Based on EPA FORM 7710

- 25 Page 1 of 18 0 3

- 2 5

- 20 1 5 Version.

- Form Not Yet Approved.



### U.S. ENVIRONMENTAL PROTECTION AGENCY



## AGENCY USE ONLY : Document control number EPA case number Date of receipt



# TSCA § 8(a) REPORTING FOR CHEMICAL SUBSTANCES

WHEN MANUFACTURED OR PROCESSED AS NANOSCALE

MAT ERIALS : DATA SUBMISSION FORM Total number

of pages

submitted



### When

completed

send this

form to 

### U.S. E.P.A.

DOCUMENT CONTROL OFFICER (7407M)

1200 PENNSYLVANIA AVE. NW

WASHINGTON, D.C. 20460

ATTN: 8(a) Reporting for Chemical Substances Manufactured or Pr ocessed as Nanoscale

Materials

[

GENERAL INSTRUCTIONS

 This form is to be used for reporting as prescribed in 40 CFR 704.20. As indicated in that regulation, definitions in TSCA a nd

40 CFR part 704 apply

.

 You must provide information requested in this form to the extent it is known to or reasonably ascertainable by you

. “ Known to

or reasonably ascertainable by” is defined in 40 CFR §704.3

. M ake reasonable estimates if you do not have actual data.

 You must provide the currently correct Chemical Abstra cts (CA) Name of the chemical substance and material characterization

data described in Part I, section C4.

 As much of this form is adapted from the Premanufacture Notice ( P MN ) form (EPA Form No. 7710

- 25), it may be instructive

to read “ Instruction Manual for Reporting Under t he T SCA §5 New Chemicals Program ” (available from the Toxic Substances

Control Act (TSCA) Information Service

, 202

- 554

- 1404, or 202

- 554

- 5603 (fax) or at

http://www.e pa.gov/opptintr/newchems/pubs/pmnforms.htm )

.

 If there are several manufacture, processing, or use operations to be described in Part II, sections A and B of this f orm

, reproduce the sections as needed.

 Attach additional sheets if there is not enough spac e to answer a question fully . Label each continuation sheet with the

correspondi ng section heading. In Part III of this Form , list all attachments, including any continuation sheets, any test data

reports or other data and any optional information provid ed

.

 Only one chemical substance may be submitted per form.

 A ny information may be claimed as confidential. To assert a claim on the form, mark (X) the confidential box next to the

information claim ed as confidential. To assert a claim in an attachment, circle or bracket the information claim ed as

confidential. If i nformation is claimed as confidential, a sanitized version (including attachments) must be provided with your

submission and should be labeled as such

.

 You are required to submit all exist ing data concerning the environmental and health effects of the substance known to or

reasonably ascertainable by you. Standard literature citations may be submitted for data in t he open scientific literature.

Submit a c omplete test data report (written in English , if available ), not summary data, unless the test data report appear s in the

open literature

. C learly identify whether test data is on the chemical substance , on an analog, or from models. Characterize the

chemical composition of the tested ma terial

.

TEST DATA

Data must be submitted according to the requirements of 40 CFR §7 04. 20

. In addition, h azard and exposure test data are most

useful if the physical/chemical properties of the nanoscale material relevant to assessing test results are obtained at the initiation

of testing. A dditional relevant information on preparation of the nanoscale material for administration and storage history of the

material between produc tion and administ ration is not required but can assist in interpretation. Indicate which of the following

data are included in this submission:

Physical / Chemical properties

Structure / activity relationships Health effects

Exposure Environmental effects

Environmental fate

Mark (x) if any information in your submission package is claimed as confidential.Based on EPA FORM 7710

- 25 Page 2 of 18



### TIM E REQUIRED TO COMPLETE THE FORM

EPA estimates that it may take

, up to 1 75 hou rs to complete this form , including time to review instructions, search

e xisting data sources, gather and maintain the data needed, and complete and review the collection of information.

More details about the EPA estimate are provided in the Information C ollection Request identified as EPA ICR

No. 2517.01, approved under OMB Control No. 2070

- [tbd] , a copy of which is available here [insert url when

finalized ]. To help us refine that estimate, p lease provide an estimate of the amount of time in work hours t hat it

took you to complete this form. Hours :

RESERVED for any additions

CHECK LIST

Please verify that the questions in the following general areas were answered by marking (X) in the boxes. (Answers may incl ude,

for example, “N/A,” “none,” “not known”).

Physical and chemical characterization

Risk management information

STATEMENT

I certify that to the best of my knowledge and belief:

1. The company named in Part I, section A, subsection 1a o f this f orm manufactures, imports, or processes or intends to

manufacture, import, or process for a commercial purpose (as those terms are defined in TSCA and 40 CFR Part 704) , the

chemical substance identified in Part I section B.

2. All information provi ded in this f orm is complete and truthful as of the date of submission.

3. I am submitting with this f orm all existing data concerning the environmental and health effects and all other required data

known to or reasonably ascertainable by me as required by 40 CFR § 7 04

. 20

.

Mark ( X ) the “Confidential” box on the right if you claim the signature and title as confidential

. Confidential

Signature and title of Authorized Official (Original Signature Required) DateBased on EPA FORM 7710

- 25 Page 3 of 18 

### Part I

-- GENERA L INFORMATION

Section A

-- SUBMITTER IDENTIFICATION Confi

Mark ( X ) the “Confidential” box in the right column next to any subsection you claim as confidential dential

1a. Person

Submitting

(in U.S.) Name of authorized official Position

Company

Mailing address (number and street)

City, State, ZIP Code

b. Other Person

Submitting

(in U.S.) Name of authorized offi cial Position

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code Number

c. If you are submitting this 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)

City, State, ZIP Code Telephone Area Code Number

2. Technical

Contact (in

U.S.) Name of authorized official P osition

Company

Mailing address (number and street)

City, State, ZIP Code Telephone Area Code NumberBased on EPA FORM 7710

- 25 Page 4 of 18 

### Part I

– GENERAL INFORMATION

– Continued

Section B

-- CHEMICAL IDENTITY INFORMATION: **

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

Complete either item 1 (Class 1 or 2 substances) or 2 (Po lymers) as appropriate. Complete all other items.

If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right.

Identify the name, company, and address of that person in a continuation sh eet. Confi

d ential

1. 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 sub stances. **

c. I dentify which method you used to develop or obtain the specifie d chemical identity information : (check one).

Method 1 (CAS Inventory Expert Service Method 2 (Other Source)

d. Molecular formula and CAS Registry Number (if a number already exists for the substance)

CAS#

e. For a class 1 substance, provide a complete and correct chemical structure diagram. 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) In di cate the

range of composition and the typical composition (where appropriate). (4) Provide a correct representative or partial chemic al structure

diagram, as complete as can be known, if one can be reasonably ascertained. (5) Note: the components of a c omposite can be separate

chemical identities. For example in a composite of starch molecules between layers of clay treated with surfactants, the sta rch, clay, and

surfactants might be on the TSCA Inventory, but since the interactions between the componen ts are weak electrical interactions, the re is no

single chemical substance representing the composite as a whole.

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 5 of 18 

### Part I

-- GENERAL INFORMATION

– Continued

Section B

-- CHEMICAL IDENTITY INFORMATION

– Continued

2. Polymers (For a definition of polymer, see the Instructions Manual.) Confi

d ential

a. Indicate the number

- average weight of the lowest molecular weight composition of the polymer y ou intend to manufacture.

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) bel ow 500 and

below 1,000 absolute molecular weight of that composition.

Describe the methods of meas urement or the basis for your estimates: GPC Other : (Specify)

i) lowest number average molecular weight:

ii) maximum weight % below 500 molecular weight:

i ii) maximum weight % below 1000 molecular weight:

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

b. M ake separate confidentiality claims for monomer or other reactant identity, composition information, and res idual 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)

- Mark (X) the identity column if you want a monomer or other reactant used at two wei ght 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 ot her 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.

Monomer or other reactant and CAS Registry Number

(1) Confi

dential

(2) Typical

c omposition

(3) Identity

(4) Confi

dential

(5) Maximum

residual

(6) Confi

dential

(7)

% %

% %

% %

% %

% %

% %

% %

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

c. I dentify which method you used to develop or obtain the specified chemical identity information (check one).

Method 1 (CAS Inventory Expert Servic e ) Method 2 (other source)

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for simila r polymers.

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained.

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 6 of 18 

## Part I

-- GENERAL INFORMATION

-- Continued

Section B

-- CHEMICAL IDENTITY INFORMATION

– Continued

3. Impurities

(a)

- Identif

y each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial pur pose. Provide the

CAS Registry Number if available. If there are unidentified impurities, enter “unidentified.”

(b)

- Estimate t he maximum weight % of each impurity. If there are unidentified impurities, estimate their total weight %.

Impurity and CAS Registry Number

(a) Maximum

percent

(b) Confi

d ential

%

%

%

%

%

%

%

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

4. Synonyms

- En ter any chemical synonyms for the chemical identified in subsection 1 or 2. Confi

d ential

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

5. Trade identification

- List trade names for the chemical substance id entified 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, provide a generic name for your substance that reveals the

specific chemical identity of the 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) thi s box if you attach a continuation sheet.

7. Byproducts

- Describe any byproducts resulting from the manufacture, processing, use, or disposal of the chemical substance. Provide the CAS Registry

Number if available.

Byproduct

(1) CAS Registry Number

(2) Confi

d ential

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 7 of 18 

## Part I

– GENERAL INFOR MATION

– Continued

Section C

-- PRODUCTION, IMPORT, AND USE INFORMATION:

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

1. Production volume

– Report the production volume during calendar year 20XX . Also estimate the max imum production volume for any

consecutive 12

- month period during the next three years of production. Make estimates on a 100% chemical substance basis.



### P roduction volume for 20XX (kg/yr)

(100% chemical substance basis) Maximum 12

- month production vol ume (kg/yr)

(100% chemical substance basis) Confi

dential

2. Use Information

-- M ake separate confidentiality claims for the description of the category of use, the percent of production volume devoted to

each category, the formulation of the substance, and other use information. Mark (X) the “Confidential” b ox next to any item you claim as

confidential.

a. (1)

-- Describe each category of use of the chemical substan ce by function and application.

(2)

-- Mark (X) this column if entry column (1) is claimed as confidential business information (CBI).

( 3 )

-- Estimate the percent of total production volume devoted to each category of use.

(4 )

-- Mark (X) this column if entry in column (4) is claimed as CBI.

(5 )

-- Estimate the percent of the substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured f or

commercial purposes at sites under your control associated with each category of use.

(6 )

-- Mark (X) this colum n if entry in column (6) is claimed as CBI.

(7 )

-- Indicate % of product volume expected for the listed “use” sectors. Mark more than one box if appropriate.

(8 )

-- Mark (X) this column if entry(ies) in column (8) is (are) claimed as CBI.

Category o f use (1) CBI Produc

tion % CBI % in

Form

CBI % of substance expected per use

( 7 ) CBI

(by function and application i.e. a coating for

automobile body parts ) (2) ( 3 ) ( 4 ) ulation

( 5 ) ( 6 ) Site

limited Con

- *

sumer Indus

trial Com

mercial (8 )

% %

% %

% %

% %

% %

% %

% %

* 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 chemical substance as expected in consumer products and describe th e 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 description If you claim any category of use description in subsection 2a as confidential, enter a generic description o f that category. Read the

Instructions Manual for examples of generic use descriptions.

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

3. Hazard Information

-- Include a copy o r reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other information

which is provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices f or the safe

handing, transport, use, or disposal of the substance. List in part III hazard information you include.

Mark (X) this box if you attach hazard information.Based on EPA FORM 7710

- 25 Page 8 of 18 

## Part I

– GENERAL INFORMATION

– Continued

Section C

– - Continued

Mark (X) the “C BI ” box next to any item you claim as confidential. CBI

4. M aterial characterization

– Describe characteristics of the nanoscale material used to distinguish it from other discrete forms

of the nanoscale material, as describe d in 40 CFR 704.xxx(a), i ncluding but not limited to the particle size, morphology, encapsulation

, and formulation

.

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

5

. Briefly desc ribe any unique or enhanced properties that arise from the nanoscale features of the material, particularly in contrast to an y

non

- nanoscale varieties that exist.

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

6. Briefly explain why this material is designed and/or produced to be a nanoscale material.

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 9 of 18 

## Part II

-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

Section A

– INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the C BI box next to any item you claim as

confidential

. Complete section A for each type of manufacture, processing, or use operation involving the chemical substance at industrial sites you contro l.

See instructions manual

1. Operation description

a. Identity

-- Enter the identity of the site at which the operation occur s

. CBI

Name

Site add ress (number and street)

City, County, State, ZIP code

If the same operation occur s 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 continuat ion sheet.

b. Type

-- Mark (X) Manufacturing Processing Use

c. Amount and Duration

-- Complete 1 or 2 as appropriate

1. Batch Maximum kg/batch (100% chemical

substance) Hours/batch Batches/year

2. Continuous Maximum kg/day (100% chemical

substance) Hours/day Days/year

d. Process description

(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/da y or kg/batch on a 100% 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 clean ing chemicals (note frequency if n ot

used daily or per batch.).

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the chemical substa nce. If releasing to two media at

the same step, assign a second release number for the second medium.

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 10 of 18



## Part II

-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

– Continued

Section A

– INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER

– Continued

2. Occupa tional Exposure

-- M ake separate confidentiality claims for the description of worker activity, physical form of the chemical substance, number o f

work er s exposed, and duration of activity. Mark (X) in the “CBI ” column next to any item you claim as confid ential.

(1)

-- Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be e xposed to the substance.

(2)

-- Mark (X) this column if entry in column (1) is claimed CBI.

(3)

-- Describe any p rotective equipment and engineering controls used to protect workers.

( 4 )

-- Indicate the physical form(s) of the chemical substance (e.g., solid: crystal, granule, powder, or dust) and % chemical subst ance (if part of a mixture) at the

time of exposure.

(5 )

-- Mark (X) t his column if entry in column (4 ) is claimed CBI.

(6 )

-- Estimate the maximum number of workers involved in each activity for all sites combined.

( 7 )

-- Mark (X) this column if entry in column ( 6 ) is claimed CBI.

(8 ) and ( 9 )

- - Estimate the maximum duration of the activity for any worker in hours per day and days per year.

(10 )

-- Mark (X) this column if entries in columns ( 8 ) and ( 9 ) are claimed CBI.

Worker activity CBI Protective Equipment/ Physical forms(s) CBI # o f CBI Maximum D uration CBI

(i.e., bag dumping, filling drums)

(1) (2) Engineering Controls

(3) and % substance

(4 )

(5 ) Workers

Exposed

( 6 ) ( 7 ) Hrs/day

( 8 ) Days/yr

( 9 ) (1 0 )

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

3. Environmental Release and Disposal

-- M ake separate confidentiality claims for the release number and the amount of the chemical substance released and other

release and disposal information. Mark (X) in the CBI column next to each item you cl aim 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 substance released (a) directly to the environment or (b) into control techn ology (in kg/day or kg/batch).

(3)

-- Mark (X) in this column if entries in columns (1) and (2) are claimed as CBI.

(4)

-- Identify the media (stack air, fugitive air (optional

- see Instruction Manual), surface water, on

- site or off

- site land or incinerat ion, POTW, or other (specify)) to

which the substance is released from that release point.

(5)

-- a. Describe control technology, if any, and control efficiency that is used to limit the release of the 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 continuat ion sheet, for each site

describe any additional disposal methods that is used and whether the waste is subject to secondary or t ertiary on

- site treatment. b. Estimate the amount

released to the environment after control technology (in kg/day).

(6)

-- Mark (X) in this column if entries in columns (4) and (5) are claimed as 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 claimed as CBI.

Release

Number Amount of substance released CBI Media of

release Control technology and efficiency (you may wish to optionally attach efficiency data) CBI

(1) (2a) (2b)

(3) e.g. stack air (4) (5a) (5b) (6)

(7) Mark (X) the POTW provide name(s) below: CBI Navigable Other

- Specify provide NPDES # CBI

destination(s) of

releases to water. wate rway

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 11 of 18



## Part II

-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

– Continued

Section B

– INDUSTRIAL SITES CONTROLLED BY OTHER S

Complete section B for typical processing or use operations involving the chemical substance at sites you do not control. See the Instructions Manual . Complete a

separate section B for each type of processing, or use operati on involving the chemical su bstance . 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. 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 car s, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2)

-- Provide the identity, the approximate weight

(by kg/day or kg/batch, on a 100% chemical substance basis), and entry point of all feedstocks (includ ing 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)

-- Identify by number the points of release, including

small or intermittent releas es, to the environment of the chemical substance. (4) Please enter the # of sites (remember to identify the locations of the se sites on a

continuation sheet):

# of sites

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

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 % chemical substance (if in mixture), and any protective equipment and engineering controls, if any,

used to protect workers.

(7)

-- Estimate the percent of the 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 rele ase point identified.

(10)

-- Estimate the amount of the substance released (a) directly to the environment or (b) into control technology to the environme nt (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 that is used to limit the release of the substance to the environme nt.

(14)

-- Identify byproducts which result from the operation.

(3), (5), (8), (11), (13) and (15)

-- Mark (X) in th e s e column s if any of the proceeding entries are claimed as CBI.

Letter

of

Act

ivity # of

Workers

Exposed CBI Duration

of

Exposure CBI Protective Equip. /

Engineering Controls/

Physical Form and %

S ubstance % in

Form

ulation CBI Release

Number Amount of

Substance

Released CBI Media of Release

& Control

Technology CBI

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (10a) (10b) (11) (12) ( 13)

(14)

-- Byproducts: (15)

Mark (X) this box if you attach a continu ation sheet,Based on EPA FORM 7710

- 25 Page 12 of 18



## Part II

-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

– Continued

Section A / B, Subsection 2. Occupational Exposure

– Continued. b. Details of protective equipment / engineering controls.

(Use this form both for sites controlled by sub mitter and by others. Make copies as necessary.)

P rovide the following information:

(1)

– The worker activ ities listed in Section A.2 or B.1 for which protective equipment/engineering controls are in use.

(2)

– A brief description of the rationale for selecting the protective equipment/engineering controls, including internal exposure control limit s

, data and the methods used to generate the data that informed the decision.

(3)

– A brief description of the cleaning, reuse, and/or disposal of the protec tive equipment

(4)

– A brief description of any data (personal and/or area), units (e.g., mass conc., surface area, or particle number conc.) and

A ny exposure monitoring methods used.

Mark (X) in the “CBI” column next to any item you cla im as confidential. CBI



### (1) Worker activity / Protective equipment / Engineering Control

(2) Rationale for selecting equipment / controls , associated internal exposure control limit / data / methods

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



### (3) Cleaning, reuse, and/or disposal of protective equipment

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



### (4) Exposure monitoring data (pe rsonal and/ or area), units (e.g., mass conc., surface area, or particle number conc.), and

methods used

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

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



### Section A.3 / Section B, subsection 2. Environmental Release and Disposal

– Continued. Details of control technology.

(Use this form both for sites controlled by submitter and by others. Make copies as necessary)

To assist EPA in gaining a better understanding of the need for and the types of control technology used at the release points in the manuf acture and

handling of engineered nanoscale materials, provide the following information for each release point for which control technology is used:

(1)

– The Release Number, as identified in the process description, part II, section A, subsection 1d(3) (page 8).

(2)

– A brief description of the rationale for selecting the control technology.

(3)

– Data and measurement methods of waste treatment efficiency studies.



### Release

Number (1) Mark (X) in the “CBI” column next to any item you claim as confidential. CBI



### (2) Rationale for selecting control technology

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



### (3) Data and measurement methods of waste tr eatment or purification studies

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

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 13 of 18



## Part II

-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

– Continued

Section C

– Lifecycle

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

1. In addition to the information already given, provide a brief overv iew of the lifecycle of the material, including all workplaces that

manufacture, process, or use the material, methods of packaging and transporting the material, all expected general population,

environmental, and consumer uses, and the manufacturing and processing methods of the material or any consumer products

containing the material. If not included in Sections A or B above, include a description of the end of life disp osal or disposition of products

containing the nanoscale materia l.

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



### Section D

– Misc. Health, Exposure, Hazard Information

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

1. Describe any training, hazard communicat ion (e.g. MSDS), etc. specific to the nanoscale material that is provided to workers.

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

2. Estimate the total number of individuals

— other than previously described workers

— (e.g. general public, consumers) who may be

exposed to the material and the duration of the exposure.

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

3. Describe any other procedure, equipment, etc . being used to mitigate exposure to the material.

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

4. Describe product labeling and any customer training specific to the nanoscale material.

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

5. Describe other risk management practices specific to the nanoscale material.

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 14 of 18



# Part III

- OPTIONAL POLLUTION PREVENTION INFORMATION

To claim information in this section as confidential circle or bracket the specific information that you claim as confidentia l.

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 substance. Please include in formation

pertinent to pollution prevention, including source redu ction, recycling activities and safer processes or products available due to the

chemical substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological

modification, process and procedure modification, pr oduct 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. D escriptions of pollution prevention, source reduction and recycling should

emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitat ive or

qualitative. EPA is interested in the informatio n to assess overall net reductions in toxicity or environmental releases and exposures,

not the shifting of risks to other environmental media or non

- environmental areas (e.g., occupational or consumer exposure). In

addition, information on the relative c ost or performance characteristics of the substance to potential alternatives may be provided.



## See Pollution Prevention Guidance in Instructions Manual for guidance and examples.

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 environ mental release; (5) an increase in product performance, a decrease in

the cost of production and/or improved operation efficiency of the chemical substance in comparison to existing chemical substances

used in similar application; or (6) the extent to whic h the chemical substance may be a substitute for an existing substance that poses a

greater overall risk to human health or the environment.

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 15 of 18 

# Part I V

-- LIST OF ATT ACHMENTS

List and then a ttach continuation sheets for sections of the form ; test data and other data (including physical/chemical properties and

structure/activity information), and optional information you are providing . Clearly identify the attachment and the section of the form

to which it relates, if appropriate. Number consecutively the pages of the attachments. In the column below, enter the incl usive page

numbers of each attachment.

Mark (X) in the “Confidential” column next to any attachment na me you claim as confidential. Read the Instructions Manual for

guidance on how to claim any information in an attachment as confidential. I nclude with the sanitized copy of the form a sanitized

version of any attachment in which you claim information as c onfidential.

Attachment name Attachment

page number(s) Confi

dential



### Safety Data Sheet (SDS)

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 16 of 18 

## PHYSICAL AND CHE MICAL PROPERTIES WORKSHEET

1

. 

### To assist EPA’s review of physical and chemical properties data, summarize data you have already provided or used to complete the

reporting form. I dentify the property measured, the page of the form on which the property appears, the value of the property, the units

in which the property is measured (as necessary), the physical state of the neat substance, and whether or not the property is claimed as

confidential. If properties are not measured for the neat (100% pure) chemical substance then the measured mixtures or formulations can

be noted (% substance in __). It is noted that, for nanoscale materials, protocols and methods may not exist or be standar dized for

measurement of the physical and chemical properties lis ted in this worksheet.

Mark

(X) if

provided Page

number Value Measured or

Estimate

(M or E) Confi

dential

Mark (X)



### Physical state of neat substance (s) (l) (g)

Vapor pressure

@ Temperature °C Torr

Density/rel ative density g/cm3

Solubility

@ Temperature °C

Solvent g/L

Solubility in water @ Temperature °C g/L

Melting temperature °C

Boiling / sublimation temperature@ torr pressure °C

Spectra

Dissociation constant

Octanol / water partition coefficient

Henry’s Law constant

Vol a t i lization from water

Volati lization from soil

pH @ concentration

Flammability

Explodability

Adsorption / coefficientBased on EPA FORM 7710

- 25 Page 17 of 18



### PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET Cont

– Nanoscale Materials Specific Data

2. To assist EPA’s review of physical and chemical properties data, summarize dat a you have already provided or used to

complete the reporting form. I dentify the property measured, the page of the form on which the property appears, the value of the

property, the units in which the property is measured (as necessary), the physical sta te of the neat substance, and whether or not the

property is claimed as confidential. If properties are not measured for the neat (100% pure) chemical substance then the measured

mixtures or formulations can be noted (% substance in __). It is noted th at, for nanoscale materials, protocols and methods may not

exist or be standardized for measurement of the physical and chemical properties listed in this worksheet.

Property Mark (X)

if

provided P age

number Value Measured /

Estimate d

(M or E) CBI

Mar k

(X)



### General Characteristics

Crystal s tructure

Agglomeration s tate

Particle Characteri stics

Particle size distribution Provide graph with percentage of particles in each diameter

class. For elongated particles, provide length distri bution

graph showing the percentage of particles in each length class.



### Mean particle size (diameter and/or length)

nm

Standard deviation from mean

Largest particle size (diameter and/or length)

nm

Smallest particle size (diamete r and/or length)

nm

Aspect ratio

Average aerodynamic diameter

nm

Average particle mass

g

Particle shape

Surface Characteristics

Surface area

m 2 

### /g

Average particle surface area

m 2



### Surface charge (Zeta potential ) mV

Porosity

Surface chemical composition

Surface / volume ratio

Other

Other

Mark (X) this box if you attach a continuation sheet.Based on EPA FORM 7710

- 25 Page 18 of 18



### PHYSICAL AN D CHEMICAL PROPERTIES WORKSHEET C ont

– Nanosc ale Materials Specific Data

3

. To assist EPA’s review of physical and chemical properties data, summarize data you have already provided or used to complete

the reporting form. I dentify the property measured, the page of the form on which the propert y appears, the value of the property, the

units in which the property is measured (as necessary), the physical state of the neat substance, and whether or not the property is

claimed as confidential. If properties are not measured for the neat (100% pure) chemical substance then the measured mixtures or

formulations can be noted (% substance in __). It is noted that, for nanoscale materials, protocols and methods may not exist or be

standardized for measurement of the physical and chemical properties li sted in this worksheet.

Mark (X)

if

provided Page

number Value Measured /

Estimate d

(M or E) CBI

Mark

(X)



### Fate and Transport

Diffusion rate

Gravitational settling rate

Sorption rate

D eposition rate

Wet and dry tran sport

Biodegradation rate

Bioaccumulation

Biotransformation

I nfluence of redox/photochemical reaction

Other

Other

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

Form EPA 7710

- 25 (Rev. 5

- 95)

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