Non-SDA Alkyl-Range Descriptions

The EPA has offered very little guidance in addition to the SDA rules. Given the EPA s current view that chemical substances should be described as accurately as possible, it is advisable to include all alkyl groups that could be reasonably anticipated to contribute commercial value to the product, and to make sure that no alkyl groups that contribute commercial value to the product are excluded from such a listing. This guidance is supported by a note in the introductory section of Volume 1 of the 1985 printed version of the TSCA Inventory. 

In the case of a class-2 substance—defined under the EPA s TSCA regulations as a substance whose composition cannot be represented by a definite chemical structure diagram—the substance may be identified on the TSCA Inventory in a less precise manner, e.g., Cg g alkenes. Persons using the TSCA Inventory are cautioned that such a category is not intended to encompass class-1 substances, defined under the EPA s TSCA regulations as substances that can be more precisely described. For example, 1-hexene, if manufactured as such, is considered a different substance than Cg.g alkenes,  

Non-SDA, alkyl-range descriptors may generally be used to describe the substances listed below. 

A combination of chemical substances that contains all of the carbon numbers in the alkyl-range descriptor. For example, a distillation cut of C5, Cg, C7, and Cg alcohols could be described as Cg g alcohols. 

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