Form 9600-031 Section 12(b) Export Notification

Confidential Business Information Claims under the Toxic Substances Control Act (TSCA) (Final Rule)

2706.02 Form 9600-031

Rule Famiilarization

OMB: 2070-0223

Document [pdf]
Download: pdf | pdf
OMB Control Number 2070-0030 expires 6/30/2024

TSCA	Section	12(b)	Export	Notification
Submission	Alias:			12b-65-8892
Submitter	Information

	CBI	

First	Name

James

Last	Name

Goldsmith

Phone	Number

3364234784

Email	Address

james.goldsmith@cgifederal.com

Job	Title

Consultant

Organization
Name

CGI	FEDERAL

Address	Line	1

12601	FAIRLAKES	CIRCLE

Address	Line	2
City

State

Postal	Code

Country

FAIRFAX

Virginia

22033

United	States

Exporter	Information
Company	Name

CGI	FEDERAL

Address	Line	1

12601	FAIRLAKES	CIRCLE

Address	Line	2
City

State

Postal	Code

Country

FAIRFAX

Virginia

22033

United	States

Exported	Chemicals
Export	-	1
Chemical	Name Naphthalene,	1,2,3,4-tetrahydro(1-phenylethyl)CASRN

63674-30-6

TSCA	Section

Section	5

Form 9600-031

	CBI	

X

	CBI	

X

X

Paperwork Reduction Act: This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB
Control No. 2070-0030). Responses to this collection of information are mandatory for certain persons, as specified at 40 CFR 707 Subpart D. An
agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB
control number. The public reporting and recordkeeping burden for this collection of information is estimated to be 0.62 hours per response. Send
comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing
respondent burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW,
Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.

Category

Perfluoroalkyl	Sulfonates	(PFAS)

Import	Country

Australia

	CBI	

X

Export	Date

01/12/2023

	CBI	

X

CBI	Substantiation
Regular	File

	CBI	

General	Claim:	Submitter	Information
Applicable	Only	to	General	CBI	Claims
A	person	may	assert	a	claim	of	confidentiality	for	the	specific	chemical	identity	of	a
chemical	substance	as	described	in	§	711.15(b)(3)	of	this	part	only	if	the	identity	of	that
chemical	substance	is	treated	as	confidential	in	the	Master	Inventory	File	as	of	the	time	the
report	is	submitted	for	that	chemical	substance.	Generic	chemical	identities	and	accession
numbers	may	not	be	claimed	as	confidential.	To	assert	a	claim	of	confidentiality	for	the
identity	of	a	reportable	chemical	substance,	you	must	submit	with	the	report	detailed	written
answers	to	the	questions	from	subsection	(b)	and	to	the	following	questions.
Question
G1)	Please	specifically	explain	what	harm	to	the
competitive	position	of	your	business	would	be	likely	to
result	from	the	release	of	the	information	claimed	as
confidential.	How	would	that	harm	be	substantial?	Why	is
the	substantial	harm	to	your	competitive	position	likely
(i.e.,	probable)	to	be	caused	by	release	of	the	information
rather	than	just	possible?	If	you	claimed	multiple	types	of
information	to	be	confidential	(e.g.	site	information,
exposure	information,	environmental	release	information,
etc.),	explain	how	disclosure	of	each	type	of	information
would	be	likely	to	cause	substantial	harm	to	the
competitive	position	of	your	business.

Yes

No

X

CBI

X

Comment:	Test

Question
G2)	Has	your	business	taken	precautions	to	protect	the
confidentiality	of	the	disclosed	information?	If	yes,	please
explain	and	identify	the	specific	measures,	including	but

Yes

No

CBI

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.

X

X

Comment:	Test

Question
G3A)	Is	any	of	the	information	claimed	as	confidential
required	to	be	publicly	disclosed	under	any	other	Federal
law?	If	yes,	please	explain.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G3B)	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.

Yes

X

Comment:	Test

Question
G3C)	Has	a	patent	been	published	for	the	chemical	identity
you	claim	confidential?	What	chemical	identity	information
is	not	revealed	by	the	patent?	How	is	release	of	that
specific	information	likely	to	cause	substantial	competitive
harm?	And	failure	to	explain	this	harm	may	lead	to	denial
of	your	confidentiality	claim.

Yes

X

Comment:	Test

Question
G4)	Is	the	claim	of	confidentiality	intended	to	last	less	than
10	years	(see	TSCA	section	14(e)(1)(B))?	If	yes,	please

Yes

X

indicate	the	number	of	years	(between	1-10	years)	or	the
specific	date	after	which	the	claim	is	withdrawn.
Comment:	Test

Question
G5)	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.

Yes

No

CBI

X

Comment:	Test

General	Claim:	Company	Name
Applicable	Only	to	General	CBI	Claims
A	person	may	assert	a	claim	of	confidentiality	for	the	specific	chemical	identity	of	a
chemical	substance	as	described	in	§	711.15(b)(3)	of	this	part	only	if	the	identity	of	that
chemical	substance	is	treated	as	confidential	in	the	Master	Inventory	File	as	of	the	time	the
report	is	submitted	for	that	chemical	substance.	Generic	chemical	identities	and	accession
numbers	may	not	be	claimed	as	confidential.	To	assert	a	claim	of	confidentiality	for	the
identity	of	a	reportable	chemical	substance,	you	must	submit	with	the	report	detailed	written
answers	to	the	questions	from	subsection	(b)	and	to	the	following	questions.
Question
G1)	Please	specifically	explain	what	harm	to	the
competitive	position	of	your	business	would	be	likely	to
result	from	the	release	of	the	information	claimed	as
confidential.	How	would	that	harm	be	substantial?	Why	is
the	substantial	harm	to	your	competitive	position	likely
(i.e.,	probable)	to	be	caused	by	release	of	the	information
rather	than	just	possible?	If	you	claimed	multiple	types	of
information	to	be	confidential	(e.g.	site	information,
exposure	information,	environmental	release	information,
etc.),	explain	how	disclosure	of	each	type	of	information
would	be	likely	to	cause	substantial	harm	to	the
competitive	position	of	your	business.
Comment:	Test

Yes

X

No

CBI

Question
G2)	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.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G3A)	Is	any	of	the	information	claimed	as	confidential
required	to	be	publicly	disclosed	under	any	other	Federal
law?	If	yes,	please	explain.

Yes
X

Comment:	Test

Question
G3B)	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.

Yes

X

Comment:	Test

Question
G3C)	Has	a	patent	been	published	for	the	chemical	identity
you	claim	confidential?	What	chemical	identity	information
is	not	revealed	by	the	patent?	How	is	release	of	that
specific	information	likely	to	cause	substantial	competitive
harm?	And	failure	to	explain	this	harm	may	lead	to	denial
of	your	confidentiality	claim.
Comment:	Test

Yes

X

Question
G4)	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.

Yes

No

CBI

No

CBI

X

Comment:	Test

Question
G5)	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.

Yes

X

Comment:	Test

General	Claim:	Entire	Address
Applicable	Only	to	General	CBI	Claims
A	person	may	assert	a	claim	of	confidentiality	for	the	specific	chemical	identity	of	a
chemical	substance	as	described	in	§	711.15(b)(3)	of	this	part	only	if	the	identity	of	that
chemical	substance	is	treated	as	confidential	in	the	Master	Inventory	File	as	of	the	time	the
report	is	submitted	for	that	chemical	substance.	Generic	chemical	identities	and	accession
numbers	may	not	be	claimed	as	confidential.	To	assert	a	claim	of	confidentiality	for	the
identity	of	a	reportable	chemical	substance,	you	must	submit	with	the	report	detailed	written
answers	to	the	questions	from	subsection	(b)	and	to	the	following	questions.
Question
G1)	Please	specifically	explain	what	harm	to	the
competitive	position	of	your	business	would	be	likely	to
result	from	the	release	of	the	information	claimed	as
confidential.	How	would	that	harm	be	substantial?	Why	is
the	substantial	harm	to	your	competitive	position	likely
(i.e.,	probable)	to	be	caused	by	release	of	the	information
rather	than	just	possible?	If	you	claimed	multiple	types	of
information	to	be	confidential	(e.g.	site	information,
exposure	information,	environmental	release	information,

Yes

X

No

CBI

etc.),	explain	how	disclosure	of	each	type	of	information
would	be	likely	to	cause	substantial	harm	to	the
competitive	position	of	your	business.
Comment:	Test

Question
G2)	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.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G3A)	Is	any	of	the	information	claimed	as	confidential
required	to	be	publicly	disclosed	under	any	other	Federal
law?	If	yes,	please	explain.

Yes
X

Comment:	Test

Question
G3B)	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.

Yes

X

Comment:	Test

Question
G3C)	Has	a	patent	been	published	for	the	chemical	identity
you	claim	confidential?	What	chemical	identity	information
is	not	revealed	by	the	patent?	How	is	release	of	that

Yes

X

specific	information	likely	to	cause	substantial	competitive
harm?	And	failure	to	explain	this	harm	may	lead	to	denial
of	your	confidentiality	claim.
Comment:	Test

Question
G4)	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.

Yes

No

CBI

No

CBI

X

Comment:	Test

Question
G5)	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.

Yes

X

Comment:	Test

Chemical	Claim:	Import	Country	-	Australia
Applicable	Only	to	Chemical	Identity	CBI	Claims
A	person	may	assert	a	claim	of	confidentiality	for	the	specific	chemical	identity	of	a
chemical	substance	as	described	in	§	711.15(b)(3)	of	this	part	only	if	the	identity	of	that
chemical	substance	is	treated	as	confidential	in	the	Master	Inventory	File	as	of	the	time	the
report	is	submitted	for	that	chemical	substance.	Generic	chemical	identities	and	accession
numbers	may	not	be	claimed	as	confidential.	To	assert	a	claim	of	confidentiality	for	the
identity	of	a	reportable	chemical	substance,	you	must	submit	with	the	report	detailed	written
answers	to	the	questions	from	subsection	(b)	and	to	the	following	questions.
Question
C1)	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

Yes

No

CBI

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	and	have
no	knowledge	of	public	information	that	would	indicate
that	the	chemical	is	being	manufactured	or	imported	by
anyone	for	a	commercial	purpose	in	the	United	States.
[provide	date].

X

Comment:	Test

Question
C2)	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.

Yes

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
C3)	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.

Yes

X

Comment:	Test

Question
C4)	Would	disclosure	of	the	specific	chemical	identity
release	confidential	process	information?	If	yes,	please
explain.
Comment:	Test

Yes
X

Question
G1)	Please	specifically	explain	what	harm	to	the
competitive	position	of	your	business	would	be	likely	to
result	from	the	release	of	the	information	claimed	as
confidential.	How	would	that	harm	be	substantial?	Why	is
the	substantial	harm	to	your	competitive	position	likely
(i.e.,	probable)	to	be	caused	by	release	of	the	information
rather	than	just	possible?	If	you	claimed	multiple	types	of
information	to	be	confidential	(e.g.	site	information,
exposure	information,	environmental	release	information,
etc.),	explain	how	disclosure	of	each	type	of	information
would	be	likely	to	cause	substantial	harm	to	the
competitive	position	of	your	business.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G2)	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.

Yes

X

Comment:	Test

Question
G3A)	Is	any	of	the	information	claimed	as	confidential
required	to	be	publicly	disclosed	under	any	other	Federal
law?	If	yes,	please	explain.

Yes
X

Comment:	Test

Question
G3B)	Does	any	of	the	information	claimed	as	confidential
otherwise	appear	in	any	public	documents,	including	(but
not	limited	to)	safety	data	sheets;	advertising	or

Yes

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.

X

Comment:	Test

Question
G3C)	Has	a	patent	been	published	for	the	chemical	identity
you	claim	confidential?	What	chemical	identity	information
is	not	revealed	by	the	patent?	How	is	release	of	that
specific	information	likely	to	cause	substantial	competitive
harm?	And	failure	to	explain	this	harm	may	lead	to	denial
of	your	confidentiality	claim.

Yes

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G4)	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.

Yes

X

Comment:	Test

Question
G5)	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.

Yes

X

Comment:	Test

Chemical	Claim:	Export	Date	-	Thu	Jan	12	00:00:00	EST	2023
Applicable	Only	to	Chemical	Identity	CBI	Claims
A	person	may	assert	a	claim	of	confidentiality	for	the	specific	chemical	identity	of	a
chemical	substance	as	described	in	§	711.15(b)(3)	of	this	part	only	if	the	identity	of	that

chemical	substance	is	treated	as	confidential	in	the	Master	Inventory	File	as	of	the	time	the
report	is	submitted	for	that	chemical	substance.	Generic	chemical	identities	and	accession
numbers	may	not	be	claimed	as	confidential.	To	assert	a	claim	of	confidentiality	for	the
identity	of	a	reportable	chemical	substance,	you	must	submit	with	the	report	detailed	written
answers	to	the	questions	from	subsection	(b)	and	to	the	following	questions.
Question
C1)	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	and	have
no	knowledge	of	public	information	that	would	indicate
that	the	chemical	is	being	manufactured	or	imported	by
anyone	for	a	commercial	purpose	in	the	United	States.
[provide	date].

Yes

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
C2)	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.

Yes

X

Comment:	Test

Question
C3)	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

Yes

X

limitations	associated	with	such	technologies?	Please
explain	why	or	why	not.
Comment:	Test

Question
C4)	Would	disclosure	of	the	specific	chemical	identity
release	confidential	process	information?	If	yes,	please
explain.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G1)	Please	specifically	explain	what	harm	to	the
competitive	position	of	your	business	would	be	likely	to
result	from	the	release	of	the	information	claimed	as
confidential.	How	would	that	harm	be	substantial?	Why	is
the	substantial	harm	to	your	competitive	position	likely
(i.e.,	probable)	to	be	caused	by	release	of	the	information
rather	than	just	possible?	If	you	claimed	multiple	types	of
information	to	be	confidential	(e.g.	site	information,
exposure	information,	environmental	release	information,
etc.),	explain	how	disclosure	of	each	type	of	information
would	be	likely	to	cause	substantial	harm	to	the
competitive	position	of	your	business.

Yes

X

Comment:	Test

Question
G2)	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.

Yes

X

Comment:	Test

Question

Yes

G3A)	Is	any	of	the	information	claimed	as	confidential
required	to	be	publicly	disclosed	under	any	other	Federal
law?	If	yes,	please	explain.

X

Comment:	Test

Question
G3B)	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.

Yes

No

CBI

No

CBI

No

CBI

No

CBI

X

Comment:	Test

Question
G3C)	Has	a	patent	been	published	for	the	chemical	identity
you	claim	confidential?	What	chemical	identity	information
is	not	revealed	by	the	patent?	How	is	release	of	that
specific	information	likely	to	cause	substantial	competitive
harm?	And	failure	to	explain	this	harm	may	lead	to	denial
of	your	confidentiality	claim.

Yes

X

Comment:	Test

Question
G4)	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.

Yes

X

Comment:	Test

Question
G5)	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

Yes

X

entitled	to	confidential	treatment,	the	entity	that	made	the
decision,	and	the	date	of	the	determination.
Comment:	Test

TSCA	CBI	Certification
I	hereby	certify	to	the	best	of	my	knowledge	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	with	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.	 taken	reasonable	measures	to	protect	the	confidentiality	of	the	information;
ii.	 determined	that	the	information	is	not	required	to	be	disclosed	or	otherwise	made	available	to	the
public	under	any	other	Federal	law;
iii.	 a	reasonable	basis	to	conclude	that	disclosure	of	the	information	is	likely	to	cause	substantial	harm
to	the	competitive	position	of	the	person;	and
iv.	 a	reasonable	basis	to	believe	that	the	information	is	not	readily	discoverable	through	reverse
engineering.
Any	knowing	and	willful	misrepresentation	is	subject	to	criminal	penalty	pursuant	to	18	U.S.C.	§	1001.

Cross-Media	Electronic	Reporting	Regulation	(CROMERR)	Certification
I	certify,	under	penalty	of	law,	that	this	document	and	all	attachments	were	prepared	under	my	direction
of	supervision	in	accordance	with	a	system	designed	to	assure	that	qualified	personnel	properly	gather
and	evaluate	the	information	submitted.	Based	on	my	inquiry	of	the	person	or	persons	who	manage	the
system,	or	those	persons	directly	responsible	for	gathering	the	information,	the	information	submitted	is,
to	the	best	of	my	knowledge	and	belief,	true,	accurate,	and	complete.	I	am	aware	that	there	are
significant	penalties	for	submitting	false	information,	including	the	possibility	of	fines	and	imprisonment
for	knowing	violations.


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