Significant New Alternatives Policy (SNAP) (40 CFR Part 82, subpart G)

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Atmospheric Programs
Washington, DC 20460
THE SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP) PROGRAM
TSCA/SNAP ADDENDUM INSTRUCTION MANUAL
EPA Form No. 1265-14 (Rev. July 2020)
The U.S. Environmental Protection Agency (EPA) has prepared this instruction manual to help you in
submitting information on alternatives to the Significant New Alternatives Policy (SNAP) program in
conjunction with a Premanufacture Notice (PMN) under the Toxic Substance Control Act (TSCA) (EPA
Form 7710‐25). This manual provides instructions on submitting the TSCA/SNAP Addendum forms,
asserting confidentiality claims, and submitting test data and optional information. However, please
note that in the event of any discrepancies between this document and the Code of Federal Regulations
(CFR), the CFR requirements are legally binding and take precedence.
This revised form has been updated to clarify the information requested by EPA. In addition, a response
checker has been added that, in the Excel version of the form, can identify questions that are missing
responses. Also, the form now requests volatile organic compounds (VOC) status information and a
description of byproducts and degradation products.

Part I: Introduction and Confidentiality Claims
Section A: Instructions
All submitters must complete all of Part I: Introduction and CBI, Part II: Contact Information, Part III:
General Information, Part VI: Attachments, and Part VII: Certification. For each sector for which the
alternative is being submitted, submitters must also complete the corresponding sector‐specific data
requirements found in Part IV.
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Refrigeration and Air Conditioning
Foam Blowing
Cleaning Solvents
Fire Suppression
Aerosols
Sterilants
Adhesives, Coatings and Inks
Tobacco Expansion

Enter any additional information in Part V. Before submitting the Notice form, you may review the
completeness of the form using the Response Checker, which can be found prior to Part VII: Certification.

Section B: Identification of Alternatives
Please identify the alternative, sector(s), end‐use(s), and application(s) (if applicable) for which the form
is being submitted in Part I, Section B. Please specify if the PNM form is provided as an attachment to
this TSCA/SNAP Addendum and, if not, provide an explanation.
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Section C: Confidentiality Claims
If you submit information for which you would like to request Clean Air Act (CAA) Confidential
Business Information (CBI) status, you must make a claim of confidentiality at the time of submission
and substantiate that claim. EPA will treat all claims of confidentiality consistent with 40 CFR Part 2,
Subpart B. To claim information as CBI, bracket the specific information you claim as confidential and
mark the confidential box in the column on the right‐side of the page in the corresponding row. If
information is claimed as CBI, then a public version must be submitted with the bracketed
information redacted/removed.
To ensure that no confidential information is disclosed to the public, you must submit an additional copy
of the notice form, including attachments, which does not contain confidential information. This version
(“sanitized,” “redacted”) will be placed in the public docket. It must contain all non‐confidential
information. To assert confidentiality claims for information in attachments to the form, provide a
complete copy of the attachment that clearly indicates (e.g., by circling or bracketing) the information you
wish to claim as confidential. Bracket only the specific information you claim as confidential.
Provide the following information:
1. Please provide the reasons why the cited passages qualify for confidential treatment.
2. If you assert that disclosure of this information would be likely to result in substantial harmful
effects to you, describe those harmful effects and explain why they should be viewed as
substantial.
3. Indicate the length of time – until a specific date or event, or permanently – for which the
information should be treated as confidential.
4. Identify the measures you have taken to guard against undesired disclosure of this information.
5. Describe the extent to which the information has been disclosed, and what precautions have
been taken in connection with these disclosures.
6. Please provide copies of any determinations of confidentiality previously made by EPA, other
Federal agencies, or courts concerning this information.
Provide a Statement of Data Confidentiality Claims in Part I, Section C based on the instructions provided
in the form. EPA requires substantiation of all CBI claims under SNAP or a submission will be considered
incomplete.

Part II: Contact Information
Section A: Submitter Contact Information
All contacts listed in Part II will be granted access to CBI, unless otherwise noted and substantiated in
Part I, Section C.
1.

Person Submitting Notice – Enter information for the primary submitter of the notice.
The person submitting the notice form must sign the certification in Part VII‐ Certification.

2.

Agent – Complete only if you authorize an agent to assist you in preparing this notice. The
agent must also sign the certification in Part VII‐ Certification.

3.

Technical Contact – Identify a person who can provide EPA with additional technical
information on the substitute during the review period, if that contact is different than the
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“Person Submitting Notice” and the “Agent.” The technical contact identified should be located
within the U.S. and be available to be reached by telephone during normal business hours.
4.

Joint Submitter – Identify the joint submitter, if any, who is authorized by the primary submitter
to provide some of the information required in the notice. A submission will not be considered
complete until EPA receives all information.
If you have a Joint Submitter who is authorized to provide information directly to EPA (e.g., a
foreign manufacturer or supplier), indicate which information will be supplied by the other
person in Part V: Additional Information. A letter in support of your notice should be provided
by the Joint Submitter on their company letterhead. An example of where this could apply
would be in situations where alternative formulation information is held confidentially by a
foreign manufacturer. A notice will be considered incomplete until this information is provided.
Whenever possible, use the same name for the alternative (e.g., generic name) to link this
information to your submission.

Part III: General Information
Section A: Alternative‐Specific Information
EPA must receive a complete and unambiguous identification of the new substitute. If the alternative is
not adequately identified, we will consider the submission incomplete. If you are an importer of an
alternative and do not know the chemical identity of a substitute because it is confidential, you must
contact the manufacturer or supplier and have the specific chemical identity provided directly to EPA. In
this way, manufacturers can protect confidential business information. This information may be
provided in a letter on company letterhead from the supplier.
1.

Identify Proposed Substitute – (a‐d) Enter the specific name of the chemical substance, the
percent of the composition, the Chemical Abstracts Service (CAS) registry number, and the
molecular formula of the alternative. In describing chemical substances, EPA prefers that
International Union of Pure and Applied Chemistry (IUPAC) nomenclature be used for
identification purposes. If the substitute is a blend of chemicals, you must provide the exact
composition and/or the range of percent composition of all components of the blend. In
addition to active ingredients, you must also list other chemical substances in blends, such as
solvents, inhibitors, etc., that may also be present in the alternative.

2.

Commercial/Trade name(s) of alternative – Indicate the name(s) under which the alternative
would be marketed.

3.

Generic name – If the identity of a substitute and the commercial/trade name are claimed as
confidential, provide a generic name that is specific enough to identify the substance uniquely.
The generic name may be published in the Federal Register notice announcing EPA’s
acceptability determination of your alternative. If the name seems more generic than
necessary, EPA will contact you and assist you in developing an adequate name.

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The generic name should provide sufficient information for the public by indicating the classes
of chemicals which the alternative contains without revealing specific information about the
product's composition. For example, it may be necessary to reveal that a refrigerant blend
contains an HCFC in order to allow users or importers to comply with regulations issued under
sections 604, 605, or 608 of the CAA.
4.

Ozone depletion potential (ODP) – (a) Provide information on the predicted 100‐year ODP of
the alternative relative to CFC‐11. If the substitute is a blend, provide the ODPs of the individual
constituents. You should also provide supporting documentation indicating how and by whom
this value was calculated.
For purposes of calculating ODP, EPA recommends the methodology used in the Scientific
Assessment of Ozone Depletion prepared for the United Nations Environment Programme
(UNEP) by the World Meteorological Organization (WMO). The ODP refers to the amount of
ozone destroyed by a gas over its entire atmospheric lifetime (e.g., at a steady state) relative
to that due to emissions of the same mass of CFC‐11. It is defined in modeling calculations as
follows:
𝑂𝑂𝑂𝑂𝑂𝑂𝑥𝑥 =

𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺 ∆𝑂𝑂3 𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐 𝑏𝑏𝑏𝑏 𝑥𝑥
𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺𝐺 ∆𝑂𝑂3 𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐 𝑏𝑏𝑏𝑏 𝐶𝐶𝐶𝐶𝐶𝐶 − 11

Calculations should reflect ground level emissions. For aircraft applications, be sure to also
include the ODP of emissions of the substitute at cruising altitude.
(b) You should also include any other related data available to you, such as information on the
substitute's chlorine or bromine loading potential. See the 2018 WMO Scientific Assessment of
Ozone Depletion for additional information on calculating ODP and related information.
5.

Global Warming Characteristics – (a‐c) Provide information on the 100‐year global warming
potentials (GWPs) of the proposed substitute relative to CO 2 , as well as atmospheric lifetime
(ATL) of the proposed substitute. If the substitute is a blend, provide the GWPs of the individual
constituents and an estimate of the blend at its nominal composition.
Provide GWPs as listed in the 2007 Intergovernmental Panel for Climate Change Fourth
Assessment Report (IPCC AR4). Alternate sources may include the 2018 WMO Scientific
Assessment of Ozone Depletion or the peer‐reviewed literature. IPCC defines GWP of the
emissions of a greenhouse gas as the time integrated commitment to climate forcing from the
instantaneous release of 1 kg of a trace gas expresses relative to that from 1 kg of CO 2 .
𝐺𝐺𝐺𝐺𝐺𝐺 =

𝑛𝑛

∫0 𝑎𝑎𝑖𝑖 𝑐𝑐𝑖𝑖 𝑑𝑑𝑑𝑑

𝑛𝑛

∫0 𝑎𝑎𝐶𝐶𝐶𝐶2 𝑐𝑐𝐶𝐶𝐶𝐶2 𝑑𝑑𝑑𝑑

where:
a i = the instantaneous radiative forcing due to a unit increase in the concentration of trace gas,
i c i = the concentration of trace gas, i, remaining at time, t, after its release, and
n = the number of years over which the calculation is performed.
Corresponding values for CO 2 are in the denominator.
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For GWP values that do not come from IPCC AR4 or WMO 2018, you should also include the
data used to calculate these potentials such as atmospheric lifetime, infrared adsorption
spectrum, and infrared absorption capacity. Provide all supporting documentation.
(d) If the alternative is captured as a byproduct of another manufacturing or industrial process,
indicate the source of the alternative. This information is important in assessing the effects of
the new use of the substitute versus those effects occurring strictly because of the release of a
byproduct.
6.

VOC Status Information – (a‐d) Indicate whether the alternative is considered to be a volatile
organic compound (VOC) and is subject to regulation under Title I of the CAA (40 CFR 51.100(s))
or exempt as a VOC, due to low photochemical reactivity. If a petition for VOC exemption has
been submitted to EPA under Title I, please provide information on that submission and the
current status of that request, and provide the information on reactivity below in (d). For
compounds that are not VOC exempt, provide information on the reactivity of the compound in
the atmosphere, such as the maximum incremental reactivity (MIR) in grams of O 3 (ozone) per
gram of VOC and the kOH (298 K) value.

7.

Byproducts – (a‐e) Identify any byproducts that you reasonably anticipate will result from the
manufacture or processing of the alternative both at sites you control and in end‐use. Identify
these byproducts by specific name or class or range of structures (e.g., HF or other acid gases
formed during the production of halocarbon compounds via dehalogenation, HFC-143a and/or
HCFC-124 formed during the production of HFC-134a), CAS Registry number (where available),
when the byproduct is formed (e.g., during manufacture), and the estimated amount formed
(grams) relative to the amount of proposed substitute manufactured. If there are unidentified
byproducts enter “unidentified.”

8.

Degradation Products – (a‐e) Identify any degradation products that you reasonably
anticipate will result from the use or disposal of the alternative both at sites you control and
in end‐use. Identify these degradation products by specific name or class or range of
structures (e.g., HF or other acid gases formed from the combustion of halocarbon
compounds), CAS Registry number (where available), when the degradation product is formed
(e.g., during end‐use, in the event of a fire, following disposal), and the rate of formation
(grams/second). If there are unidentified degradation products enter “unidentified.”

Section B: End‐Use and Application Information
1.

Specific End‐use – (a‐c) Identify the specific end‐uses within the sector in which the
alternative is to be used. For an explanation of each end-use and application visit the SNAP
website: https://www.epa.gov/snap/snap-substitutes-sector. For refrigeration and air
conditioning, select the appropriate applications and indicate if the substitute is intended for
new equipment, retrofit equipment or both. Specify the ozone‐depleting substance (ODS) and
other substances being replaced and include an estimate of the quantity of alternative (lb)
needed to replace the ODS or other substance for each end‐ use. This is known as the
replacement ratio. For example, if 100 lb of a new refrigerant will replace 150 lb of CFC‐12, the
replacement ratio is 1:1.5.

2.

End‐Use Specific Standards – List any standard‐setting organizations that will evaluate the
proposed substitute or will set requirements or guidelines for the substitute rom a health and
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safety perspective in the proposed end‐use(s), such as the Underwriters Laboratories (UL), the
American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE), the Society
of Automotive Engineers (SAE), the National Fire Protection Association (NFPA), or the
International Organization for Standardization (ISO).
3.

Technology Changes and Cost – Describe any new equipment technology changes and
associated costs that will be necessary in order to use the proposed substitute.

4.

Production and Market Share – Provide estimated information on production of the proposed
substitute or equipment using the proposed substitute. Indicate when you anticipate the
substitute or new equipment using the substitute will enter the marketplace. Include the value
for total production anticipated during the first year of production in kg.
Also, provide information on the levels of market penetration that you expect for the substitute
or new use of an existing substitute. Include estimates for the number of years you anticipate
until the substitute reaches its maximum market penetration for those uses included in
submission, and the total production level that you anticipate for the substitute when it reaches
the point of market saturation. Finally, if possible, estimate the percentage of the market held
by the substance(s) being replaced that will be captured by this substitute.

5.

Energy Efficiency – (a‐b) For refrigeration, air conditioning and foam blowing, provide the
alternative’s impact on energy efficiency relative to the substance it is replacing for each end‐
use. Attach and describe the results of any energy efficiency testing or modeling performed.
Laboratory testing of equipment should evaluate the proposed substitute vs. the substance(s)
being replaced. Values should be given as a percent difference relative to the substance(s)
being replaced or a similar measure.

Section C: Flammability (Required for Refrigeration and Air Conditioning; Foam Blowing;
Cleaning Solvent; Aerosols; Sterilant; and Adhesives, Coatings, and Inks Sectors)
1.

Flammability‐Related Physical and Chemical Properties – Provide information on the
physical and chemical properties relevant to evaluating the flammability of the proposed
substitute.

2.

Flammability Assessments and Test Data – For flammable substitutes, please include as an
attachment the results of ASTM E681 Flammability Limits in Air. The numerical values for the
upper and lower flammability limits are requested in Part III. For flammable refrigerants, please
provide information on the maximum pressure of combustion, the maximum rate of pressure
increase during combustion, and the minimum ignition energy. If you have conducted any
analyses on flammability, please provide them.
For refrigeration and air conditioning, if an alternative is flammable (this applies to both blends
and pure materials), you must analyze the risk of fire resulting from the use of the substitute in
each proposed end‐use/application through a risk assessment. For refrigeration and air
conditioning, a Fault Tree Analysis (FTA) or Failure Mode and Effects Analysis (FMEA) is also
required. An FTA should include, but not be limited to, a description of typical scenarios in which
the substitute is used, potential leak scenarios, sources of ignition, and probabilities of ignition.
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It should also assess the likelihood of injury within each scenario. An FMEA should describe
identified failures that could result in a spark, flame, explosion, or other fire risk and mitigation
measure for each failure mode. Significant differences exist both in the design and in the
ambient conditions for various end‐uses. Thus, risk assessments are extremely sensitive to end‐
use. Low risk in one end‐use does not, in general, imply low risk in another end‐use.
3.

Flammability Concerns and Mitigation – If a substitute is flammable under the conditions
expected in the proposed end‐use/application, describe any abatement techniques being used
to minimize the risks associated with use of a flammable substance (e.g., equipment design
modifications or alternate labeling).
For flammable foam blowing agents used in spray foam, provide a training program that address
flammability concerns specific to the substitute.

Part IV: Sector‐Specific Information

Due to the unique uses and exposures of alternatives for each of the SNAP industrial sectors, Part IV
includes individual Sections for each sector. You are only required to complete those sections for which
you are submitting to SNAP. Below are instructions for questions found in Part IV. If you are submitting
the substitute for several end‐uses or applications, you must provide the requested information for
each.
•

Application of Proposed Substitute – Provide information requested in each sector‐specific
section on the specific application of the substitute. These questions are related to both
manufacturing and use.

•

Additional End‐Use Description – Provide a written description of the specific uses for which
you are submitting.

•

Refrigerant Oil – For refrigeration and air conditioning only, provide information on the
chemical class of refrigerant oil you anticipate will be used (e.g., polyalkylene glycol, polyolester,
mineral oil) and information on the refrigerant/oil solubility.

•

Compatibility – For cleaning solvents only, provide information on the compatibility of the
solvent with metals and plastics with regards to its use as a cleaning solvent (e.g., is the solvent
corrosive to some materials).

•

Consumer Use – Where requested, indicate whether the proposed substitute will be used for
consumer use. If consumer use is expected, please describe the anticipated consumer
applications.

Part V: Additional Information
Provide any additional information that may assist EPA’s review. Submitters are not required to include
information in this section.

Part VI: Attachments
Clearly identify all attachments being provided in support of the submission.
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Mark (X) in the CBI box next to any attachment that you claim as confidential. The public version of the
submission form must include the attachment name/citation at a minimum. All claims of confidentiality
must be substantiated in Part I.

Response Checker

The Response Checker identifies questions in the Notice form that are missing responses. Please review
the questions that are missing responses carefully to ensure that all required information is provided
before submitting the TSCA/SNAP Addendum form to EPA. Please note that this checker is not an
indicator of whether EPA will consider the submission complete, but rather, this checker is an indicator
of whether all questions have been answered.

Part VII: Certification
The individual identified in Part I of the form as the person submitting the Information Notice must sign
the certification in Part XIV of the form. This official is responsible for the truth and accuracy of each
statement in the certification. If an agent assists you in preparing the submission, the agent must also
sign the certification.
A printed copy of the certification page, with original signature, must be submitted with electronic or
paper submissions. If the submission is not signed, EPA will consider the submission incomplete and will
not review the substitute.

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