General Communications (GENCOMMS)

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

2706.02 GENCOMMS_Submission

OMB: 2070-0223

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NON-CBI	SUBMISSION

Submission	Date:	12/19/2022

General	Communication	Submission
Submitting	Official	Information
Name	of	Authorized	Official

William	K	Brigman

CBI:

Company	Name

NEW	TEST	ORG	111

Position

Email	Address

william.brigman@cgifederal.com

Phone	Number

8289191634

Mailing	Address	1

12601	FAIR	LAKES	CIRCLE

Mailing	Address	2

Apt	200

City

FAIRFAX

State

VA

Postal	Code

22033

Country

US

X

Part	I.	COMMUNICATION	INFORMATION
Communication	Number

Office

OCSPP/OPPT

Case	Number

Not	Assigned

Communication	Type

ChemicalINV-Section8bINV

Facility	Program	ID

PMN	Number

6585564

Chemical	Name

test	chem	name

Generic	Name

test	generic	name

CSRN
Accession	Number

401203

Unique	Identifier

Chemical	Name	Check

true

Unique	Identifier	Check

CSRN	Check

Generic	Name	Check

Accession	Number	Check
Message

CBI	:

Message

test	message

Y

Part	II.	Attachments
File	Name

CBI

Attachment	for	Testing_1.docx

Y

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.

Message
Applicable	Only	to	General	CBI	Claims

Yes

No

CBI

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

Page	1

NON-CBI	SUBMISSION
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.
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.	
			test

X

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.	
			test

X

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

X

3.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.	
			test

X

3.C.		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.	
			test

X

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.	
			test

X

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.	
			test

X

Document	Name
Applicable	Only	to	General	CBI	Claims

Yes

No

CBI

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.
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.	
			test

X

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.	
			test

X

X

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NON-CBI	SUBMISSION
3.A.		Is	any	of	the	information	claimed	as	confidential	required	to	be	publicly	disclosed	under	any	other	Federal	law?	If
yes,	please	explain.	
			test

X

3.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.	
			test

X

3.C.		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.	
			test

X

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.	
			test

X

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.	
			test

X

X

X

X

Submitting	Official
Applicable	Only	to	General	CBI	Claims

Yes

No

CBI

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.
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.	
			test

X

X

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.	
			test

X

X

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

X

3.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.	
			test

X

3.C.		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.	
			test

X

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.	
			test

X

X

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,

X

X

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NON-CBI	SUBMISSION
whether	the	information	was	found	to	be	entitled	to	confidential	treatment,	the	entity	that	made	the	decision,	and	the
date	of	the	determination.	
			test

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