U.S . ENVIRONMENTAL PROTECTION AGENCY 

&FPA 

in the Premanufacture Notice 

PREMANUFACTURE 

NOTICE 

p. 1 

Form Approved. O.M.B . No. 2070-0012 . Approval Expires 10-31-96 . 

Date of receipt 

> 

AGENCY USE ONLY 

Company Sanitizec 

GENERAL INSTRUCTIONS TS 44 Ju IT S 8 S 

. 

You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do 

not have actual data. 

Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or taxing 202-554-5603). 

If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226), P.O. 

360399M, Pittsburgh, PA 15251-6399, Arm. TSCA User fee. 

Part I -GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 

chemical substance, even if you claim the identity as confidential. You may authorize 

another person to submit chemical identity information for you, but your submission will 

not be complete and the review will not begin until EPA receives this information. A 

letter in support of your submission should reference your TS user fee identification 

number . You must submit an original and two copies of this notice including a11 test data . 

If you claimed any information as confidential, a single sanitized copy must also be 

submitted . 

Part li-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part ll, 

sections A and B of this notice, reproduce the sections as needed . 

Part I(I-LIST OF ATTACHMENTS 

Attach additional sheets if there is not enough space to answer a question fully . Label 

each continuation sheet with the corresponding section heading . In Part 111, list these 

attachments, any test data or other data and any optional information included in the 

notice . 

TEST DATA AND OTHER DATA 

You are required to submit all test data in your possession or control and to provide 

a description of all other data known to or reasonably ascertainable by you, if these 

data are related to the health and environmental effects on the manufacture, 

processing, distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

scientific literature. Complete test data (written in English), not summaries of data, 

must be submitted if they do not appear in the open literature . You should clearly 

identify whether test data is on the substance or on an analog . Also, the chemical 

composition of the tested material should be characterized. Following are 

examples of test data and other data . Data should be submitted according to the 

requirements of §720 .50 of the Premanufacture Notification Rule (40 CFR Part 

720). 

Test Data (Check Below any included in this notice) 

Environmental fate data 0 Yes " Other data ® Yes 

Health effects data ® Yes Risk assessments 

" Environmental effects data D Yes Structure/activity relationships, _ 

OPTIONAL INFORMATION 

You may include any information that you want EPA to consider in evaluating the new 

substance. On page I 1 of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new 

substance. 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingness to be bound to certain statements you make in this section, such as use, 

production volume, protective equipment . . . This option is intended to reduce delays 

that routinely accompany the development of consent orders or Significant New Use 

Rules . Except in the case ofexemption applications (such as TMEA, LVE, LOREX) 

where certain information provided in such notification is binding on the submitter when 

the Agency approves the exemption application, checking a binding box in this notice 

does not by itself prohibit the submitter from later deviating from the information (except 

chemical identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential . To assert a claim on the 

form, mark (X) the confidential box next to the information that you claim as 

confidential. To assert a claim in an attachment, circle or bracket the information you 

claim as confidential. If you claim information in the notices as confidential, you must 

also provide a sanitized version of the notice . (including attachments) . For additional 

instructions on claiming information as confidential, read the Instructions Manual. 

® Mark (x) if any information in this notice is claimed as confidential. 

1v17710-25 (Rev . 5-95) 

Physical/Chemical Properties* ® Yes Test data not in the possession 

or control of the submitter 

* A physical and chemical properties worksheet is located on the last page of this form. 

TYPE OF NOTICE (Check Only One) 

® 

0 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

LV E (Low Volume Exemption) (N, 40 CFR 723.50(c)(1) 

LOREX (Low Release/Low Exposure Exemption) (ail 40 CFR 723 .50(c)(2) 

LVE Modification 

IS THIS A CONSOLIDATED PMN? 

0 LOREX Modification 

Yes 

# of chemicals 

(Prenotice Communication # required, enter # on page 3) 

Replaces previous editions of EPA Form 7710-25. ~i~i73 
p. 2 

Public reporting burden for this collection of information is estimated to average 1 10 hours per response, including time for reviewing 

instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of 

information . Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for 

reducing this burden, to Chief, Information Policy Branch, PM-223, U.S . Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 

20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C . 20503. 

CERTIFICATION 

I certify that to the best of my knowledge and belief: 

1 . The company named in Part 1, section A, subsection 1 a of this notice form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part 1, 

Section B. 

2. All information provided in this notice is complete and truthful as of the date of submission. 

3. I am submitting with this notice all test data in my possession or control and a description of all other data known to or 

reasonably ascertainable by me as required by §720 .50 of the Premanufacture Notification Rule. 

Additional Certification Statements: 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 

statement that applies: 

The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 

® The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 

700.43) in accordance with 40 CFR 700.45(b), or 

0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 

in accordance with 40 CFR 700.45(b) . 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements : 

~ The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 

purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723.50. 

0 The manufacturer is familiar with the terms of this section and will comply with those terms; and 

F~ The new chemical substance for which the notice is submitted meets all applicable exemption conditions . 

0 If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day 

review period . 

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An knowing and willful misinter p retation is sub'ect to criminal penalty p ursuant to 18 USC 1001 . Confidential Signature and title of Authorized Official (Original Signature Required) Date 

X 

Signature of agent -(if applicable) Date 

EPA FORM 7710-25 (Rev . 5-95) Page 2 
p. 3 

Part I -- GENERAL INFORMATION 

Section A -- SUBMITTER IDENTIFICATION 

I a . Person Name of authorized official Position 

Submitting 

Notice (in U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

b. Agent (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

c. If you are submitting this notice as part of a joint submission, mark (X) this box . - 

Joint Submitter (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

2. Technical Name of authorized official Position 

Contact (in 

U.5 .) X 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

3 . If you have had a prenotice communication (PC) concerning this notice 

and EPA assigned a PC Number to the notice, enter the number. Mark (X) 10 X if none 

4 . If you previously submitted an exemption application for the chemical 

substance covered by this notice, enter the exemption number assigned by Mark (X) 10 EPA . If you previously submitted a PMN for this substance enter the if none PMN number assigned by EPA (i.e . withdrawn or incomplete) . 10 

5 . If you have submitted a notice of Bona fide intent to manufacture or import 

for the chemical substance covered by this notice, enter the notice number 

i Mark (X) 10 ass gned by EPA. ---No. if none 

I . ~ Manufacture 2. F-1 Import 6. Type of Notice - Mark (X) Only Only 3. ® Both 

Binding Option El Binding Option 

Mark (X) Mark (X) 

Mark () the "Confidential" box next to an subsection you claim as confidential 

Confidential 

EPA FORM 7710-25 (Rev . 5-95) Page 3 
p. 4 

Part I -- GENERAL INFORMATION -- Continued 

Section B - CHEMICAL IDENTITY INFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on 

the ninth Collective Index (9C1) of CA nomenclature rules and conventions. 

Mark (X) the "Confidential" box next to an item you claim as confidential 

Complete either item I (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. 

If another person will submit chemical identity information for you (for either Item l or 2), mark (X) the box at the right . ConfiIdentify the name, company, and address of that person in a continuation sheet . El dential 

1 . Class 1 or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

a. Class of substance - Mark (X) I Ej Class I or 2 [:] Class 2 

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. 

For Class I substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA Preferred Name must 

be provided, which ever is appropriate based on CA 9Cl nomenclature rules and conventions). 

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice : (check one) . 

® Method I (CAS Inventory Expert Service - a copy of the Identification El Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

X 

CAS# 

X 

e. For a class 1 substance, provide a complete and correct chemical structure diagram. For a class 2 substance - (1) List the immediate 

precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the 

range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure 

diagram- as comnlete as can he known. if one can be reasonablv ascertained. 

See Pages 4A and 4B 

® Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page 4 
Synthesis of PMN Substance 
Inventory Expert Service 

A division of the American Chemical Society Phone: 800-631-1884,614-"7-3870 

Fax: 614-447-3747 

E-mail : answers@cas.org 

Web: www.cas .org/products/client/ 

INVENTORY EXPERT SERVICE REPORT 

r 

Please print the above CA Index Name on the appropriate page of your PhIIO . 

If this box is checked, CAS has made correction(s) marked in red to 

your IES order . Please make the same correction(s) to your PPIIA before 

submitting it to the EPA . 

Page 413 

n', " :51ilr~Ir ~r~ v, R  11 ,i " f . P( - R~, . 1 143 " 1 ,i,- hw ~ . , 4 1' W i ~i4 " 1 i, a 
p. 7 

Part I -- GENERAL INFORMATION -- Continued 

Section B - CHEMICAL IDENTITY INFORMATION -- Continued 

2. Polymers (For a definition of polymer, see the Instructions Manual.) Confidential 

a . Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture . 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and below 1,000 absolute molecular weight of that composition . 

Describe the methods of measurement or the basis for your estimates: GPC EI Other 0: (Specify) 

i) lowest number average molecular weight : 

ii) maximum weight % below 500 molecular weight : 

iii) maximum weight % below 1000 molecular weight : 

Mark (X) this box if you attach a continuation sheet. 

b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the 

"Confidential " box next to any item you claim as confidential 

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of the polymer. 

(2) - Mark (X) this column if entry in column (1) is confidential . 

(3) - Indicate the typical weight percent of each monomer or other reactant in the polymer . 

(4) - Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer description on the TSCA Chemical Substance Inventory . 

(5) - Mark (X) this column if entries in columns (3) and (4) are confidential . 

(6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. 

(7) - Mark (X) this column if entry in column (6) is confidential . 

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential 

(1) (2) (3) (4) (5) (6) (7 

% % 

% % 

Mark (X) this box if you attach a continuation sheet. 

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one) . 

Method 1 (CAS Inventory Expert Service - a copy of the identification report ~ Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this notice) 

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers . 

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. 

~ Mark (X) this box if you attach a continutation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 5 
p. 8 

Part I -- GENERAL INFORMATION -- Continued 

Section B - CHEMICAL IDENTITY INFORMATION -- Continued 

3 . Impurities 

(a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose 

CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." 

(b) - Estimate the maximum weight % of each im purit y. If there are unidentified impurities, estimate their total weight %. 

. Provide the 

Impurity and CAS Registry Number 

(a) 

Maximum 

percent 

(b) 

Confidential 

% 

% X 

% X 

% 

% 

% 

% 

Mark (X) this box if you attach a continuation sheet. 

4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2. Confidential 

a Mark (X) this box if you attach a continuation sheet. 

X 

5. Trade identification - List trade names for the new chemical substance identified in subsection l or 2. 

Mark (X) this box if you attach a continuation sheet. 

X 

6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals 

the specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

Mercaptosilane ester 

Mark (X) this box if you attach a continuation sheet. 

7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry Number if available. 

Byproduct 

(1) 

CAS Registry Number 

(2) 

Confidential 

X 

X 

X 

I O Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 6 
p. 9 

Part I -- GENERAL INFORMATION -- Continued 

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: 

Mark (X) the "Confidential" box next to any item you claim as confidential . 

1 . Production volume -- Estimate the maximum production volume during the first 12 months of production . Also estimate the maximum 

production volume for any consecutive 12-month period during the first three years of production . Estimates should be on 100% new chemical 

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 

10,000 k / , s pecify the volume and mark (x) in the binding box. If anted, you are bound to this volume 

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confi- Binding 

(100% new chemical substance basis) (100% new chemical substance basis) dential option 

Mark (x) 

X 

2. Use Information -- You must make separate confidentiality claims for the description of the category of use, the percent of production volume 

devoted to each category, the fonnulation of the new substance, and other use information . Mark (X) the "Confidential" Box next to any item 

you claim as confidential . 

a . (1) -- Describe each intended category of use of the new chemical substance by function and application . . 

(2) -- Mark (X) this column if entry column (1) is confidential business information (CBI). 

(3) -- Indicate your willingness to have the information provided in column (1) binding. 

(4) -- Estimate the percent of total production for the first three years devoted to each category of use . 

(5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI). 

(6) -- Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for 

commercial purposes at sites under your control associated with each category of use . 

(7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI). 

(8) -- Indicate % of product volume expected for the listed "use" sectors . Mark more than one box if appropriate. Mark (X) to indicate 

your willingness to have the use type provided in (8) binding . 

(9) -- Mark (X) this column if ent (ies) in column (8) is (are) confidential business information (CBI). 

Category of use (1) CBI Binding 

option 

Produc- CBI % in CBI % of substance expected per use CBI 

tion % Form- ($) 

(by function and application i .e . a dispersive dye M ~; (x) ulation Site- Con-* Indus- Coin- Binding 

forfinishing pol yester fbers) (2) 

~ 

(4) (5) (6) (7) limited sumer trial mercial Option (9) 

% % 

% % 

o~ o~ 

o~ o~ 

o~ o~ 

o~ o~ 

o/ % 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products . In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. 

~ Mark (X) this box if you attach a continuation sheet. 

b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the 

use Instructions Manual for examples of generic use descriptions . 

description Processing Additive Intermediate 

Mark (X) this box if you attach a continuation sheet. 

3. Hazard Information - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding 

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding p rprotective equipment or practices Option 

for the safe handing, transport, use, or disposal of the new substance. List in part Ill hazard information you include. 

Mark (x) 

® Mark (X) this box if you attach hazard infonnation. 

EPA FORM 7710-25 (Rev . 5-95) Page 7 
p. 10 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you 

claim as confidential 

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you 

control . Importers do not have to complete this section for operations outside the U.S . ; however, you may still have reporting requirements if 

there are further industrial processin g or use operations after import . You must describe these operations . See instructions manual 

1 . Operation description Confia. Identity -- Enter the identit y of the site at which the operation will occur. dential 

Name X 

Site address (number and street) 

City, County, State, ZIP code 

If the same operation will occur at more than one site, enter the number of sites . Identify the X 

additional sites on a continuation sheet, and if any of the sites have significantly different 

production rates or operations, include all the information requested in this section for those 

sites as attachments . 

Mark (X) this box if you attach a continuation sheet. 

b. Type -- 

Mark (X) DManufacturing E]Processing ~U se 

c. Amount and Duration -- Complete 1 or 2 as appro priate 

Maximum kg/batch 0 00% new chemical Hours/batch Batches/year X 

substance) 

l . Batch 

Maximum kg/batch 0 00% new chemical Hours/batch Batches/year X 

substance) 

2. Continuous 

d. Process description El Mark (X) to indicate your willingness to have your process description binding. 

(1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g . 5 gallon pails, 55 gallon 

drum, rail car, tank truck, etc.) . (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and 

feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not 

used daily or per batch.) . 

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 

See Page 8A 

® Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page 8 
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Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued _ 

2 . Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, 

number of works exposed, and duration of activity . Mark (X) the "Confidential" box next to any item you claim as confidential . 

(1) -- Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc . ) in which workers may be exposed to the substance. 

(2) -- Mark (X) this column if entry in column (1) is confidential business information (CBI) . 

(3) -- Describe any protective equipment and engineering controls used to protect workers. 

(4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. 

(5) -- Indicate the physical form(s) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) 

at the time of exposure . 

(7) --Mark (X) this column if entry in column (5) is confidential business information (CBI). 

(8) -- Estimate the maximum number of workers involved in each activity for all sites combined . 

(9) --Mark (X) this column if entry in column (8) is confidential business information (CBI). 

(10) and (It) --Estimate the maximum duration of the activity for any worker in hours per day and days per year. 

(12) --Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). 

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI 

m 

(i .e ., bag dumping, filling drums) Engineering Controls Optton and % new Option workers Hrs/day Days/yr 

Mark (x) substance Mark (x) Exposed 

(1) (2) (3) (4) (5) (6) (7) (8) (9) (l0) (Il) (IZ) 

X gloves, goggles, X X X 

nrot . clothina_ vent. 

X gloves, goggles, X X X 

nrot . clothina . vPnt. 

X gloves, goggles, X X X 

nrot . dothinn. vPnt. 

X gloves, goggles, X X X 

nrot . dothinn vent. 

X gloves, goggles, X X X 

nrnt . clothina . vent 

~ Mark (X) this box if you attach a continuation sheet. 

3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential . 

(1) -- Enter the number of each release point identified in the process description, part ll, section A, subsection ld(3). 

(2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch). 

(3) --Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI). 

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to 

which the new substance will be released from that release point. 

(5) --a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for 

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate 

the amount released to the environment after control technology (in kg/day). 

(6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). 

(7) -- Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES numbers of the POTW (Publicl Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CB1). 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) 

Number released release 

(1) (2a) (2b) Us "wk - 

(4) 

Binding 

M k X (3) (Sa) ar ( ) (5b) (6) 

1 X X 

2 X X 

3 X X 

X 

(7) Mark (X) the El POTW provide name(s) below: C131 F Navigable ~ Other - Specify provide NPDES # CBI 

destination(s) of X waterway X 

releases to water. 

I® Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page 9 
Waste Disposal Management and 

Conversion / Recycle o4 IProcess Materials 

Page 9f> 
p. 14 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this 

section for operations outside the U.S . ; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate 

section B for each type of processing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

typical operation common to these sites . Identify additional sites on a continuation sheet . 

1 . Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential . 

(1) -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g . 5 gallon pails, 55 gallon 

drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all 

products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points of release, 

including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify the locations of 

these sites on a continuation sheet) : 

# of sites 

See Page 10A 

® Mark (X) this box if you attach a continuation sheet. 

2. Worker Exposure/Environmental Release 

(1) -- From the diagram above, provide the letter for each worker activity . Complete 2-8 for each worker activity described. 

(2) -- Estimate the number of workers exposed for all sites combined . 

(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. 

(6) -- Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to 

protect workers. 

(7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. 

(9) -- From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified . 

(10) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch). 

(12) -- Describe media of release i .e . stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other 

(specify) and control technology, if any, that will be used to limit the release of the new substance to the environment. 

(14) -- Identify byproducts which may result from the operation. 

(3), (5), (8), (11), ( I 3) and (15) -- Mark (X) this column if an of the proceedin g entries are confidential business information (CBI). 

Letter # of CBI Duration CBI Protective Equip . / % in CBI Release Amount of CBI Media of Release CBI 

of 

ActWorkers Exposed 

of 

Exposure 

Engineering Controls/ 

Physical Form and % 

Formulation 

Number New 

Substance 

& Control 

Technology 

'vity new substance Released 

(l) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (IOb) (ll) (12) (13) 

A X X gloves, goggles, prot. X X X 

clothing, ventilation 

14) -- Byproducts : ` (15) 

0 Mark (X) this box if you attach a continuation sheet, 

EPA FORM 7710-25 (Rev . 5-95) Page 10 
p. 15 

v 

A 

CC 

a 

0 

a 

. 
p. 16 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in this section as confidential circle or bracket the specific information that you claim as confidential . 

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce 

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal 

of the PMN substance. Please include new information pertinent to pollution prevention, including source 

reduction, recycling activities and safer processes or products available due to the new chemical substance. 

Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological 

modification, process and procedure modification, product reformulation, raw materials substitution, and/or 

inventory control. Recycling refers to the reclamation of useful chemical components from wastes that would 

otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution 

prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance 

with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the 

information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting 

of risks to other environmental media or non-environmental areas (e.g ., occupational or consumer exposure). In 

addition, information on the relative cost or performance characteristics of the PMN substance to potential 

alternatives may be provided. 

All information provided in this section will be taken into consideration during the review of this 

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the 

volume manufactured ; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a 

reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in 

the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical 

substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing 

substance that poses a greater overall risk to human health or the environment. 

~ 0 Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page 11 
p. 17 

Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form and test data and other data (including physical/chemical properties and 

structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to 

which it relates, if appropriate . Number consecutively the pages of the attachments . In the column below, enter the inclusive page 

numbers of each attachment. 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on 

how to claim any information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized 

version of any attachment in which you claim information as confidential . 

Attachment name I Attachment 

page number(s) 

Material Safety Data Sheet (MSDS) 

El Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number. 

A1--A8 

Confidential 

X 

X 

X 

X 

EPA FORM 7710-25 (Rev . 5-95) Page 12 
p. 18 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value of the property, 

the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . The physical 

state of the neat substance should be provided . These measured properties should be for the neat (100% pure) chemical substance . 

Properties that are measured for mixtures or formulations should be so noted (% PMN substance in ) . You are not required to 

submit this worksheet ; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential 

information is properly protected. You should submit this worksheet as a supplement to your submission of test data . This worksheet 

is not a substitute for submission of test data . 

Property 

(a) 

Mark 

(X) if 

provided 

Page 

number 

(b) 

Value 

(e) 

Measured o 

Estimate 

(M or E) 

confid-cial 

Mark (X) 

(d) 

, X A4 M X 

Physical state of neat substance (s) (1)- (g) 

X A4 

Vapor pressure 

@ Temperature 20 °C Not available Torr 

X A4 X 

Density/relative density g/cm3 

X 

Solubility 

@ Temperature °C 

Solvent g/L 

X A4 X 

Solubility in water Temperature °C g/L 

Melting temperature Not available °C 

Boiling / sublimation temperature torr pressure Not available °C 

X X 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

X 

Volitalization from water 

X 

Volitalization from soil 

X 

pH@ concentration 

X A2 X 

Flammability 

Explodability 

Adsorption / coefficient 

Other - Specify 

EPA FORM 7710-25 (Rev . 5-95) Page 13 
p. 19 

MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

01/28/2005 

Page: 1 of 8 

1 . PRODUCT AND COMPANY IDENTIFICATION 

Product name: 

Chemical name: 

Supplier: 

Contact numbers : 

I 

2. COMPOSITION / INFORMATION ON INGREDIENTS 

MMMOMA 

COMPONENT CAS# CONCENTRATION 

Note(s): 

See Section or chemicals appearing on Federal or State Right-To-Know lists. 

3. HAZARDS IDENTIFICATION 

EMERGENCY OVERVIEW 

WARNING! 

CAUSES EYE. SKIN AND RESPIRATORY TRACT IRRITATION. 

4. FIRST AID MEASURES 

Swallowing 

If patient is fully conscious, gi-,e two glasses of water. Obtain medical attention . 

Skin 

Remove contaminated clothing . Wash skin with soap and water. Obtain medical attention if discomfort persists . 

Inhalation 

Remove to fresh air. Obtain medical attention. 

E%e contact 

Inim-liatelI. flush c~ e. \k ith ~~,Urr ,tnd cow inue \kashing, ti~r ,tt Ic .i .t I ~ ininutr . t tht,un tnMtK,al .ittentiun 

Attachment Page AI 
p. 20 i 

immediately. 

5. FIRE-FIGHTING MEASURES 

Flash point: I 

MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

01/28/2005 

Page : 2 of 8 

Flammable limits 

Lower limit: Not available 

Upper limit: Not available 

Special fire fighting procedures 

Due to the initial water-silane reaction, use remote spray monitors or fight fire from behind barriers . 

Special protective equipment for firefighters 

Self-contained breathing apparatus. Body covering protective clothing . 

Extinguishing media 

Suitable : Large fires: 

- alcohol-type foam or universal-type foams 

Small fires : 

- C02 

- dry chemical 

Unsuitable : None. 

Unusual fire and explosion hazards 

None known. 

6. ACCIDENTAL RELEASE MEASURES 

Personal precautions 

Avoid contact with eyes and skin . Avoid contact with liquid and vapors. Wear suitable protecti~e equipment. 

Environmental precautions 

Prevent runoff. 

Methods for cleaning up 

('o%cr with absorbent or contain . 

Collect ti)r kli .po.31 . 

t )h~rr~ ~~~ ~ticrnment rr~;ul<rn~~n . 

Attachment Page A? 
p. 21 

MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

01/28/2005 

Page: 3 of 8 

7. HANDLING AND STORAGE 

HANDLING 

Handling precautions 

Do not swallow. Do not get in eyes, on skin, on clothing . Avoid breathing vapor, aerosol and mist. Use with adequate ventilation. Wash thoroughly after handling . 

STORAGE 

Storage requirements 

Keep away from heat and flame. Keep container closed . 

8. EXPOSURE CONTROLS / PERSONAL PROTECTION 

PERSONAL PROTECTION 

Respiratory protection 

Self-contained breathing apparatus in high vapor concentrations . 

Hand protection / protective gloves 

Recommended order of use: 

4H 

Butyl 

Neoprene 

Nitrile (NBR) 

PVC-coated 

Eye protection 

Safety glasses. 

Skin protection 

Chemical protective clothing . 

Other protective equipment 

Eye bath 

Safety shower 

ENGINEERING CONTROLS 

Ventilation 

General mechanical room ventilation is satisfactory for normal handling and storage operations . Special. local ventilation is needed at points where %apors can be expected to escape to the workplace air. 

EXPOSURE LIMITS 

Comaonent TVae Value Remark 

Attac}iment Page A3 
p. 22 

[ MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

01/28/2005 

Page: 4 of 8 

9. PHYSICAL AND CHEMICAL PROPERTIES 

APPEARANCE 

Physical state 

Color 

Odor 

OTHER PROPERTIES 

Boiling point 

Melting point 

pH 

Specific gravity (H20=1) 

Vapor pressure 

Vapor density (air--1) 

Solubility in water 

Evaporation rate (Butyl 

Acetate=1) 

Flash point 

Upper explosion limits 

Lower explosion limits 

Percent volatiles 

Molecular weight 

10 . STABILITY AND REACTIVITY 

Stability : Stable . 

Stability - Conditions to avoid 

None known. 

Incompatible materials 

Acids. 

Base,. 

Strong oxidizing agents . 

Attnchment Pa9P A 
p. 23 

L 

MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

01/28/2005 

Page: 5 of 8 

I 

Hazardous combustion products 

Burning can produce the following combustion products : 

r'des of carb 

Oxides of silicon. 

Carbon monoxide is highly toxic if inhaled; carbon dioxide in sufficient concentrations can act as an asphyxiant. 

Acute overexposure to the products of combustion may result in irritation of the respiratory tract. 

Hazardous polymerization: Will not occur. 

Hazardous polymerization - Conditions to avoid 

None known. 

11 . TOXICOLOGICAL INFORMATION 

SWALLOWING 

May cause the following effects: 1 

- dizziness, faintness, drowsiness, decreased awareness and responsiveness, euphoria, abdominal discomfort, nausea, vomiting, staggering gait, lack of coordination and coma 

Effects of repeated overexposure 

Long-term repeated oral exposumay result in the development 

SKIN ABSORPTION 

Acute effects 

No evidence of harmful effects from available information. 

INHALATION 

Acute effects 

May cause irritation . 

SKIN CONTACT 

Acute effects 

May cause irritation . 

EVE CONTACT 

Acute effects 

May cause irritation . 

of progressive liver injury with fibrosis . 

Medical conditions aggravated by overexposure 

Repeated exposur F--- Jmay aggravate liver injury produced from other causes. 

Other effects o overexposure 

Repeated ingestion ~ as been shown to adversel y affect the cc r I nen ous svstem of the fetus . producing a collecticm ~~f cfferts hir i tc~gether c~~nstitute Fhe.e include 

mcntal and ph ical retardati n . iiaurh nces f m t r langu;»e etici ncie . hcha~ ioral nd %s o d a () learning. o t) and e s disorder,; . a Smell .IiC hrad . 

Attachmpnt Prnge A5 
p. 24 

[ MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

01/28/2005 

Page: 6 of 8 

r-- 

SIGNIFICANT DAT- --- 

A WITH POSSIBLE RELE VANCE . TO HUMAN HEALTH 

12. ECOLOGICAL INFORMATION 

All available ecological data have been taken into account for the development of the hazard and precautionary 

information contained in this Safety Data Sheet. 

13. DISPOSAL CONSIDERATIONS 

General: Incinerate in a furnace where permitted under appropriate Federal, State, and local regulations. 

14 . TRANSPORT INFORMATION 

DOT Classification 

This product is not regulated by DOT. 

Freight description road: CHEMICALS, NOIBN 

IMDG Classification 

This product is not regulated by IMDG. 

ICAO Classification 

This product is not regulated by ICAO. 

15 . REGULATORY INFORMATION 

Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) requires notification of the National Response Center of release of quantities of hazardous substances equal to or greater than the reportable quantities (RQ's) in -tOCFR302 .4 . 

Components present in this product at a level ~khich could require reporting under the statute are: **** NONE   

Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III requires emergency planning based on Threshold Planning Quantities (TPQ's) and release reporting based on Reportable Quantities (RQ's) in 40CFR355 (used for SARA 302 and 304). 

Components present in this product at a level which could require reporting under the statute are: ** ** NONE   

Superfund Amendments and Reauthorization Act of 1986 (SAR:1) Title I11 requires submission of annual reports of release of toxic chemicals that appear in 1t1CFR372 (for ti %RA 313) . This information must he included in NiSUS's that are copied and di%tributed for this material . 

Attachment Page Ah 
p. 25 

MATERIAL SAFETY DATA SHEET 

Revision: 1 .0 

01/28/2005 

Page: 7 of 8 

Components present in this product at a level which could require reporting under the statute are: 

** ** NONE   

Massachusetts Right-To-Know Substance List (MSL)--Hazardous Substances and Extraordinarily Hazardous 

Substances on the MSL must be identified when present in products. 

Components present in this product at a level which could require reporting under the statute are: 

** ** NONE   

Pennsylvania Right-To-Know Hazardous Substance List--Hazardous Substances and Special Hazardous 

Substances on the list must be identified when present in products . 

Components present in this product at a level which could require reporting under the statute are : 

** ** NONE   

New Jersey Worker and Community Right-To-Know Act (Labeling Requirements) 

Chemical name CAS# New Jersey TS Number 

EPA Hazard Categories (SARA 311, 312): Immediate Health Hazard 

California Proposition 65 

This product contains no levels of listed substances, which the State of California has found to cause cancer, birth 

defects or other reproductive harm, which would require a warning under the statute. 

California SCAQMD Rule 443.1 VOC's 

Volatile Organic Components (VOC's) = Substances with vapor pressure of => 0.5 mmI-Ig at 104'C (219.2'F). 

** **NOT DETERMINED**** 

CHEMICAL INVENTORY 

United States : This is a new chemical substance that is not currently on the TSCA Inventory. Under 

TSCA regulations, 40 CFR Section 720.36, experimental products such as these can only 

be used for research and development purposes either directly by, or under the supervision 

of a technically qualified person . The law further stipulates that an evaluator may test and 

evaluate samples such as these but, with few exceptions, the sample or products derived 

from it may not be used for commercial purposes until the new substance is added to the 

TSCA Inventory via Premanufacture Notification . 

16. OTHER INFORMATION 

RECOMMENDED USES AND RESTRicrIONS 

Please consult the product and or application information bulletins for this product. 

HivIIS RATING 

Health: I Flammabilitv : 1 Reactivity I PPIX 

LEGEND 

STP Standard temperature and pressure 

' 'Kei ght kk'ei ltt -

u (H0, 11 's) !llinimal hai,ird 

Attachment Page A7 
p. 26 

, MATERIAL SAFETY DATA SHEET 

Revision : 1 .0 

01128/2005 

Page: 8 of 8 

1 (HMIS) Slight hazard 

2 (HMIS) Moderate hazard 

3 (HMIS) Serious hazard 

4 (HMIS) Severe hazard 

~ X (HMIS) Personal protection rating to be supplied by user depending on use conditions 

The opinions expressed herein are those of qualified experts withi We believe that the information contained herein is current as of the date of this Safety Data Sheet. Since the s_e of this information and of these opinions and the conditions of use of this product are not within the control of~~ it is the user's obligation to determine the conditions of safe use of the products . 

Attachment Pape AR 
HEALTH 0 EFFECT STATEMENT 

The Intermediate PMN substance, has not been tested . However toxicology studies 

have been conducted with an 

is of a very low order of toxicity by swallowing or skin contact. is mildly 

irritating to the skin and is a minor eye irritant capable of producing corneal injury. ,~was 

not mutagenic in an Ames bacterial mutagenicity assay. Similar findings are anticipated fo4 

Acute Oral Toxicit 

When undiluted was administered by oral gavage to rats, the acute oral LDS0 was 

determined to be > 2000 mg/kg, indicating very low toxicity in the rat by this route. 

Acute Dermal Toxicity 

In order to determine the potential for systemic toxicity by absorption across the skin, I 

(undiluted) was applied to the skin of rabbits and maintained in contact for 24 hours. The acute 

percutaneous LDS was determined to be > 2000 mg/kg, indicating a very low order of toxicity in 

the rabbit by this route. 

Effect on Skin 

When 0.01 mL of was applied uncovered to rabbit belly marked-to-moderate redness 

%4as observed, indicatin is a mild skin irritant under the conditions ofthis study . 

1 

ti i ;-Ili ~ i c, il) IN (IX (I H 

AttnchmPnt PnKP A9 
Effect on Eyes 

When rabbit eyes were flooded with 0.5 mL o~trace corneal injury was observed on l of 

5 rabbit eyes, indicating= is a minor eye irritant capable of producing corneal injury. 

Genotoxicit 

was evaluated for potential mutagenic activity in the Salmonella/Escherichia coli 

mutagenicity assay (Ames test) in the presence and absence of metabolic activation . The 

material was concluded to be negative under the conditions of this test . 

F 

I 

AttacYhment Pip_e Al(1 
Preliminary Risk Assessment of Intermediate PMN Substance 

Worker Exposure Assessment and End-Use 

. 

The _syn_ thesisT------- will take place 

in closed, 

Operators will obtain samples o 1t the end of the reaction and strip, using a 

self-contained and vented sampling system. QC laboratory personnel will use exhaust 

hoods when preparing samples and will follow analytical methods that have been 

develoved to maximize safety and minimize exnosure. Prior to samnlin 

j 

trained 

and experienced in handlin 'hazardous materials, such as the various 

olefinic raw materials~interme iates, an products. ~ .____--- ~~ - 

specific manufacturing department. The operating personnel are required to use personal 

protective equipment (PPE) and are trained to follow all safety recommendations as 

specified in the MSDSs and within the Operating Instructions . The PPE worn by workers 

will effectively eliminate the potential for dermal or inhalation exposure. The personnel 

protective equipment includes safety hard hat, steel-toed shoes, chemical resistant gloves, 

and goggles. Breathing devices are available in the operating areas for emergency use, as 

_ well as su lied air respirators for special tasks. In addition, operations personnel wear 

-- at all times within the processing areas as emergency equipment. The 

workers are trained in emergency procedures in the event of an unexpected exposure, 

accidental release, spill or fire . 

Once the fin'she 

t 

CL has met specifications 

h __7~or the final synthetic st to n at the end 

- 

---I---- ~1 - - __ - 

_aoduct. known The 

long-term plan. e same trainin PPE, an procedures described above are used 

downstream for the 

Attarhment Page All 
p. 30 

GC (1F TNTERMRDTATE PMN SUBSTANCE 

Attachment P3p,P AI? 
W 

H 

d 

H 

A W 

W U 

W E-H 

Ea In 

z pq 

F-1 ",D 

W 

O 

P4 

E-H 

W 

Attachment Page A13