To: "John V. Massingale" <john@grcci.com>, 

Cc:

Bcc:

Subject: Re: HPV-2 Chemical - CAS RN 144-62-7

From: Paul Campanella/DC/USEPA/US - Wednesday 05/02/2012 02:45 PM

John, After reviewing all the email messages and phone conversations I agree that we made the 

determination to extend the date for receipt of test data for testing under the HPV 2 Test Rule for CASRN 

144-62-7 at the same time we responded to you regarding the WEGO Chemical and Mineral request for 

an extension (November 2011). I think that synchronizing the dates makes a lot of sense for you in 

managing both projects. The new date for receipt of test data on this chemical will be December 31, 

2012.

Paul J. Campanella, Ph.D.

Chemical Information and Testing Branch

Chemical Control Division

U.S. Environmental Protection Agency

Washington, D.C. 

202-564-8091

"John V. Massingale" ***This E-mail Contains No CBI*** Paul, 04/21/2012 04:24:23 PM

From: "John V. Massingale" <john@grcci.com>

To: Paul Campanella/DC/USEPA/US@EPA

Date: 04/21/2012 04:24 PM

Subject: HPV-2 Chemical - CAS RN 144-62-7

***This E-mail Contains No CBI***

Paul,

Prior to Univar USA and WEGO Chemical and Mineral forming a consortium to

test ethanedioic acid [CAS RN 144-62-7], Univar submitted on November 16,

2011 to the Docket (with a copy to you) a formal extension request. This

request was made for a 2-month extension. It appears that the Agency has not

had the opportunity to respond. 

Separately, WEGO also submitted a request for a 9-month (i.e., to December

31,2012) extension which you granted, as you indicated in the e-mail

immediately below. So that Univar's and WEGO's extensions are of the same

duration and also because this process is taking longer than expected, would

it be possible for you to formally grant to Univar the same 9-month

extension? 

If there are any questions or comments, please do not hesitate to let me

know. 

Thank you.

John V. Massingale

April 21, 2012

-----Original Message-----
From: Cuthbert Frederick [mailto:CFrederick@wegochem.com]

Sent: Thursday, April 19, 2012 1:29 PM

To: John V. Massingale

Subject: FW: Requests for extension and exemption of date to submit testing

results to EPA.

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

-----Original Message-----

From: Paul Campanella [mailto:Campanella.Paul@epamail.epa.gov] 

Sent: Thursday, January 19, 2012 2:17 PM

To: Cuthbert Frederick

Cc: John Schaeffer; Marcus Aguilar

Subject: Re: Requests for extension and exemption of date to submit testing

results to EPA.

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

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:Campanella.Paul@epamail.epa.gov]

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

(See attached file: Exemption request 0112.pdf)(See attached file:

Extension request 0112.pdf)