Data Limitations

CDR Data Limitations Summary

While CDR data are very useful to the EPA for assessing exposure to chemicals, informing chemical prioritization efforts, and other efforts, there are several limitations to the application and use of CDR data. In general, data presented in this CDR National Review should be considered with the following limitations in mind:

• A considerable portion of the CDR data is claimed by CDR reporters as confidential business information (CBI). Such data are not made available to the public but are included in this review to the extent possible while protecting any confidentiality claims.
• CDR data are reported every four years, and besides prior year PV values, all information is based on the principal reporting years (e.g., 2015 for the 2016 CDR reporting cycle, 2019 for the 2020 reporting cycle).
• Sites are only required to report for chemicals for which they exceed PV thresholds of 25,000 pounds or 2,500 pounds for chemicals that are subject to certain actions under TSCA.
• Certain chemical uses and entities may be exempt from reporting (e.g., small businesses/governments, certain byproducts, non-isolated intermediates, naturally occurring substances, polymers).
• A fair portion of CDR data are reported in ranges (e.g., workers likely exposed, maximum chemical concentration, industrial sites).
• Sites report information that is "Known to or Reasonable Ascertainable by," meaning all information in a person's possession or control, plus all information that a reasonable person similarly situated might be expected to possess, control, or know (40 CFR 704.3).
• Only manufacturers/importers report to CDR, not processors or users. Therefore, the processing and use information and consumer and commercial use information may be less precise than the reporting manufacturing (including import) information.
• There is not a definitive method of determining whether the processing or use(s) occur at the CDR reporting manufacture (including import) site or elsewhere downstream (though volumes reported as used on-site may be able to be linked to certain associated processing/use scenarios with equivalent percent production volumes).

Confidential Business Information

The table below lists numerous CDR reporting elements, the percentage of each claimed as CBI, and whether there was an increase or decrease in the percentages from the 2016 to the 2020 CDR reporting cycles. Note that the 2020 CDR Revisions rule changed reporting requirements, and reporters could no longer claim certain elements as CBI in the 2020 CDR and future reporting cycles.