On or about July 12, 2006, Respondent submitted 109 studies to EPA concerning acute inhalation toxicity in rats. Respondent submitted additional studies over the next eleven months. In all, Respondent voluntarily provided 176 submissions to EPA. All studies were acute inhalation toxicity studies performed on rats exposed to the test substances in an aerosol or particulate form. Respondent designed 57 studies as 8E submissions and 119 studies as FYI submissions. EPA has determined that the 57 inhalation studies meet EPA's criteria for reporting under TSCA section 8(e). Respondent's failure to immediately submit each of the 57 studies to the Administrator as required under TSCA section 8(e) constitutes 57 failures to submit a report, notice, or other information as required by TSCA section 15(3)(B), 15 U.S.C. section 2614(3)(B).