Using the CDR Database
This page provides information on using the 2020 CDR Database. For information on using the 2016 CDR database, click here.
On this page:
- Data dictionary
- Factors to consider when using the database
- Reporting thresholds
- Reporting in ranges
- Processing and use information
- Confidential Business Information
EPA has generated a data dictionary to assist users in interpreting and using CDR data.
Factors to consider when using the database
In March 2020, EPA published the final CDR Revisions Rule to reduce burden for certain reporters, improve the quality of data collected, and align reporting requirements with the Lautenberg Act amendments to TSCA. The amendments added and modified certain data elements, updated requirements for making confidentiality claims to align with the requirements in amended TSCA, and added reporting exemptions for specific types of byproducts.
In May 2020, EPA finalized the Small Manufacturer Definition Update Rule. The final revisions update the TSCA 8(a) small manufacturer definition and include a new definition for small government. The rule is used to determine reporting and recordkeeping requirements under TSCA for CDR.
The 2020 CDR data publication includes chemicals which lost their confidential status on the TSCA Inventory because one or more manufacturers reported the chemical identities as non-confidential during the 2012, 2016, and/or 2020 CDR reporting periods.
CDR reporting is triggered by the amount of a chemical manufactured (including imported), rather than the hazard or potential exposures associated with a chemical. Understanding reporting thresholds of manufactured (including imported) chemicals that trigger reporting is important when using and interpreting the CDR data.
- 25,000 pounds or greater: Reporting for 2016 and future submission periods was triggered based on whether site-specific production volume met or exceeded 25,000 pounds during any calendar year since the last principal reporting year. For 2020, the last principal reporting year was 2015 and therefore the submitter considered annual production from 2016 to 2019.
- 2,500 pounds or greater: For chemicals subject to certain TSCA actions, the production volume reporting threshold was lower, and for those chemicals the submitter considered whether the annual production volume met or exceeded 2,500 pounds.
- For all reportable chemicals, manufacturers (including importers) were required to report the full manufacturing data for the principal reporting year (e.g., calendar year 2015 for 2016 CDR and calendar year 2019 for 2020 CDR) and production volume for each calendar year since the previous principal reporting year (e.g., 2012 to 2015 for 2016 CDR and 2016 to 2019 for 2020 CDR).
Due to these reporting thresholds, totals of CDR production volumes reported may underestimate the actual total amount manufactured and imported in the United States, particularly if there are a substantial number of sites that manufacture (including import) the chemical in quantities less than 25,000 pounds per year or are otherwise exempted from reporting (such as small manufacturers). When comparing changes in production over time at a site, particularly on regional or national levels, it is important to take into account changes in the reporting thresholds across the years.
Reporting in ranges
The following data elements are reported as ranges to reduce the industry reporting burden:
- Manufacturing Information:
- Number of workers reasonably likely to be exposed to the chemical
- Maximum concentration of the chemical
- Processing and use Information:
- Percent production volume for each product category
- Number of sites for each product category
- Number of workers for each product category
- Maximum concentration for consumer and commercial use
Processing and use information
Processing and use of chemicals is often not under the control of the manufacturers (including importers); therefore, they may have incomplete knowledge of these activities. Manufacturers (including importers) were required to report processing and use information that was known to or reasonably ascertainable by them. They were not required to collect information from their customers regarding end uses. In addition, CDR submitters were not required to report processing and use information for quantities that were exported. As a result of these factors, the processing and use information in the CDR public database presents only a limited picture of the actual processing and use situation in the United States.
Confidential Business Information
It is important for users of the CDR public data files to understand what data submitters were permitted to claim as confidential business information (CBI), and that the public data have been aggregated and masked to protect CBI. The 2020 CDR Revisions Rule changed which data elements could be claimed as CBI and the process for substantiating such claims.
In general, submitters could claim individual CDR data elements as CBI when they reported the information, if a submitter believed that publication would reveal trade secrets or confidential commercial or financial information. For most CBI claims, submitters were required to provide substantiations by answering a series of questions. A blank response or a response that was designated as “not known or reasonably ascertainable” could not be claimed as confidential.
Important highlights about CBI claims include:
- Chemical identity could only be claimed confidential if the chemical was listed on the confidential portion of the TSCA Inventory. Note that, subsequent to the 2020 submission period, EPA declassified a number of chemicals, moving them off of the confidential portion of the inventory. To the extent possible, EPA has included the declassified identity for those chemicals in the published 2020 data. Due to ongoing CBI reviews, EPA was not able to include the declassified identity for all of the reported chemicals.
- Submitters were able to claim as CBI the link between the submitter identity and the chemical substance.
- Production volume could be claimed as CBI and did not require a substantiation at the time the data were submitted.
- Other manufacturing-related information, such as the volume directly exported or the physical form, could be claimed as CBI.
- Some processing and use data elements could not be claimed as CBI (e.g., the type of processing or use, the industry sector, the product code, or the function of the chemical)
- Other processing and use data elements could be claimed as CBI (e.g., the number of industrial or commercial workers or the percent production volume)
In preparing the CDR public database, EPA takes care to avoid releasing CBI while also publishing as much information as possible. Users examining individual records will notice CBI-protected entries in some data fields.
If all of the production volumes for a chemical were not claimed as CBI, then the public CDR database would include specific values for individual and aggregated production volumes for that chemical. However, if some or all of the reported production volumes for a given chemical substance were claimed as CBI, then some or all of the individual CBI production volumes were not published and aggregated production volumes were published as a range.