### Re: Requests for extension and exemption of date to submit testing results to EPA. Paul Campanella to: Cuthbert Frederick 01/19/2012 02:16 PM Cc: John Schaeffer, Marcus Aguilar From: Paul Campanella/DC/USEPA/US To: Cuthbert Frederick <CFrederick@wegochem.com> Cc: John Schaeffer/DC/USEPA/US@EPA, Marcus Aguilar/DC/USEPA/US Mr Cuthbert Frederick, WEGO Chemical & Mineral Corp. 239 Great Neck Road Great neck, NY 11021 Mr. Frederick, We have reviewed the information provided in your Request for Exemption for products CAS # 110-44-1 and CAS # 6381-77 submitted on January 6, 2011. Based on your explanation that these products are imported and sold as is only into the food production industry we have determined that the chemicals are not covered by the test rule published on January 7, 2011. The exemption request is granted.
We have also reviewed the WEGO request for a nine (9) month extension (i.e., to December 31,2012)submitted on January 6, 2011 on CAS #84- 65-1 and CAS# 144-62-7 to provide the required data. This extension is granted. Paul J. Campanella, Ph.D. Chemical Information and Testing Branch Chemical Control Division U.S. Environmental Protection Agency Washington, D.C. 202-564-8091 Cuthbert Frederick 01/06/2012 02:18:25 PM Dr. Campanella, As per our conversation and e...
From: Cuthbert Frederick <CFrederick@wegochem.com> To: Paul Campanella/DC/USEPA/US@EPA Cc: John Schaeffer/DC/USEPA/US@EPA, "B. Eshaghpour" <BEshaghpour@wegochem.com>, Vincent1 Gamboli1 <VGamboli1@wegochem.com>, Adam Cohen <ACohen@wegochem.com> Date: 01/06/2012 02:18 PM Subject: Requests for extension and expemption of date to submit testing results to EPA.

Dr. Campanella, As per our conversation and email correspondence, I have attached (1) Wego's Request for exemption from testing products SOrbic acid and Erythorbic acid. (2) Wego's request for extension to submit test data Re Docket ID # EPA-HQ-OPPT-2007-0531. We await your response. Thanks and regards, Cutty Frederick -----Original Message-----From: Paul Campanella [mailto : C ampanella

. P aul @ epamail

. epa . g ov] Sent: Thursday, January 05, 2012 4:23 PM To: Cuthbert Frederick Cc: John Schaeffer Subject: Request for extension of date to submit testing results to EPA.

Cutty, You can add all tests ( e.g., A, B, C , E1 etc,) for the chemicals that you want to extend the date for "receipt of test data" in the same letter. Make sure you explicitly tell us the chemical and the tests. You will have to formally submit this to the Docket. When you do submit it please send me a PdF copy so I can be sure it is received here and entered into the docket correctly. Question concerning other companies reporting on the IUR that might be subject to the Test Rule: CASRN # 110-44-1 only Wego CASRN# 8465-1 Wego and Chemical Product Corp.( C6 -Algal Plant Tox) CASRN# 6381-77-7 only Wego The issue regarding the substances imported for FDA type uses is a bit more complicated. Can you send me a draft letter requesting an exemption from testing explaining exactly what you are doing ,the amount of chemicals substance involved and any other relevant information? Remember you cannot do anything other than label and ship the substance. If you open and repackage it in smaller containers then you are subject to the rule. I will ask our legal folks to look it over and get back to you. Send it as a Pdf attachment to an email. If the exemption request is validated then you will have to send an official letter to the docket. Paul J. Campanella, Ph.D. Chemical Information and Testing Branch Chemical Control Division U.S. Environmental Protection Agency Washington, D.C. 202-564-8091

Exemption request 0112.pd f Extension request 0112.pd f