Mixtures and trade name products

How Mixture and Trade Name Products (M/TNP) Factor Into Your Reports... 

If you are unsure if you are subject to the reporting requirements of Section 313, or need more information, call the EPA Emergency Planning and Community Right-To-Know Information Hotline (800) 535-0202 or (202) 479-2449 (in Washington D.C. or Alaska). Your other suppliers should also be notifying you if section 313 chemicals are In the mixtures and trade name products they sell to you. 

De Minimis Limitation. A listed toxic chemical does not have to be considered if it Is present in a mixture at a concentration below a specified de nvnimis level. The de minimis level is 1.0%, or 0.1% if the chemical meets the OSHA carcinogen standard. See Table II for the de minimis value associated with each listed toxic chemical. For mixtures that contain more than one member of a listed chemical category, the de minimis level applies to the aggregate concentration of all such members and not to each individually. EPA included the de minimis exemption In the njle as a burden reducing step, primarily because facilities are not likely to have information on the presence of a chemical in a mixture or trade name product beyond that available in the product s MSDS. The de minimis levels are consistent with OSHA requirements lor development of MSDS information concerning composition. 

Supplier Notification. In 1989 and subsequent years, suppliers of facilities in SIC codes 20-39 are required to develop and distribute a notice if the mixtures or trade name products that they manufacture or process, and subsequently distribute, contain listed toxic chemicals. These notices are distributed to other companies in SIC codes 20-39 or to companies that sell the product to facilities in SIC codes 20-39. tf a Material Safety Data Sheet (MSDS) is not required for the mixture or trade name product, the notification must be in written form (i.e., letter or attachment to a MSDS). Otherwise, the notice must be incorporated into or attached to the MSDS for that product. The supplier notification requirement began with the first shipment of a product in 1989 and must accompany the first shipment each year thereafter. In addition, a new or revised notice must be sent if a change occurs in the product which affects the weight percent of a listed chemical or if it is discovered that a previous notice did not property identify the chemicals or the percentage by weight. For more information on supplier notification, see Appendix E. 

Any toxic chemicals in mixtures or trade name products (M/TNP) must be factored into your threshold and release determinations. 

This column should be completed as described in the instructions for column A of Section 5 above. Enter the amount, in pounds, of the toxic chemical that is being transferred, including mixtures or trade name products containing the chemical. Do not enter the total poundage of wastes. See Section 5 for information on reporting off-site transfers of less than 1 pound As in Section 5, if the total amount transferred is less than 1,000 pounds, you may report a range, but only for reporting years 1987, 1988, and 1989. Enter not applicable, NA, in column A.2 if you have no off-site transfers of the listed chemical. 

The language of the supplier notification requirements covers mixtures or trade name products that are sold or otherwise distributed. The "otherwise distributes" language applies to intra-company transfers. However, if the company has developed an internal communications procedure that alerts their other facilities to the presence and content of covered toxic chemicals in their products, then EPA would accept this. 

Specific percentage by weight of a toxic chemical In the mixture or trade name product to be a trade secret, your notice to customers must contain a statement that the chemical Is present at a concentration that does not exceed a specified upper bound. For example, if a mixture contains 12 percent toluene and you consider the percentage a trade secret, the notification may state that the mixture contains toluene at no more than 15 percent by weight. The upper bound value chosen must be no larger than necessary to adequately protect the trade secret. 

Toxic chemicals in mixtures and in trade name products must be factored into threshold and release determinations. 

The production and uses of PCNs have been reviewed previously [5-7, 12,33,34] and thus are only briefly described here. PCNs were produced commercially as complex technical mixtures with trade names which included Halowaxes (USA), Seekay Waxes (UK), Nibren Waxes (Germany), and Clonacire Waxes (France). The synthesis involved the chlorination of molten naphthalene using chlorine gas and metal chlorides (iron(III) or antimony(V)) as catalysts. Reaction temperatures ranged from 80-200 °C depending on the degree of chlorination required, and proceeded as nucleophilic and electrophilic reactions favoring substitution in the a-(l,4,5,8) positions on the naphthalene molecule (Fig. 1) [6]. 

Natural organic substances and confinfiercial products often use traditional and trade names, respectively. (One reason is that these substances often are not a single compound, rather they are mixtures of many different and compiex compounds.)... 

Phenol—formaldehyde (PF) was the first of the synthetic adhesives developed. By combining phenol with formaldehyde, which has exceptional cross-linking abiHties with many chemicals and materials, and a small amount of sodium hydroxide, a resin was obtained. The first resins soHdified as they cooled, and it was discovered that if it was ground to a powder with a small amount of additional formaldehyde and the appHcation of more heat, the mixture would Hquify and then convert to a permanently hard material. Upon combination of the powdered resin mixture with a filler material such as wood flour, the result then being placed in a mold and pressed under heat and pressure, a hard, durable, black plastic material was found to result. For many years these resulting products were called BakeHte, the trade name of the inventor. BakeHte products are still produced today, but this use accounts for only a small portion of the PF resins used. 

Glycerol Esters. Commercial glycerol esters, though named after the most abundant species, almost always are mixtures of isomeric mono-and diglycerides (see Glycerol). Trade names and compositions of typical commercial products are given in Table 16. 

Surfactants in E/ectroc/eaners. Surfactants typically consist of a long-chain hydrocarbon molecule having a solubilising or water-loving group which can be anionic, cationic, or nonionic when solubilized. Thousands of surfactant products are marketed, usually under trade names (32). In commercially formulated electrocleaners, surfactants are usually anionic, and often mixtures of anionics and nonionics. 

If listed toxic chemicals are present equal to or above the de minimis cut-off level, your supplier must identify the specific components as they appear in Table II and provide their percentage composition by weight in the mixture or product, tf your supplier maintains that the identity ot a toxic chemical is a trade secret, a generic identity that is structurally descriptive must be supplied on the notice. A maximum concentration level must be provided if your supplier contends that chemical composition information is a trade secret. In either case, you do not need to make a trade secret claim on behalf of your supplier (unless you consider your use of the proprietary mixture a trade secret). On Form R, identify the toxic chemical you are reporting according to its generic name provided in the notification. (See the instructions for Part III, Section 2 on page 18 for more information.) tf the listed chemical is present below the de minimis level, no notification is required. 

Pine oil is a by-product of the pulp industry. This oily liquid contains a mixture of terpene alcohols and monoterpenes and is available under the trade name Norpine-65. Snowshoe hare, L. americanus, and voles,M. townsendii, consume less laboratory chow, apples, or carrots if they are treated with pine oil. This response did not habituate within the time of the experiment. When considering the use of pine oil as a herbivore repellent, we have to keep in mind that it is phytotoxic to seedlings if applied topically (Bell and Harestad, 1987). Red deer, C. 

---