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TS-Number Duplication, Revised Instructions Available
Some PMN submitters have not complied with PMN Manual Instructions for creating TS-numbers, which call for creation of an alphanumeric identifier. These submitters have been submitting numeral-only TS-numbers.
If all-numeral identifiers are used, duplication is far more likely than with an alphanumeric, and we have recently received submissions with identical TS-numbers. Obviously, duplicate TS-numbers greatly increase the chance that there can be document mishandling. Similarly, numerical series and company-identifiable abbreviations in TS-numbers can lessen the protection the TS-number is designed to provide. The New Chemicals Program has revised the TS-number instructions: if the revised instructions are followed it is extremely unlikely that TS-numbers will be duplicated.
Industry submitters are encouraged to carefully review the Premanufacture Notice Manual [PDF], paying careful attention to the instructions regarding the creation of TS-numbers found at page 21. The Agency intends to review the TS-numbers submitted in the year after issuance of these new instructions to determine whether there continue to be similarity problems. For further information contact David Schutz, of the EPA New Chemicals Program at (202) 564-9262.
The revised TS-number instructions from the PMN Manual [PDF] are reprinted below:
TS-number: The submitter chooses this number. It is used by the bank which receives money for EPA when it notifies the Agency that the fee has been received, and also to enable us to assemble the parts of a submission when additional communications (letters of support, joint submissions, corrections) are sent before a PMN/LVE number has been assigned.
There are six spaces in the TS-number block on the PMN form. We have actually had duplication of TS-numbers, and these instructions have been revised to add some new requirements to make duplication less likely in future: your TS-number should be a 6-character alphanumeric. It should include 2, 3, or 4 letters. One or more numerals must be interposed between two letters (that is, LLNNLL, LNNNLL, NNLLNL, NLNLNL are okay, LLLNNN, NNNNLL are not). We recommend against company names, recognizable words and numerical series (ROY01X, X01DOW are not good ideas). The TS-number should be unique to this submission from your company. Do not give this number to a subsequent submission. If we get a TS-number with a submission and it does not comport with this guidance, we will call the submitter and ask for a new number which does.