Most Common Errors Found on Form R Reports

MOST COMMON ERRORS FOUND ON FORM R REPORTS 

CAS number and the chemical name reported on page three must exactly match the listed section 313 CAS number and chemical name. Chemical categories should not be reported with a CAS number. A generic chemical name should only be provided if you are claiming the section 313 chemical identity as trade secret. Chemical names should be taken directly from the list in this document (see pages 40-48). Mixture names are to be entered in Part III, Section 1.4 if that is the sole identification. Mixture names that include the name (or CAS number) of one or more section 313 chemical(s) are not valid. 

Failure to consider listed chemical qualifier. Aluminum, vanadium and zinc are qualified as fume or dust. Isopropyl alcohol and saccharin have manufacturing qualifiers. Ammonium nitrate and ammonium sulfate are qualified as solutions. Phosphorus is qualified as yellow or white. Asbestos is qualified as friable. Only chemicals meeting the qualifiers require reporting under section 313 and should be reported on Form R with the appropriate qualifier in parenthesis. 

Missingcertificatlonsignature. An original certification signature must appear on page one of every Form R submitted to EPA. 

Maximum amount on-site left blank. In a surprising number of Forms, Part HI, Section 4 on page three of Form R is left blank. Leaving this section blank will result in a Notice of Technical Error. 

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Appendix D—Most Common Errors Found on Form R Reports.91... 

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