IMPORTANT: Before completing this form, please r ead the accompanying instructions carefully. Form Approved: OMB No. 2070-0054

EPA Form 7710-35 (01/2005) U.S. ENVIRONMENTAL PROTECTION AGENCY 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 C ONTROL NUMBER

MANUFACTURER’S REPORT

PRELIMINARY ASSESSMENT INFORMATION PERIOD COVERED

FROM: Mo. Yr. TO: Mo. Yr. Send completed form to: Document Control Office (7407M)

Office of Pollution Prevention and Toxics

U.S. EPA

Room 6438 EPA East 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 This information is required under t he authority of Section 8(a), Toxic

Substances Control Act. 15 U.S.C. 2607. Attn: 8(a) PAIR Reporting

Section I

-- CERTIFICATION Signature Date TECHNICAL CERTIFICATION STATEMENT I hereby certify that, to the best of my knowledge and belief, all information entered on this

form is complete and accurate. I agree to permit access to, and the copying of records by, a duly authorized representative of the EPA Admi nistrator, in accordance with the Toxic Substances Control Act, to document any information reported here. Name and title Pleas e prin t or type

CONCERNING EPA DISCLOSURE OF INFORMATION Any person who submits information to EPA under the Preliminary A ssessment I n formation Rule (40 CFR 712) should be aware of EPA regulations (40 CFR Part 2) which govern the disclosure of such information. Those regulations provide that any such person may, if he or she desires, ass ert a confidentiality claim covering part or

all of the information submitted. Inform ation covered by such a claim will be pub licly disclosed by EPA on ly to the extent, an d by means of the procedures, set forth in 40 CFR Part 2. However, if no such claim accompanies the information when it is received, EPA may make that information public wi thout notifying the submitter.

CONFIDENTIALITY STATEMENTS Information disclosed to EPA on this form may be claimed confidential by marking the appropriate boxes below. The person signi n g the Confidentiality Certification Statement attests to the truth of the following four statements concerning all information that is claimed confidential. Note that chemical substance identity may not be

claimed confidential for this rule.

1. My company has taken measures to protect the confidentiality of the information, and intends to continue to take such measur es

. 2. Th e information is not, and has not been, reasonably obtainable without our consent by other persons (other than governmenta l b odi es) by use of legitimate means

(other than discovery based on a showing of special need in a judicial or quasi-judicial proceeding). 3. The information is not publicly available elsewhere. 4. Disclosure of the information would cause substantial harm to our competitive position. Signature Date CONFIDENTIALITY CERTIFICATION STATEMENT I hereby certify that the Confidentiality Statements on this form are true as to that

infor m ation below for which I have asserted a confidentiality claim. Name and title Please print or type

Section II – CHEMICAL IDENTIFICATION

► Part A ► Part B

CAS No. Category name (first 15 characters)

Chemical name (first 15 characters) Inventory Form C number

Section III -- RESPONDENT IDENTIFICATION

MARK THIS BOX TO CLAIM THIS SECTION CONFIDENTIAL

► Part A --- Plant Site --- Physical location

Name ► Part B --- Mailing Address of: Corporate headquarters Plant Site

Number and street Name

City Number and street

County City

State ZIP Code State ZIP Code

Dun and Bradstreet number Dun and Bradstreet number (for corporate headquarters only)

--- --- --- ---

► Part C
--- Technical contact

Name and title ► Part D --- Acknowledgement

At headquarters Telephone ( Area c ode/ number ) At plant site EPA will send acknowledgement to – Name and titleSection IV – PRELIMINARY ASSESSMENT INFORMATION

NOTE Mark the box to the left of the item to claim the answer to the item as confidential. Report all quantities in kilograms (1 kilogram equals 2.2 pounds). Enter N/A for any item that does not apply to you; do not leave any blanks.

► Part A
– Plant Site Activities – Information in part A must be your best estimate from readily obtainable data. For items 3b, 3c, and 3d, specify the accuracy of your answers.

1. Total quantity imported kg 2. Qua ntity manufactured for sale or use kg

3 a. Quantity lost during manufacture (3b + 3c + 3d must equal 3a) kg 3 c. Q uantity in wastes treated to destroy the chemical kg

3 b. Quantity lost to the

environment kg± % 3 d. Quantity in wastes not treated to destroy the chemical kg± %

Activity

(1) Process category (2) Quantity (kilograms) (3) Total worker-hours (4) Total workers (5)

a. Enclosed

b. Controlled release 4. Manufacture of the chemical

c. Open

a. Enclosed

b. Controlled release 5. On-site use as a reactant

Total Quantity ________________ kg c. Open

a. Enclosed

b. Controlled release 6. On-site nonreactant use of the

chemical substance

Total Quantity ________________ kg c. Open

a. Enclosed

b. Controlled release 7. On-site preparation of products

Total Quantity ________________ kg c. Open

8. MANUFACTURER’S PRODUCTS – Report on the quantity of the chem ical substance that you prepare for eac h of the following

a. Chemical or mixture kg d. Chemical or mixture kg

b. Article with some release kg e. Article with some release kg INDUSTRIAL

PRODUCTS (domestic)

c. Artic le with no release kg CONSUMER

PRODUCTS (domestic)

f. Artic le with no release k g

g. Products for export

─ ─── ───────────────────────────────────────────────► k g

► Part B – Chemical Substance Processing by Customers
– Information in part B must be accurate within ± 50%

. 9. CUSTOMERS’ USES AND PRODUCTS – Estimate the qu antity of the chemic al substance that y our customers use or prepare for each of the following.

a. Chemical or mixture kg d. Chemical or mixture kg

b. Article with some release kg e. Article with some release kg INDUSTRIAL

PRODUCTS (domestic)

c. Artic le with no release kg CONSUMER

PRODUCTS (domestic)

f. Artic le with no release k g

g. Products for export ───────────────────────────────────────────────────► kg

h. Quantity of chemical consumed as reactant ──────────────────────────────────────► kg

i. Unknown customer uses

── ── ─────────────────────────────────────────────► kg

10. MARKET NAMES – If you report your customers’ uses as unknown (9i above) for more than 20% of the total quantity of the chemica l substance that you

manufacture and import (20% of items 1 and 2 above), list the market names under which you distribute the chemical (if you need more space, attach an additional sheet.)

a. c.

b. d.

11. CUSTOMERS’ PROCESS CATEGORIES – Based on your knowledge of general industry practices, estimate the quantity of the chemical su bstance that you sell

to customers as the chemical and that your customers further process in each of the following categories.

a. Enclosed processes kg c. Open processes k g

b. Controlled release processes kg d. Unknown kg

EPA Form 7710-35 (01/2005) Reverse

### INSTRUCTIONS FOR MANUFA CTURER’S REPORT FORM

PRELIMINARY ASSESSMENT INFORMATION

What chemicals to report – This form applies to substances that are listed in 40 CFR 712.30.

Do not report on listed chemical s ubstances if these are manufactur ed or imported incidentally as a byproduct, non-isolated intermediate, or impurity.

A byproduct or co-product must be reported if it' s marketed or used as a subject (listed)

chemical.

Do not report a listed chemical substance if it is a component of a mixture (imported or manufactured). Note, though, that the mixture itself may be liste d as a reportable substance. Reporting is required, however, if the chemical is manufactured separa tely by a given company,

and then blended into a mixture. In such a cas e, the blending step(s) would be reported as processing activities. Reporting is al so required if the manufactured or imported chemical is (1) in aqueous solution; (2) in a solution containi ng an additive (such as a stabilizer or other chemical) to maintain the integrity or physical form of the substance; or (3) present in any grade or purity.

Reporting Period – Enter the months and years beginni ng and ending the 12-month period for which you report (e.g., July 81 - June 82). This reporting period is liste d with the chemical

substance in 40 CFR 712.30.

Who must report – Manufacturers and importers mu st report. See 40 CFR 712.25 for

exem ptions from reporting. In addition to th e actual synthesis of a compound, all refining, extracting, and purifying activities of a listed chemical subs tance are considered manufacturing

activities under Secti on 3(7) of TSCA (15 U.S.C. 2602(7 )). Reporting is required for all companies involved in any of these activities.

Repackaging is considered a processing activity and should not be reported as ma nufacture. A company that only repackages a listed chemical s ubstance is considered only a processor. Note, however, that if the company imports the chemi cal prior to repackagi ng it is considered a manufacturer and must report.

How many forms to complete – For each chemical, complete a separate form for each plant site

that manufactured the chemical.

If a site manufactured and imported the chemical , report both manufacture and import data on a single form.

A company that imported the chem ical, but did not process the imported quantity or manufacture an additional quantity, may subm it a separate form for each import site or may submit a single form with the total data for all import sites.

Who may submit forms – Companies may choose to complete and submit forms to EPA from each plant site directly, or through company headquarters.

EPA Form 7710-35 (01/2005) Page 1 of 10Retention of forms – You should keep a copy of each completed form. Refer to the preprinted Control Number (shown in the upp er right corner on the front of the form) when communicating

with EPA.

EPA Assistance – For further information or to obtai n copies of the Manufacturer’s Report form, contact:

Environmental Assistance Division, Office of Pollution Prevention and Toxics (7408), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460; Telephone (TSCA Hotline): (202) 554–1404

E-mail: TSCA-Hotline@epa.gov.

Internet: http://www.epa.gov/opptintr/chem test/info.htm

Paperwork Reduction Act ion Notice: The public reportin g an d r eco rd keeping burd en fo r this

collection is estim ated to average 3 1.5 h o u rs p er response, including the time for reviewing instructions, searching existing d ata sources, g ath ering and main taining the data need ed, and

co mpleting and reviewing the collection of in formation. Send comments regarding this burden

estim ate or any other aspect o f this collectio n of inform ation, in cluding suggestions for reducing

th e burden, to Directo r
, Collecti o n Strategies Division (Mail Code 2822T), U.S. Environmental Protection Agency, Washington, DC 20460. Include the OMB control number in any

co rrespondence, but d o not su bm it the f orm or r epor t to this address. The actual inform ation o r form should be subm itted in acco r d an ce with th e in structions accomp anying the inf orm ation or f orm , specified in the corresponding r eg u lation.

I. CERTIFI CATION

Technical certifica tion – Certify the technical accuracy of data you report on the form by signing and dating the Technical Certification Statem ent. Print or type the name and title of the person who signs this statement.

Confidentia lity certification – You may claim information conf idential by marking appropriate boxes in sections III and IV. If you claim any in formation confidential, you must certify that the Confidentiality Statements are true for all inform ation claimed confidential on the form. Do this by signing and dating the Confiden tiality Certification Statement. Remember: To claim confidentiality, both the appropr iate box must be marked and the confidentiality certification must be signed by personnel with designated authority (e.g., genera l counsel or corporate office in charge).

EPA Form 7710-35 (01/2005) Page 2 of 10II. CHEMICAL IDENTIFICATION (Complete A or B)

Item A – If you are reporting on a chemical that has its CAS Nu mber and Chemical Name

listed in 40 CFR 712.30, rather than on a confidential chemical described in Item B below,

enter the CAS Number and the fi rst fifteen (15) characters of the listed Chemical Name.

Enter N/A in section II, part B, in the spaces for Category Name and I nventory Form C Number.

Item B – If you are reporting a confid ential chemical that is in a category listed in 40 CFR 712.30, enter the Category Name as listed, and en ter the number of the Inventory Reporting Form C on which you reported the chemical for th e TSCA Inventory. (If the Inventory Form C Number is not available, contact the TSCA Hotline.)

In section II, part A, enter N/A in the spaces for CAS Number and Chemical Name.

III. RESPONDENT IDENTIFICATION

Confidentiality – Mark this box to claim confidential al l Respondent Identification in section III. Note that you may not claim your identity confiden tial if you reported this chemical for the Inventory and did not claim your id entity confidential at that time.

Item A – Enter the name, physical location address, and Dun and Brad street number of the plant

site for which the data are reported.

If your company imported but did not further process or manufacture additional chemicals, and you choose to submit data for all import sites on a single form, enter N/A.

If the plant site does not have a Dun and Bradstreet number, enter N/A.

Item B – Mark the appropriate box to show whether th e plant site or corporate headquarters is submitting this form. Enter the corresponding name and mailing address.

If corporate headquarters submits this form, ente r its Dun and Bradstreet number, or if the the plant site submits this form, enter N/A in the space for the Dun and Bradstreet number.

EPA will send all correspondence regard ing the form to this address.

Item C – Enter the name, title, and te lephone number (including area code) of a person for EPA to contact if there are questions a bout the data reported on this form.

Item D – EPA will acknowledge receipt of the form to the person named in this item.

EPA Form 7710-35 (01/2005) Page 3 of 10IV. PRELIMINARY ASSESSMENT INFORMATION

TSCA Regulable Quantities – Except under items 4 and 5, do not report any quantity of

chem ical substance that is manufactured or proce ssed solely for use as: a pesticide; tobacco or any tobacco product; any source material, specia l nuclear material, or byproduct material (as terms defined in the Atomic Energy Act of 1954 and regulations issued under such Act); firearms or ammunition; or food, food additives, drug, cosmetic, or device (as such terms are defined in section 201 of the Federal Food, Drug and Cosmetic Act). The above are not TSCA regulable.

Some of the chemical substances are manuf actured for both TSCA and non-TSCA regulable purposes. If a chem ical from a given manufactur ing stream is solely for a non-TSCA use, no reporting is required. However, if a company produces a chemical from the same stream that will be used for both TSCA and non-TSCA purposes , the total quantity must be reported under items 4 and 5. Note that the quantity produced fo r TSCA purposes only is entered under item 2.

PART A: PLANT SITE ACTIVITIES

Accuracy – For each item, provide nu mbers that repres ent your best estimates based on readily

obtainable data.

Item 1 – Enter the total quantity of the chemical s ubstance imported in bulk during the reporting period. For a given compound, if a company is not involved in any manufacturing activity, and imports a chemical at one site and processes it at another facility, answer s need to be provided only for item 1 and items 9 through 11 (Part B). Note that the transfer of chemical to another site of the same company for processing is tr eated as if it were a customer use.

Item 2 – Enter the total quant ity of chemical domestically ma nufactured for TSCA use during the reporting period, not counting the losses report ed in item 3.

Item 3a–3d – In 3a, report the total quantity lost in manufacture of the substance during the reporting period. Report only routine losses. Do not report unusual spills or accidents. In calculating estimates for quantities not recovered you may: (1) use measured losses, if available,

or emission factors and other calcul ated releases from individual s ources; or (2) if these are not available, or only account for a portion of the total loss, you may make a simple mass balance estimate of the expected yield mi nus actual yield, where actual yiel d is the value reported in item 2. This quantity in 3a should then be broken down into three categories below (i.e., 3b + 3c + 3d = 3a). Specify the accuracy you report for 3b, 3c, and 3d, e.g., 1000 kg ± 30%.

3b. Quantity lost to the environment – This covers fugitive emissions to the atmosphere

and other losses not de scribed in 3c and 3d.

3c. Quantity in wastes trea ted to destroy the chemical.

EPA Form 7710-35 (01/2005) Page 4 of 103d. Quantity in wastes not trea ted to destroy the chemical – This includes, for example, any quantity disposed of in a landfill, surface impoundment, municipal sewage, or

storage.

Items 4–7 – Items 4–7 in part A require you to descri be the manufacturing process and your use

of the chemical in terms of the number of work ers and quantity of substance associated with three process categories. Three process categorie s are described below, followed by instructions for calculating quantities, worker-hours, and nu mber of workers. Additional instructions concerning items 4 through 7 are also listed.

PROCESS CATEGORIES

Enclosed Process – The process is designed an d operated so that there is no intentional release of the chemical. In this process category, only f ugitive or inadvertent releases occur and special measures are taken to prevent worker exposur e and environmental contamination. “Special measures” refer to procedures and equipment th at are monitored and used to prevent worker exposure, and scrubbers and other recovery equipment employed to prevent environmental release. Equipment with emergency pressure re lief venting would be allowed in this category; routine venting would not. With regard to handling the manufactured chemical, persons who handle closed packages containing the material would be counted under “enclosed process.” Person who package or transfer the unpackaged chemical woul d be counted in one of the following categories.

Controlled Release Process – The process is operated in a co ntrolled manner to minimize the release of the chemical into the workplace. Rele ase should generally be w ithin prescribed limits. These limits may be dictated by government regul ations or by company guidelines. If the chemical is vented outside the pl ant, the process is a “controlled release” process. Do not count general space ventilation fans.

Open Process – The chemical is routinely in direct c ontact with the atmosphere (workplace or outside the plant) and no measures are taken to prevent release. Routine direct contact would be associated, for example, with reaction vessels that are open vats, the tran sport or storage of the chemical in open containers (even in an othe rwise enclosed process) , and the venting of a chemical freely into the workplace atmosphere.

QUANTITIES

Process Category – Enter the gr eatest quantity that is pr ocessed in each process category. If there is more than one process stream, calculate each stream separately a nd then add the values for each process category. If a quantity of the ch emical passes in a series through an enclosed process and then passes through an open process, the same quantity would be reported twice, once under each process category. (The sum of thes e quantities may be greater than 100% of the total quantity manufactured.)

EPA Form 7710-35 (01/2005) Page 5 of 10Example 1 – A company manufactures technical grade chemical x in four steps.

350,000 kg—— ▸ 350,000 kg—— ▸ 350,000 kg—— ▸ 200,000 kg Open Enclosed Open Enclosed

The company would report: Enclosed 350,000 kg

Controlled release 0 Open 350,000 kg

Example 2 – A company produces the same chemical in a reagent and techni cal grade with the following steps.

Technical Grade Process:

350,000 kg—— ▸ 350,000 kg—— ▸ 350,000 kg—— ▸ 200,000 kg Open Enclosed Open Enclosed

Reagent Grade Process:

650,000 kg—— ▸ 500,000 kg—— ▸ 500,000 kg—— ▸ 400,000 kg Controlled Controlled Open Open

Release Release

The company would report: Enclosed 350,000 kg Controlled release 650,000 kg Open 850,000 kg

(The open process amount is the total of the maximum quantity in the open process category from each grade.)

Total Quantity – For items 5, 6, and 7, enter the tota l quantity processed in all process

categor ies. (This total may be less than the sum of the quantities reported in the individual process categories.)

WORKER-HOURS

Worker-hours may be calculated for a given process category by multiplying the average number of full-time employees needed for the operati on by the number of hours operating annually. Alternatively, worker-hour information may be taken from preexisting in formation source such as resource planning or budget figures.

WORKERS

Report the total number of workers for each proce ss category. Workers are counted in a process category if (1) they are directly involved in manufacturing, processing, and handling the chemical during the reporting peri od or (2) they are regularly a ssigned maintenance or inspection

EPA Form 7710-35 (01/2005) Page 6 of 10personnel who work with the process from a re mote control room, and who do not regularly come in contact with the actual chemical stream, are not to be counted unless their exposure to the chemical stream is greater than or equa l to that of regularly assigned inspection and maintenance workers. If only control room work ers are associated with a process, and their exposure to the chemical stream is less than that of regularly assigned inspection and maintenance workers, the company must nevert heless report the process categories associated

with the manufacture and on-site use of the ch emical (column 3 in items 4 through 7). The

number of workers and total worker- hours however may be listed as zero.

Three process categories are described in the fo rm: enclosed, controlled release, and open. A worker should be counted as working with onl y one process category. If he operates several process types, count him under the one with which he spends the most time. If he spends an equal amount of time with several, c ount him under the most open process.

Example 3 – A company ma nufactured 1,000,000 kg of a chemical substance. It

manufactured the chemical for all twelve months of the year and did so in an enclosed process.

In order to run the production lin e, ten (10) workers were pres ent working 40 hour weeks; thus over the course of the year 20,800 worker-hours were used to run the production line.

Over the course of the year, twelve (12) di fferent workers worked on the production of the

chemical.

The fo rm would then be filled out as follows:

Process category Quantity (kg) Worker-hours Total workers

Open

Controlled release

Enclosed 0

0 1,000,000 kg 0

0

20.800 0

0

12

Example 4 – A company ma nufactured 1,000,000 kg of a chemical substance. It manufactured the chemical for the entire year in a 24 hour/day process co nsisting of three steps in the open, controlled release, and open proce ss categories. The produc tion line was shut down

for maintenance for 2 weeks of th e years. The production line had three 8-hour shifts. Each shift in step 1 required 5 workers, while 7 and 10 wo rkers were needed per shift in steps 2 and 3, respectively. The total worker-hou rs required for each step follows:

Process category (Shifts/day x hours/shift x workers x days/week x weeks/year) Workers-hours

Open (Step 1) Controlled (step 2) Open (step 3) (3 x8 x 5 x7 x 50) (3 x8 x 7 x7 x 50) (3 x8 x 10 x7 x 50) 42,000 58,800 84,000

EPA Form 7710-35 (01/2005) Page 7 of 10Analysis of the personnel records showed that a total of 75 individuals worked on the production of the chemical. After examining th e personnel records, the company was able to fill in the following table:

Process category Total workers

Open (Step 1) Controlled (step 2) Open (step 3) 21

19

35

75

Note that some workers are not double counted or “split” even though some jobs may require moving from one step of the process to another st ep of the sam e process. An employee working on both step 1 and step 2 is counted only in step 1 if he/she spends most of his time at that step. After adding together steps in the same pro cess category, the company would report as follows:

Process category Quantity (kg) Worker-hours Total workers

Open

Controlled release

Enclosed 1,000,000 kg 1,000,000 kg

0 126,000 58,800

0 56

19

0

Item 4 – This item applies to the ma nufacture of the chemical substa nce and includes all steps to ready the chemical for fu rther processing or use.

Item 5 – This item applies to the use of the chemical at your plant site as a reactant in the

ma nufacture of another chemical substance, wher e the molecular structure of the chemical is altered by breaking chemical bonds or making new chemical bonds between the original substance and some other substance. Report on all processing up to and including the actual reaction step and any ancillary steps which recy cle unreacted chemicals back to the reactor vessel. Do not report on subse quent activities in this question.

Item 6 – Report the quantity of the chemical substance that you use on site. Examples include cleaning solvents, dielectric fluids, emulsifiers, and lubricants. Do not report any quantity that you react to make a product.

Item 7 – Report the quantity of the chemical substance that you process at the manufacturing site into products for on site use or sa le. (Note that this does not in clude ma nufacture of the chemical substance; this is reported in item 4 above.) Th is items does not include the quantity of chemical substance that you incorpor ate into a mixture or article. Report the steps up to and including incorporation of the chemical into an article; do not include any further pr ocessing of the article.

Item 8 – Report the quantity of the chemical substance that you prepare for commercial

distribution in each of the product types in 8a to 8g. Do not include any quantity of chemical substance that your customers will further pr ocess. This will be reported in item 9.

In items 8a to 8f, report the quantity of the chem ical substance in products that are for dome stic use. If you are uncertain about whether your pr oducts are for domestic or foreign use, report

them as domestic.

EPA Form 7710-35 (01/2005) Page 8 of 10The products are divided into industrial a nd consumer products. “Industrial” means the manufacturing and service industries covered by the North American Industry Classification System codes. Products meant to be used prim arily by the general popula tion are considered to be “consumer” products. The following definition from the Consumer Product Safety Act can be used as a guide (15 U.S.C. 2052(a)(1)): “The te rm ‘consumer product’ means any article, or component part thereof, produced or distributed (i) for sale to a consumer for use in or around a permanent or temporary household or residence, a school, in recreation, or ot herwise, or (ii) for the personal use consumption or enjoyment of a consumer in or around a permanent or temporary household or residence, a school, in recreation, or othe rwise.” If you are uncertain about whether your products are industrial or consumer, report them as consumer.

Three types of industrial and consumer product types are described below.

“Chemical substance or mixture” means a chemical, or mixture containing the chemical, that is used directly by the persons using the product, e.g., cleaner s, paints, inks, deodorizers, solvents, etc. This includes chemicals or mixtur es in containers or other articles whose purpose is to release the chemical (e.g., cans of spra y paint, ink pens, and other applicators).

“Articles or products with no release” are articles constructed to preven t human exposure to or

release to the environment of the chemical substance during normal use and storage (e.g., chemical coatings on internal components, a nd chemicals inside sealed articles as in thermometers and batteries).

“Articles or products with some release” are articles whose ma teri al components are made of chemicals which come in direct contact with pe rsons using the article, the atmosphere, land or water; e.g., exposure can come from leaching eva poration, or surface contact. This includes such articles as plastic containers, chemically treated te xtiles, printed paper, coat ed appliances, etc. If

the chemical itself is sold in a bottle or othe r container it should be reported under “Chemical substance or mixture,” not as an article. Only the container itself is an article for purposes of this form; the substance it contains is not a component of an article.

In item 8g, report the quantity of chemical substance that you export directly either as the

chemical or contained in mixtures or articles.

Item 9 – Estima te the quantity of the chemical substa nce that your customers process for each of the uses listed in items 9a to 9h. (Do not include the quantity of chemical substances that your customers will use without further processing; that quantity should be reported in item 8a or 8d.)

For items 9a to 9g, follow the same directions as for 8a to 8g.

For item 9h, report the quantity of chemical s ubstance for which your customers’ uses are unknown.

Report your best estimate for items 9a to 9h within ± 50%. If you cannot estimate an item to this degree of accuracy, include the quantity in item 9i. You may report “unknown” if the data would reveal information subject to a c onfidentiality agreemen t between you and your

customers.

EPA Form 7710-35 (01/2005) Page 9 of 10Item 10 – If you report your customers’ uses as unknow n (item 9i above) for more than 20% of the total quantity that you manufacture and import (items 1 and 2 above) list the names under which you distribute the chemical substance.

This item will allow EPA, if necessary, to find out about the chemical uses you have reported as “unknown” by requiring processors of yourproducts to report directly to us.

Item 11 – This item addresses your general knowledge of the pro cess types your customers use to process the chemical. Estimate the quantity of the chemical that your customers process in each of the three process categories. Specify “unknown” if you do not know to within ± 50%.

EPA Form 7710-35 (01/2005) Page 10 of 10