7710-25 Notice of Commencement (NOC)

CBI SUBMISSION

OMB No. 2070-0038 Expires 12/31/2025

NOC2023P1

U.S. Environmental Protection Agency

EPA

Part I - SUBMITTER IDENTIFICATION
Manufacturer/
Importer
(in U.S.)

Report Number

NOTICE OF COMMENCEMENT OF
MANUFACTURE OR IMPORT (40CFR§720.102)
Document Control #:

Name of Authorized Official
(first)
(last)
Scott
Stevenson
Company Name

12601 FAIRLAKES CIRCLE
City

CGI FEDERAL

FAIRFAX

Technical
Contact
(first)
(in U.S.)
Scott

Mailing Address (number and street)

Name

State

VA

Zip

22033

Telephone Number

(last)

Stevenson

CBI*

X
X

5713180113

Part II - Premanufacture Notice (PMN) "P" Case Number:

P-23-0105

Part III - Check the appropriate box and provide the exact date of manufacture or importation:
First Commercial Manufacture**
Date:

X
Date:

First Commercial Importation***
01/05/2023

**Date of commencement is the date of completion of non-exempt manufacture of the first amount (bath, drum, etc.)
***For importees, the date of commencement is the date that the new chemical substance clears U.S. customs.

Part IV - Manufacturing Plant Site(s) or Importing Site(s): (Importers, provide street address of destination)
CGI FEDERAL DEMO
12601 FAIR LAKES CIR
FAIRFAX, VA 22033

X

Part V - Specific Chemical Identity: (For Consolidated submissions, each substance must have a separate NOC form with the specific
identity of each chemical substance.)

Chemical Name: Formaldehyde
CASRN: 50-00-0

X

Part VI - Generic Chemical Name (if chemical identity is claimed CBI*):
test chem

EPA Form 7710-25 (12-19)

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. 2070-0012). Responses to this collection of information are
mandatory for certain persons, as specified at 40 CFR 721 and 725. 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
between 16.97 to 525.85 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.

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Part VII - Substance Identity Confidentiality Status:

X

I wish to continue to claim the substance identity confidential and the substantiation to support this claim is attached. Failure to submit
the required substantiation in accordance with 40 CFR 720.85(b) will result in a waiver of your claim.
I previously claimed the substance identity as confidential and hereby relinquish that claim.
I did not claim the substance identity as confidential in my original PMN submission.

The public reporting and recordkeeping burden for this collection of information is estimated to average 0.8 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, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection
Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the
completed EPA Form 7710-56 to this address.
You must submit your completed notice no later than 30 calendar days after the first date of commercial manufacture/importation to the address
shown below:
U.S. Environmental Protection Agency
OPPT Document Control Office (7407M)
1200 Pennsylvania Ave., NW
Washington, D.C. 20460
ATTN: Notice of Commencement

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.
Signature of authorized official

ES/Scott Stevenson

Note: CBI* - refers to the term "Confidential Business Information". Mark (X) in the box if the information is to be held Confidential.

EPA Form 7710-25 (12-19)

Date

01/05/2023

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CBI Substantiation
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
1. 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: Yes
Cbi: Yes
test 2
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
2. 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: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
3. 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/No: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
4. Would disclosure of the specific chemical identity release confidential process information? If yes, please explain.
Yes/No: No
Cbi: No
test

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Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
1. 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: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
2. 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: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
3B. 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: No
Cbi: No
test

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Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
3C. 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: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
4. 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: No
Cbi: No
test
Selected Chemical Identifier:50-00-0
Selected Chemical Claim: Chemical
5. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
1. 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: Yes
Cbi: Yes
test 5
Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
2. 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

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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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
3B. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
3C. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
4. 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: No
Cbi: No
test

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Selected Chemical Identifier: N/A
Selected Chemical Claim: Optional Cover Letter
5. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information
1. 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: Yes
Cbi: Yes
test 3
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information
2. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information

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3B. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information
3C. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information
4. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Site Information
5. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
1. 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.

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Yes/No: Yes
Cbi: Yes
test 7
Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
2. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
3B. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
3C. 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: No
Cbi: No
test

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Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
4. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Submitting Official Information
5. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information
1. 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: Yes
Cbi: Yes
test 1
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information
2. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information

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3A. Is any of the information claimed as confidential required to be publicly disclosed under any other Federal law?
If yes, please explain.
Yes/No: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information
3B. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information
3C. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information
4. 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: No
Cbi: No
test
Selected Chemical Identifier: N/A
Selected Chemical Claim: Technical Contact Information
5. 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: No
Cbi: No
test

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