1998 EPCRA 313 Q&A, Question # 390

390. We use a toxic chemical with a CAS number not on the list of Section 313 toxic chemicals. There are similar toxic chemicals on the list, but none with the same CAS number. How can I be sure I do not have to report?
Although CAS numbers are useful, a covered facility should also use the toxic chemical name to determine if a toxic chemical is listed on the EPCRA Section 313 list. Be aware, however, that mixtures are often assigned CAS numbers. These mixtures may contain individually listed toxic chemicals. The facility should use all available information, including the toxic chemical name as well as process and chemical knowledge, to determine if a component of the mixture is a listed toxic chemical under Section 313. CAS numbers may be of limited use in this case. Also, certain specific compounds (e.g., copper chloride) are not listed individually on the EPCRA Section 313 list with a specific CAS number, but are reportable under a compound category.

Additional Details

Question # 390 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-390 Status Archived
Category 3. Determining Whether or Not to Report: Listed Toxic Chemicals Subcategory 3.A. General Questions
Keyword(s) CAS Number, Chemical Name, Mixture (Mixtures)
Updated Q&A Question Number 14
Prior Q&A [Archived] Question Number 270, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 270, 1997 EPCRA 313 Q&A: CAS Number; Chemical Name; Mixture. Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.