7710-25 Primary Premanufacture Notice (PMN)

CBI SUBMISSION

PMN Page 1

PMN2023P1

OMB No. 2070-00 38 Expires 12/31/2025

U.S. ENVIRONMENTAL PROTECTION AGENCY

EPA
When
completed,
send this
form to:

AGENCY USE ONLY

If sending by US Mail:
Office of Pollution Prevention and Toxics
Document Control Office (7407M)
US EPA, 1200 Pennsylvania Ave NW
WASHINGTON, D.C. 20460

Submission Report Number

TS Number

52

•

01/05/2023

FOR NEW CHEMICAL SUBSTANCES

If sending by Courier:
Office of Pollution Prevention and Toxics
Document Control Office (7407M)
US EPA, 1201 Constitution Ave NW
WASHINGTON, D.C. 20460
Contact Numbers: 202-564-8930/8940

Total Number of Pages

•
•

Date of receipt:

PREMANUFACTURE
NOTICE

123456

GENERAL INSTRUCTIONS
You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do not have actual data.
Before you complete this form, you should read the “Instructions Manual for Premanufacture Notification” (the Instructions Manual is available from the Toxic Substances Control Act
(TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603).
If a fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS fee identification number you have generated. Remember, your fee ID number must also
appear on your corresponding fee remittance. For mailing address information see the Help instructions in the e-PMN tool.

Part I – GENERAL INFORMATION
You must provide the currently correct Chemical Abstracts (CA)
Name of the new chemical substance, even if you claim the
identity as confidential. You may authorize another person to
submit chemical identity information for you, but your submission
will not be complete and the review will not begin until EPA
receives this information. A letter in support of your submission
should reference your TS fee identification number. For all
Section 5 Notice submissions (paper or electronic) you must
submit an original notice including all test data; if you claimed any
information as confidential, an original sanitized copy must also be
submitted.

Part II – HUMAN EXPOSURE AND ENVIRONMENTAL
RELEASE
If there are several manufacture, processing, or use operations to
be described in Part II, sections A and B of this notice, reproduce
the sections as needed.

TEST DATA AND OTHER DATA
You are required to submit all test data in your possession or control and to provide a
description of all other data known to or reasonably ascertainable by you, if these data are
related to the health and environmental effects on the manufacture, processing, distribution in
commerce, use, or disposal of the new chemical substance. Standard literature citations may
be submitted for data in the open scientific literature. Complete test data (written in English),
not summaries of data, must be submitted if they do not appear in the open literature. You
should clearly identify whether test data is on the substance or on an analog. Also, the
chemical composition of the tested material should be characterized. Following are examples
of test data and other data. Data should be submitted according to the requirements of
§720.50 of the Premanufacture Notification Rule (40 CFR Part 720).

Test Data (Check Below any included in this notice)

X

Part III – LIST OF ATTACHMENTS
For paper submissions, attach additional sheets if there is not
enough space to answer a question fully. Label each continuation
sheet with the corresponding section heading. In Part III, list these
attachments, any test data or other data and any optional
information included in the notice.

Environmental fate data

Other Data

Health effects data

Risk Assessments

Environmental effects data

Structure/activity relationships

Physical/Chemical Properties (A physical and chemical properties worksheet is
located on the last page of this form.)
Test data not in the possession or control of the submitter

OPTIONAL INFORMATION
You may include any information that you want EPA to consider in
evaluating the new substance. On page 11 of this form, space has
been provided for you to describe pollution prevention and
recycling information you may have regarding the new substance.
“Binding” boxes are included throughout this form for you to
indicate your willingness to be bound to certain statements you
make in this section, such as use, production volume, protective
equipment . . . The intention is to reduce delays that routinely
accompany the development of consent orders or Significant New
Use Rules. Checking a "binding" box in a PMN does not by itself
prohibit the submitter from later deviating from the information
(except chemical identity) reported in the form; however, in the
case of exemption applications (such as TMEA, LVE, LOREX)
certain information provided in such notifications is binding on the
submitter when the Agency approves the exemption application,
especially if the production volume "binding" box is chosen in a
LVE.

CONFIDENTIALITY CLAIMS
You may claim any information in this notice as confidential. To
assert a claim on the form, mark (X) the confidential box next to
the information that you claim as confidential. To assert a claim in
an attachment, circle or bracket the information you claim as
confidential. If you claim information in the notices as confidential,
you must also provide a sanitized version of the notice, (including
attachments). For additional instructions on claiming information
as confidential, read the Instructions Manual.

TYPE OF NOTICE (Check Only One)

X

PMN (Premanufacture Notice)
SNUN (Significant New Use Notice)
TMEA (Test Marketing Exemption Application)
LVE (Low Volume Exemption) @ 40 CFR 723.50(c)(1)
LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723.50(c)(2)
LVE Modification
LOREX Modification
Mock Submission

X

Mark (X) if pending Letter of Support

N

IS THIS A CONSOLIDATED PMN (Y/N)?

1
X

# of chemicals or polymers (Prenotice Communication # required, enter # on
p. 3).
Mark (X) if any information in this notice is claimed as confidential.

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 2

Paperwork Reduction Act: This collection of information is approved by OMB under the Paperwork Reduction
Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2070-0038). Responses to this collection of information are
mandatory for certain persons, as specified at 40 CFR 721 and 725. An agency may not conduct or sponsor, and a
person is not required to respond to, a collection of information unless it displays a currently valid OMB control
number. The public reporting and recordkeeping burden for this collection of information is estimated to be
between 16.97 to 525.85 hours per response. Send comments on the Agency’s need for this information, the
accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden to the
Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave.,
NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the
completed form to this address.

CBI SUBMISSION

PMN Page 2

PMN2023P2

The public reporting and recordkeeping burden for this collection of information is estimated to average 93 hours per response. Send
comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies
Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB
.
control number in any correspondence. Do not send the completed EPA Form 7710-25 to this address.

CERTIFICATION -- A printed copy of this signature page, with original signature, must be submitted
with CD or paper submission.
I hereby certify to the best of my knowledge and belief that all information entered on this form is complete and accurate.
I further certify that, pursuant to 15 U.S.C. § 2613(c), for all claims for protection for any confidential information made with this
submission, all information submitted to substantiate such claims is true and correct, and that it is true and correct that the
person submitting the claim has:
(i) taken reasonable measures to protect the confidentiality of the information;
(ii) determined that the information is not required to be disclosed or otherwise made available to the public under any other
Federal law
(iii) a reasonable basis to conclude that disclosure of the information is likely to cause substantial harm to the competitive
position of the person; and
(iv) a reasonable basis to believe that the information is not readily discoverable through reverse engineering.
Any knowing and willful misrepresentation is subject to criminal penalty pursuant to 18 U.S.C. § 1001.

Additional Certification Statements:
If you are submitting a PMN, SNUN, LoREX, LVE, or TMEA, check the following Fees Certification
statement that applies:
X

The Company named in Part I, Section A is a “small business concern” as defined under 40 CFR 700.43 and will remit the
fee as specified in 40 CFR 700.45(c).
The Company named in Part I, Section A will remit the fee as specified in 40 CFR 700.45(c).
This joint submission includes at least one Company which is a “small business concern” and at least one Company which is
not a “small business concern,” as defined under 40 CFR 700.43. The fee will be remitted with the joint submission. Any
remaining balance due for this joint submission is to be paid by the secondary submitter(s).
The company named in Part I, Section A is submitting a sustainable futures TME. The company has graduated from EPA's
Sustainable Futures program and is therefore exempt from fees for this sustainable futures TME.

If you are submitting a Low Volume Exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a
Low Release and Low Exposure Exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check
the following certification statements:
The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes,
other than in small quantities solely for research and development, under the terms of 40 CFR 723.50.

The manufacturer is familiar with the terms of this section and will comply with those terms; and

The new chemical substance for which the notice is submitted meets all applicable exemption conditions.
If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence manufacture of
the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period.

Confidential

Signature and title of
Authorized Official (Original
Signature Required)

ES/Scott Stevenson

Date

EPA Form 7710-25 (12-19)

01/05/2023

X

Replaces previous editions of EPA Form 7710-25

Page 3

CBI SUBMISSION

PMN Page 3

PMN2023P3

Part I -- GENERAL INFORMATION
Section A – SUBMITTER IDENTIFICATION
Mark (X) the "Confidential" box next to any subsection you claim as confidential

1a.

Confidential

Person Submitting Notice (in U.S.)

Name of Authorized Official

(first)

Position

Not Applicable

Company

CGI FEDERAL

Mailing Address (number & street)

12601 FAIRLAKES CIRCLE

City

FAIRFAX

email

[email protected]

b.

Agent (if Applicable)

(last)

Scott

X

State

(first)

Name of Authorized Official

Stevenson

VA

Postal Code

22033

Confidential
(last)

Scott

Stevenson

Position
Company

CGI FEDERAL

Mailing Address (number & street)

12601 FAIRLAKES CIRCLE

City

X

State

FAIRFAX

VA

Postal Code

Telephone
(include area code)

e-mail

[email protected]

c.

Joint Submitter (if applicable)

22033
5713180113
Confidential

X

If you are submitting this notice as part of a joint submission, mark (X)
(first)

Name of Authorized Official

(last)

John

Doe

Position
Company

Test

Mailing Address (number & street)

123 fakestreet

X

City

Test

e-mail

[email protected]

2.

Technical Contact (in U.S.)

State

(first)

Name of Authorized Official

VA

Postal Code

Telephone
(include area code)

12345
1234567890
Confidential

(last)

Scott

Stevenson

Position
Company

CGI FEDERAL

Mailing Address (number & street)

12601 FAIRLAKES CIRCLE

City
e-mail

State

FAIRFAX

X
VA

Postal Code

Telephone
(include area code)

[email protected]

3.

If you have had a prenotice communication (PC) concerning
this notice and EPA assigned a PC Number to the notice,
enter the number.

4.

If you previously submitted an exemption application for the
chemical substance covered by this notice, enter the
exemption number assigned by EPA. If you previously
submitted a PMN for this substance enter the PMN number
assigned by EPA (i.e. withdrawn or incomplete).

5.

If you have submitted a notice of Bona fide intent to
manufacture or import for the chemical substance covered
by this notice, enter the notice number assigned by EPA.

6.

22033
5713180113

Mark (X) if none

1

Confidential

X
Mark (X) if none

P-22-2222

Confidential

X
Mark (X) if none

3

Confidential

X

Type of Notice – Mark (X)
Manufacture Only

1.
Binding Option

X

Import Only

2.

3.

Both

Binding Option

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 4

CBI SUBMISSION
PMN2023P4-1

Continuation Sheet
ID

P3SB1bC1

Field

Part I, Section A, 1.c. Letter Of Support

First Name: Jane
Last Name: Doe
Position:
Company Name: Test
Address: 123 fakestreet
City: Test
State: VA
Postal Code: 12345
Country: US
Email: [email protected]
Telephone: 1234567890
CBI: Y

Replaces previous editions of EPA Form 7710-25

EPA Form 7710-25 (12-19)

Page 5

CBI SUBMISSION

PMN Page 4

PMN2023P4

Part I – GENERAL INFORMATION -- Continued
You must provide a currently correct Chemical Abstracts (CA) name of the substance
based on current CA index nomenclature rules and conventions.
Mark (X) the “Confidential” box next to any item you claim as confidential

Section B – CHEMICAL IDENTITY INFORMATION:

Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items.
If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right. Identify
the name, company, and address of that person in a continuation sheet.
1. Class 1 or 2 chemical substances (for definitions of class 1 and class
2 substances, see the Instructions Manual)

Class 1

Class 2

CBI

a. Class of substance - Mark (X)
b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar
substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA
Preferred Name must be provided, which ever is appropriate based on current CA index nomenclature rules and conventions).

X

Formaldehyde

CAS Registry Number (if a number already exists for the substance)

50-00-0

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one).
Method 2
Method 1 (CAS Inventory Expert Service - a copy of the
IES Order
Identification report obtained from the CAS Inventory Expert
(Other
X
Number
Services must be submitted as an attachment to this notice)
Source)
Enter Attachment filename for Part I, Section B, 1. c.
d. Molecular formula

test

X

e. For a class 1 substance, provide a complete and correct chemical structure diagram. For a class 2 substance, provide a correct
representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained.

X

See Attachment (Original Document: 1 CBI.docx
)

Enter Attachment filename for Part I, Section B, 1. e.

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 6

PMN2023P4A

CBI SUBMISSION

PMN Page 4a

For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe
the nature of the reaction or process. (3) Indicate the range of composition and the typical composition (where appropriate).

Confidential

e. (1) List the immediate precursor substance names with their respective CAS Registry Numbers.

Enter Attachment filename for Part I, Section B, 1. e. (1)
e. (2) Describe the nature of the reaction or process.

Enter Attachment filename for Part I, Section B, 1. e. (2)
e. (3) Indicate the range of composition and the typical composition (where appropriate).

Enter Attachment filename for Part I, Section B, 1. e. (3)

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 7

PMN2023P6

PMN Page 6
Part I -- GENERAL INFORMATION -- Continued

CBI SUBMISSION

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued
3. Impurities
(a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial
purpose. Provide the CAS Registry Number if available. If there are unidentified impurities, enter “unidentified.”
(b) - Estimate the maximum weight % of each impurity. If there are unidentified impurities, estimate their total weight %.
CAS Registry
Maximum
ConfiImpurity (a)
Number
Percent %
dential
(a)
(b)

Formaldehyde

50-00-0

5.0

X

Mark (X) this box if the data continues on the next page.
Enter Attachment filename for Part I, Section B, 3.
4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2.

Enter Attachment filename for Part I, Section B, 4.
5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2.

Enter Attachment filename for Part I, Section B, 5.
6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals the
specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the TSCA Chemical
Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names.

test chem,

Enter Attachment filename for Part I, Section B, 6.
7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the
CAS Registry Number if available.
CAS Registry Number
ConfiByproduct (1)
(2)
dential

Mark (X) this box if the data continues on the next page.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 8

PMN2023P5X1

PMN Page 5
Part I -- GENERAL INFORMATION – Continued

CBI SUBMISSION

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued
2. Polymers (For a definition of polymer, see the Instructions Manual.)
a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture.
Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents)
below 500 and below 1,000 absolute molecular weight of that composition.

Confidential

Describe the methods of measurement or the basis for your estimates:

Other (Specify Below)

GPC
Specify Other:

(i) lowest number average molecular
weight:

(ii) maximum weight % below 500 molecular
weight:

(iii) maximum weight % below 1000 molecular
weight:

Enter Attachment filename for Part I, Section B, 2. a.
b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark
(X) the “Confidential” box next to any item you claim as confidential
(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the
manufacture of the polymer.
(2) - Mark (X) this column if entry in column (1) is confidential.
(3) - Indicate the typical weight percent of each monomer or other reactant in the polymer.
(4) - Choose “yes” from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of
the polymer description on the TSCA Chemical Substance Inventory.
(5) - Mark (X) this column if entries in columns (3) and (4) are confidential.
(6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as
manufactured for commercial purposes.
(7) - Mark (X) this column if entry in column (6) is confidential.
Max
Typical Include in
Monomer or other reactant specific chemical name
CBI residual CBI
CBI composition identity
(1)
(6)
(4)
(3)
(7)
(5)
(2)

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)
Mark (X) this box if the data continues on the next page.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 9

PMN2023P5AX1

CBI SUBMISSION

PMN Page 5a

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice
(check one).
Method 1 (CAS Inventory Expert Service
IES Order
Method 2
- a copy of the identification report obtained
Number
(other source)
from CAS Inventory Expert Service must be
submitted as an attachment to this notice)

CBI

Enter Attachment filename for Part I, Section B, 2. c.
d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar
polymers.

CAS Registry Number (if a number already exists for the substance)
e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably
ascertained.

Enter Attachment filename for Part I, Section B, 2. e.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 10

PMN2023P7

CBI SUBMISSION

PMN Page 7
Part I -- GENERAL INFORMATION -- Continued

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION:
The information on this page refers to consolidated chemical number(s):

X 1

2

3

4

5

6

Mark (X) the “Confidential” box next to any item you claim as confidential.
1. Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production
volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% new chemical substance basis.
For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 kg/yr, specify the
volume and mark (x) in the binding box. If granted, you are bound to this volume.
Maximum first 12-month production (kg/yr)
(100% new chemical substance basis)

2

Maximum 12-month production (kg/yr)
(100% new chemical substance basis)

Binding Option
Mark (X)

Confidential

X

2

CBI

Enter Attachment filename for Part I, Section C, 1.

2. Use Information -- You must make separate confidentiality claims for the description of the category of use, the percent of production volume devoted
to each category, the formulation of the new substance, and other use information. Mark (X) the “Confidential” Box next to any item you claim as
confidential.
a. (1) --Describe each intended category of use of the new chemical substance by function and application.
(2) --Mark (X) this column if entry column (1) is confidential business information (CBI).
(3) --Indicate your willingness to have the information provided in column (1) binding.
(4) --Estimate the percent of total production for the first three years devoted to each category of use.
(5) --Mark (X) this column if entry in column (4) is confidential business information (CBI).
(6) --Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for
commercial purposes at sites under your control associated with each category of use.
(7) --Mark (X) this column if entry in column (6) is confidential business information (CBI).
(8) --Indicate % of product volume expected for the listed “use” sectors. Mark more than one box if appropriate. Mark (X) to indicate your
willingness to have the use type provided in (8) binding.
(9) --Mark (X) this column if entry(ies) in column (8) is (are) confidential business information (CBI).
% of substance expected per use
% in
Prod
Binding
Category of use (1)
(8)
CBI
FormCBI
uction
CBI
Option
CBI
(by function and application i.e. a dispersive dye for
ulation
%
Mark (X)
SiteConComBinding
finishing polyester fibers)
Industrial
limited
sumer*
mercial
Option
(9)
(7)
(5)
(2)
(6)
(4)
(3)

X

test

100.0

X

100.0

X

25.0

25.0

25.0

25.0

* If you have identified a “consumer” use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in
consumer products. In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe
the chemical reactions by which this substance loses its identity in the consumer product.

X

Mark (X) this box if the data continues on the next page.
b.

Generic use
description

If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category.
Read the Instruction Manual for examples of generic use descriptions.

testing

CBI

Enter Attachment filename for Part I, Section C, 2. b.

3. Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety
data sheet, or other information which will be provided to any person who is reasonably likely to be exposed to this substance
regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III
hazard information you include.

Binding Option
Mark (X)

Mark (X) this box if you attach hazard information.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 11

CBI SUBMISSION
PMN2023P7-1

Continuation Sheet
ID

Field

Part I, Section C, 2.a. Additional Consumer Use Text

Category of Use: test
Consumer Use: test : testing
Attachments:

Replaces previous editions of EPA Form 7710-25

EPA Form 7710-25 (12-19)

Page 12

PMN Page 8
Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

CBI SUBMISSION

PMN2023P8

Mark (X) the “Confidential” box next to
any item you claim as confidential

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER
X 1

The information on pages 8 and 8a refer to consolidated chemical number(s):

2

3

4

5

6

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites
you control. Importers do not have to complete this section for operations outside the U.S.; however, you may still have reporting
requirements if there are further industrial processing or use operations after import. You must describe these operations. See
instructions manual
1. Operation description
Confidential
a.1 Identity -- Enter the identity of the site at which the operation will occur.
Name

CGI FEDERAL DEMO

Site address (number and
street)
City
State

12601 FAIR LAKES CIR

X

FAIRFAX

County

FAIRFAX COUNTY

VA

ZIP code

22033

a.2 If the same operation will occur at more than one site, enter the number of sites. Identify the additional sites on
a continuation sheet, and if any of the sites have significantly different production rates or operations, include all the
information requested in this section for those sites as attachments. Æ

1

X

Mark (X) this box if the data continues on the next page.

b. Type -Mark (X)

Manufacturing

Use

Processing

Confidential

c. Amount and Duration -- Complete 1 or 2 as appropriate

1. Batch

2. Continuous

Maximum kg/batch
(100% new chemical
substance)

Hours/batch

Batches/year

Maximum kg/day
(100% new chemical substance)

Hours/day

Days/year

Mark (X) to indicate your willingness to
have your process description binding.

d. Process description
(1)
(2)

(3)

Æ

Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon
pails, 55 gallon drum, rail car, tank truck, etc.).
Provide the identity, the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting
materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning
chemicals (note frequency if not used daily or per batch.).
Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. If
releasing to two media at the same step, assign a second release number for the second medium.

test

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

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PMN2023P8A

PMN Page 8a

CBI SUBMISSION

Confidential

Diagram of the major unit operation steps.

Enter Attachment filename for Part II, Section A, 1. d.

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

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CBI SUBMISSION

PMN Page 9

PMN2023P9

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued
Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued
X 1
2
3
4
The information on pages 9 and 9a refer to consolidated chemical number(s):

5

6

2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical
substance, number of workers exposed, and duration of activity. Mark (X) the “Confidential” box next to any item you claim as confidential.
(1) -- Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the
substance.
(2) -- Mark (X) this column if entry in column (1) is confidential business information (CBI).
(3) -- Describe any protective equipment and engineering controls used to protect workers.
(4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding.
(5) -- Indicate the physical form(s) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (if
part of a mixture) at the time of exposure.
(7) -- Mark (X) this column if entries in columns (3) and (5) are confidential business information (CBI).
(8) -- Estimate the maximum number of workers involved in each activity for all sites combined.
(9) -- Mark (X) this column if entry in column (8) is confidential business information (CBI).
(10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year.
(12) -- Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI).
Worker activity
(i.e., bag dumping, filling
drums)
(1)

Loading into Bottles

Protective Equipment/
CBI
Engineering Controls
(3)

(2)

X

test

Binding
Option
Mark (X)
(4)

Physical
form(s)
& % new
substance
(5)

1, 1

Binding
Option
Mark (X)
(6)

# of
CBI Workers CBI
Exposed
(7)
(8)
(9)

1

Maximum Duration
Hrs/Day
(10)

Days/Yr
(11)

1

1

CBI
(12)

Mark (X) this box if the data continues on the next page.
Enter Attachment filename for Part II, Section A on the bottom of page 9a.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 15

CBI SUBMISSION

PMN Page 9a

PMN2023P9A

3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical
substance released and other release and disposal information. Mark (X) the “Confidential” box next to each item you claim as confidential.
(1) -- Enter the number of each release point identified in the process description, part II, section A, subsection 1d(3).
(2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch).
(3) -- Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI).
(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or
other (specify)) to which the new substance will be released from that release point.
(5) -- a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment.
For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste.
On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to
secondary or tertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day).
(6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI).
(7) -- Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct
discharges or NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential
business information (CBI).
Release
Number
(1)

Amount of New
Substance Released
(2a)

(2b)

CBI

Medium of release
e.g. Stack air

(3)

(4)

Control technology and efficiency (you may wish to
optionally attach efficiency data)
Binding
Mark
(X)

(5a)

(5b)

CBI
(6)

Mark (X) this box if the data continues on the next page.

(7) Mark (X) the destination(s) of releases to water.

NPDES#

X

POTW--provide
name(s)

Scott Stevenson

1234

X

Navigable waterway- provide name(s)

John Doe

1234

X

Other--Specify

CBI

X

Jane Doe

Enter Attachment filename for Part II, Section A.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 16

PMN2023P10

CBI SUBMISSION

PMN Page 10

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE – Continued
Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS
1
2
3
4
The information on pages 10 and 10a refer to consolidated chemical number(s):

5

6

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to
complete this section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual.
Complete a separate section B for each type of processing, or use operation involving the new chemical substance. If the same operation is performed at
more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet.

1(a). Operation Description -- To claim information in this section as confidential, bracket (e.g. {}) the specific information that you claim as
confidential.
(1) -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 gallon
pails, 55 gallon drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity.
(2) -- Either in the diagram or in the text field 1(b) below, provide the identity, the approximate weight (by kg/day or kg/batch, on an 100% new
chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle
streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch).
(3) -- Either in the diagram or in the text field 1(b) below, identify by number the points of release, including small or intermittent releases, to the
environment of the new chemical substance.
(4) -- Please enter the # of sites (remember to identify the locations of these sites on a continuation sheet):

Number of Sites

1(b). (Optional) This space is for a text description to clarify the diagram above.

Confidential

Confidential

Enter Attachment filename for Part II, Section B on the bottom of page 10a.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 17

CBI SUBMISSION

PMN Page 10a

PMN2023P10A

2. Worker Exposure/Environmental Release
(1) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described.
(2) -- Estimate the number of workers exposed for all sites combined.
(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year.
(6) -- Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if
any, used to protect workers.
(7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product.
(9) -- From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified.
(10) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in
kg/day or kg/batch).
(12) -- Describe media of release i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration,
POTW, or other (specify) and control technology, if any, that will be used to limit the release of the new substance to the environment.
(14) -- Identify byproducts which may result from the operation.
(3), (5), (8), (11), (13) and (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI).
Letter
of
Activity

# of
Workers
Exposed

CBI

(1)

(2)

(3)

Release
Number

Duration of
Exposure
(4a)

(4b)

CBI

Protective Equip./Engineering Controls/Physical
Form

% new
substance

% in
Formulation

CBI

(5)

(6)

(6)

(7)

(8)

Amount of New Substance Released

(9)

(10a)

(10b)

CBI

Media of Release & Control Technology

CBI

(11)

(12)

(13)

Mark (X) this box if the data continues on the next page.
(14) Byproducts:

(15) CBI

Enter Attachment filename for Part II, Section B.

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 18

PMN2023P11

CBI SUBMISSION

PMN Page 11

OPTIONAL POLLUTION PREVENTION INFORMATION
To claim information in the following section as confidential, bracket (e.g. {}) the specific information that you claim as confidential.
In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce or minimize potential risks
associated with activities surrounding manufacturing, processing, use and disposal of the PMN substance. Please include new information
pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new chemical
substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, process and
procedure modification, product reformulation, and/or raw materials substitution. Recycling refers to the reclamation of useful chemical components
from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal. Quantitative or qualitative
descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction in addition to compliance with existing
regulatory requirements. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and
exposures, not the shifting of risks to other media (e.g., air to water) or nonenvironmental areas (e.g., occupational or consumer exposure). To the
extent known, information about the technology being replaced will assist EPA in its relative risk determination. In addition, information on the
relative cost or performance characteristics of the PMN substance to potential alternatives may be provided.
Describe the expected net benefits, such as
(1) an overall reduction in risk to human health or the environment;
(2) a reduction in the generation of waste materials through recycling, source reduction or other means;
(3) a reduction in the use of hazardous starting materials, reagents, or feedstocks;
(4) a reduction in potential toxicity, human exposure and/or environmental release; or
(5) the extent to which the new chemical substance may be a substitute for an existing substance that poses a greater overall risk to human
health or the environment.
Information provided in this section will be taken into consideration during the review of this substance. See PMN Instructions Manual
and Pollution Prevention Guidance manual for guidance and examples.

This pollution prevention information contains CBI.
testing

Enter Attachment filename for Pollution Prevention Page 11.

EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 19

PMN2023P12

CBI SUBMISSION

PMN Page 12
Part III -- LIST OF ATTACHMENTS

Attach continuation sheets for sections of the form, test data and other data (including physical/chemical properties and
structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form
to which it relates, if appropriate. Number consecutively the pages of any paper attachments. In the Number of Pages column
below, enter the inclusive page numbers of each attachment for paper submissions or enter the total number of pages for each
attachment for electronic submissions. Electronic attachments can be identified by filename.
Mark (X) the “Confidential” box next to any attachment name or filename you claim as confidential. Read the Instructions Manual
for guidance on how to claim any information in an attachment as confidential. You must include with the sanitized copy of the
notice form a sanitized version of any attachment in which you claim information as confidential.
Attachment Name

#

1

test

Attachment Filename

CBI.docx

Number
of Pages

1

Associated
PMN Section
Number

Class 1 or 2 Substances Chemical
Structure Diagram (test)

CBI

X

Mark (X) this box if the data continues on the next page.
EPA Form 7710-25 (12-19)

Replaces previous editions of EPA Form 7710-25

Page 20

CBI SUBMISSION
PMN2023P13

X

7

X

1

Page 21

Estimate

X

CBI SUBMISSION
PMN2023P14

CBI Substantiation
Selected Chemical Identifier: N/A
Selected Chemical Claim: Additional Submission Information - Bona Fide Intent Notice Number--3
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 5
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
test
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
test
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No

Page 22

CBI SUBMISSION

test
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
test
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Additional Submission Information - Prenotice Communication Number--1
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 3
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*

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CBI SUBMISSION

3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: Additional Submission Information - Previously Submitted Notice Number--P-22-2222
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 4
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
Page 24

CBI SUBMISSION

taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
test
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
test
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
test
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
test
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
test

Page 25

CBI SUBMISSION

Selected Chemical Identifier: N/A
Selected Chemical Claim: Agent Contact Information--Stevenson, Scott
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 1
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
test
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
test
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
test

Page 26

CBI SUBMISSION

4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
test
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: 50-00-0
Selected Chemical Claim: CLASS 1 OR 2 CHEMICAL SUBSTANCES - Chemical Name--Formaldehyde
1. Is this chemical substance publicly known (including by your competitors) to be in U.S. commerce? If yes, please
explain why the specific chemical identity should still be afforded confidential status (e.g.,the chemical substance is
publicly known only as being distributed in commerce for research and development purposes, but no other
information about the current commercial distribution of the chemical substance in the United States is publicly
available). If no, please complete the certification statement:
I certify that on the date referenced I searched the internet for the chemical substance identity (i.e.,by both chemical
substance name and CASRN). I did not find a reference to this chemical substance and have no knowledge of
public information that would indicate that the chemical is being manufactured or imported by anyone for a
commercial purpose in the United States. [provide date].
Yes/No: Yes
Cbi: Yes
test 6
2. Does this specific chemical substance leave the site of manufacture (including import) in any form,e.g.,as a
product, effluent, emission? If yes, please explain what measures have been taken to guard against the discovery
of its identity.
Yes/No: No
Cbi: No
test
3. If the chemical substance leaves the site in a form that is available to the public or your competitors, can the
chemical identity be readily discovered by analysis of the substance (e.g.,product, effluent, emission), in light of
existing technologies and any costs, difficulties, or limitations associated with such technologies? Please explain
why or why not.
Yes/No: No
Cbi: No
test
Page 27

CBI SUBMISSION

4. Would disclosure of the specific chemical identity release confidential process information? If yes, please explain.
Yes/No: No
Cbi: No
test
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: No
Cbi: No
test
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Page 28

CBI SUBMISSION

Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: CLASS 1 OR 2 CHEMICAL SUBSTANCES - Document--CBI.docx (Chemical Structure)
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 8
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
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CBI SUBMISSION

3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: CLASS 1 OR 2 CHEMICAL SUBSTANCES - Molecular Formula--null
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 7

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2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
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Selected Chemical Identifier: 50-00-0
Selected Chemical Claim: ADDITIONAL CHEMICAL INFORMATION - Impurity--Formaldehyde
1. Is this chemical substance publicly known (including by your competitors) to be in U.S. commerce? If yes, please
explain why the specific chemical identity should still be afforded confidential status (e.g.,the chemical substance is
publicly known only as being distributed in commerce for research and development purposes, but no other
information about the current commercial distribution of the chemical substance in the United States is publicly
available). If no, please complete the certification statement:
I certify that on the date referenced I searched the internet for the chemical substance identity (i.e.,by both chemical
substance name and CASRN). I did not find a reference to this chemical substance and have no knowledge of
public information that would indicate that the chemical is being manufactured or imported by anyone for a
commercial purpose in the United States. [provide date].
Yes/No: Yes
Cbi: No
test 9
2. Does this specific chemical substance leave the site of manufacture (including import) in any form,e.g.,as a
product, effluent, emission? If yes, please explain what measures have been taken to guard against the discovery
of its identity.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3. If the chemical substance leaves the site in a form that is available to the public or your competitors, can the
chemical identity be readily discovered by analysis of the substance (e.g.,product, effluent, emission), in light of
existing technologies and any costs, difficulties, or limitations associated with such technologies? Please explain
why or why not.
Yes/No: No
Cbi: No
test
4. Would disclosure of the specific chemical identity release confidential process information? If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: No
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Cbi: No
test
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
test
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
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CBI SUBMISSION

Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET - Property
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 14
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
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CBI SUBMISSION

Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: PRODUCTION VOLUME AND HAZARD/SAFETY INFORMATION - Production Volume
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 10
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
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CBI SUBMISSION

3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: USE INFORMATION - Category of Use (PMN)
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 11

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CBI SUBMISSION

2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
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CBI SUBMISSION

Selected Chemical Identifier: N/A
Selected Chemical Claim: USE INFORMATION - In Formulation (PMN)
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 13
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*

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CBI SUBMISSION

4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: USE INFORMATION - Total Production Percent (PMN)
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 12
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
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CBI SUBMISSION

or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: ENVIRONMENTAL RELEASES - POTW
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 16
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
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CBI SUBMISSION

that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: JOINT SUBMITTER INFORMATION - Contact--Doe,John
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
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CBI SUBMISSION

the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 18
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
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CBI SUBMISSION

*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: LETTER OF SUPPORT SUBMITTER INFORMATION - Contact--Doe,Jane
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 19
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
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CBI SUBMISSION

*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: OCCUPATIONAL EXPOSURES - Worker Category
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 15
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
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3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: OPTIONAL COVER LETTER - Optional Cover Letter (PMN)
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
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substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 18
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
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CBI SUBMISSION

determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: OPTIONAL POLLUTION PREVENTION-Information-Comments
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 17
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
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CBI SUBMISSION

competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: SUBMITTER OPERATION INFORMATION - Facility--CGI FEDERAL DEMO
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 15
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
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CBI SUBMISSION

Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*
Selected Chemical Identifier: N/A
Selected Chemical Claim: SUBMITTING OFFICIAL INFORMATION - Submitter
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: Yes
test 20
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CBI SUBMISSION

2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
test
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
test
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
test
4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
test
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
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CBI SUBMISSION

test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information--Stevenson, Scott
1. Please specifically explain what harm to the competitive position of your business would be likely to result from
the release of the information claimed as confidential. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g. site information, exposure information,
environmental release information, etc.), explain how disclosure of each type of information would be likely to cause
substantial harm to the competitive position of your business.
Yes/No: Yes
Cbi: No
test 2
2. Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please
explain and identify the specific measures, including but not limited to internal controls, that your business has
taken to protect the information claimed as confidential. If the same or similar information was previously reported
to EPA as non-confidential (such as in an earlier version of this submission), please explain the circumstances of
that prior submission and reasons for believing the information is nonetheless still confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3B. Does any of the information claimed as confidential otherwise appear in any public documents, including (but
not limited to) safety data sheets; advertising or promotional material; professional or trade publications; state, local,
or Federal agency files; or any other media or publications available to the general public? If yes, please explain
why the information should be treated as confidential.
Yes/No: No
Cbi: No
*Text Area Left Empty*
3C. Has a patent been published for the chemical identity you claim confidential? What chemical identity
information is not revealed by the patent? How is release of that specific information likely to cause substantial
competitive harm? And failure to explain this harm may lead to denial of your confidentiality claim.
Yes/No: No
Cbi: No
*Text Area Left Empty*
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CBI SUBMISSION

4. Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please
indicate the number of years (between 1-10 years) or the specific date after which the claim is withdrawn.
Yes/No: No
Cbi: No
*Text Area Left Empty*
5. Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, please provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that made the
decision, and the date of the determination.
Yes/No: No
Cbi: No
*Text Area Left Empty*

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