1

1850 M Street NW • Suite 700 • Washington, DC • 20036 Phone: 2 02

- 721

- 4157 • Fax: 202

- 296

- 8120 September 4, 2015

Document Control Office (740 5 M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency Environmental Protection Agency East Building, Room E6428 (202

- 564

- 8930) 1201 Constitution Avenue, NW Washington, DC 20460

At tention: Toxic Substances Control Act Section 4

40 CFR 799.5087 Docket ID Number : EPA

- HQ

- OPPT

- 2007

- 0531

Re: Testing of Certain High Production Volume Chemicals; Second Group of Chemicals, Federal Register 76 (5), 1067

- 1093, January 7, 2011; Castor Oil, S ul fated, S odium Salt, CAS No. 68187

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- 8

To Whom It May Concern:

The U

. S. Environmental Protection Agency (EPA) promulgated a final TSCA test rule on January 7, 2011 (76 FR 1067

- 1093) that requires manufacturers (including importers) and processors of Sulf ated Castor Oil to conduct testing to obtain screening level data for health and environmental effects and chemical fate.

The Sulfated Castor Oil (SCO) Consortium
, a cost

- sharing consortium affiliated with the Society of Chemical Manufacturers & Affilia tes ( SOCMA), is pleased to p rovide test results in response to the EPA test rule, which we believe will fulfill the rule requirements. The SCO is made up of the following U.S. manufacturers of Castor Oil, S ulfated, s odium S alt, CAS No. 68187

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- 8 :

Afton Chemical Corporation Manufacturers Chemical, LLC Emerald Carolina Chemical LLC

The SCO has conduct ed testing in accordance with the EPA

- approved Test Plan and offers the following studies :2

1850 M Street NW • Suite 700 • Washington, DC • 20036 Phone: 2 02

- 721

- 4157 • Fax: 202

- 296

- 8120 1. Development and Validation of an Analytical Method for the Analysis of Castor Oil, Sulfated, Sodium Salt, 75% in Water 2. Determination of Physico

- Chemical P roperties of Castor Oil, Sul fated, Sodi um Salt, 75% 3. Acute Toxicity Study in D aphnia magna with Castor Oil, Sulfated, Sodium Salt, 75% in Water (Static) 4. 96

- Hour Acute Toxicity Study in Fathead Minnow with Castor Oil, Sulfated, Sodium Salt, 75% (Static) 5. Fresh Water Algal Growth Inhibition Test with Castor Oil, Sul fated, Sodi um Salt, 75% 6. Assessme nt of Acute Oral Toxicity with Castor Oil, Sul fated, Sodi um Salt, 75% in the Rat (Up and Down Procedure) 7. Evaluation of the Mutagenic Activity of Castor Oil Sul fated, Sodi um Salt, 75% in the Salmonella typhimurium Reverse Mutation Assay and the Escherichia c oli Reverse Mutation Assay (With Independent Repeat) 8. Evaluation of the Ability of Castor Oil, Sul fated, Sodi um Salt, 75% to Induce Chromosome Aberration s in Cultured Peripheral Human Lymphocytes (With Repeat Experiment) 9. Results Table Extracted from SCO Lymphocyte Chromosomal Aberration Study 10. Combined 28

- Day Repeated Dose Toxicity with the Reproduction/Developmental To xicity Screening Test of Castor Oil, Sul fated, Sodi um Salt, 75% in Rat s by Oral Gavage

These studies are being submitted in electronic format on a CD due to difficulties encounte red with the web

- based CDX system. Please contact me at (301) 987

- 0924 or johnd@nanoreg.net for questions or additional information.

Sincerely yours,

John DiLoreto Executive Director Sulfated Castor Oil Consortium

Enclo sed: Castor Oil, Sul fated, Sodi um Salt ; Test Plan Studies