7710-25 Pmn

Header Sheet for Creating Extra PMN Submission Pages:
If your PMN needs extra pages, or is a consolidated PMN, fill out this page to instruct the
electronic form on how many additional pages will be needed prior to entering your
submission data. If this is not a consolidated form AND you do not require extra pages, you
may skip this header page and proceed to the PMN form on the following page.
For consolidated Section 5 submissions:
(If not a consolidated submission skip to step 5 below.)
.

1. Enter the prenotice communication number here
2. Does this consolidated PMN form cover polymer or nonpolymer substances?
Polymer

Nonpolymer

3. How many substances were approved for consolidation?
2

3

4

5

6

Based on your answers above, this software will generate required additional copies of pages 4 (if nonpolymer) or 5 (if
polymer) and 6 and 7.
4. Do you need additional copies of other pages for the member substances in this consolidation? If so, please check
the corresponding box for the required extra pages below: (The corresponding pages you check will be generated for
EACH substance, although you may not need the extra page for each substance. If you need more than one extra page
8 and/or page 9 for member substances of your consolidation, you may request them under step 5 below.)
8

9

10

11

13

For any Section 5 submission, consolidated or not:
5. For additional copies of pages 8 and 9 (to show different exposures resulting from manufacturing and processing),
indicate the number of additional pages required here:
8

0

9

0

6. If you have entered information for a consolidated PMN (steps 1 - 4) and/or requested additional pages under step 5,
click on the following button to generate (spawn) the additional pages.
Push here to spawn required pages

The software will now spawn the required number of pages. This will take several minutes, and will not require additional
input from you while it generates the pages.
Note: The PMN pages will be automatically numbered. This header page will not be included in the page count showing
on the form itself.

PMN Page 1 ; Page 1 of 18
Form Approved. O.M.B. No. 2070-0224. Approval Expires 11-30-2025

U.S. ENVIRONMENTAL PROTECTION AGENCY

AGENCY USE ONLY
Date of receipt

PREMANUFACTURE
NOTICE

Save Draft

FOR NEW CHEMICAL SUBSTANCES
When
completed
send this
form to
Enter the total number of pages
in the Premanufacture Notice

Validate PMN

18

?

Document control number

GENERAL INSTRUCTIONS
•
•
•

Create Sanitized PMN

DOCUMENT CONTROL OFFICER
OFFICE OF POLLUTION PREVENTION
AND TOXIC SUBSTANCES, 7407
U.S. E.P.A. 1200 Pennsylvania, NW
WASHINGTON, D.C. 20460
EPA case number

TS -

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 user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember,
your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, Washington Financial Management Center (3303), P.O.
360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee.

Part I  GENERAL INFORMATION

TEST DATA AND OTHER DATA

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 user fee identification number.
You must submit an original and two copies of this notice including all test data. If you
claimed any information as confidential, a single sanitized copy must also be submitted.

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.

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).

Part III  LIST OF ATTACHMENTS

Test Data

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

Yes

•

Health effects data

Yes

Risk assessments

•

Environmental effects data

Yes

Structure/activity relationships

OPTIONAL INFORMATION

•

Physical/Chemical Properties*

Yes

Test data not in the possession
or control of the submitter

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.

*

A physical and chemical properties worksheet is located on the last page of this form.

Part II  HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

(Check Below any included in this notice)

TYPE OF NOTICE
So-called “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 . . . This option is intended to reduce delays that
routinely accompany the development of consent orders or Significant New Use Rules.
Except in the case of exemption applications (such as TMEA, LVE, LOREX) where
certain information provided in such notification is binding on the submitter when the
Agency approves the exemption application, checking a binding box in this notice does not
by itself prohibit the submitter from later deviating from the information (except chemical
identity) reported in the form.

• Other data

Yes

(Check Only One)

PMN (Premanufacture Notice)
INTERMEDIATE PMN (submitted in sequence with final product PMN)
SNUN (Significant New Use Notice)
TMEA (Test Marketing Exemption Application)

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.

?

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
Yes

IS THIS A CONSOLIDATED PMN?
Mark (x) if any information in this notice is claimed as confidential.

EPA FORM 7710-25 (Rev. 2/25)

1

# of chemicals or polymers
(Prenotice Communication # required, enter # on page 3)

Replaces previous editions of EPA Form 7710-25.

PMN Page 2

; Page 2 of 18

Paperwork Reduction Act Notice: This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2070-0224).
Responses to this collection of information are mandatory for certain persons, as specified at 15 U.S.C. 2604 and 40 CFR Parts 720, 721, 723 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 110 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 Information Engagement 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.

CERTIFICATION -- A Printed copy of this signature page, with original signature, must be submitted
I certify that to the best of my knowledge and belief:
1.

The company named in Part I, section A, subsection 1a of this notice form intends to manufacture or import for a
commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I,
Section B.

2.

All information provided in this notice is complete and truthful as of the date of submission.

3.

I am submitting with this notice all test data in my possession or control and a description of all other data known to or
reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule.

Additional Certification Statements:
If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification
statement that applies:
The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or
The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR
700.43) in accordance with 40 CFR 700.45(b), or
The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100
in accordance with 40 CFR 700.45(b).
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.
The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance
described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001.
Signature and title of Authorized Official (Original Signature Required)
Date

?

Signature of agent - (if applicable)

Date

Do you want these signatures to be digital?

EPA FORM 7710-25 (Rev. 2-25)

Page 2

Confidential

; Page 3 of 18

PMN Page 3

Part I -- GENERAL INFORMATION
Confidential

Section A -- SUBMITTER IDENTIFICATION
Mark () the “Confidential” box next to any subsection you claim as confidential
1a. Person
Name of authorized official
Position
Submitting
Notice (in U.S.)
Company

Mailing address (number and street)

City, State

b. Agent (if
applicable)

Postal Code

Name of authorized official

Position

Company

Mailing address (number and street)

City, State

c.

Postal Code

Telephone (include area code)

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

Joint Submitter (if
applicable)

Name of authorized official

Position

Company

Mailing address (number and street)

Province, Country

2.

Technical
Contact (in
U.S.)

City, State

Postal Code

Telephone (include country or area code)

Name of authorized official

Position

Company

Mailing address (number and street)

City, State

3.

4.

5.

6.

Postal Code

Telephone(include
Areaarea
Codecode) Number
Telephone

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

Mark (X)
if none

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).
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.

Type of Notice - Mark (X)

EPA FORM 7710-25 (Rev. 2/25)

1.

Manufacture
Only
Binding Option
Mark (X)

Mark (X)
if none
Mark (X)
if none
2.

Page 3

Import
Only
Binding Option
Mark (X)

3.

Both

PMN Page 4 ; Page 4 of 18
Part I -- GENERAL INFORMATION -- Continued
Section B -- CHEMICAL IDENTITY INFORMATION:

You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninth
Collective Index (9CI) of CA nomenclature rules and conventions.

Mark (X) the “Confidential” box next to any item you claim as confidential
Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items.

1.

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.
Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substances, see the Instructions Manual)
a.
Class of substance - Mark (X)
1
Class 1
or 2
Class 2
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 CA 9CI nomenclature rules and conventions).

c.

d.

e.

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 - a copy of the Identification
Method 2 (Other Source)
report obtained from the CAS Inventory Expert Services must be
submitted as an attachment to this notice)
Molecular formula
CAS Registry Number
CBI
(if a number already
exists for the substance)
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. Please see the E-PMN Instruction Manual for
discussion of "native format" diagram software which can be helpful in reviewing your substance.

Add Picture

Diagram for class 1 or class 2 goes here.

Mark (X) this box if you attach a continuation sheet.

EPA FORM 7710-25 (Rev 2/25)

Page 4

Clear Picture

Confidential

PMN Page 4a ; Page 5 of 18
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).
e. (1) List the immediate precursor substances with their respective CAS Registry Numbers.
ConfiName (CAS #)

dential

e. (2) Describe the nature of the reaction or process.

e. (3) Indicate the range of composition and the typical composition (where appropriate).

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 2/25)

Page 4a

PMN Page 5

; Page 6 of 18

Part I -- GENERAL INFORMATION -- Continued
Section B -- CHEMICAL IDENTITY INFORMATION -- Continued
2. Polymers (For a definition of polymer, see the Instructions Manual.)
a.

Confidential

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.
Describe the methods of measurement or the basis for your estimates: GPC
Other
: (Specify below)
(i) lowest number average molecular weight:
(ii) maximum weight % below 500 molecular weight:
(iii) maximum weight % below 1000 molecular weight:

b.

Mark (X) this box if you attach a continuation sheet.
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.
ConfiMaximum
Include in ConfiTypical
Monomer or other reactant and CAS Registry Number
Confidential
residual
dential
identity
composition
dential
(7)
(6)
(5)
(4)
(3)
(2)
(1)
%
%

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 2/25)

Page 5

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

%

PMN Page 5a ; Page 7
c.

of 18

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 - a copy of the identification report
Method 2 (other source)
obtained from CAS Inventory Expert Service must be submitted as an attachment to this notice)

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. . Please
see the E-PMN Instruction Manual for discussion of "native format" diagram software which can be helpful in reviewing your substance.

Add Picture

Clear Picture

Click on Add Picture button to add PDF illustration

Mark (X) this box if you attach a continuation sheet.

EPA FORM 7710-25 (Rev. 2/25)

Page 5a

CBI

PMN Page 6 ; Page 8

of 18

Part I -- GENERAL INFORMATION -- Continued
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 %.
Impurity and CAS Registry Number
Maximum
Confipercent
dential
(a)
(b)
%

%

%

%

%

%

%

Mark (X) this box if you attach a continuation sheet.
4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2.

Confidential

Mark (X) this box if you attach a continuation sheet.
5.

Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2.

Mark (X) this box if you attach a continuation sheet.
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.

Mark (X) this box if you attach a continuation sheet.
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.
Byproduct
CAS Registry Number
Confi(1)
(2)
dential

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 2/25)

Page 6

PMN Page 7

; Page 9 of 18

Part I -- GENERAL INFORMATION -- Continued
Section C -- PRODUCTION, IMPORT, AND USE INFORMATION:
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)

Confidential

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

Binding
Option
Mark (x)

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).
Binding
Prod% in
Category of use (1) (by function and application i.e. a
CBI
CBI
CBI
% of substance expected per use
CBI
Option
uction
Formu
dispersive dye for finishing polyester fibers)
(8)
Mark
(2)

(x)
(3)

%

lation

(4)

(5)

(6)

%

%

%

%

%

%

%

%

%

%

%

%

%

%

(7)

Sitelimited

Consumer

Industrial

Commercial

Binding
Option

(9)

* 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.
Mark (X) this box if you attach a continuation sheet.
b. Generic use
If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the Instruction
description
Manual for examples of generic use descriptions.

Mark (X) this box if you attach a continuation sheet.
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.
Mark (X) this box if you attach hazard information.
EPA FORM 7710-25 (Rev. 2/25)

Page 7

Binding
Option
Mark (x)

PMN Page 8 ; Page 10 of 18

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE
Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER

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

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
Confia. Identity -- Enter the identity of the site at which the operation will occur.
dential
Name

Site address (number and street)

City, County, State, ZIP code

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.
Mark (X) this box if you attach a continuation sheet.

b.

Type -Mark (X)
c.

Manufacturing
Amount and Duration -- Complete 1 or 2 as appropriate
Maximum kg/batch (100% new chemical

Processing

Use

Hours/batch

Batches/year

Hours/day

Days/year

substance)

1. Batch
Maximum kg/day (100% new chemical
substance)

2. Continuous
d. Process description
Mark (X) to indicate your willingness to have your process description binding.
(1) 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.).
(2) 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.).
(3) 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.

Enter your descriptive text here.
a PDF diagram.

There is space on the next page for a separate file name and/or

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 2/25)

Page 8

PMN Page 8a ; Page 11 of 18
Confidential

Add Picture

Clear Picture

Diagram of the major unit operation steps goes here if you didn't describe it in the text field.

EPA FORM 7710-25 (Rev. 2/25)

Page 8a

PMN Page 9

; Page 12 of 18

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued
Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued
2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, number of
works 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 entry in column (5) is 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).
Binding
Binding
CBI
Physical
CBI
CBI
Maximum
duration
CBI
Worker activity
Protective Equipment/
# of
(i.e., bag dumping, filling drums)
(1)

Option
Mark (x)

Engineering Controls
(2)

(4)

(3)

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev.2/25)

Page 9

forms(s)
and % new
substance
(5)

Option
Mark (x)

(6)

(7)

Workers
Exposed
(8)

(9)

Hrs/day

Days/yr

(10)

(11)

(12)

PMN Page 9a ; Page 13

of 18

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).
CBI
Medium of
Release
Amount of new
CBI
Control technology and efficiency (you may wish to optionally attach
release
Number
substance released
efficiency data)
e.g. stack air
Binding
(1)
(2a)
(2b)
Mark
(4)
(3)
(5b)
(6)
(5a)
(X)

?

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

NPDES #

POTW--provide
name(s)

Navigable waterway-provide name(s)

Other--Specify

Mark (X) this box if you attach a continuation sheet.

EPA FORM 7710-25 (Rev. 2/25)

Page 9a

CBI

PMN Page 10 ; Page 14 of 18
Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued
Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS
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, circle or bracket 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):

CBI

# of sites

Add Picture

Clear Picture

Diagram the major unit operation steps and chemical conversions...

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

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 2/25)

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PMN Page 10a ; Page 15 of 18
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
CBI
CBI
% in
CBI
Duration Of
Protective Equip. /Engineering Controls/Physical Form and/ % new substance
of
Workers
FormExposure
Activity

Exposed

(1)

(2)

ulation

(3)

(4a)

Release
Number

(4b)

(5)

Amount of
New
Substance
Released

(9)

(10a)

(7)

(6)

(10b)

(8)

CBI

Media of Release & Control Technology

CBI

(11)

(12)

(13)

(14) -- Byproducts:

(15)

Mark (X) this box if you attach a continuation sheet,

OPTIONAL POLLUTION PREVENTION INFORMATION
To claim information in the following section as confidential circle or bracket 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, raw materials substitution, and/or inventory control. 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. Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to
compliance with existing regulatory requirements and can be either quantitative or qualitative. 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 environmental media or nonenvironmental areas (e.g., occupational or consumer exposure). In addition, information on the relative cost or performance characteristics of
the PMN substance to potential alternatives may be provided.
All 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.

EPA FORM 7710-25 (Rev. 2/25)

Page 10a

PMN Page 11 ; Page 16 of 18
Optional Pollution Prevention Information (Continued) Describe the expected net benefits, such as (1) an overall reduction in risk to
human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation of waste materials
through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental
release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new
chemical substance in comparison to existing chemical substances used in similar application; or (6) 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.
CBI

Mark (X) this box if you attach a continuation sheet.
EPA FORM 7710-25 (Rev. 2/25)

Page 11

PMN Page 12

; Page 17 of 18

Part III -- LIST OF ATTACHMENTS
Attach continuation sheets for sections of the form and 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 column below, enter the inclusive page
numbers of each attachment. Electronic attachments can be identified by filename.
Mark (X) the “Confidential” box next to any attachment name 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

Attachment Filename

Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number.
EPA FORM 7710-25 (Rev. 2/25)

Page 12

Attachment
page number(s)

Confidential

PMN Page 13

; Page 18 of 18

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET
To assist EPA’s review of physical and chemical properties data, please complete the following worksheet for data you provide and
include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value of the property,
the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential. If the attachments
are electronic, give the attachment number (found on page 12) at (b). The physical state of the neat substance should be provided.
These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or
formulations should be so noted (% PMN substance in __). You are not required to submit this worksheet; however, EPA strongly
recommends that you do so, as it will simplify review and ensure that confidential information is properly protected. You should submit
this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for submission of test data.
Mark (X) Page
Measured or
Property
Value
if
Estimate
number
provided (b)
(a)
(c)
(M or E)

Physical state of neat substance
Vapor pressure
@ Temperature

(s)

Temperature

g/cm3

°C

Solvent
Solubility in water @ Temperature

g/L
°C

Melting temperature
Boiling / sublimation temperature@

(g)

Torr

°C

Density/relative density
Solubility
@

(l)

Confidential
Mark (X)
(d)

g/L
°C

torr pressure

°C

Spectra
Dissociation constant
Particle size distribution
Octanol / water partition coefficient
Henry’s Law constant
Volatilization from water
Volatilization from soil
pH@ concentration
Flammability
Explodability
Adsorption / coefficient
Other - Specify

Other - Specify
Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number.

ATTACHMENT
PAGE 13