TSCA Initial Inventory

TSCA Initial Inventory, 1979, 43,278 records, irregular updates (DIALOG Information Retrieval Service, Palo Alto, CA and Environmental Protection Agency, Office of Toxic Substances, Washington, D.C.)... 

TSCA Initial Inventory (Derived from the Initial Inventory of the Toxic Sub-... 

The Toxic Substances Control Act (TSCA) was enacted in 1976 to identify and control toxic chemical ha2ards to human health and the environment. One of the main provisions of TSCA was to estabUsh and maintain an inventory of all chemicals in commerce in the United States for the purpose of regulating any of the chemicals that might pose an unreasonable risk to human health or the environment. An initial inventory of chemicals was estabhshed by requiring companies to report to the United States Environmental Protection Agency (USEPA) all substances that were imported, manufactured, processed, distributed, or disposed of in the United States. Over 50,000 chemical substances were reported. PoUowing this initial inventory, introduction of all new chemical substances requires a Premanufacturing Notification (PMN) process. To be included in the PMN are the identity of the new chemical, the estimated first year and maximum production volume, manufacture and process information, a description of proposed use, potential release to the environment, possible human exposure to the new substance, and any health or environmental test data available at the time of submission. In the 10 years that TSCA has been in effect, the USEPA has received over 10,000 PMNs and up to 10% of the submissions each year are for dyes (382)... 

In the United States, the Toxic Substances Control Act (TSCA) Chemical Substances Inventory (derived from the Initial Inventory of the TSCA Chemical Substance Inventory) is a listing of chemical substances manufactured, imported, or in commercial use in the United States.27 It is not a list of toxic chemicals, since toxicity is not a criterion for inclusion in the list. It was developed in response to Section 8 (d) of the TSCA, public law 94-469, and was prepared by the U.S. EPA. 

The initial Inventory covers chemicals that were manufactured in or imported into the United States for the period of January 1,1975 through December 31,1977. New chemicals that have completed PMN review are added to the Inventory after commercial manufacture of the chemical has commenced. In addition, the TSCA Inventory provides a basis for chemical screening, chemical risk assessment, and chemical management. Many new chemicals are submitted as confidential materials, which mean that information on structure, use, etc. is not available to the public.28 The premise is that the release of this information would be detrimental to the financial interests of the submitting company. 

Under TSCA Section 8(b), the EPA is required to develop and maintain a list of all chemical substances that are manufactured, processed, or used in the U.S. for commercial purposes (note that the term manufacture includes importation under the TSCA). The initial Inventory was developed from 1978 to 1980 using input from the chemical industry that allowed existing chemical... 

One particular area within the category of branched alkyl groups that has resulted in major confusion to the chemical industry and in hundreds of errors in the identification of substances on the TSCA Inventory is that of nonylphenol and its derivatives. The problem arises due to vague and inaccurate descriptions of nonylphenol for the purposes of placing substances on the initial Inventory and in subsequent PMN involving nonylphenol derivatives. The result is that there are numerous nonylphenol derivatives on the TSCA Inventory but they are listed with incorrect chemical identities. 

When EPA rejects a request for a correction, it sends the submitter a denial letter with the reasons for the denial. In some situations, EPA will specify what additional information will be needed for it to reevaluate the request, and a second submittal may lead to an acceptance. If the correction is accepted, the correct substance identity is considered to be legally included in the TSCA Inventory retroactively to the time of the initial Inventory, or to the time when the substance was placed on the Inventory through submission of a Notice of Commencement. When an Inventory correction is accepted, the erroneously listed chemical remains on the Inventory until EPA makes a formal Federal Register announcement of its removal from the Inventory to avoid disrupting commercial activity by the unpublished deletion of a chemical listing upon which some companies may be relying. 

Includes both chemicals on the initial Inventory and those subsequently added. Does not include substances formally exempted from TSCA notification. 

A second major provision of TSCA which is self-implementing, is the requirement for a pre-manufacturing notice on new chemical substances. This requirement was triggered by the publication of the Initial TSCA Inventory in May of 1979. By law, the PMN program started 30 days after the inventory of chemical... 

The inventory of products, isolated intermediates, imports and useful byproducts was initially collected in a complex database with room for additional substances and attributes. For TSCA submission, computer tapes were then easily produced with appropriate plant location grouping and CAS Registry number and inventory number identification. This not only saved considerable clerical effort but assured accuracy in transcription and form preparation. 

Section 8 regulates the division between new and existing substances, the latter initially being all chemicals on the market before December 1979 and listed (according to Section 8(b)) in the TSCA Chemical Substance Inventory . The approximately... 

Many CASRN are associated with trade names, which were valuable to chemical processors and users at the time of the compilation of the initial TSCA Inventory, but trade names have no significance with respect to the chemical identity of substances or their status in the TSCA Inventory. 

The two-percent rule has been used since the development of the TSCA Inventory in the determination as to which reactants must be included in naming the polymer for TSCA purposes. The two-percent rule means that monomers and reactants of a polymer that are used or incorporated at no more than 2 wt%, may be, but need not be, included in the considerations leading to the formal chemical description of a polymer manufactured from those precursors [3]. It is the submitter s choice as to whether he/she wishes to have these reactants considered or not considered in describing a polymer. There is no choice for precursors used or incorporated (whichever is less) at more than two weight percent. These precursors must be included in the information reported, and, ordinarily, they will be reflected in the name of the polymer. The two-percent rule has not meant that a precursor reflected in the description of a polymer must be used [4] or incorporated [5] at more than two weight percent. Therefore, any precursor reflected in description of a polymer can be used at any concentration greater than zero, but a precursor must not be completely omitted. These applications and interpretations of the two-percent rule also applied under the initial polymer exemption of 1983. 

At least one other possibility exists. Assume, for example, that a very small amount of BPA is used with an excess of ECH under conditions that favored homopolymerisation of ECH (which may be different than conditions used to copolymerise the two). BPA would not be a monomer because it would not occur as a repeat unit, but rather would become a locus of initiation for a homopolymer of ECH. The most accurate description of the substance would be oxirane, (chloromethyl)-, homopolymer, ether with 4,4 -(l-methylethylidene) bis[phenol] (2 1), CASRN 139873-26-0. This principle also applies for cases in which a reactant such as a peroxide is used as a free radical initiator for a vinyl polymer. For example, a copolymer of monomers A, B, and C made using a free-radical initiator D may be called A, copolymer with B and C, D-initiated. Before 1989, the EPA had not informed industry of the need to include free-radical initiators as part of a polymer name, and therefore polymers placed onto the TSCA Inventory before 1989 do not have to include the free-radical initiator in the polymer name, even if it is used at a level of greater than two percent. In the latter case, the polymer would be named as A, polymer with B and C, without reference to the initiator. 

The Inventory was established in two versions, a public Inventory available and searchable by the public, and a confidential Inventory. The initial public Inventory was published in 1979 and has been continually supplemented. TSCA 14 allows the submission of information imder a claim of confidentiality. Manufacturers and processors were allowed in making initial submissions to the Inventory, and are allowed in submitting PMNs, to claim as confidential certain business information, including specific chemical identity, composition, and process details. If the chemical identity is claimed as confidential, a generic name is used for fifing the Notice of Commencement (NOC). A NOC must be filed after the first manufacture or import of the substance after the PMN process is complete, in order to put the substance on the Inventory. Only the name on the NOC goes on the public Inventory. 

This regulation was issued in connection with compiling the initial TSCA Inventory. For background on the Inventory, see Chapter 3, The hiventory. 

---