U.S. EPA, The TSCA Inventory: Submitting Successful Corrections (revised, undated) (ELR Order No. AD-467)

• Author: Carolyne R. Hathaway/William K. Rawson/Ann Claassen/Julia A. Hatcher
• Pages: 329-332

The TSCA Inventory: Submitting Successful Corrections Page 329

The TSCA Inventory:

Submitting Successful Corrections

Introduction

Eective May 19, 1980 the Agency no longer accepted

late TSCA Inventory reports for subst ances manufac-

tured or imported in bul k for inclusion in the TSCA

Inventory. Substances manufact ured or imported in

bulk after t hat date were subject to the Premanufacture

Notication reporting re quirements prescribed under

Section 5 of TSCA. e one except ion to this rule

applied to substances th at were processed or imported

as parts of mi xtures, which were reportable until

August 30, 1980.

Since the publication of the Revi sed TSCA Inventory

(collectively the Initial I nventory and Cumulative

Supplement I), the Agency has continued to receive

and review correct ions related to substance s previously

included in the TSCA Inventory. e Federal Reg ister

notice of Tuesday, July 29, 1980 (45 FR 50544), identi-

es three categorie s under which such corrections can

be submitted to the Agency for re view.

Correction Categories

First Category Corrections

e rst category inc ludes corrections to the identi-

ties of previously reported subst ances. e majority

of correction submissions received by t he Agency are

included under this categ ory. ese submissions usu-

ally concern a correct ion based on one or more of the

following:

1) A typographic al or transcriptional error that

was included in the chemic al identity informa-

tion provided on the original Inventory repor t-

ing form

2) Renement of the identity of a previously

reported substance (e.g., specif ying the precise

location of a substituent on an aromatic ri ng

that was origina lly described as non-specied

or unknown).

3) Identication of a previously unrec ognized

or unconrmed component that is produced

in association with a sub stance previously

reported (e.g., such as an additional i somer

of the substance origin ally reported, an assy-

metrical form of a substa nce that was origi-

nally reported a s symetrical only); byproducts

or impurities without commercial va lue are

excluded as such components.

4) Discovery that a more accu rate identity of a

substance as ma nufactured is dierent from

the identity of the same substa nce as origi-

nally reported (e.g., a polymer was reporte d

originally a s including trimethylolpropane as a

monomer when trimethylolethane is t he mono-

mer actually u sed in its manufacture).

e preceding ty pes of category one corrections are

often discovered as a re sult of one or a combination of

the following:

• improved analytic al methods and/or equip-

ment become available to the submitter

• commercial manufac turing process for reported

substances is re- evaluated by the submitter,

including nature of the rea ctants (routine qual-

ity control reviews or interna l company audits

of TSCA Inventory reports)

• raw material supplier noties subm itter that the

identity of a raw material ha s been corrected

(prompting a correction request from the sub -

mitter who uses the raw materi al in the manu-

facture of other reported subs tances)

Second Category Corrections

e second category consis ts of corrections which iden-

tify substa nces that qualify as prev iously unrecognized

isolated intermediates produced dur ing the manu-

facture of substa nces already i ncluded in the TSCA

Inventory. On July 15, 1986, the Agency provided

clarcation on its de nition of a non-isolated inter-

mediate to the Chemical M anufacturer’s Association

(attached).

Third Category Corrections

e third category c overs corrections submitted in

response to communications (written a nd/or oral) from

the Agency descr ibing specic problems encountered

in the processing of subst ances described on original

Inventory report forms.

Correction Category Information

Requirements

First Category Corrections

Adequate support documentation should acc ompany

rst category c orrection submissions submitted for

Agency review. Submissions wit hout documentation

will not be processed u ntil documentation is rec eived

by the Agency. Documentation should consist of :