Enforcement and Compliance Communication Submission

CBI SUBMISSION

Enforcement and Compliance Communication Submission

Submission Date: 06/07/2021

Submitting Official Information
Name of Authorized Official

Jilliane ( Conley

CBI:

Company Name

jew elstesting

Position

Email Address

jilliane.conley@cgi.com

Phone Number

3374841699

Mailing Address 1

684 Wylie Dr

Mailing Address 2

null

City

Baton Rouge

State

LA

Postal Code

70808

Country

US

X

Part I. COMMUNICATION INFORMATION
Case Number

Office

OECA

Reference Number

Region

HQ

Message

this is a test of the em ergency
broadcast system .

Communication Type

ResponseToSupoena

PMN Number

Chemical Name

CSRN

Generic Name

Accession Number

Chemical Name Check

CSRN Check

Generic Name Check

Accession Number Check
Message

CBI :

Y

Part II. Attachments
File Name

CBI

Y
TSCA CBI Substantiation
Substantiation questions applicable to Chemical Identification CBI claims
(i) Is this chemical substance publicly known (including by your competitors) to be in U.S. commerce? If yes, please explain why the specific chemical identity should still be afforded confidential status
(e.g., the chemical substance is publicly known only as being distributed in commerce for research and development purposes, but no other information about the current commercial distribution of the
chemical substance in the United States is publicly available). If no, please complete the certification statement:
I certify that on the date referenced I searched the internet for the chemical substance identity (i.e., by both chemical substance name and CASRN). I did not find a reference to this chemical substance that
would indicate that the chemical is being manufactured or imported by anyone for a commercial purpose in the United States. [provide date].

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(ii) Does this specific chemical substance leave the site of manufacture (including import) in any form, e.g., as a product, effluent, emission? If yes, please explain what measures have been taken to
guard against the discovery of its identity.
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(iii) If the chemical substance leaves the site in a form that is available to the public or your competitors, can the chemical identity be readily discovered by analysis of the substance (e.g., product,
effluent, emission), in light of existing technologies and any costs, difficulties, or limitations associated with such technologies? Please explain why or why not.
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(iv) Would disclosure of the specific chemical identity release confidential process information? If yes, please explain.
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Substantiation questions applicable to All CBI claims
(i) Will disclosure of the information claimed as confidential likely cause substantial harm to your business's competitive position? If you answered yes, describe the substantial harmful effects that would likely
result to your competitive position if the information is disclosed, including but not limited to how a competitor could use such information, and the causal relationship between the disclosure and the harmful
effects.

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(ii) Has your business taken precautions to protect the confidentiality of the disclosed information? If yes, please explain and identify the specific measures, including but not limited to internal controls, that your
business has taken to protect the information claimed as confidential. If the same or similar information was previously reported to EPA as non-confidential (such as in an earlier version of this submission),
please explain the circumstances of that prior submission and reasons for believing the information is nonetheless still confidential.
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(iii) (A) Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law? If yes, please explain.
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(B) Does any of the information claimed as confidential otherwise appear in any public documents, including (but not limited to) safety data sheets; advertising or promotional material; professional or
trade publications; state, local, or Federal agency files; or any other media or publications available to the general public? If yes, please explain why the information should be treated as confidential. .
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CBI SUBMISSION

(C) Does any of the information claimed as confidential appear in one or more patents or patent applications? If yes, provide the associated patent number or patent application number (or numbers)
and explain why the information should be treated as confidential.
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(iv) Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If yes, please indicate the number of years (between 1-10 years) or the specific date after which the claim is
withdrawn.
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(v) Has EPA, another federal agency, or court made any confidentiality determination regarding information associated with this chemical substance? If yes, please provide the circumstances associated
with the prior determination, whether the information was found to be entitled to confidential treatment, the entity that made the decision, and the date of the determination.
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TSCA CBI Certification
I hereby certify to the best of my know ledge and belief that all information entered on this form is complete and accurate.
I further certify that, pursuant to 15 U.S.C. § 2613(c), for all claims for protection for any confidential information made w ith this submission, all information submitted to substantiate such claims is true and
correct, and that it is true and correct that the person submitting the claim has:

i.
ii.
iii.
iv.

taken reasonable measures to protect the confidentiality of the information;
determined that the information is not required to be disclosed or otherw ise made available to the public under any other Federal law ;
a reasonable basis to conclude that disclosure of the information is likely to cause substantial harm to the competitive position of the person; and
a reasonable basis to believe that the information is not readily discoverable through reverse engineering.

Any know ing and w illful misrepresentation is subject to criminal penalty pursuant to 18 U.S.C. § 1001.

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