40
CFR
710.3)
40

"
Non­
isolated
intermediate
is
any
intermediate
that
is
not
intentionally
removed
from
the
equipment
in
which
it
is
manufactured,
including
the
reaction
vessel
in
which
it
is
manufactured,
equipment
which
is
ancillary
to
the
reaction
vessel,
and
any
equipment
through
which
the
substance
passes
during
a
continuous
flow
process,
but
not
including
tanks
or
other
vessels
in
which
the
substance
is
stored
after
its
manufacture."
(
40
CFR
710.43)

By­
product,
impurities,
and
non­
isolated
intermediates
41
Non­
isolated
intermediate
status

Taking
laboratory
samples
of
an
intermediate
does
not
negate
the
non­
isolated
status
of
the
substance.


Any
storage,
even
storage
within
the
reaction
vessel,
negates
the
non­
isolated
status
of
the
intermediate.
42
Example
#
6
­
Non­
Isolated
Intermediate
Exemption
Reactants
A
and
B
are
charged
to
a
vessel
where
they
react
to
form
Chemical
Substance
X.
Reactant
C
is
then
added
to
the
same
vessel.
Chemical
Substance
X
reacts
completely
with
Reactant
C
to
form
Chemical
Substance
Y.
Is
Chemical
Substance
X
non­
isolated?
43
Reactants
A
and
B
are
charged
to
a
Reactor
#
1
to
form
Chemical
Substance
X.
Chemical
Substance
X
is
stored
in
Reactor
#
1
until
being
transferred
to
Reactor
#
2
where
it
is
mixed
with
Reactant
C
to
form
Chemical
Substance
Y.
Is
Chemical
Substance
X
non­
isolated?

Example
#
7
­
Non­
Isolated
Intermediate
Exemption
44
Do
you
qualify
as
a
small
manufacturer?

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

(
710.48)
Do
you
qualify
for
additional
exemptions?

(
710.50)

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

(
710.46)

YES
NO
YES
45
CRITERION
III
What
parts
do
you
need
to
complete?

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

(
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
Yes
COMPLETE
PARTS
I
AND
II
OF
FORM
U.
46
Partial
Exemptions
 
Part
III
Reporting
Not
Required
You
do
not
need
to
complete
Part
III
of
Form
U
for:


Specific
petroleum
process
streams
listed
in
Part
710.46(
b)(
1)
and
in
Appendix
F
of
the
Instructions
for
Reporting.


Specific
chemical
substances
listed
in
Part
710.46(
b)(
2)(
iv)
and
in
Appendix
F.


Inorganic
substances
are
partially
exempt
for
the
2006
reporting
period
only
(
40
CFR
710.46(
b)(
3)).
47
What
information
do
you
need
to
report?
Part
III
Complete
for
all
reportable
substances
manufactured
or
imported
in
quantities
of
25,000
pounds
or
more.
Complete
if
you
produce
300,000
pounds
or
more
per
year
except
for
the
following:

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

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

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

Parts
I
and
II
Summary
of
Reporting
Requirements
48
Example
#
8
­
Reporting
Requirements
Zero
Pollution
Chemical
Company
Annual
Sales
$
50
Million
What
does
this
company
submit?

California
Site
10,000
pounds
of
organic
pigment
Arizona
Site
30,000
pounds
of
organic
pigment
New
Mexico
Site
350,000
pounds
of
organic
pigment
49
Summary

Form
U
must
be
submitted
if
°
The
chemical
is
on
the
TSCA
chemical
substance
inventory
°
The
chemical
is
manufactured
or
imported
in
an
amount
greater
than
25,000
pounds

Exemptions
°
Polymers,
certain
natural
gas
streams,
microorganisms,

naturally
occurring
substances
°
Small
manufacturers
°
Substance
is
manufactured
as
an
impurity,
non­
isolated
intermediate,
or
byproduct
without
separate
commercial
intent
°
Substance
is
imported
as
a
part
of
an
article
Note:
Additional
information
on
Reporting
Requirements
can
be
found
in
Chapter
2
of
the
Instructions
for
Reporting
50
Completing
Form
U
51
Completing
Form
U

General
Requirements

Part
I
 
Site
Identification
Information

Part
II
 
Manufacturing
Information

Part
III
 
Processing
and
Use
Information
52
General
Requirements

Separate
forms
are
required
for
each
plant
site
(
40
CFR
710.52).


If
you
are
reporting
for
more
than
one
chemical,
you
should
make
the
required
number
of
copies
of
Parts
II
and
III.


Information
can
be
submitted
either
on
electronic
disk
(
not
email)
or
a
printed
version
of
Form
U
(
40
CFR
710.52).
53
Reporting
Standards

EPA
expects
all
information
in
Parts
I
and
II
of
Form
U
should
be
known
to
or
reasonably
ascertainable
by
the
submitter.


Report
all
readily
obtainable
information
in
Part
III.
If
any
information
is
not
readily
obtainable,
enter
`
NRO'
(
not
readily
obtainable)
in
the
block
for
that
data
element.
54

Report
all
information
that
is
known
to
or
reasonably
ascertainable
by
you
in
Parts
I
and
II
of
Form
U.

Known
to
or
reasonably
ascertainable
by
means
all
information
in
a
person's
possession
or
control,
plus
all
information
that
a
reasonable
person
similarly
situated
might
be
expected
to
possess,
control,
or
know.


Report
readily
obtainable
information
in
Part
III
of
Form
U.

Readily
obtainable
information
is
information
known
to
or
readily
obtainable
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.
Readily
obtainable
information
includes
using
best
professional
judgment
based
on
past
experiences
for
similar
chemical
substances
in
the
same
or
similar
markets.

Reporting
Standards
55
Known
to
or
Reasonably
Ascertainable

Examples
of
reasonably
ascertainable
information
include:

°
Files
maintained
by
your
company
that
are
associated
with
research,
development,
test
marketing
or
commercial
marketing
of
the
chemical
substance.

°
Information
contained
in
standard
references
such
as
MSDSs.

°
Information
from
Chemical
Abstracts
Service
(
CAS),
Dun
&
Bradstreet,
and
NAICS.

°
Common
market
research
information.
56
Readily
Obtainable
Information

Lesser
standard
than
the
known
to
or
reasonably
ascertainable
by
standard.


Includes
use
of
your
best
professional
judgment
based
on
past
experiences
for
similar
chemical
substances
in
the
same
or
similar
markets.


Does
not
include
surveying
your
downstream
customers.
However,
if
you
have
any
information
that
would
allow
you
to
provide
estimates,
you
should
report
the
information
on
Part
III
of
the
form.
57
SECTION
A.
CERTIFICATION
Certification
Statement:
I
hereby
certify
to
the
best
of
my
knowledge
and
belief
that
Parts
I
and
II
have
been
completed
in
compliance
with
the
requirements
of
40
CFR
710.52(
c)(
1),
(
2),
and
(
3);
Part
III
of
this
form
has
been
completed
in
compliance
with
the
requirements
of
40
CFR
710.52(
c)(
4);
and
the
confidentiality
statements
at
the
end
of
this
form
are
true
and
correct
as
to
that
information
for
which
a
confidentiality
claim
has
been
asserted.

1.
A.
1
Signature
1.
A.
2
Date
signed
1.
A.
3
Name
1.
A.
4
Official
Title
Part
I,
Section
I:
Certification

This
section
should
be
completed
by
an
authorized
official
of
your
company.
The
certification
statement
attests
to
the
accuracy,
completeness,
and
truthfulness
of
the
submitted
information
to
the
best
of
your
knowledge.
58
Part
I,
Section
II:

Parent
Company
Information
Make
sure
you
enter
the
parent
company
Dun
&
Bradstreet
number.

SECTION
B.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION
1.
B.
1
Parent
Company
Name
1.
B.
2
Parent
Company
Dun
&

Bradstreet
Number
1.
B.
3
Technical
Contact
Name
1.
B.
4
Technical
Contact
Telephone
(
w/
Area
Code)
1.
B.
5
Technical
Contact
Email
Address
Technical
Contact
Mailing
Address
1.
B.
6
Technical
Contact
Address
(
Line1)

1.
B.
7
Technical
Contact
Address
(
Line
2)

1.
B.
8
City
1.
B.
9
State
1.
B.
10
Zip
Code
59
Technical
Contact

The
technical
contact
should
be
able
to
answer
questions
regarding
all
of
the
information
submitted
on
Form
U.
The
submitter
is
responsible
for
determining
if
the
technical
contact
should
be
from
the
parent
company
or
the
plant
site.


Form
U
should
be
completed
for
each
chemical
at
each
plant
site.
Therefore,
you
may
have
different
technical
contacts
for
each
site
and
each
chemical.

SECTION
B.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION
1.
B.
1
Parent
Company
Name
1.
B.
2
Parent
Company
Dun
&

Bradstreet
Number
1.
B.
3
Technical
Contact
Name
1.
B.
4
Technical
Contact
Telephone
(
w/
Area
Code)
1.
B.
5
Technical
Contact
Email
Address
Technical
Contact
Mailing
Address
1.
B.
6
Technical
Contact
Address
(
Line1)

1.
B.
7
Technical
Contact
Address
(
Line
2)

1.
B.
8
City
1.
B.
9
State
1.
B.
10
Zip
Code
60
Part
I,
Section
III:

Plant
Site
Identification

Dun
&
Bradstreet
assigns
separate
numbers
to
plant
sites
and
parent
companies.
Be
sure
to
provide
the
correct
number
for
both
the
parent
company
and
plant
site.


You
can
request
a
number
from
your
local
Dun
&
Bradstreet
office.
See
www.
dnb.
com/
us
for
more
information.
SECTION
C.
PLANT
SITE
IDENTIFICATION
1.
C.
1
Plant
Site
Name
1.
C.
2
Plant
Site
Dun
&

Bradstreet
Number
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)
LEAVE
BLANK
1.
C.
3
Street
Address
(
Line
1)

1.
C.
4
Street
Address
(
Line
2)

1.
C.
5
City
1.
C.
6
County/

Parish
1.
C.
7
State
1.
C.
8
Zip
Code
Make
sure
you
enter
the
plant
site
Dun
&
Bradstreet
number.
61
Plant
Site
Identification
SECTION
C.
PLANT
SITE
IDENTIFICATION
1.
C.
1
Plant
Site
Name
1.
C.
2
Plant
Site
Dun
&

Bradstreet
Number
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)
LEAVE
BLANK
1.
C.
3
Street
Address
(
Line
1)

1.
C.
4
Street
Address
(
Line
2)

1.
C.
5
City
1.
C.
6
County/

Parish
1.
C.
7
State
1.
C.
8
Zip
Code
EPA
will
assign
a
facility
identification
number.
62
Part
II
Manufacturing
Information

Section
A.
Chemical
Information
°
Chemical
Identification
Number
and
Code
°
Chemical
Name

Section
B.
Manufacturing
Information
°
Manufacturing
Activities
and
Production
Volume
°
Number
of
Potentially
Exposed
Workers
°
Maximum
Concentration
°
Physical
Form(
s)
of
Substance
63
Part
II,
Section
A:

Chemical
Identification

Enter
the
CAS
Registry
number
for
the
substance
in
Block
2.
A.
1.

If
the
CAS
number
is
not
known,
then
you
may
use
the
EPA
Accession
or
PMN
number.


Specify
the
type
of
identifying
number
in
Block
2.
A.
2
by
using
the
codes
in
Table
4­
1
of
the
Instructions
for
Reporting.


Enter
the
Chemical
Abstracts
Index/
Preferred
names
if
available
in
Block
2.
A.
3.
Trade
names
may
not
be
used
unless
the
supplier
refuses
to
disclose
the
specific
chemical
identity
of
the
substance.


You
may
claim
the
identity
of
your
substance
as
confidential
by
checking
the
CBI
box
and
submitting
a
separate
written
substantiation.
Note
that
you
can
not
claim
confidentiality
for
any
chemical
on
the
non­
confidential
portion
of
the
TSCA
Inventory.
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
64
Part
II,
Section
B
 
Manufacturing
Information

Checking
the
CBI
box
in
Block
2.
B.
1
asserts
a
confidentiality
claim
for
the
link
between
the
chemical
substance
and
the
information
about
the
parent
company.


Checking
the
CBI
box
in
Block
2.
B.
2
asserts
a
confidentiality
claim
for
the
link
between
the
site
of
manufacture/
import
and
the
chemical
identity.


Additional
information
on
CBI
claims
will
be
presented
in
another
section.
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
65

Mark
`
Y'
in
Block
2.
B.
3
if
the
substance
is
site­
limited.

Mark
`
N'
if
it
is
not.


Site­
limited
means
a
chemical
is
manufactured
and
processed
only
within
a
site
and
is
not
distributed
for
commercial
purposes
as
a
substance
or
as
part
of
a
mixture
or
article
outside
the
site.


An
imported
chemical
is
never
site­
limited.

Part
II,
Section
B
 
Manufacturing
Information
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
66

In
Block
2.
B.
4,
report
if
you
are
manufacturing
and/
or
importing
the
chemical
substance
by
checking
the
appropriate
box
or
boxes.

Part
II,
Section
B
 
Manufacturing
Information
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
67

Add
the
manufacture
and
import
volumes
together
and
report
the
total
volume
in
Block
2.
B.
5.


EPA
will
assign
a
production
volume
range
for
Block
2.
B.
6.

Part
II,
Section
B
 
Manufacturing
Information
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
68
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."

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


Include
exposures
through
any
route
of
entry
 
inhalation,

ingestion,
skin
contact.


Do
not
exclude
workers
wearing
personal
protective
equipment.


Reasonably
likely
to
be
exposed
 
Exposure
to
a
chemical
substance
under
foreseeable
conditions
of
manufacture,
processing,
distribution
in
commerce.
69
Estimating
Number
of
Exposed
Workers

Include
workers
who,
as
part
of
their
daily
activities,

may
potentially
be
exposed
to
the
chemical
substance.


Include
any
temporary,
seasonal,
or
contract
workers
if
they
may
be
potentially
exposed.


Report
individual
workers,
not
full­
time
equivalents.


Use
the
range
codes
listed
in
40
CFR
710.52(
c)(
3)(
vi)
and
Table
4­
3
of
the
IUR
Instructions
for
Reporting.
70

Use
the
range
codes
listed
below
which
can
also
be
found
in
40
CFR
710.52(
c)(
3)(
vi)
and
Table
4­
3
of
the
IUR
Instructions
for
Reporting.

Estimating
Number
of
Exposed
Workers
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
71
Example
#
9
­
Number
of
Workers
My
site
produces
isopropyl
alcohol
and
formaldehyde.
Six
employees
are
involved
in
the
production
of
each
chemical
(
12
total).
On
a
few
occasions
throughout
the
reporting
year,
two
employees
from
the
isopropyl
alcohol
production
line
were
moved
to
the
formaldehyde
production
line
to
provide
additional
assistance.
These
two
employees
had
minimal
exposure
to
formaldehyde.
How
many
workers
should
be
reported
for
the
production
of
formaldehyde?
72
Example
#
10
­
Number
of
Workers
I
employ
12
workers
to
operate
three
different
chemical
production
lines
(
X,
Y,
and
Z).
The
workers
rotate
between
the
different
lines.
Only
four
workers
work
on
the
production
for
Chemical
X
at
any
given
time.
However,

any
of
the
12
workers
may
be
assigned
to
Chemical
X
production.
How
many
workers
are
reasonably
likely
to
be
exposed
during
the
manufacture
of
Chemical
X?
73
Example
#
11
­
Number
of
Workers
My
site
uses
15
workers
during
the
production
of
my
chemical
substance.
This
chemical
is
then
stored
until
needed
for
shipment.
These
same
15
workers
package
the
final
product
for
shipment.
Should
these
workers
be
counted
twice
since
they
are
involved
in
two
separate
activities?
74
Maximum
Concentration
 
Block
2.
B.
8

In
Block
2.
B.
8,
report
the
maximum
concentration,

measured
by
weight,
at
the
time
the
chemical
is
reacted
on­
site
or
as
it
leaves
the
plant
site.
(
40
CFR
710.52(
c)(
3)(
vii))

SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
75
Maximum
Concentration

Round
estimates
to
the
nearest
1%
using
standard
rounding
procedures.
Numbers
ending
in
0.5
to
0.9
should
be
rounded
up
to
the
nearest
percent.
Reporting
code
M1
should
be
reported
for
concentrations
less
than
1%
by
weight.


Concentrations
of
laboratory
samples
do
not
need
to
be
considered
when
reporting
the
maximum
concentration.
76
Maximum
Concentration

Use
the
range
codes
listed
below
which
are
also
listed
in
40
CFR
710.52(
c)(
3)(
vii)
and
Table
4­
4
of
the
IUR
instructions
for
reporting.

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
77
Example
#
12
­
Maximum
Concentration
My
company
manufactures
a
solution
of
Chemical
Q.
During
the
manufacturing
process
several
samples
are
taken,
which
may
contain
Chemical
Q
at
concentrations
up
to
80
percent.

The
samples
are
sent
off­
site
for
laboratory
analysis.
The
final
solution
at
50
percent
concentration
is
packaged
and
shipped
to
customers.
What
do
I
report
for
the
maximum
concentration?
78
Physical
Form
 
Block
2.
B.
9
 
2.
B.
14

Report
all
physical
forms
of
the
chemical
at
the
time
it
is
reacted
or
as
it
leaves
your
site
and
the
percentage
of
production
volume
for
each
physical
form.


Round
estimates
to
the
nearest
10%.

SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
79
Company
A,
Delaware
Site
Company
A
manufactures
90,000,000
lbs
of
NaOH
(
187,500,000
lbs
of
a
48%
solution)
Company
A
imports
10,000,000
lbs
of
NaOH
(
20,800,000
lbs
of
a
48%
solution)

100,000,000
lbs
of
NaOH
20,000,000
lbs
purified
to
a
72%
wt
solution
6,000,000
lbs
crystallized
to
a
solid
at
>
97%
concentration
74,000,000
lbs
sold
as
a
48%
wt
solution
Sold
for
laboratory
and
industrial
uses.

Example
#
13­
Completing
Part
II
Sodium
Hydroxide
(
NaOH)

Note
that
further
information
about
Company
A's
production
of
NaOH
is
included
in
your
handouts.
80
Example
#
13
(
cont'd)

SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
81
Example
#
13
(
cont'd)

Is
NaOH
site­
limited?

SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
Does
Company
A
manufacture
or
import?
82
What
is
the
production
volume?

Example
#
13
(
cont'd)

SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
83
Workers
per
Shift
Process
engineers
Total
Load
drums
onto
truck
trailers
Administrative
personnel
Maintenance
staff
Support
other
manufacturing
operations
Package
the
NaOH
for
shipment
Sample
the
NaOH
Transfer
NaOH
to
other
processes
Operate
and
monitor
NaOH
process
Load
raw
materials
into
storage
tanks
Total
Exposed
Workers
Number
of
Shifts
Exposed
Workers
per
Shift
Activity
Example
#
13
(
cont'd)

How
many
workers
should
be
reported
in
Block
2.
B.
7?
84
What
code
should
be
entered
for
the
number
of
workers?

Example
#
13
(
cont'd)

SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
85
What
code
should
be
entered
for
the
maximum
concentration?

Example
#
13
(
cont'd)

SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
86
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
What
physical
forms
and
percent
of
production
volume
associated
with
each
form
should
be
reported?

Example
#
13
(
cont'd)
87
Part
III:
Processing
and
Use
Information

Complete
Part
III
for
chemical
substances
manufactured
in
quantities
of
300,000
pounds
or
more
(
40
CFR
710.52(
c)(
4))


Report
readily
obtainable
information
about
the
industrial
processing
and
use
for
each
chemical
substance:

°
Sites
under
your
control
°
Sites
that
receive
a
reportable
substance
88
Part
III,
Section
I:

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

Process
or
use;
NAICS;
and
IFC.

SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
89
Part
III,
Section
I:

Industrial
Processing
and
Use
If
you
have
less
than
10
combinations,
leave
the
remaining
lines
blank.

If
you
have
more
than
10
combinations,
report
only
the
10
unique
combinations
that
cumulatively
represent
the
largest
percentage
of
production,
by
weight.

SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
90
Process
or
Use
Code

Report
the
process
or
use
code
corresponding
to
the
appropriate
processing
or
use
operation.
These
codes
are
also
found
in
40
CFR
710.52(
c)(
4)(
i)(
A)

and
Table
4­
5
in
the
Instructions
for
Reporting.

PC:
Processing
as
a
reactant
PF:
Processing
 
incorporation
into
a
formulation,

mixture,
or
reaction
product
PA:
Processing
 
incorporation
into
an
article
PK:
Processing
 
repackaging
U:
Use
 
non­
incorporative
activities
91
NAICS
Codes

The
North
American
Industry
Classification
System
(
NAICS)
codes
have
superseded
the
1987
Standard
Industrial
Classification
(
SIC)
code
system.


Report
the
five­
digit
NAICS
code
corresponding
to
the
site(
s)
that
processes
or
uses
the
reportable
chemical
substance
or
that
receives
the
reportable
chemical
substance.


For
definitions
of
NAICS
codes
and
tables
crossreferencing
NAICS
and
SIC
codes,
see
http://
www.
census.
gov/
epcd/
www/
naics.
html.
92
IFC
Code

33
Industrial
Function
Categories
(
IFC)


Report
the
IFC
code
that
corresponds
to
the
function
of
the
industrial
process
or
use.
The
codes
are
listed
in
40
CFR
710.52(
c)(
4)(
i)(
C)
Table
4­
6
of
the
Instructions
for
Reporting.
Definitions
are
listed
in
Appendix
G.
93
Part
III,
Section
A
 
Industrial
Processing
and
Use
Data

For
each
unique
combination
of
Process
or
Use,

NAICS,
and
IFC
codes,
report
the
following:

°
Percent
of
production
volume
associated
with
the
use
°
Number
of
sites
°
Number
of
workers
reasonably
likely
to
be
exposed
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
94
Percentage
of
Production
Volume

Round
estimates
to
nearest
10%

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


If
the
amount
is
less
than
5%
of
the
production
volume
and
the
amount
is
less
than
300,000
pounds,
reporting
is
not
required.
If
the
amount
is
less
than
5%
and
the
amount
exceeds
300,000
pounds,
round
to
the
nearest
percent.


The
total
percentage
production
volume
may
add
up
to
more
than
100%
since
you
are
reporting
for
sites
under
your
control
as
well
as
downstream
sites.
95
Number
of
Sites

Report
an
estimate
of
the
total
number
of
sites.
Use
the
codes
listed
in
40
CFR
710.52(
c)(
4)(
i)(
E)
or
Table
4­
8
corresponding
to
the
appropriate
range.


If
a
chemical
substance
is
both
manufactured
and
processed/
used
at
a
site,
that
site
should
be
counted
as
both
a
manufacturing
site
in
Part
II
and
a
processing
or
use
site
in
Part
III.
96

Report
an
estimate
of
the
total
number
of
workers
including
those
at
sites
not
under
your
control.
Follow
the
same
guidelines
as
in
reporting
the
number
of
exposed
workers
during
manufacturing
(
40
CFR
710.52(
c)(
3)(
vii)).

Number
of
Workers
97
Example
#
14
­
Part
III,
Section
A:

Industrial
Processing
and
Use
Data
Company
B
manufactures
25,000,000
lbs
of
xylene
1,000,000
lbs
sold
to
paint
formulators
for
use
as
a
solvent
in
architectural
paints
24,000,000
lbs
sold
to
organic
chemical
manufacturers
as
a
chemical
intermediate
What
unique
combinations
of
Process
or
Use,
NAICS,
and
IFC
codes
should
Company
B
report
for
xylene?
98
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
What
%
PV
should
be
entered
for
each
use?

Example
#
14
(
cont'd)
99
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
What
codes
should
be
reported
for
the
number
of
sites
and
exposed
workers
for
each
use?

Example
#
14
(
cont'd)
100
Part
III,
Section
B:
Commercial
and
Consumer
End
Use
Commercial
Use
­
Use
of
a
chemical
substance
or
mixture
in
a
commercial
enterprise
providing
saleable
goods
or
a
service.

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

SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
101

Designate
up
to
10
commercial
and
consumer
product
categories
that
represent
the
predominant
uses.


Determine
if
the
chemical
is
present
in
or
on
any
consumer
product
intended
for
use
by
children.


Report
the
percent
production
volume
and
maximum
concentration
associated
with
each
use.

SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
Part
III,
Section
B:
Commercial
and
Consumer
End
Use
102
Commercial
and
Consumer
Product
Categories

19
commercial
and
consumer
product
categories

Report
the
code
that
corresponds
to
the
use.
The
codes
are
listed
in
40
CFR
710.52(
c)(
4)(
ii)(
A)
and
Table
4­
10
of
the
Instructions
for
Reporting.

Definitions
are
listed
in
Appendix
G.


If
more
than
10
codes
apply,
report
only
the
codes
that
represent
the
largest
percentage
of
production
volume,
measured
by
weight.
103
Intended
for
Use
by
Children
Intended
for
use
by
children
means
the
chemical
substance
or
mixture
is
used
in
a
product
that
is
specifically
intended
for
use
by
children
age
14
or
younger.
If
you
answer
yes
to
any
of
the
following
questions,
you
should
report
`
Y'
for
children's
use.

(
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
for
use
by
children
age
14
or
younger?

(
3)
Is
the
advertising,
promotion,
or
marketing
of
the
product
aimed
at
children
age
14
or
younger?
104
Children's
Use
Examples

Examples
of
products
specifically
intended
for
use
by
children:

°
Plastic
parts
for
toys,
car
seats,
or
cribs
°
Art
supplies
such
as
crayons,
water
colors,
and
markers
°
Flame
retardants
that
may
be
applied
to
children's
pajamas

Examples
of
products
not
intended
for
use
by
children:

°
Interior
paint
 
This
product
is
not
specifically
intended
for
use
by
children
even
though
it
may
be
used
to
paint
children's
rooms.

°
Paper
 
This
product
is
not
specifically
intended
for
use
by
children
even
though
it
may
be
used
by
children.
105
Architectural
paints
containing
<
15%
xylene
Commercial
and
Consumer
Uses
Industrial
Processing
and
Uses
Company
B
manufactures
25,000,000
lbs
of
xylene
1,000,000
lbs
sold
to
paint
formulators
for
use
as
a
solvent
in
architectural
paints
24,000,000
lbs
sold
to
organic
chemical
manufacturers
as
a
chemical
intermediate
Xylene
destroyed
(
no
commercial
and
consumer
uses)

Example
#
14
(
cont'd)­
Part
III,
Section
B:

Commercial
and
Consumer
End
Use
106
SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
Is
the
architectural
paint
intended
for
use
by
children?

What
Percent
Production
Volume
and
Maximum
Concentration
should
be
Reported?
Example
#
14
(
cont'd)
107

Reporting
ends
when
either:

°
The
chemical
is
consumed
to
form
another
chemical
substance.

°
The
final
processing
and
use
of
the
chemical
substance
is
reported.


For
the
purposes
of
IUR
reporting,
the
final
consumer
use
for
a
fertilizer
is
land
application
described
by
C07,
Lawn
and
Garden
Products.


Downstream
processing
or
use
information
ends
once
the
chemical
has
been
converted
into
a
new
chemical
substance.
However,
you
should
evaluate
your
IUR
reporting
requirements
for
any
new
substances
manufactured.

Where
does
reporting
end?
108
Example
#
15
 
End
of
Reporting
I
manufacture
anhydrous
ammonia
and
ship
it
to
5
agricultural
supply
wholesalers.
They
react
the
anhydrous
ammonia
with
water
to
form
ammonium
hydroxide.
The
wholesalers
then
sell
the
ammonium
hydroxide
to
farmers
for
use
as
a
fertilizer.
What
should
I
report
in
Part
III?
109
Claiming
Confidential
Business
Information
(
CBI)
110
Overview

Claiming
CBI
for
information
submitted
to
EPA

Additional
requirements
for
claiming
CBI
for:

°
Chemical
identity
°
Manufacturing
plant
site
identity
°
Production
volume
and
production
volume
range

Example

Discussion
111
To
claim
confidentiality
on
Form
U:


In
general,
information
submitted
to
EPA
is
entitled
to
confidential
treatment
if:

°
The
business
asserts
a
claim
for
confidentiality
by
marking
the
appropriate
box
on
IUR
Form
U;

°
The
submitter
has
taken
reasonable
measures
to
protect
the
confidentiality
of
the
information;

°
The
information
is
not
reasonably
ascertainable
without
the
consent
of
the
business
submitting
the
information;
and,

°
The
disclosure
of
the
information
is
likely
to
cause
substantial
harm
to
the
business's
competitive
position
(
40
CFR
part
2).
112
To
claim
confidentiality
on
Form
U:


An
authorized
official
must
sign
Part
I,
Section
I.


Must
mark
the
appropriate
boxes
on
Form
U.


Must
file
a
written
substantiation
for:

°
Chemical
Identity
°
Manufacturing
Plant
Site
Identity

Note:
CBI
should
not
be
submitted
by
email.
113
Chemical
Identity

Must
file
a
separate
written
substantiation,
signed
and
dated
by
an
authorized
official,
for
each
chemical
substance.


Only
assert
a
confidentiality
claim
if
EPA
treats
the
identity
as
confidential
in
the
TSCA
Inventory.


Address
all
questions
in
40
CFR
710.58(
b)
and
Table
5­
2.

°
Harmful
effects
to
competitive
position
°
Length
of
time
information
must
remain
confidential
°
Patent
and
licensing
status
°
Publication
in
technical
journals
or
trade
literature
°
Ability
of
others
to
analyze
products
or
wastes
114
Manufacturing
Plant
Site
Identity

Check
the
CBI
box
next
to
Block
2.
B.
2.


Submit
a
written
substantiation,
signed
and
dated
by
an
authorized
official,
answering
the
questions
in
40
CFR
710.58(
c)
and
Table
5­
3.

°
Has
site
information
been
linked
with
a
chemical
identity
in
any
other
reporting
scheme
(
e.
g.
through
an
MSDS).

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


Upfront
substantiation
is
not
required
for
company
information
CBI
claims
(
Block
2.
B.
1).
115
Company
Identity
versus
Plant
Site
Identity
Checking
this
box
asserts
a
confidentiality
claim
for
the
link
between
your
plant
site
and
the
chemical
substance.

Checking
this
box
asserts
a
confidentiality
claim
for
the
link
between
your
company
and
the
chemical
substance.
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
116
Production
Volume
vs.

Production
Volume
Range

To
claim
production
volume
as
CBI,
check
the
CBI
box
next
to
Block
2.
B.
5

To
claim
production
volume
range
as
CBI,
check
the
CBI
box
next
to
Block
2.
B.
6

EPA
wants
to
provide
as
much
information
to
the
public
as
possible

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


The
production
volume
ranges
listed
in
Table
4­
2
of
the
Reporting
Instructions
are
assigned
by
EPA
117
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
67­
64­
1
2.
A.
2
ID
Code
C
2.
A.
3
Chemical
Name
2­
propanone
N
60
X
40
X
M5
W3
800,000
X
X
X
X
X
X
X
X
X
X
X
X
X
Claiming
CBI
on
Form
U
118
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
PART
III.
PROCESSING
AND
USE
INFORMATION
Complete
Part
III,
Sections
A
and
B
only
if
the
production
volume
noted
in
Block
2.
B.
5
is
greater
than
or
equal
to
300,000
lb/
year
PA
S1
40
W3
U08
32619
PF
S3
60
W5
U08
32551
SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
40
C15
M1
NRO
C18
30
M2
Y
C12
40
M2
N
X
X
X
X
X
X
X
X
X
X
X
X
XXX
XX
X
XX
X
XX
X
Claiming
CBI
on
Form
U
119
Sending
CBI
to
EPA

Send
any
CBI
in
a
double­
wrapped
package.


Label
the
inner
package
with
the
recipient's
name
and
`
Confidential
Business
Information'.


Label
the
outer
wrapper
with
the
name
and
address
of
the
recipient
and
your
return
address.
Do
not
place
anything
on
the
outer
wrapper
that
would
indicate
that
the
package
contains
CBI.


Send
the
package
by
certified
or
registered
mail,

return
receipt
requested,
or
by
courier
service
or
U.
S.
Postal
Service
Express
Mail.
120
Submitting
Information
to
EPA
121

General
Reporting
Information

Electronic
Reporting
System
Topics
122

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


Information
must
be
submitted
for
all
chemicals
that
are
on
the
TSCA
Inventory
at
the
beginning
of
the
submission
period
(
currently
August
25,
2006),
which
are
otherwise
subject
to
reporting
(
40
CFR
710.45).


Information
from
calendar
year
2005
should
be
reported
during
the
2006
submission
period.

When
do
you
report?
123

Send
a
completed
written
or
electronic
Form
U
to
EPA
at:

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,
D.
C.
20460
How
do
you
submit
Form
U?
124

You
are
required
to
retain
records
of
IUR
reports
for
5
years
after
the
effective
date
of
the
reporting
period
(
40
CFR
710.57).


You
should
retain
records
that
document
any
information
reported
to
EPA.


If
you
do
not
report
a
substance
because
the
annual
production
is
less
than
25,000
pounds,
EPA
suggests
you
maintain
records
to
document
your
reasons
for
not
filing
Form
U.
What
are
the
recordkeeping
requirements?
125

Features:

°
Platform
independent
 
Java
based
program
can
be
run
using
any
operating
system.

°
Automatically
creates
the
required
fields
for
each
submission.

°
Validation
feature
checks
for
submission
errors.

Automated
IUR
Software
126

Minimum
System
Requirements:

°
CD
ROM
drive
°
30
MB
hard
drive
°
64
RAM

Software
will
be
downloadable
from
the
IUR
Web
site
or
on
CD.


Additional
information
is
available
in
Appendix
E
of
the
Instructions
for
Reporting.

Automated
IUR
Software
Screen
1
 
Parent
Company
and
Technical
Contact
Information
Standard
File
Menu
Options:

New:
Create
new
Form
U
Open:
Continue
work
on
Form
U
previously
started
Validate:
Review
input
Finalize:
Save,
Validate,
Print
File
Menu
Options
°
A
full
help
system
will
be
available
containing
information
from
the
regulatory
text
and
the
Instructions
for
Reporting.

°
Click
on
`
Enable
Tool
Tips'
to
see
the
definition
of
each
data
element.

Help
Systems
Move
the
mouse
over
the
data
element
name
to
see
the
definition
of
that
element.

Tool
Tips
Screen
2
 
Plant
Site
Information
Screens
3
and
4
 
Parts
II
Information
Arrows
in
the
data
entry
block
note
that
pull­
down
menus
are
available.
On
this
page
there
are
pull­
down
menus
for
chemical
identifying
number,

number
of
workers,
and
maximum
concentration.
Pull­
Down
Menus
In
addition
to
the
pull­
down
menus,
look­
up
tables
define
the
range
codes
used
in
reporting.
Look­
up
Tables
Screen
4
 
Parts
II
Information
Screen
5
 
Questionnaire
Screen
6
 
Parts
III
Processing
and
Use
Information
The
look­
up
table
for
NAICS
codes
contains
a
description
of
the
5­
digit
NAICS
codes
and
allows
you
to
search
on
key
words.
Look­
up
Tables
Screen
7
 
Parts
III
Commercial
and
Consumer
End
Use
Information
140

Choose
`
Finalize'
in
the
File
Menu
to
save,
validate,

and
print
the
certification.


Copy
file
to
disk
or
CD.


Mail
electronic
media
and
signed
certification
to
EPA.


Follow
instructions
for
mailing
CBI
if
required.

Submitting
an
Electronic
Form
U
141

Background
Information

Reporting
Requirements

Completing
Form
U

CBI

Submitting
Information
to
EPA

Case
Study
1
 
Ammonia
Phosphate

Special
Topics
°
Mixtures,
Impurities,
By­
products,
Wastes
°
Importers/
Exporters
°
TSCA/
non­
TSCA
Use

Case
Study
2
 
Acetone

Case
Study
3
 
Xylene

Case
Study
4
 
EDTA

Revisions
Rule
Training
Agenda
142
Beneficiation
Plant:
Phosphate
rock
is
crushed,
washed,
and
deslimed.

Ore
is
ground
into
approximately
2.9
billion
lbs
of
phosphate
slurry
using
a
ball
mill.
The
slurry
contains
35%
net
phosphate.

Mining
Operation:
PQR,
a
subsidiary
of
KLM,
surface
mines
4
billion
lbs
of
phosphate
rock
containing
25%
net
phosphate.
Phosphoric
Acid
Plant
Sulfuric
Acid
Plant:
At
a
nearby
plant
also
owned
by
KLM,
sulfur
dioxide
emitted
as
a
waste
product
from
copper
smelting
is
converted
to
sulfur
trioxide,
and
then
to
2.1
billion
pound
of
98%

sulfuric
acid.
Neither
sulfur
dioxide
nor
sulfur
trioxide
are
isolated
or
stored.

Case
Study
1
 
Ammonium
Phosphate
Production
143
Case
Study
1
 
Ammonium
Phosphate
Production
Ammonia
Plant:
Hydrogen
(
extracted
from
natural
gas)

and
nitrogen
(
extracted
from
air)
are
reacted
to
produce
of
ammonia
immediately
after
extraction.
PQR
produces
215
million
lbs
of
ammonia.

Phosphoric
Acid
Plant:
The
phosphate
slurry
is
combined
with
sulfuric
acid
to
produce
1.65
billion
lbs
of
78%

phosphoric
acid.
During
this
reaction,

2.7
billion
pounds
of
gypsum
crystals
(>
99%
anhydrous
CaSO
4)
are
formed
as
a
byproduct
and
sold
to
a
wallboard
manufacturer.

Granulation
Plant:
Phosphoric
acid
is
reacted
with
ammonia
to
form
a
liquid
slurry.
The
slurry
is
granulized
and
dried
to
produce
1.5
billion
pounds
of
fertilizer
containing
98%

ammonium
phosphate
and
2%
diammonium
phosphate.

Beneficiation
Plant
Sold
to
Customers
Sulfuric
Acid
Plant
144

Phosphate
rock
ore?

Which
chemical
substances
need
to
be
reported?
145

Phosphate
rock
following
beneficiation?

Which
chemical
substances
need
to
be
reported?
146

Sulfur
dioxide?

Which
chemical
substances
need
to
be
reported?
147

Sulfur
trioxide?

Which
chemical
substances
need
to
be
reported?
148

Sulfuric
acid?

Which
chemical
substances
need
to
be
reported?
149

Phosphoric
acid?

Which
chemical
substances
need
to
be
reported?
150

Gypsum?

Which
chemical
substances
need
to
be
reported?
151

Hydrogen?

Which
chemical
substances
need
to
be
reported?
152

Nitrogen?

Which
chemical
substances
need
to
be
reported?
153

Ammonia?

Which
chemical
substances
need
to
be
reported?
154

Ammonium
phosphate?

Which
chemical
substances
need
to
be
reported?
155

Diammonium
phosphate?

Which
chemical
substances
need
to
be
reported?
156
SECTION
B.
PARENT
COMPANY
AND
TECHNICAL
CONTACT
INFORMATION*

1.
B.
1
Name
Parent
Company
1.
B.
2
Dun
&
Bradstreet
Number
1.
B.
3
Name
1.
B.
4
Telephone
1.
B.
5
Email
Address
1.
B.
6
Address
line
1
1.
B.
7
Address
line
2
Technical
Contact
1.
B.
8
City
1.
B.
9
State
1.
B.
10
Zip
Code
SECTION
A.
CERTIFICATION
Certification
Statement:

1.
A.
1
Signature
1.
A.
2
Date
signed
1.
A.
3
Name
1.
A.
4
Official
Title
Case
Study
1
 
Part
I
157
SECTION
C.
PLANT
SITE
IDENTIFICATION
1.
C.
1
Plant
Site
Name
1.
C.
2
Plant
Site
Dun
&

Bradstreet
Number
EPA
Facility
Identification
Number
(
for
Agency
Use
Only)
LEAVE
BLANK
1.
C.
3
Street
Address
(
Line
1)

1.
C.
4
Street
Address
Line
2)

1.
C.
5
City
1.
C.
6
County/

Parish
1.
C.
7
State
1.
C.
8
Zip
Code
Case
Study
1
 
Part
I,
Section
C
Note
that
PQR
could
complete
one
copy
of
Part
I,
and
then
Parts
II
and
III
for
each
chemical.
158
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
Case
Study
1
 
Part
II,
Section
A
159
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
Case
Study
1
 
Part
II,
Section
B
160
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
Case
Study
1
 
Part
III
What
information
should
be
completed
for
Part
III?
161
Byproducts,
Impurities,
and
Mixtures
162

"
Byproduct
means
a
chemical
substance
produced
without
separate
commercial
intent
during
the
manufacture
or
processing
of
another
chemical
substance(
s)
or
mixture(
s)."
(
40
CFR
710.3)


"
Impurity
means
a
chemical
substance
which
is
unintentionally
present
with
another
chemical
substance."
(
40
CFR
710.3)

Byproduct
or
Impurity
163

Chemicals
listed
on
the
TSCA
Inventory
may
be
generated
as
byproducts
from
chemical
reactions.


You
only
need
to
report
byproducts
that
are
used
for
commercial
purposes
and
meet
the
reporting
requirements.


IUR
does
not
recognize
a
de
minimus
value.


Do
not
report
byproducts
disposed
as
waste
or
only
combusted
as
fuel.


Do
not
report
impurities.

Do
I
Report
Byproducts
and
Impurities?
164
An
energy
company
operates
a
sulfur
recovery
plant
as
a
pollution
control
device
to
minimize
sulfur
oxide
emissions.
This
sulfur
plant
generates
100,000
pounds
of
elemental
sulfur;
40,000
pounds
is
sold
to
customers
and
60,000
pounds
is
landfilled
as
waste.
Does
this
site
need
to
report
for
sulfur?

Example
#
16
­
Byproduct
165
My
company
paints
its
products
(
metal
articles)
with
an
oil­
based
paint.
As
the
paint
cures,
new
chemical
substances
are
created.
Do
I
need
to
report
these
chemical
substances
under
IUR?

Example
#
17
­
Byproduct
166
Organo
Chemicals
Co.
imports
styrene.
The
styrene
may
contain
small
quantities
of
toluene
and
benzene.
Does
Organo
Chemicals
need
to
report
for
the
benzene
and
toluene?

Example
#
18
­
Impurity
167
"
Mixture
means
any
combination
of
two
or
more
chemical
substances
if
the
combination
does
not
occur
in
nature
and
is
not,
whole
or
in
part,
the
result
of
a
chemical
reaction;
except
that
mixture
does
include:

(
1)
Any
combination
which
occurs,
in
whole
or
in
part,
as
a
result
of
a
chemical
reaction
if
the
combination
could
have
been
manufactured
for
commercial
purposes
without
a
chemical
reaction
at
the
time
the
chemical
substances
comprising
the
combination
were
combined
and
if,
after
the
effective
date
or
premanufacture
notification
requirements,
none
of
the
chemical
substances
comprising
the
combination
is
a
new
chemical
substance,
and
(
2)
Hydrates
of
a
chemical
substance
or
hydrated
ions
formed
by
association
of
a
chemical
substance
with
water."
(
40
CFR
710.3)

Mixtures
168
Are
Mixtures
Subject
to
IUR?


Mixtures
are
not
subject
to
IUR,
but
the
chemical
substances
comprising
the
mixture
are
subject
to
IUR.


If
you
import
a
mixture,
you
must
evaluate
your
reporting
obligations
for
all
chemical
substances
in
the
mixture.


If
you
produce
a
mixture
by
combining
existing
substances
that
your
company
does
not
manufacture
and
no
chemical
reaction
occurs
(
i.
e.,
blending
and
formulating),
do
not
report
those
substances.
169
Complex
Chemical
Substances

Any
material
extracted
or
removed
from
nature
is
a
chemical
substance
(
not
a
mixture)
even
though
it
may
be
comprised
of
many
different
chemical
substances.

Examples:
natural
gas,
iron
ore,
and
lemon
oil
extract

A
complex
reaction
product
combination
is
not
a
mixture
under
TSCA,
but
rather
is
a
chemical
substance.

Example:
catalytic
cracked
petroleum
distillates
170
Example
#
19
­
Mixture
I
manufacture
50,000
pounds
of
a
hydrochloric
acid
and
water
mixture,
which
contains
22,000
pounds
of
hydrochloric
acid.
Do
I
need
to
complete
a
Form
U
for
the
hydrochloric
acid?
171
Example
#
20
­
Mixture
I
purchase
several
chemical
substances
from
suppliers
and
formulate
these
chemicals
to
create
my
cleaning
products.
The
chemicals
do
not
react
when
I
combine
them.
Do
I
need
to
complete
a
Form
U
for
the
substances
in
my
cleaning
products?
172
Hydrated
Substances

The
TSCA
Inventory
does
not
include
hydrated
forms
of
a
chemical
substance
or
hydrated
ions
formed
by
association
of
a
chemical
substance
with
water.


Anhydrous
forms
of
chemical
substances
are
subject
to
IUR
regulations.


Example:
You
manufacture
copper
sulfate
pentahydrate.
Copper
sulfate
is
subject
to
IUR
regulations.
173
Example
#
21
­
Hydrate
Thrifty
Chemical
Company
manufactured
1,000,000
pounds
of
sodium
hypochlorite
pentahydrate,
NaOCl°
5
H2O
(
CAS#
10022­
70­
5).

How
does
Thrifty
report
this
chemical
substance?
174
What
is
an
Alloy?


An
alloy
is
a
solid
mixture
containing
two
or
more
elements,
at
least
one
of
which
is
a
metal.


If
you
blend
chemical
substances
to
create
an
alloy,

but
do
not
manufacture
any
of
the
component
substances,
then
you
are
not
subject
to
IUR
reporting.


If
you
import
an
alloy,
evaluate
whether
you
need
to
report
for
each
chemical
substance
present
in
the
alloy.


More
information
and
examples
are
available
in
the
1995
Statutory
Mixture
Policy
available
at
http://
www.
epa.
gov/
oppt/
newchems/
mixtures.
txt
175
Example
#
22
­
Alloy
A
circuit
board
manufacturer
imports
100,000
pounds
of
lead
solder
from
a
non­
domestic
supplier.

The
solder
contains
40%
tin
and
60%
lead
and
is
received
as
wire
or
bars.
The
solder
is
used
to
manufacture
electronic
circuit
boards.
176
Imported
and
Exported
Chemicals
177
Importer

"
Importer
means
any
person
who
imports
any
chemical
substance
or
any
chemical
substance
as
part
of
a
mixture
or
article
into
the
customs
territory
of
the
U.
S.
and
includes:

(
1)
The
person
primarily
liable
for
the
payment
of
any
duties
on
the
merchandise,
or
(
2)
An
authorized
agent
acting
on
his/
her
behalf
(
as
defined
in
19
CFR
1.11)."
(
40
CFR
710.3)


Chemical
importers
have
the
same
reporting
obligations
as
chemical
manufacturers.
178
Imported
Chemicals

Report
information
for
domestic
sites
only.


Report
for
each
chemical
substance
in
a
mixture,
if
it
meets
the
reporting
requirements.


Do
not
report
chemical
substances
that
are
imported
as
a
part
of
an
article.
For
example,

°
Coolants
contained
in
refrigeration
units
°
Chemicals
contained
in
batteries
°
Chemicals
contained
in
electronic
devices
°
Plastic
parts
whose
shape
does
not
change
(
not
including
pellets)

°
Metal
products
whose
shape
is
retained
during
use
(
not
including
ingots)
179
Import
Using
a
Broker

The
party
who
controls
the
transaction
is
responsible
for
reporting.

°
If
the
broker
plays
an
active
role,
ordering
the
chemical
substance,
arranging
for
shipment,
directing
delivery,
paying
import
duties
etc.,
then
the
broker
controls
the
transaction
and
has
primary
responsibility
for
reporting.

°
If
the
broker
merely
puts
you
in
touch
with
a
supplier,
and
you
make
the
individual
orders,
then
you
should
report.


If
no
one
reports
an
imported
chemical,
the
EPA
can
hold
all
parties
involved
in
the
transaction
responsible
for
any
violations.
See
40
CFR
710.55(
b).
180
Example
#
23
­
Importer
My
chemical
company
imports
a
chemical
substance
directly
to
sites
that
sell
the
product
for
commercial
and
consumer
use
and
does
not
handle
the
substance.

Who
is
responsible
for
reporting
this
chemical
to
IUR?
181
Example
#
24
­
Importer
I
imported
a
chemical
to
two
different
sites
within
my
company
during
the
reporting
year
 
15,000
pounds
to
one
site
and
10,000
pounds
to
a
second
site.
Do
I
need
to
report?
182
Example
#
25
­
Importer
The
corporate
headquarters
for
Lotsa
Chemicals
Co.
purchases
65,000
pounds
of
a
chemical
and
has
it
delivered
directly
to
three
of
its
sites
Louisiana
Site
30,000
pounds
Texas
Site
30,000
pounds
Ohio
Site
5,000
pounds
Who
should
report?
183

If
you
import
a
mixture
but
do
not
know
the
chemical
composition,
refer
to
the
MSDS
or
contact
the
supplier
for
more
information.


If
a
chemical
composition
is
proprietary
or
trade
secret,
you
can
claim
the
chemical
name
as
confidential
(
if
the
supplier
will
disclose
this
information
to
you).


If
the
supplier
will
not
disclose
the
chemical
name
to
you,
the
supplier
can
submit
a
Form
U
for
the
chemical.
Importing
Mixtures
of
Unknown
Composition
184
Importing
Mixtures
of
Unknown
Composition
(
cont'd)


If
you
know
the
amount
of
mixture
imported,
you
can
use
the
following
rules
to
calculate
how
much
chemical
you
imported
from
information
provided
on
the
MSDS:

°
Exact
concentration
­
use
concentration
provided
°
Ex)
MSDS:
25%
Use:
25%

°
Upper
bound
­
use
upper
limit
°
Ex)
MSDS:
<
40%
Use:
40%

°
Range
 
use
the
maximum
of
the
range
°
Ex)
MSDS:
60­
80%
Use:
80%

°
Lower
bound
 
subtract
out
other
known
constituents
to
determine
the
maximum
concentration
°
Ex)
MSDS:
>
60%
chemical
Use:
80%

20%
water
185
Exporting
a
Chemical

Report
information
for
domestic
sites
only.


If
you
manufacture
a
chemical
solely
for
export
(
distribute
it
to
a
customer(
s)
outside
the
U.
S.
territory),

you
still
need
to
complete
a
Form
U
if
you
meet
the
reporting
requirements.

°
Complete
Parts
I
&
II
(
Chemical
Identification
and
Manufacturing
Information
sections)

°
Check
the
"
NA"
box
for
both
sections
in
Part
III

If
you
manufacture
a
chemical
and
distribute
it
to
both
domestic
and
foreign
customer
sites,
you
still
need
to
complete
a
Form
U
if
you
meet
the
reporting
requirements.

°
Complete
Parts
I
&
II
for
the
entire
PV
°
Complete
Part
III
for
domestic
industrial
and
consumer
uses.
186
Non­
TSCA
Uses
187
Non­
TSCA
Uses

Non­
TSCA
uses
are
regulated
by
other
federal
acts,

including:

°
Federal
Food,
Drug,
and
Cosmetic
Act
°
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
°
Atomic
Energy
Act
188
What
are
Non­
TSCA
Uses?


Pesticide
active
ingredients

Tobacco
product
additives

Food
and
food
additives

Pharmaceutical
drugs

Cosmetic
products

Nuclear
source,
special
nuclear,
and
nuclear
byproduct
material
189
What
are
Non­
TSCA
Uses?


Intermediates
for
chemicals
used
in
certain
non­

TSCA
uses
(
e.
g.
pesticides)
are
still
reportable
under
IUR.


Solvents,
catalysts,
and
other
chemicals
used
in
the
synthesis
of
certain
non­
TSCA
use
chemicals
(
e.
g.

pesticides)
are
still
reportable
under
IUR.


Inert
ingredients
in
pesticides
must
still
be
reported;

however,
inert
ingredients
in
pharmaceuticals,
food
additives,
and
cosmetics
are
exempt.
190
Example
#
26
­
Non­
TSCA
Uses

Company
A
manufactures
500,000
lbs
of
a
solvent
used
in
commercial
and
consumer
insecticide
products.


Company
B
manufactures
500,000
lbs
of
an
active
ingredient
in
commercial
and
consumer
insecticide
products.


Company
C
manufactures
500,000
lbs
of
an
intermediate
for
an
active
ingredient
in
commercial
and
consumer
insecticide
products.

Which
company
manufactures
a
chemical
for
a
non­

TSCA
use?
191
Reporting
a
Chemical
with
a
Non­
TSCA
Use

If
the
chemical
is
only
used
for
non­
TSCA
uses,
you
do
not
need
to
report
under
IUR.


If
the
chemical
is
used
for
both
TSCA
and
non­
TSCA
uses,
only
complete
Form
U
for
the
portion
of
the
production
volume
that
is
associated
with
TSCA
uses.
192
Example
#
27
­
Non­
TSCA
Use
Company
D
manufactures
10,000,000
pounds
of
benzoic
acid.
Company
XYZ
uses
9,000,000
lbs
of
benzoic
acid
as
a
chemical
intermediate
and
formulates
1,000,000
lbs
of
benzoic
acid
into
mixtures
and
products.
The
customers
use
these
products
as
a
a
food
preservative.
How
should
Company
D
complete
Form
U
for
benzoic
acid?
193
Case
Study
2
 
Acetone
Manufacturing
30,000,000
lbs
used
on­
site
as
a
chemical
reactant
40,000,000
lbs
shipped
off­
site
Industrial
Processing
and
Use
next
page
Chemical
reacted
AAA
Chemicals,
Inc.
manufactures
70,000,000
lbs
of
acetone
at
>
99%
conc.
194
Case
Study
2
 
Acetone
40,000,000
lbs
of
>
99%
conc.

acetone
shipped
off­
site
30,000,000
lbs
used
as
a
chemical
reactant
at
7
other
sites
Industrial
Processing
and
Use
10,000,000
lbs
shipped
to
20
formulators
of
commercial
and
consumer
adhesives
and
sealants
Commercial
and
Consumer
Use
10,000,000
lbs
used
as
a
component
in
commercial
and
consumer
adhesives
and
sealants
at
concentrations
from
5%
to
45%.
Chemical
reacted
195
Exposed
Workers
per
Shift
Number
of
Shifts
Total
Administrative
personnel
Engineering
staff
Load
regular
grade
acetone
into
drums,
tank
trucks,
and
rail
cars
Operate
production
equipment
using
acetone
as
a
reactant
for
other
chemicals
Maintenance
and
equipment
cleaning
Operate
and
monitor
equipment
Exposed
Workers
Activity
Number
of
Workers
Potentially
Exposed
During
Manufacturing
Case
Study
2
 
Worksheet
#
1
196
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
Case
Study
2
 
Worksheet
#
2
Form
U,
Part
II,
Section
A
197
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
Case
Study
2
 
Worksheet
#
2
Form
U,
Part
II,
Section
B
198
Case
Study
2
 
Worksheet
#
3
#
of
Workers
#
of
Sites
IFC
Code
NAICS
Code
Proc
/
Use
Code
Amount,

pounds
Process
or
Use
Description
Organic
Chemical
Production
On­
Site
Formulation
of
Adhesives
and
Sealants
Organic
Chemical
Production
Off­
Site
199
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
Case
Study
2
 
Worksheet
#
5
Form
U,
Part
III,
Section
A
200
Maximum
Concentration
Used
in
Children's
Products
(
Y,
N,
NRO)

Comm.
&
Cons.

Product
Category
Code
Amount,

pounds
End
Use
SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
Case
Study
2
 
Worksheet
#
6
Form
U,
Part
III,
Section
B
201
Case
Study
2
 
Acetone
40,000,000
lbs
of
>
99%
conc.

acetone
shipped
off­
site
30,000,000
lbs
used
as
a
chemical
reactant
at
7
other
sites
Industrial
Processing
and
Use
10,000,000
lbs
shipped
to
20
formulators
of
commercial
and
consumer
adhesives
and
sealants
Chemical
reacted
How
would
the
facilities
receiving
acetone
report?
202

Aggregate
identical
combinations
of
Process
or
Use,
NAICS,
and
IFC
codes.


Once
a
chemical
has
been
reacted,
the
downstream
uses
are
not
reported.


Workers
wearing
personal
protective
equipment
should
still
be
reported.

Case
Study
2
 
Summary
203
Case
Study
3
 
Flow
Diagram
Manufacturing
Industrial
Processing
and
Use
Company
G
manufactures
19,000,000
lbs
of
xylene
up
to
99%
conc.
Company
G
imports
1,000,000
lbs
of
xylene
up
to
99%
conc.

Company
G
manufactures
a
total
of
20,000,000
lbs
xylene
at
99%
max.
conc.

6,000,000
lbs
shipped
directly
to
3
customers
at
99%
for
use
as
a
chemical
reactant
14,000,000
lbs
shipped
to
warehouses
for
storage
until
shipment
to
formulators
Xylene
reacted
to
form
a
different
chemical
14,000,000
lbs
shipped
to
15
customers
for
formulation
into
products
at
0.5
 
95%
conc.
204
Case
Study
3
 
Flow
Diagram
14,000,000
lbs
shipped
to
15
customers
for
formulation
into
products
at
0.5
 
95%
conc.

6,000,000
lbs
is
simply
resold
to
200
hardware
manufacturers
at
95%
concentration
for
use
as
a
metal
degreaser
800,000
lbs
formulated
into
paint
at
15%
concentration
Industrial
Processing
and
Use
5,000,000
lbs
formulated
into
automotive
care
products
at
35%
maximum
concentration
2,000,000
lbs
blended
into
pesticide
formulations
at
10%

concentration
200,000
lbs
formulated
into
as
a
component
of
consumer
products
at
95%
maximum
concentration
205
Case
Study
3
 
Flow
Diagram
Industrial
Processing
and
Use
Commercial
and
Consumer
Use
5,000,000
lbs
formulated
into
automotive
care
products
at
35%
maximum
concentration
2,000,000
lbs
blended
into
pesticide
formulations
at
10%

concentration
Automotive
care
products
used
by
consumers
and
commercial
users
at
35%
concentration
or
less
Pesticide
sold
for
commercial
and
consumer
applications
206
Case
Study
3
 
Flow
Diagram
Industrial
Processing
and
Use
800,000
lbs
formulated
into
paint
at
15%
concentration
200,000
lbs
formulated
into
as
a
component
of
consumer
products
at
95%
maximum
concentration
Commercial
and
Consumer
Use
Paint
sold
for
commercial
and
consumer
applications
Used
by
consumers
for
various
uses
207
Case
Study
3
 
Worksheet
#
1
Loading
tank
trucks
and
rail
cars
from
bulk
storage
Total
Administrative
personnel
Engineering
staff
Transferring
xylene
to
bulk
storage
Drumming
operations
Analyze
samples
(
lab
technicians)

Maintenance
and
equipment
cleaning
Operating
and
monitoring
equipment
Exposed
Workers
Number
of
Shifts
Exposed
Workers
per
Shift
Activity
Number
of
Workers
Potentially
Exposed
During
Manufacturing
208
Case
Study
3
 
Worksheet
#
2
Physical
Form
and
Percent
of
PV
2.
B.
9
­

2.
B.
14
Maximum
Concentration
and
Maximum
Concentration
Code
2.
B.
8
Number
of
Workers
and
Number
of
Workers
Code
2.
B.
7
Production
Volume
(
lbs)

2.
B.
5
Activity
(
M,
I,
or
both)

2.
B.
4
Site
limited
(
Y/
N)

2.
B.
3
Chemical
Name
2.
A.
3
ID
Code
2.
A.
2
Chemical
ID
Number
2.
A.
1
Entry
Block
Title
Block
Manufacturing
Information
209
Case
Study
3
 
Worksheet
#
3
Industrial
Processing
and
Use
Information
Blended
into
pesticides
Various
consumer
products
Formulated
into
automotive
care
products
Chemical
reactant
Formulated
into
paints
Metal
degreaser
Code
#

Code
#
Exposed
Workers
Sites
%
PV
IFC
Code
NAICS
Code
Proc
/

Use
Code
Amount,

pounds
Process
or
Use
Description
210
Case
Study
3
 
Worksheet
#
4
Painting
applications
Blended
into
pesticides
Various
consumer
products
Use
of
automotive
care
products
Code
%
Maximum
Concentration
%
PV
Children's
Products
(
Y,
N,
?)

Comm.
&
Cons.

Product
Category
Code
Amount,

pounds
End
Use
Commercial
and
Consumer
End­
Use
Information
211
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
Case
Study
3
 
Form
U
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
212
Case
Study
3
 
Form
U
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
213
Case
Study
3
 
Summary

Combine
manufactured
and
imported
production
volumes

Non­
TSCA
uses
(
pesticides,
cosmetics,
etc.)
are
exempt
from
IUR
reporting
214
Case
Study
4
 
Flow
Diagram
On­
Site
Activities
Chelant
Chemical
Company
(
CCC)
manufactures
30,000,000
lbs
of
Tetrasodium­
EDTA
at
40%
concentration
(
75,000,000
lbs
of
solution)

15,000,000
lbs
reacted
to
other
chemical
substances
on­
site
15,000,000
lbs
of
liquid
tetrasodium­
EDTA
Some
of
the
product
is
reacted
back
to
1,500,000
lbs
of
highpurity
tetrasodium­
EDTA
1,500,000
lbs
of
high­
purity
liquid
3,000,000
lbs
of
solid
product
12,000,000
lbs
of
original
liquid
3,000,000
lbs
used
to
make
a
solid
product
at
100%
conc.

13,500,000
lbs
of
other
chemical
substances
Shipped
Off­
Site
215
Case
Study
4
 
Flow
Diagram
High­
Purity
Distribution
750,000
lbs
direct
to
customers
750,000
through
distributors
(
325,000
lbs
repackaged)

High­
Purity
Liquid
Processing
and
Use
1,500,000
lbs
of
high­
purity
liquid
Institutional
and
consumer
cleaning
products
0.1­
2.5%
conc.
Personal
care
products
<
2.5%
conc.

High­
Purity
Use
#
1
1,200,000
lbs
formulated
into
cleaning
products
High­
Purity
Use
#
2
300,000
lbs
formulated
into
personal
care
products
Commercial
and
Consumer
Use
216
Solid
Distribution
3,000,000
through
distributors
(
300,000
lbs
repackaged)

Solid
Product
Processing
and
Use
3,000,000
lbs
of
solid
product
Institutional
and
consumer
cleaning
products
<
3%
conc.

Personal
care
products
<
5%
conc.

Solid
Use
#
1
2,400,000
lbs
formulated
into
personal
care
products
Solid
Use
#
2
600,000
lbs
formulated
into
cleaning
products
Commercial
and
Consumer
Use
Case
Study
4
 
Flow
Diagram
217
Case
Study
4
 
Flow
Diagram
Commercial
and
Consumer
Use
Institutional
and
consumer
cleaning
products
containing
EDTA
at
0.1
to
5%
concentration
Liquid
Use
#
1
4,000,000
lbs
formulated
into
institutional
and
consumer
cleaning
products
Original
Liquid
Product
Processing
and
Use
CCC
Terminals
3,000,000
direct
to
customers
9,000,000
through
terminals(
repackaged)

12,000,000
lbs
of
original
liquid
product
8,000,000
lbs
of
original
liquid
product
Next
Slide
Liquid
Distributors
4,000,000
lbs
repackaged
and
sold
to
cleaning
product
formulators
218
Case
Study
4
 
Flow
Diagram
Industrial
Cleaner
Use
at
unknown
sites
Liquid
Use
#
2
4,800,000
lbs
used
as
a
stabilizer
in
pulp
and
paper
mills
8,000,000
lbs
of
original
liquid
product
Original
Liquid
Product
Processing
and
Use
Liquid
Use
#
3
2,000,000
lbs
formulated
into
industrial
cleaners
Liquid
Use
#
4
720,000
lbs
used
as
a
stabilizer
in
textile
mills
Liquid
Use
#
5
360,000
lbs
used
to
control
metal
ions
in
plastic
plating
Liquid
Use
#
6
120,000
lbs
used
in
natural
gas
conditioning
219
High­
Purity
(
operations)
Exposed
Workers
per
Shift
Number
of
Shifts
Total
Solid
Production
(
sampling
and
packaging)

Manufacturing
(
sampling
and
transfers)
Exposed
Workers
Activity
Number
of
Workers
Potentially
Exposed
During
Manufacturing
Case
Study
4
 
Worksheet
#
1
220
SECTION
A.
CHEMICAL
IDENTIFICATION
CBI*

2.
A.
1
Chemical
Identifying
Number
2.
A.
2
ID
Code
2.
A.
3
Chemical
Name
Case
Study
4
 
Worksheet
#
2
Form
U,
Part
II,
Section
A
221
SECTION
B.
MANUFACTURING
INFORMATION
CBI
CBI
a.
Physical
Form
b.
Percent
of
Production
Volume
in
Each
Physical
Form
2.
B.
1
Company
Information
2.
B.
2
Plant
Site
Identity*
Check
All
That
Apply
CBI
Percent
CBI
CBI
2.
B.
3
Site
Limited
(
Y/
N)
2.
B.
9
Dry
Powder
CBI
2.
B.
4
Activity
(
Check
all
that
apply)
G
Manufacture
G
Import
2.
B.
10
Pellets
or
Large
Crystals
CBI
2.
B.
5
Production
Volume
(
LB)
2.
B.
11
Water
or
Solvent
Wet
Solid
CBI
2.
B.
6
Production
Volume
Range
LEAVE
BLANK
2.
B.
12
Other
Solid
CBI
2.
B.
7
Number
of
Workers
(
code)
2.
B.
13
Gas
or
Vapor
CBI
2.
B.
8
Maximum
Concentration
(
code)
2.
B.
14
Liquid
Case
Study
4
 
Worksheet
#
2
Form
U,
Part
II,
Section
B
222
Liquid
Use
#
1
Liquid
Use
#
4
Industrial
Cleaner
Use
High­
Purity
Use#
2
Intermediate
High
Purity
Distributors
High­
Purity
Use#
1
Liquid
Distributors
CCC
Terminals
Solid
Use
#
2
Solid
Use
#
1
Solid
Distributors
Liquid
Use
#
5
#
of
Workers
#
of
Sites
Liquid
Use
#
2
Liquid
Use
#
6
Liquid
Use
#
3
IFC
Code
NAICS
Code
Proc
/
Use
Code
Amount,

pounds
Process
or
Use
Description
Case
Study
4
 
Worksheet
#
3
223
Case
Study
4
 
Worksheet
#
4
Data
Aggregation
for
Proc/
Use
Code
PF,
NAICS
32562,

and
IFC
U09
(
Personal
Care
Products
Formulation
Solid
Use
#
1
Total
High­
Purity
Use
#
2
Code
#

Code
#
Exposed
Workers
Sites
Amount,
lbs
Process
or
Use
Description
224
SECTION
A.
INDUSTRIAL
PROCESSING
AND
USE
DATA
N/
A
a.
Type
of
Process
or
Use
b.
(
5­
digit)
NAICS
c.
Industrial
Function
Category
d.
%
Production
Volume
e.
Number
of
Sites
f.
Number
of
Workers
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
Code
CBI
3.
A.
1
3.
A.
2
3.
A.
3
3.
A.
4
3.
A.
5
3.
A.
6
3.
A.
7
3.
A.
8
3.
A.
9
3.
A.
10
Case
Study
4
 
Worksheet
#
5
Form
U,
Part
III,
Section
A
225
Maximum
Concentration
Used
in
Children's
Products
(
Y,
N,
NRO)

Comm.
&
Cons.

Product
Category
Code
Amount,

pounds
End
Use
Commercial
and
Consumer
End­
Use
Information
Case
Study
4
 
Worksheet
#
6
226
Case
Study
4
 
Worksheet
#
6
Form
U,
Part
III,
Section
B
Information
from
Worksheet
#
6
SECTION
B.
COMMERCIAL
&
CONSUMER
END­
USE
EXPOSURE
RELATED
DATA
N/
A
a.
Commercial
and
Consumer
Product
Category
b.
Use
in
Children's
Product
c.
Percent
Production
Volume
associated
with
each
category
d.
Maximum
Concentration
associated
with
each
category
Code
CBI
Y/
N/?
CBI
Percent
CBI
Code
CBI
3.
B.
1
3.
B.
2
3.
B.
3
3.
B.
4
3.
B.
5
3.
B.
6
3.
B.
7
3.
B.
8
3.
B.
9
3.
B.
10
227

Aggregate
identical
combinations
of
Process
or
Use,
NAICS,
and
IFC
codes.


Aggregate
identical
Commercial
and
Consumer
Product
Category
Codes.

Case
Study
4
 
Summary
228
Revisions
Rule
229
Revisions
Rule

EPA
proposed
revisions
to
the
IUR
in
the
Federal
Register
on
January
26,
2005.


Comments
must
be
submitted
by
February
25,
2005
to
docket
number
OPPT­
2004­
0106.


These
revisions
do
not
affect
the
intent
of
the
rule
or
the
information
collected
by
the
IUR.
The
revisions
clarify
certain
aspects
of
the
rule
and
slightly
modify
how
some
information
is
collected.


This
presentation
is
based
on
the
rule
as
it
is
currently
appears
in
Code
of
Federal
Regulations
and
does
not
include
any
of
the
proposed
revisions.
230
Revisions
Rule

Proposed
changes
to
the
IUR
include:

°
Changing
the
reporting
cycle
from
every
4
years
to
every
5
years.

°
Moving
the
submission
period
from
August
25
through
December
23
to
January
1
though
April
30.

°
Clarifying
the
partial
exemption
petition
process.

°
Adding
additional
petroleum
process
streams
to
the
list
of
partially
exempt
chemicals.

°
Revising
the
list
of
commercial
and
consumer
product
categories
to
combine
"
Soaps
and
Detergents"
and
"
Polishes
and
Sanitation
Goods",
remove
the
"
Photographic
Chemicals"
category,
and
add
a
"
Agricultural
Products
(
non­
pesticidal)"
category.
231
Revisions
Rule

Proposed
changes
to
the
rule
also
include:

°
Separating
the
reporting
the
volume
of
the
chemical
substance
imported
and
the
volume
manufactured
domestically.

°
Restricting
the
reporting
of
processing
and
use
information
to
domestic
activities.

°
Revising
the
definition
of
polymer
to
exclude
reference
to
1985
Inventory.

°
Deleting
the
requirement
to
determine
confidentiality
of
a
production
volume
range.
