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B. MIXTURES AND COMPOUNDS <br />General guidelines: Report only the weight of listed hazardous substances and characteristic <br />substances (see Appendix D) contained in mixtures and compounds used in manufacturing. Do <br />not report the weight of the entire mixture or compound unless reporting the entire weight is <br />easier. <br />If a mixture or compound contains a characteristic substance, but the mixture or compound itself <br />is not characteristic and does not become characteristic during its life cycle in Eugene, then the <br />characteristic substance contained in the mixture or compound is not reportable. <br />In other cases, it is necessary to calculate the percentages of reportable substances contained in <br />mixtures and compounds and report these amounts by weight. <br />18. QUESTION: Particleboard and certain plywood products are manufactured with <br />formaldehyde -based adhesives. Most manufacturers of these products provide SDSs <br />stating the board contains formaldehyde, a listed EHS chemical, but they do not list <br />percentages. Does this exempt these products from being reportable by secondary <br />manufacturers (cabinet shops)? <br />ANSWER: In this case, one cannot know the amounts of formaldehyde. Most of the <br />formaldehyde reacts with the phenolic, hydroxyl or amine components of the adhesives <br />and thus is no longer formaldehyde, but there is no way to know how much of the <br />formaldehyde reacts and how much is residual or emitted to the air without very <br />sophisticated measurements, and thus any reported amounts would be meaningless. <br />19. QUESTION: The SDS for an ink lists three ingredients, but no percentages. One of the <br />ingredients is a reportable substance. What should we report? <br />ANSWER: While businesses are not required to do extra research, an inquiry to the <br />supplier would not be especially burdensome. Otherwise, it would be necessary to <br />estimate the percentage of the reportable substance in the ink, using best engineering <br />judgment, and report the substance accordingly. <br />20. QUESTION: In our business we spray a compound that contains hazardous substances <br />onto our products. We have three types of outputs for the substances in this compound: <br />shipped as product, shipped as waste (residue cleaned from equipment), and emitted to <br />air. What is the best way to estimate percentages for each output type? <br />ANSWER: If you know that a portion of a listed hazardous substance (HS) remains with <br />the product as shipped, provide your best estimate of the percentage of the HS in the <br />product and multiply that by the estimated total pounds of product. Estimate the pounds <br />of waste that were generated and the percentage of the listed HS in the total waste. <br />-59- <br />