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

From: "John V. Massingale" < j ohn@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 : C Frederick @ w egoche m

. c om ] 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)