COMMENTS: RESPONDENT MANUFACTURED AND DISTRIBUTED COMMERCE CHEMICAL SUBSTANCES AS THAT TERM IS DEFINED AT SECTION 3 OF TSCA,15 USC SECTION 2602, INVIOLATION OF REGULATION PURSUANT TO SECTION OF TSCA 15 USC, SECTION 2607(A),SECTION 3 2614. RESPONDENT FAILED TO MAINTAIN RECORDS WHICH IS INVIOLATION OF TSCA 4O CFR PART 710.