PUBLIC GOPY

September 9,2010

Bv Certified Mait

TSCA Confidential Business lnformation Center (7407M)

EPA East - Room 6428 Attn: Section 8(e)

U. S. Environmental Protection Agency

1200 Pennsylvania Avenue. N.W.

Washington, DC 20460

Subject: TSCA g S(e)

Test Substance: CAS Registry Number 68650-79-3 (amides, tall-oil fatty, N-13-gdimethylaminolpropyl)

Dear Sir or Madam:

Bayer MaterialScience LLC (the "Company") previously submitted the following study summaries for the Test Substance:

l. SEHQ-O9-17540, submitred June l,Z00g, 2. submitted August 10, 2009, and 3. submitted April2g, 2010 (3 srudies).

The Company is now submitting the summary of an Inherent Biodegradability: Modified MITI Test (If of the Test Substance, which the Company imports, processes, and distributes in the United States.

The Company is submitting these data in accordance with our understanding of EpA,s interpretation of the requirements of TSCA $ s(e) as expressed in agency guidance. However, the Company has not determined whether these data actually disclose u *u.täniiul risk of injury to health or the environment associated with the chemical substance or mixture.

Product Safety & Regulatory Affairs and

Management Systems

Bayer MaterialScience LLC

I 00 Bayer Road

Pittsburgh, P A 1 5205-97 41

Phone:FAX:

e-mail:

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STUDY TITLE:

A study was performed to assess the inherent biodegradability of the Test Substance.

The study was conducted in accordance with the OECD Guideline 302C "Inherent Biodegradability:

Modified MITI Test (ID" (1981) (based on standard operating procedures for OECD Guideline 30lF(L992) and the Council Regulation (EC) No 440/2008, method C.4-D "Manometric Respirometry Test"

(2008).

A solution of the Test Substance in a mineral medium was inoculated with 40 % sludge of each of two

different municipal sewage treatment plants (STP) and20 % sludge of an industrial STP and incubated

under aerobic conditions. During this period, degradation was followed by continuous automated BOD

determinations.

Test Substance showed:

47 %o degradation after 7 days

70 %o degradation after 14 days

90 %o degradation after 21 days

97 %o degradation after 28 days

Therefore, the Test Substance is considered to be "Inherently biodegradable"

lWithin the test period of 28 days, a degradation of 97o/o was determined, and this substance was classifiedas "Inherently biodegradable". This substance is considered as moderate for biodegradation under the

EPA "Classification Criteria for Environmental Fate". This substance is highly toxic to Daphnia and

algae based on acute toxicity testing and moderately toxic to fish and bacteria based on acute toxicity

testing(Daphnia-EC50:0.11mg/L-48hrs.; algae-IC50:0.53mglL-72hrs.;frsh-CL50-2.5

mg/L - 96 hrs.; bacterial - EC50 - 2ll mglL - 3 hrs.). Based on typical uses (additive for use in the

production of polyurethane; reacted in final products), we would not expect widespread exposure. Also,we are not aware of previously unsuspected distribution in environmental media or information that

widespread or significant exposure to humans or nonhuman organisms has occurred or that there is asubstantial likelihood that such exposure will occur.

Inherent Biodegradability: Modified MITI Test (If

ComPanY Sanft¡zed