TSCA	Section	5	Premanufacture	and	

Significant	New	Use	Notification	

Electronic	Reporting;	Revision	to	

Notification	Regulations:

Questions	and	Answers	Document

US EPA

9/10/2014
ePMN 2.0: Questions and Answers Sept 2014

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Contents

A. CDX Related Questions........................................................................................................... 6

1. Do I need to register with CDX to submit or to work on section 5 notices? ....................... 6

2. Where do I go to register with CDX? .................................................................................. 6

3. Can I be registered under more than one company name? What company name should I

register for? ................................................................................................................................. 6

4. What is LexisNexis? ............................................................................................................ 6

5. What if I do not pass ID proofing with LexisNexis? What do I have to do?...................... 6

6. If I have been approved for the TSCA workflow, do I need to reregister in CDX to work 

in the new ePMN under CSPP workflow?.................................................................................. 7

7. What role should I register for in CDX?.............................................................................. 7

8. Can I have more than one role in CDX?.............................................................................. 7

9. Do Support persons need their identities validated?............................................................ 7

10. What does Primary mean (AO, Agent/Consultant or Support)?...................................... 7

11. What does Secondary mean (AO, Agent/Consultant or Support)?.................................. 7

B. Role Function Questions ......................................................................................................... 8

12. What functions can Authorized Officials (AO) perform in Section 5 Notices and 

Supports (ePMN)? ...................................................................................................................... 8

13. Who can submit an original/initial submission of the PMN form, biotech form, NOC 

form, or Bona Fide form? ........................................................................................................... 8

14. What functions can an Agent/Consultant perform in Section 5 Notices and Supports 

(ePMN)?...................................................................................................................................... 8

15. What functions can a Support person perform in Section 5 Notices and Supports 

(ePMN)?...................................................................................................................................... 8

16. Who can create and submit a support form? .................................................................... 8

17. What can I submit using the Support form?..................................................................... 9

C. Security Questions................................................................................................................... 9

18. What is a passphrase?....................................................................................................... 9

19. Who creates the passphrase? ............................................................................................ 9

20. Where is my data stored? ................................................................................................. 9

21. Is the data encrypted?..................................................................................................... 10

D. Document Access Questions................................................................................................. 10

22. How do I assign support persons to work on a document?............................................ 10

23. Do I have to give access to a support person for each document separately?................ 10

24. I am an Authorized official who created a form in the new system. Who has access to 

my data, i.e., can open the document with the passphrase?...................................................... 10
ePMN 2.0: Questions and Answers Sept 2014

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25. I am an Agent/Consultant who created a form in the new system. Who has access to 

my data, i.e., can open the document with the passphrase?...................................................... 11

26. Who can only see my forms in the forms view? ............................................................ 11

27. If I am an Authorized Official (AO) and I leave the company, how can another AO 

from the same company have access to my documents?.......................................................... 11

28. If my company changes name, how do I access old company files? ............................. 11

29. What if my company bought rights from another company's chemicals, how will I get 

access to the submission?.......................................................................................................... 11

E. Result of Submission Questions............................................................................................ 12

30. When is the Case number assigned? .............................................................................. 12

31. Will I still receive an acknowledgement letter? ............................................................. 12

32. How do I know that EPA has received my submission?................................................ 12

33. Why is it important to download my COR?................................................................... 12

F. Document Creation/Population Questions ............................................................................ 12

34. How is a Section 5 notice created?................................................................................. 12

35. How do I create a Letter of Support or Joint Submission? ............................................ 13

36. In the Thick client, there was a Profiler to store contact information which allowed for 

easy download of that information. Does the new online version of the ePMN have something 

equivalent? ................................................................................................................................ 13

37. What is a form Alias? How is it used? .......................................................................... 13

38. For sections of the ePMN displayed in an accordion style, do I have to fill in all 

required fields to save the form?............................................................................................... 14

39. How do I enter the Authorized Official information on the form? ................................ 14

40. How do I create a multicomponent (discrete mixture) submission?.............................. 14

41. How do I create a consolidated submission? ................................................................. 14

42. How do I delete a consolidated chemical? ..................................................................... 15

43. How do I "copy" my submission in the new version of the ePMN?.............................. 15

44. How do I enter microorganinsm data into the Bona Fide form?.................................... 15

G. Amend Questions .................................................................................................................. 15

45. When can I "amend" a submission versus when do I have to create a new submission?

15

46. What if I forget my passphrase to my original notice and then need to make an 

amendment? .............................................................................................................................. 15

47. How do I amend “new” submissions? How do I amend an “older” submission? ........ 15

H. Modifications Questions........................................................................................................ 16

48. When do I create a Modification to an LVE or LoREX instead of "amending" the 

original submission? ................................................................................................................. 16
ePMN 2.0: Questions and Answers Sept 2014

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49. I need to submit a Modification to EPA. When do I use a PMN form to modify an LVE 

or LoREX and when do I use a support form (Communication) to EPA (e.g., a j(6) letter)? .. 16

I. Attachment Questions............................................................................................................ 16

50. Do I need to upload my sanitized attachments at the same time that I upload my CBI 

attachments?.............................................................................................................................. 16

51. Is there a file size limitation for my attachments? ......................................................... 17

52. Will the software sanitize my attachments?................................................................... 17

J. XML Questions ..................................................................................................................... 17

53. When I am working online, can I save my work in progress locally? ........................... 17

54. Can I use the eTSCA Client software to create my documents? ................................... 17

55. What is an XML schema? .............................................................................................. 17

56. Where can the XML schema be found? ......................................................................... 18

57. Can I import my data which was created from the thick client?.................................... 18

58. Can my forms created in CDX which are in progress be stored locally? ...................... 18

59. Can I work behind my firewall?..................................................................................... 18

60. Will CBI be designated with the curvy brackets in some text fields? ........................... 18

61. What is an original Notice submission?......................................................................... 18

62. Is there a copy of the PMN form available outside of the software for informational 

purposes and not for submission? ............................................................................................. 18

63. If I find my substance in SRS, does this mean my chemical is on the TSCA Inventory?

18
ePMN 2.0: Questions and Answers Sept 2014

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Disclaimer: This Q&A document is not a rule and is not legally enforceable. The document 

explains some of the electronic reporting requirements in 40 CFR parts 720, 723 and 725 

applicable to documents submitted pursuant to those provisions. The document also discusses 

recommended practices for such submission. The document neither creates any new 

requirements nor replaces existing established laws or regulations. The use of the word "should" 

in this document means that something is suggested or recommended, but not required.
ePMN 2.0: Questions and Answers Sept 2014

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A. CDX	Related	Questions

1. Do I need to register with CDX to submit or to work on section 5 notices?

Yes, you must be registered with CDX to work online or to submit Section 5 

Notices and Supports forms. 

You can use the eTSCA Client to work on PMN files locally. The formdata.xml

for the PMN form can then be exported and uploaded into the online application.

Please refer to the CDX CSPP registration user guide for any other questions you 

may have.

2. Where do I go to register with CDX?

http://cdx.epa.gov is the website to register and access the Section 5 Notices and 

Supports submission software.

 

There are also a variety of user guides available for quick tutorials regarding the 

CDX registration process.

3. Can I be registered under more than one company name? What company 

name should I register for?

Yes, you may register for more than one company name, and can select which 

organization you will be working under when logging into CDX.

In addition, multi-Authorized Official (AO) functionality means that all AOs 

registered under the same company name will be able to view the forms that other 

AOs within that company create. 

The role sponsorship functionality means that if Agents/Consultants create a 

form, all sponsors of the company he/she represents can also see the form as well 

as the Agent that created the form.

To keep the forms secure, select a unique company name to work under. But 

remember, that company name will populate on the forms when submitting.

4. What is LexisNexis?

LexisNexis is a third-party identity proofing service that verifies a user's identity. 

It does not verify organization information or an association to an organization.

5. What if I do not pass ID proofing with LexisNexis? What do I have to do?

If the LexisNexis identity validation fails, the user is required to sign and mail a 

paper electronic signature agreement (ESA) which may take ten (10) business 

days to process.
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6. If I have been approved for the TSCA workflow, do I need to reregister in CDX 

to work in the new ePMN under CSPP workflow?

If you have been approved for the TSCA workflow, you do not need to re-register 

in CDX. You will, however, need to update your user role and workflow. 

If you have already been identity-proofed and have an ESA approved on-file, you 

can add the CSPP workflow and add a user role under that workflow since the 

ESA can be reused for certain workflows. All persons registered and approved for 

TSCA have already been identity-proofed, but must electronically sign an ESA.

It is not necessary for legacy CDR persons to re-register in CDX.

7. What role should I register for in CDX?

There are six user roles: 3 roles are associated with the main forms and its 

supporting forms (Primary Authorized Official, Primary Support, Primary

Agent/Consultant) and 3 roles are associated with the secondary forms (i.e. Joint 

or Letter of Support) (Secondary Authorized Official, Secondary Support, and 

Secondary Agent/Consultant). 

To determine which role is best for you, please refer to the appropriate user guide 

on the 'Resources' screen within the Section 5 Notices and Supports application, 

or refer to the user guides posted on the New Chemicals website; 

http://www.epa.gov/oppt/newchems/epmn/epmn-index.htm.

8. Can I have more than one role in CDX?

It is possible to register for more than one role under a single user ID. You can 

register under all 6 roles, but under different user IDs. 

However, when you access the application, you can only access the application 

under one user role at a time.

9. Do Support persons need their identities validated?

Since a Support user will not have the ability to sign/submit data to EPA, they do 

not need to undergo the same level of validation as Authorized Officials or 

Agents/Consultants.

10. What does Primary mean (AO, Agent/Consultant or Support)?

Primary is a term used to designate CDX registrants who wish to access and 

submit main submissions and support document. Main submissions include: the 

PMN form, the Biotechnology form, the NOC form, the Bona Fide form and the 

Alternative Control Measures form.

11. What does Secondary mean (AO, Agent/Consultant or Support)?

Secondary is a term used to designate CDX registrants who wish to access and 

submit Joint and Letter of Support submissions.
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B. Role	Function	Questions

12. What functions can Authorized Officials (AO) perform in Section 5 Notices 

and Supports (ePMN)?

All AOs can create, edit, delete, designate Agents/Consultants, designate 

Supports, unlock, and download the Copy of Record (CoR).

The submitting AO is the person from the submitting company who legally signs, 

certifies, and submits the initial Notice forms: PMN, NOC, Biotechnology, or 

Bona Fide. The AO can also submit the Alternative Control Measures (ACM) 

form and the support form.

All persons can save, validate to check for errors, and preview documents in 

progress.

13. Who can submit an original/initial submission of the PMN form, biotech form,

NOC form, or Bona Fide form?

The initial submission for these types of notices must be submitted by a Primary 

Authorized Official from the company who is authorized to legally sign, certify, 

and submit the initial notice.

Any subsequent amendments to these forms may be submitted by any AO of the 

submitting company or Agent/Consultant assigned under that company name. 

14. What functions can an Agent/Consultant perform in Section 5 Notices and 

Supports (ePMN)?

Agents/Consultants can create, edit, delete, unlock, and download the Copy of 

Record (CoR) for all forms.

The Agents/Consultants cannot submit the initial Notice forms: PMN, NOC, 

Biotechnology, or Bona Fide forms. The Agent /Consultant can submit the initial

ACM form, all amended forms and Support forms.

All persons can save, validate to check for errors, and preview documents in 

progress.

15. What functions can a Support person perform in Section 5 Notices and 

Supports (ePMN)?

Support persons can only edit documents that are in progress which have been 

assigned to them by their Authorized Official.

All persons can save, validate to check for errors, and preview documents in 

progress.

16. Who can create and submit a support form?

The role of the Support person has changed with the Section 5 Notices and 

Supports thin client application. The Support person will no longer have the 

ability to create and submit Support forms in the new Section 5 Notices and 
ePMN 2.0: Questions and Answers Sept 2014

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Supports application. Only Authorized Officials or Primary Agents/Consultants 

can create and submit Support forms. Registered Support persons will only be 

able to edit form information once they have been assigned to and given access to 

the form by an AO. 

17. What can I submit using the Support form?

A Support form includes the following subtypes: 'Amendment,' 'Suspension 

Request,' 'Test Data,' 'Transfer of Ownership,' 'Withdrawal Request,' and 'Other 

Correspondence.' The purpose of the Support form is to provide additional 

information, or supplement information to the PMN form. 

For the most part, the Support form has not changed except with regards to 

submitting amendments to the PMN and Biotechnology form. If you submitted an 

original Notice form using the thin client, you cannot amend the original using the 

Support form; you must unlock the original notice and resubmit.

C. Security	Questions

18. What is a passphrase?

The passphrase is a text string used to encrypt a form (e.g. PMN, Biotechnology, 

NOC, Support, Bona Fide, or ACM). If you want to edit a form, unlock a 

submission, or download a Copy of Record (CoR), you will need the passphrase. 

Only Authorized Officials or Agents/Consultants can create passphrase for forms. 

This passphrase can be shared with whomever they would like to provide access 

to the forms. 

If you forget the passphrase for a submission in progress, you must recreate the 

form and resubmit. If you want to download the CoR of a particular document 

and you forgot the passphrase, you will need to contact EPA and request a copy.

Also, a passphrase is reusable, so the same passphrase can be used on all forms. 

19. Who creates the passphrase?

The person who creates the form creates the passphrase for that form. A 

passphrase is created or entered on the 'Create Passphrase' or 'Enter Passphrase' 

screens, respectively. 

Since the passphrase cannot be changed once it has been assigned to a form, the 

passphrase should be decided upon before the form is created amongst members 

who will be working on the form. You are encouraged to create a passphrase that 

is easy to remember because it cannot be recovered if lost or forgotten. The same 

passphrase can be reused for multiple forms. For example, you may want to use 

the same passphrase for all forms associated with a case.

20. Where is my data stored?

The data will be stored encrypted on the EPA server when logged into the Section 

5 Notices and Supports application. 
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Otherwise, if you are using an XML file, or saving a Copy of Record, this will be 

stored on your local hard drive, and you are responsible for the security of these 

items via your computer's security measures.

21. Is the data encrypted?

Data stored on the EPA server is encrypted by a passphrase. 

Once the Copy or Record is downloaded, it can be stored locally unencrypted.

D. Document	Access	Questions

22. How do I assign support persons to work on a document?

If an Authorized Official (AO) wants one of his/her Support persons (as 

designated within CDX) to work on a form, the AO must assign the form to this 

person. Forms are assigned using the 'User Management' tab in the Section 5 

Notices and Supports application. 

The AO can select the form alias from the 'Form Alias' drop-down menu on the 

'User Management' screen and then select the specific Support person(s) from the 

'Unassigned' list. Once the specific Support person(s) is/are assigned, the assigned 

form will appear in a Support person's view when they log into the Section 5 thin 

client. 

The AO will need to provide the Support person with the passphrase in order for 

the Support person to access the form for editing.

Agents / Consultants are not able to assign Support persons to a form.

23. Do I have to give access to a support person for each document separately?

Yes. If the AO wants a Support person to have access to one or more forms, the 

AO must assign access to each form, one at a time, via the 'User Management' 

tab. It is not possible to assign a Support to multiple forms at one time.

24. I am an Authorized official who created a form in the new system. Who has 

access to my data, i.e., can open the document with the passphrase?

1) Any Authorized Officials registered under the submitting company. 2) 

Agents/Consultants who are associated with you under the submitting company 

may also be assigned to work on the form. 3) Support persons who are associated 

with you may be assigned to work on the form that is in progress. 

This multi-AO functionality allows other Authorized Officials within a submitting 

company to view forms that other AOs have created.
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25. I am an Agent/Consultant who created a form in the new system. Who has 

access to my data, i.e., can open the document with the passphrase?

When an Agent/Consultant logs into CDX, they must select which company they

will be they want to work under. When the Agent/Consultant creates a new 

document, he/she and any Authorized Official from the selected company can 

then open the document with the passphrase.

26. Who can only see my forms in the forms view?

a. If you are an Authorized official for Company A, you can see all forms created 

under Company A.

b. If you are an Agent/Consultant for an AO from Company A, you can see all forms 

that you created and all forms created by your AO to which you were assigned.

c. If you are a Support person for an AO from Company A, you can see all forms 

which were assigned to you by your AO.

27. If I am an Authorized Official (AO) and I leave the company, how can another 

AO from the same company have access to my documents?

Any AO registered under the same company has access to all forms created by

any AO of that company (i.e., the forms will be listed in the forms view). To open 

a form, the AO will need to have the passphrase. Remember, passphrases cannot 

be recovered once lost or forgotten. It is always a good practice to download the 

Copy of Record to your local hard drive for each form sent to EPA for future 

reference. 

In addition, if the sponsoring AO of an Agent/Consultant leaves the company, 

then the Agent/Consultant must find another sponsoring AO from the company as 

their role sponsorship will have been revoked.

28. If my company changes name, how do I access old company files?

Users should maintain old company names within CDX registration and keep the 

passphrase for all documents. Make sure you download the Copy of Record and 

securely maintain records outside of CDX in case access to the files online is no 

longer available.

29. What if my company bought rights from another company's chemicals, how 

will I get access to the submission?

The second company (company B) that bought the chemical should request 

information that was saved locally (i.e., the Copy of Record) from the company

whose chemical rights were purchased (company A). Company B will not have 

access to Company A’s documents in the Section 5 Notices and Supports 

application.

If company B wants is not able to obtain this information from Company A, 

please request this information from EPA. 
ePMN 2.0: Questions and Answers Sept 2014

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E. Result	of	Submission	Questions

30. When is the Case number assigned?

After a form is submitted to EPA, the Section 5 Notices and Supports application 

will assign a case number within minutes. The case number will appear within the 

'Section 5 Notices and Supports Forms' screen, but it may be necessary to refresh 

the page by selecting the Browser refresh button. 

For non-consolidated submissions a single case number is assigned; for 

consolidated submissions, multiple case numbers are assigned. 

After you submit a form to EPA and the submission has been successfully 

received, the system will provide a Copy of Record (CoR) represented by a green 

arrow icon.

31. Will I still receive an acknowledgement letter?

Acknowledgement letters will continue to be sent by U.S. mail.

32. How do I know that EPA has received my submission?

In the previous process using the PMN thick client, users would receive emails 

regarding the CDX transaction ID, and another email with a confirmation of the 

Copy of Record. 

With the new Section 5 Notices and Supports thin client, the application generates 

a Copy of Record (obtained by selecting the green arrow icon) within several 

minutes of submitting a form, which indicates that EPA has received the form. 

The application will also generate a single case number for a non-consolidated 

submission, or multiple case numbers for a consolidated submission. No emails 

will be generated in this process.

33. Why is it important to download my COR?

It is very important to download the Copy of Record (CoR). The information 

stored on EPA’s server is encrypted using the passphrase. If something happens to 

the form on the EPA server, or to the passphrase, or to the Authorized Official, 

etc. users will need to have copies of the forms submitted to EPA for your 

records. A downloaded file is not encrypted and easily shared.

F. Document	Creation/Population	Questions

34. How is a Section 5 notice created?

The Authorized Official or Agent/Consultant logs into CDX and selects the 

Primary Authorized Official or Agent/Consultant role within the CSPP workflow. 

Select 'TSCA Section 5 Notices and Supports - ePMN' from the CISS drop-down 

menu.

Users will then have the option to create the following notices and support forms 

from the Forms screen: 'Premanufacture Notice (PMN),' 'Biotechnology,' 'Notice 
ePMN 2.0: Questions and Answers Sept 2014

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of Commencement (NOC),' 'Support,' 'Bona Fide,' and/or 'Alternative Control 

Measures (ACM)' by selecting the form type from the drop-down menu and 

clicking the 'Start New Form' button. 

For specific steps on creating a new notice or support form, refer to the applicable 

Section 5 Notices and Supports user guide.

35. How do I create a Letter of Support or Joint Submission?

Third party submitters will receive an email from the main submitter. In the 

email will be a unique identifier that Secondary Authorized Officials will use to 

create the Letter of Support or Joint Submission. The Secondary AO will launch 

the TSCA Section 5 Notices and Supports thin client application and from the 

forms screen, select to create a new document. The system will ask for the unique 

identifier – it is suggested that this identifier be copied from the email as it can be 

quite complex. After entering the identifier and a passphrase, the form will 

appear where the Secondary AO can then either fill out the PMN information, 

attach supporting information in a file, or enter the supporting information in the 

cover letter.

36. In the Thick client, there was a Profiler to store contact information which 

allowed for easy download of that information. Does the new online version of 

the ePMN have something equivalent?

The TSCA Section 5 Notices and Supports thin client application does not have 

an equivalent profiler feature. However, there is an option for the person logged 

into a form to populate the agent or technical contact information with their CDX 

registration information. If the person filling out the form is not the 

agent/technical contact then this information will need to be entered manually. 

The submitting person's information will automatically populate within the form 

during the submission process. 

Note: a user may use Google Chrome as a browser which allows you to autopopulate information that is consistently re-used.

37. What is a form Alias? How is it used?

When you create a form, you will be given the option to provide a user defined

alias for the form. The form alias is a text description entered by a user into a 

field in the form to assist other user in locating and organizing multiple forms 

within the application. The form alias can be edited by any user who has access to 

the form. 

As a hint, you may want to define a naming convention to be used for all 

documents under one case number.

Within the application you may view forms in a dashboard view. The form alias is 

also used on the 'User Management' page to identify and assign specific forms to 

Support users or company registered Agents/Consultants.
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38. For sections of the ePMN displayed in an accordion style, do I have to fill in 

all required fields to save the form?

There are several screens within the Section 5 Notices and Supports application 

which will not allow you to move forward without filling out all required data. 

This is especially true for sections of the form which utilize 

expandable/collapsible field sets. All required data must be entered in the 

expandable/collapsible field set before the field set data can be saved. Screens 

without expandable/collapsible field sets can be saved and users can move to 

another screen using the links within the navigation tree instead of using the 

'Previous' and 'Next' buttons. 

However, there are some forms within the application (i.e., Letters of Support or 

Joint Submissions) where the validation varies, and not all fields may be required 

within an expandable/collapsible field set.

39. How do I enter the Authorized Official information on the form?

The submitting company Authorize Official’s information is not manually

entered; the information will be pre-populated on the 'Submitting Official 

Information' page during the submission process. 

The only field that a user can edit on this page is the 'Job Title' field. All other 

data changes must be made within CDX registration information. 

If you are not the correct person to submit data to EPA or if the CDX registration 

data is incorrect, you may cancel the submission process at any time.

40. How do I create a multicomponent (discrete mixture) submission?

The new Section 5 Notices and Supports application can easily accommodate 

multi-component chemical submissions. A multi-component chemical submission 

is one where two or more chemicals are always generated together in one pot and 

are never isolated. 

Add each chemical component by clicking the 'Add Chemical Component' button 

on the 'Class 1 or 2 Chemical Substances' or 'Polymer Identification Information' 

screen.

41. How do I create a consolidated submission?

In order to create a consolidated submission, the user needs to create a file folder 

for the first chemical. Subsequent consolidated chemicals are generated by 

clicking the 'Add Consolidated Chemical' link to add a new set of chemical 

screens within the navigation tree.

Chemicals with similar chemical ID information (PMN pages 4, 5 and 6) can be 

copied by clicking the 'Copy' link within the navigation tree. However, neither the 

chemical name nor CASRN will be copied. Attachments are also removed and 

must be uploaded again.
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42. How do I delete a consolidated chemical?

To delete a chemical within a consolidated submission, click the 'Remove' link 

(red 'X' icon) within the navigation tree within the folder for the particular 

chemical you would like to remove. After clicking the 'Remove' link there is no 

way to recover the deleted chemical folder. 

Please note: the 'Remove' link is only available if the user is not currently working 

on one of the selected chemical's screens.

43. How do I "copy" my submission in the new version of the ePMN?

After a case is submitted to EPA, the Section 5 Notices and Supports application 

will generate a Copy of Record. The Copy of Record includes: submission XML, 

form PDF, and attachments. The submitter should download the Copy of Record 

to their local hard drive. 

To create a copy of the downloaded submission in the Section 5 Notices and 

Supports application, the user should create a new PMN form, upload the XML

file from the Copy of Record, re-attach the document files, and make changes as 

needed. 

44. How do I enter microorganinsm data into the Bona Fide form?

To enter microorganism data into the Bona Fide form of the software, select the 

Class 1 or 2 option then fill out the rest of the form as if the substance was a Class 

2 substance.

G. Amend	Questions

45. When can I "amend" a submission versus when do I have to create a new 

submission?

EPA will notify the submitter to say if the submission can be amended or if the 

submission is incomplete. A submission marked as incomplete by EPA cannot be 

"revised" or "amended"; a new form must be created and submitted. The 

resubmission will be given a new day 1 and a new case number.

46. What if I forget my passphrase to my original notice and then need to make an 

amendment?

If a form was created online in the Section 5 Notices and Supports application, 

and the passphrase was forgotten, the form cannot be opened or recovered. To 

create an amendment, create a Support form and designate it as "Other 

Correspondence." Attach or describe any amended information.

47. How do I amend “new” submissions? How do I amend an “older” 

submission?

The procedure for amending a form is dependent on how the original form was 

created and submitted to EPA. 
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1) Amendments to submissions originally created and submitted using the online 

Section 5 Notices and Supports application are made by unlocking submissions 

on the 'Section 5 Notices and Supports Forms' screen, making changes, providing 

a reason for the amendment and resubmitting. 

2) Amendments to submissions sent to EPA using the eTSCA EPA thick client 

are submitted via a Support form and selecting 'Amendment' as the type of 

support.

H. Modifications	Questions

48. When do I create a Modification to an LVE or LoREX instead of "amending" 

the original submission?

An amendment is typically a change to an original notice during the 30-day 

review period for an LVE or a LoREX submission. After the 30-day review 

period has expired and the changes constitute a Modification as defined by 40 

CFR 723, the submitter must create a new Premanufacture Notice (PMN) form 

and select LVE Modification or LoREX Modification as the form type. These 

Modifications will receive a new case number (LM or XM) and a new 30-day

review period.

If there are questions, contact the TSCA hotline at 202-554-1404 or facsimile at 

202-554-5603. 

49. I need to submit a Modification to EPA. When do I use a PMN form to modify 

an LVE or LoREX and when do I use a support form (Communication) to 

EPA (e.g., a j(6) letter)?

For an already-approved LVE, you can send a notification in the form of a letter 

as a support document (select Other Correspondence as the Support form subtype) 

to the existing LVE and need not file a request for modification requiring 30-day

review by the Agency if your site change meets the criteria of 40 CFR Sec. 

723.50(j)(6). The (j)(6) notification must be received by the Agency before the 

30th day after first manufacture at the new site. 

If your changes to the LVE or LoREX do not meet the criteria for 40 CFR Sec. 

723.50(j)(6), use the PMN form and select LVE Modification or LoREX 

Modification as your PMN form subtype. These modifications receive a new case 

number and will go through the full 30-day review.

I. Attachment	Questions

50. Do I need to upload my sanitized attachments at the same time that I upload 

my CBI attachments?

The online application performs immediate validation to ensure that the CBI files 

have sanitized files attached. If a user does not want to upload the sanitized file 

along with the CBI file, the user may mark the file as non-CBI and then later 
ePMN 2.0: Questions and Answers Sept 2014

17

change the CBI status when the user is ready to upload the sanitized file. 

However, do not forget to go back and change the CBI status of the attachment if 

you choose to do this option.

51. Is there a file size limitation for my attachments?

There is no actual file size limit, but you are limited to your network bandwidth 

and the application timeout of ten (10) minutes per upload.

52. Will the software sanitize my attachments?

No, the application will not sanitize attachments; the software only sanitizes 

fielded data. Sanitized attachment files will need to be created outside of the 

Section 5 Notices and Supports application. In order for data to be sanitized, you 

will need to flag the specific data fields as CBI by checking the associated 'CBI' 

checkbox. 

J. XML	Questions

53. When I am working online, can I save my work in progress locally?

Within the current eTSCA thick client, users are able to save their working files to 

their hard drive. With the new thin client, in-progress forms will be created and 

saved online. 

A user can save a partial XML in the thin client, and export it. Only the fields that 

were populated in the thin client were exported – not any attachments. Please note 

that, if the field was not populated in the thin client, blank fields will not be 

available in the exported XML file.

54. Can I use the eTSCA Client software to create my documents?

The eTSCA thick client will not be removed from a person’s computer if was 

previously installed. The option to download the eTSCA Client lite will also be 

available from the New Chemicals website. However, this software will not be 

maintained. Users will be able to save forms created within the thick client, export 

the fielded data as an XML file (PMN form only) and upload them to the thin 

client using the upload XML functionality. Attachments uploaded within the thick 

client will not be imported and must be reattached in the thin client.

55. What is an XML schema?

According to WIKIPEDIA, Extensible Markup Language (XML) is a markup 

language that defines a set of rules for encoding documents in a format that is 

both human-readable and machine-readable. The data fields defined in the XML

schema can allow users to upload XML data into a blank PMN form, or export inprogress PMN form data into an XML file. 

The XML file allows users to work on forms outside of the thin client application, 

or to populate forms for similar chemicals.
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56. Where can the XML schema be found?

The Section 5 Notices and Supports extensible markup language (XML) schema 

for the PMN form will be available on the New Chemical Programs website: 

http://www.epa.gov/oppt/newchems/epmn/epmn-index.htm

57. Can I import my data which was created from the thick client?

Yes, but only for the PMN form; PMN forms created in the thick client can be 

exported as XML files and uploaded into a blank PMN form within the thin client 

using the upload XML functionality. Attachments will need to be re-uploaded one 

at a time. 

58. Can my forms created in CDX which are in progress be stored locally?

Yes, partial XML files can be downloaded and saved locally.

59. Can I work behind my firewall?

Yes; the purpose of the XML schema for the PMN form is for users to work 

locally and offline. The XML can then be uploaded into a PMN form, 

attachments can be uploaded, and the form can be validated to make sure that 

there are no errors, and then submitted to EPA.

60. Will CBI be designated with the curvy brackets in some text fields?

Some of the large text fields in the eTSCA downloaded software allowed CBI to 

be designated within the field by surrounding the text with braces {e.g., enter CBI 

here}). With the new Section 5 Notices and Supports application thin client, these 

fields are now considered to be entirely CBI or entirely non-CBI by selecting a 

single CBI checkbox for the field.

61. What is an original Notice submission?

An original Notice submission is defined as the first time a Premanufacture 

Notice (PMN), Biotechnology, Notice of Commencement (NOC), or Bona Fide 

form is ever submitted to EPA. Subsequent changes to these forms are referred to 

as amended or modified notices. 

Support forms or Alternative Control Measure (ACM) forms will never be 

considered an original form. 

62. Is there a copy of the PMN form available outside of the software for 

informational purposes and not for submission?

The Premanufacture Notice (PMN) PDF will be included as a link on the New 

Chemicals Program website (http://www.epa.gov/oppt/newchems/epmn/epmnindex.htm). A Notice of Commencement (NOC) PDF will also be posted on the

website.

63. If I find my substance in SRS, does this mean my chemical is on the TSCA 

Inventory?

No. If you find your chemical in the Substance Registry Services (SRS), this does 

not necessarily mean that the chemical is on the TSCA Inventory.
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If you are searching by CAS number on the public TSCA Inventory or SRS and 

the chemical is not found, it could be located on the confidential portion of the 

TSCA Inventory. In which case, a Bona Fide form can be created and submitted 

within the Section 5 Notices and Supports application to have EPA determine 

whether or not a chemical is located on the confidential portion of the TSCA 

Inventory.