On or about June 29, 2023, Shepherd voluntarily informed the Agency that it had manufactured a chemical between 2020 and 2023 on at least 2 occasions (with the relevant dates and quantities claimed as TSCA CBI) prior to submitting a Pre-manufacture Notice (PMN), in violation of Section 5(a)(1) of TSCA, 15 U.S.C. 2604(a)(1).