PMN Page 1 ; Page 1 of 18 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

ES 

GENERAL INSTRUCTIONS 


You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates if you do 


not have actual data. 


Before you complcte this form, you should read the "Instructions Manual for Premanufaeture Notification" (the Instructions Manual is availablc from the Toxic 


Substances Control Aet (TSCA) Information Service by calling 202.554-1404, or faxing 202-554-5603). 


If a user fcc has becn remitted for this notice (40 CFR 700.45), indieate in the boxes above the TS·uscr fcc identification number you have generated. Remember, 


your user fcc ID number must also appear on your corresponding fcc remittance, which is sent to EPA, Washington financial Management Center (3303), P.O. 


DDI.i'l\,f A 1\TTT~ &rTITRF, 

1111111 1II11 11111 III!I 11111 1111111111 1IIIIIIIIi IIIIIIIII! 111111111111111111 

5 1 09000041:'0/::3 

Company Sanitized 

360399M. Pittsburgh, PA 15251-6399, Attn. TSCA Uscr fcc. 

Part I-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 

chemical substance. even if you claim the identity as confidential. You may authorize 

another person [0 submit chemical identif}' infonnation for you, but your submission will 

not be complete and the review will not begin until EPA receives this information. A letter 

in support ofyour submission should reference your TS user fee identification number. 

You mus[ submit an original and two copies of this notice including all test data.. Ifyou 

claimed any infonnation as confidential, a single sanitized copy must also be submitted, 

Pal1l1-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing. or use operations to be described in Part II, 

sections A and B of this notice. reproduce the sections as needed. 

Part Ill-LIST OF AITACHMENTS 

Attach additional sheets ifthere is not enough space to answer a question funy. Label each 

continuation sheet ~ith the corresponding section heading. In Part lIt list these 

attachments, any test data or other data and any optional infmmation included in the notice. 

OPTIONAL INfORMATION 

You may indude any information that you wanl EPA to consider in evaluatJng the new 

substance. On page 11 oftbis form~ space has been provided for you to describe 

pollution prevention and recycling information you may have regarding the new substance 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingness to be bound to certain statements you make in this section~ such as use, 

production volume. protective equipment. This option is intended to reduce delays that 

routinely accompany the development of consent orders: or Significant New Use Rules. 

Except in the case of exemption applications (such as TMEA, LVE, LOREX) where 

certain information provided in such notification is binding on the submitter when the 

Agency approves the exemption application. checking a binding box in this notice does not 

by itself prohibit the submitter from later deviating from the information (except chemical 

identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To assert a claim on the 

fonn, mark (X) the confidential box next to the information that you claim as confidential, 

To assert a claim in an attachment, circle or bracket the information you daim as 

confidential. If you claim information in the notices as confidential you must also provide 

a sanitized version ofthe notice (including attachmentsi. For additional instructions on 

claiming tflfonnatlon as cOflfidential. read the Instructions Manual. 

[8J Mark (x) if any infonnalion in this notice is claimed as confidential, 

TEST DATA AND OTHER DATA 

You arc required to submit all test data in your possession or control and to 

provide a description of all other data known to or reasonably ascertainable by 

you, if these data arc related to the health and environmcntal effects on the 

manufacture, processing, distribution in commerce, usc. or disposal of the new 

chemical substance. Standard literature citations may be submitted for data in thc 

open scientific litcrature. Complete test data (written in English). not summaries 

ofdata must be submitted if they do not appear in the open literature. You should 

clearly identify whether tcst data is on the substance or on an analog. Also, the 

chemical composition oflhc tested material should be characterized. Following 

arc examples of tcst data and other data. Data should be submitted according to 

the requirements of §720.50 of the Premanufaeture Notification Rule (40 CfR 

Part 720). 

Test Data (Check Below any included in this notice) 

EnVironmental fate data 0 Yes Other data D Yos 

Health effects data 0 Yes Risk assessments E1 

Emlironmental effects data 0 Yes Structure/activity relttKmSbipSD 

PhysicaliChemical Properties· 0 Yes Test data not in the possession 

or control of the submitter D 

A physical and chemical properties worksheet is located on the last page of this form. 

TYPE OF NOTICE (Che<:k Only One) 

o PMN (Premanufacture Notice) 

D INTERMEDIATE PMN (submitted in sequence with final product PMN) 


D SNUN (Signiticant New Use Notice) 


D TMEA (Tesf Marketing Exemption Application) 


D LVE (Low Volume Exemption) !if 40 CFR 723.50(,)(1) 


D LOREX (Low R.le.selLow E~posure Exemption)@40CfR 723.50(e)(2) 


D LVE Modification D 
 LOREX Modific.tion


IS THIS A CONSOLIDATED PMN" o Yes

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Form 7710-25. 
PMN Page 2 ; Page 2 of 18 

Public reporting burden for this collection of infonnation is estimated to average 110 hours per response, including time for reviewing 

instructions, searching existing data sources, gathering and maintaining the data needed. and completing and reviewing the collection of 

infonnation. Send comments regarding the burden estimate or any other aspect of this collection of infonnation, including suggestions for 

reducing this burden, to Direetor, Collection Strategies Division (2822), U.S. Environmental Protection Agency, 1200 Pennsylvania Ave., N.W., 

Washington, D.C. 20460; and to the Office of Management and Budget. Paperwork Reduction Act (2070-00 12), Washington, D.C. 20503. 

CERTIFICATION - A Printed copy of this signature page, with original signature, must be submitted 

I certify that to the best of my knowledge and belief: 

I. 	 The company named in Part I, section A, subsection I a of this notice fonn intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, 

Section B. 

2. 	 All infonnation provided in this notice is complete and truthful as of the date of submission. 

3. 	 I am submitting with this notice all test data in my possession or control and a description ofall other data known to or 

reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule. 

Additional Certification Statements: 

If you are submitting a PMN, Intennediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 

statement that applies: 

o 	The Company named in Part I, Section A has remitted the fee of$2500 specified in 40 CFR 700.45(b), or 

o The Company named in Part I, Section A has remitted the fee of $1 000 for an Intennediate PMN (defined @ 40 CFR 

700.43) in accordance with 40 CFR 700.45(b), or 

o The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 

in accordance with 40 CFR 700.45(b). 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(I) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements: 

o The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 

purposes, other than in small quantities solely for research and development, under the tenns of 40 CFR 723.50. 

o 	The manufacturer is familiar with the tenns of this section and wi II comply with those tenns; and 

o 	The new chemical substance for which the notice is submitted meets all applicable exemption conditions. 

o If this application is for an LVE in accordance with 40 CFR 723.50(c)(I), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within I year ofthe date of the expiration of the 30 day 

review period. 

The accuracy of the statements you make in this notice should renect your best predictitm of the anticipated facts regarding the chemicat subsrante 


described herein. AllY knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001. 
 Confidential 

ignature . of Au . ed om at (Original Sign aature Requiredl 	 .. f) Date Ta:::;; \ i'-1A-IJ A.C«;::= 1<.,.,. 

AtJ>:>':2.EA, !?'Au2S'\~\ ~\ 2...:3! 0'1 D ~~~agent -(ifapplicable) Dare 

o 

EPA FORM 7710-25 (Rev. 5-95) 	 Page 2 
PMN Page 3 ; Page 3 of 18 

Confidential 

lao Person 

Submitting 

Notice (in C .S.) ______ _________D 

Company 

b. Agent (if 

applicable) 

LAMBERTI USA Inc. 

Mailing address (number and street) 

Highway 59 at Mfbiza Road (Country Road 212) 

State 

Hungerford, Texas 

Name 

Mailing 

Postal 

street) 

Telephone (include area code) 

C. lfyouare<111,mitt~;;~;;no~tT.ic;e~a~s~p;a~rt~o~f~a~j~o;'in;t~~bl~rJls~~lo~I~,~k7(Xx)lith~i~sbbo~x.~:::::::::::::::::::::::::::::::::::::::::::~":l~r 

Joint Submitter (if 

applicable) 

2. Technical 

Contact (in 

U.S.) 

Name ofauthorized official 

Colombo Maurizio 

Company 

LAMBERTI S.p.A. 

Mailing address (number and street) 

Via Piave, 18 

Province, Country 

Italy 

Name of authorized official 

Balestrini Andrea 

Company 

LAMBERTI USA Inc. 

Mailing address (number and street) 

Postal Code 

I-21041 

Highway 59 at Mlniza Road (Country Road 212) 

4. 

5. 

6. 

City, State 

Hungerford, Texas 

Postal Code 

77448 

(PC) concerning this notice and 

EPA assigned a PC Number to the notlce, enter :::th:;.e.:,:n:;um:::b:;eT;:..'--____ 

Ifyou prevlously submitted an exemption application for the cbemical 

substance covered by this notice~ enter the exemption number assigned by 

EPA. tfyou previOUSly submitted a PMN for this substance enter the PMN 

number assigned EPA (I.e, withdrawn or II 

Tfyou 

for the chemical substance covered by this notice. enter the notice number 

assigned by EPA. • 

I. 

Type of Notice - Mark (X) 

Manufacture o Only

o Binding Option 

12. 

I 

I 

I 

I 

Position 

Health & Product Safety Manager 

City, State 

Albizzate (VA) 

Telephone (include country or area code) 

0039 0331 715226 

Position 

Technical Manager 

o 

o 

Telephone (include area code) 

281 342 565 

Import 

Only 

Mark (X) 

if none 

Mark (X) 

ifnone 

Mark (X) 

ifnone 

Binding Option 

Mark 

I 

13. 

I 

I 

D Both 

EPA FORM 7710-25 (Rev. 5-95) Page 3 

06/25/2009 THU 14:13 FAX 979 532 3749 Lamberti U.S.A 
 121002/003

PMN Page 4 ; Page 4 of 18 


Sectlett B - CHEMICAL IDENTITY INFORMATION: 

l. 

a. Class of substance - Marie (X) or 

b. Chemical name (Cunently ~IChemical Abs1l8CI8 (CA) Name !hilt is consistent wi1h TSCA lnventoIY listings for similarsubstances. For 

Class 1 substances a CA Index Name mllSl be provided. For CIaR 2 suIl6_ either a CA Index Name or CA Preferred NlIlllt must be provided. 

which ever is appropriate basI:d on CA 9CI nomem:brture rules and oonventiou). 

1~Propanone r 1·!l.i;:16kydb~J~15~hen¥~~~~)i6i~h ~t.:(~1idxY:2 -metnil-" 

c. Please identifY which method you used 10 develop or obtain the 'l'ecitied chemical identity informatioo repOrled in this notice: (check one). 

O Method I, (CAS InventOty Expert Service ­ 8 copy ofthe !dentiticatioo r;'1 Method 2 (Other Source) 

report obtained ftom the CAS InvenlOry Expert Service5 must be ~ submitted as an alladlmeat 10 1his notice) 

d. Molecular formula 

C20 lf22 05 

CBI 

D 

CAS RegislIY Number 

(if a oumbe'f already 

ex:ifl1s for the IiUbstance) 

7186a-:L5~O 

C, For a class I substance. provide a complete and correct cbemical structure diagram. For a class 2 substance, provide a com:ct representative Or 

partial chemical structure diagram. as complete as can be known. ifOIIe ClUl be reasonably ascer1ained. Please see the E-PMN Instruction Manual for 

discussion ofnnat;ve format" diagram software which eM be helpful in reviewing your substan<:e. 

o Mark (X) Ibis box ifyou attadt a cooUnuation sheet. 

CoofidentiaJ 

D 

EPA FORM 7710-25 (Rev. 5-95) Page 4 

PMN Page 4a ; Page 5 of 18 

For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. 

(3) Indicate the range ofcomposition and the typical composition (where appropriate). 

e. (l) List the immediate precursor substances with their respective CAS Registry Numbers. ConfiName (CAS#) dential 

D 

e. (2) Describe the nature ofthe reaction or process. D 

e. (3) Indicate the range of composition and the typical composition (where appropriate). D 

] Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 4a 
PMN Page 5 ; Page 6 of 18 

Part I - GENERAL INFORMA nON ­ Continued 

Section B ­ CHEMICAL IDENTITY INFORMATION ­ Continued 

2. Polymers (For a definition of polymer, see the Instructions ManuaL) Confidential 

a. Indicate the number-average weight of the lowest molecular weight composition ofthe polymer you intend to manutacture. 

Indicate 

below 1,000 

maximum 

absolute 

weight 

molecular 

percent 

weight 

of low 

of

molecular 

that cOlllposition. 

weight species (not including residual monomers, reactants, or solvents) below 500 and D

Describe the methods ofmeasurement or the basis for your estimates: GPCU o·'r (SpecifY below) 

(i) lowest number average molecular weight: 

I 

(ii) maximum weight % below 500 molecular weight: 

(iii) maximum weight % below 1000 molecular weight: 

0 Mark (X) this box if you attach a continuation sheet. 

b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the 

"Confidential" box next to any item you claim as confidential 

(I) Provide the specific chemical name and CAS Registry ]\iumber (if a number exists) ofeach monomer or other reactant used in the manufacture of 

the polymer. 

(2) - Mark (X) this column if entry in column (I) is confidential. 

(3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer. 

(4) - Choose "yes" from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

(5) Mark (X) this column ifentries in columns (3) and (4) are confidential. 

(6) Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

commercial purposes. i (7) - Mark (Xl this column if entry in column (6) is confidential. 

Monomer or other reactant and CAS Registry Number Confi- Typical Include in Confi- Maximum Confidential composition identity dential residual dential 

(I) (2) (3J (4) (5) (6) (7) 

D % DD % 

D % 0 D % il 

% DD % 

I 

D % 0 D % D 

D % JlL % D 

D % I D % 

i 

D % 0 D % 

c:::::J % ;---­ % I I - C=I % % I I 

c:::::J % ;---­ % 

c:::::J % % 

L--I I I

c= % [:=J % 

[ % CJ % 

- I I

0 Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 5 

PMN Page Sa; Page 7 of 18 

c. 	 o Please identify which method you used to develop or obtain the specified chemical identioormation reported in this notice (check one), CHI

Method I (CAS Inventory Expert Service - a copy ofthe identification report Method 2 (other source) 


obtained from CAS Inventory Expert Service must be submitted as an attachment to this notice) 
 D 

d, 	 The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers. 

D 

CAS Registry Number (ifa number already exists for the substance) [ ] e. 	 Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained .. Please 

see the E-PMN Instruction Manual for discussion of Hnative format" diagram software which Can be helpful in reviewing your substance. D 

ark (X) this box if you attach a continuation sheet. 

EPA FORM 77\0-25 (Rev. 5-95) 	 Page Sa 
Impurities 

attach a continuation sheet. 

PMN Page 6 : Page 8 of 18 

(a) 	 Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide 

the CAS Registry Number if available. Ifthere are unidentified impurities, enter "unidentified." 

Estimate the maximum . . 

Maximum Confi· 

percent dential 

% D 

% D 

Confi· 

dential 

D Mark (X) this box ifyou attach a continuation sheet. 

5. Trade identification List trnde names for the new chemical substance identified in subsection I or 2. 

ESACURE KIP 160 


ESACURE 2006 


LFC 2006 


o Mark (X) this box if you attach a continuation sheet. 

6. name· If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals 

the specific chemical identity ofthe new chemical substance to the maximum extent possible. Refer to the 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

N/A 

resulting from the manufacture, processing. use, or disposal of the new Provide the CAS Registry 

CAS Number Confi· 

D 


D 


D 


EPA FORM 7710-25 (Rev. 5-95) 	 Page 6 
PMN Page 7 ; Page 9 of 18 

Part I - GENERAL INFORMATION - Continued 

Section C - PRODUCTION. IMPORT AND USE INFORMATION: 

Mark X the "Confidential" box next to an item ou claim as confidential. 

I. 	Production volume - Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum 

production volume for any consecutive 12-month period during the first three years ofproduction . Estimates should be on 100% new chemical 

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 

10,000 k r, s eci the volume and mark x in the bindin box. If nted, ou are bound to this volume 

Confidential

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) 

(100% new chemical substance basis) 	 (100% new chemical substance basis) 

2. 	 Use Information - You must make separate confidentiality claims for the description of the category of use, the percent ofproduction volume devoted to each 

category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item you claim as confidential. 

a. (I) --Describe each intended category of use ofthe new chemical substance by function and application. (2) -Mark (X) this column if entry column (I) is 

onfidential business information (CBI). (3) --Indicate your willingness to have the information provided in column (I) binding. (4) --Estimate the percent of total 

roduction for the first three years devoted to each category of use. (5) --Mark (Xl this column ifentry in column (4) is confidential business information (CBI). (6)-­

stimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under 

our control associated with each category ofuse. (7) --Mark (X) this column if entry in column (6) is confidential business information (CBJ). (8) --Indicate % of 

roduct volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) 

indin 9 --Mark X this column if ent ies in column 8 is are confidential business infonnation CBI . 

cate~~~e~~:edV: i!:fi~~S~:~; ;~~y:;iel:c;.~~r· a CBI ;~: :;;;, CBI Fonnu CBI 

0/3 lalion 

* non dispersive use 

{xi 

(2) (3) (4) (5) (6) (7) 

% 

% 

Site­

% ofsubstance expected per use 

(8) 

Cons~ Indus- Comlimited umer trial mercia! 

CBI 

Co-photoinitiator for UV-curable 

pigmentated inks· 

Co-photoinitiator for photoresists, 

optical fibers and printed plates· 

Co-photoinitiator for UV-curable 

coatings· 

Co-photoinitiator for uv-curable 

adhesives and other coatings* 

• 	 If you have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) of this chemical substance in consumer products. 

In addition include estimates orlhe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this 

substance loses its identity in the consumer product. 

Mark (X) this box if you attach a continuation sheet. 

b. Generic use 

description 

Ifyou claim any category ofuse description in subsection 2a as confidential, enter a generic description ofthat category. Read the Instruction 

Manual for examples of generic USe descriptions. 

Mark (X) this box if you attach a continuation sheet. 

3. Hazard Information -Include in the notice a copy ofreasonable facsimile ofany hazard warning statement, label, material safety data sheet, or other 

infonnation which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices for 

the safe handing, transport, use. or disposal ofthe new substance. List in part III hazard information you include. 

Mark (X) this box ifyou attach hazard information. 

Binding 

Option 

Mark {x} 

EPA FORM 7710-25 (Rev. 5-95) 	 Page 7 
PMN Page 8 ; Page 10 of 18 

Use D

Batches/year D 

Days/year 

2. Continuous D

d. Process description Mark (Xl to indicate your willingness to have your process description binding. 

(1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify. e.g. 5 gallon pails, 55 gallon 

drum, rail car, tank truck, etc.). 

(2) 	 Provide the identity, the approximate weight (by kg/day or kglbatch on a 100% new chemical substance basis), and entry point ofall starting materials and 

feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot 

used daily or per batch.). 

(3) 	 Identify by number the points of release, including small or intennittent releases, to the environment of the new chemical substance. If releasing to two media 

at the same step, assign a second release number for the second medium. 

see Att.#4 - Processing Information 

attach a continuation sheet. 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER 	 Mark (Xl the "Confidential" box next to any item you 

claim as confidential 

Confidential 

op1erauon involving the new ehemieal substance at industrial sites you 

the U.S.; however, you may still have reporting requirements if 

nrtu"p·«.na or use "n/·r~lr.nr•• 

ofthe site at which the will 

. . 

see Att.#3 - Manufacturing Information 

Site address (number and street) 

If the same operation will occur at more than one site, enter the number of sites. IdentilY the 

additional sites on a continuation sheet, and if any of the sites have significantly different 

production rates or operations, include all the information requested in this section for those 

sites as attachments. 

1. Batch 

substance; 

Maximum kg/day (100% new chemi,.1 Hours/day substance) 

EPA FORM 7710-25 (Rev. 5·95) 	 Page 8 
PMN Page 8a; Page 11 of 18 

Confidential 

D 


EPA FORM 7710-25 (Rev. 5-95) Page 8a 
PMN Page 9 ; Page 12 of 18 

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section A INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER - Continued 

2. Oecupational Exposure - You must make separnte confidentiality claims for the description of worker activity, physical fonn of the new chemical substance, number of 

works exposed, and duration of activity. Mark (X) the "Confidential" box next to any item you claim as confidential. 

(I) Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. 

(2) Mark (X) this column if entry in column (I) is confidential business infonnation (CBI). 

(3) -- Describe any protective equipment and engineering controls used to protect workers. 

(4) and (6) Indicate your willingness to have the infonnation provided in column (3) or (5) binding. 

(5) -- Indicate the physical fonn(s) of the new chemical substance (e.g., solid: crystal. granule. powder. or dust) and % new chemical substance (if part ofa mixture) at the 

ti me of exposure. 

(7) Mark (X) this column if entry in column (5) is confidential business infonnation (CBI). 

(8) -- Estimate the maximum number of workers involved in each activity for all sites combined. 

(9) -- Mark (X) this column if entry in column (8) is confidential business infonnation (CBI). 

(10) and (II) Estimate the maximum durntion ofthe activity for any worker in hours per day and days per year. 

(12) -­ Mark (X) this column if entries in columns (l 0) and Ill) are confidential business infonnation (CBI). 

Worker activity CBt Protective Equipment! Binding Physical Bind.ng est #of IeBI Maximum duration CSI 

forms(s) 

(i.e.• bag dumping. filling drums) Engineering Controls Oprion and% new Option Workers Brs/day Dayslyr 

Mark!x) substance Mark (x) 

Exposed I (9) 

(I) (2) (3) (4) (5) (6) (7) (8) ) (10) (II) (12) 

See Att.#5 D Occupational 

Exposure Information 

D D 

D 

D - ---­ r-­

D L....­ '-­

D D -

D -

-= r-­

D Mark (Xl this box ifyou attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5·95) Page 9 

PMN Page 9a; Page 13 of 18 

3. Environmental Release and Disposal-- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal infonnation. Mark (X) the "Confidential" box next to each item you claim as confidential. 

(1) -- Enter the number of each release point identified in the process description. part II. section A, subsection Id(3). 

(2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kglbatch). 

(3) -- Mark (X) this column if entries in columns (I) and (2) are confidential business infonnation (CBI). 

(4) --Identify the media (stack air, fugitive air (optional.see Instruction Manual), surface water, on·site or off-site land or incineration, POTW, or other (specify» to 

which the new substance will be released from that release point. 

(5) --a. Describe control technology, ifany, and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for 

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate the 

amount released to the environment after control technology (in kg/day). 

(6) -- Mark (X) this column if entries in columns (4) and (5) are confidential business infonnation (CHI). 

(7) --Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business infonnation (CHI). 

Release 

Number 

(I) 

Amount of new 

substance released 

CHI 

(3) 

Medium of 

release 

e.g.slilckair 

(4) 

Control technology and efficiency (you may wish to optionally attach 

efficiency data) 

CBI 

(6) 

(2a) (2b) 

(5a) 

Binding 

Mark 

X (5b) 

D Att.#6 - Environmental 

Release and Disposal 

Information D .--­

'--­

D D -

-

D D -

- r-­ D .--­

'--­

r--­ D .--­

'--­

[ D D 

D D D

[ D D 

D D D 

(7) Mark (X) the destination(s) of releases to water. NPDES # CBI 

D POTW--provide 

name(s) D 

0 Navigable waterway-­

provide name(s) D 

D Other--Specify 

D 

] Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 9a 
PMN Page 10; Page 14 of 18 

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this section for 

operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate section B for each type of 

processing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the typical operation common to these 

sites. Identify additional sites on a continuation sheet. 

l(a). Operation Description -- To claim information in this scction as confidcntial, circlc or brackct thc specific information that you claim as confidential. 

(I) -­ Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specity - e.g. 5 gallon pails, 55 gallon drums, rail 

cars, tank trucks, etc). On the diagram, identity by letter and briefly describe each worker activity. (2) -­ Either in the diagram or in the text field I(b) below, provide the 

identity, the approximate weight (by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and 

catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or per batch). (3) -­ Either in the diagram or in the 

text field l(b) below, identity by number the points of release, including small or intermittent releases. to the environment of the new chemical substance. (4) Please enter 

the # of sites (remember to identify the locations of these sites on a continuation sheet): 

# of sites CBI 

o 

Diagram the major unit operation steps and chemical conversions... 

l(b). (Optional) This space is for a text description to clarity the diagram above. 

see Att.#7 - Processing Information (other sites) o 

] Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 10 
PMN Page 10a ; Page 15 of 18 


2. Worker Exposure/Environmental Release 

(I) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) -- Estimate the number of workers exposed for all sites combined. 

(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. 

(6) -- Describe physical fonn of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect 

workers. 

(7) -- Estimate the percent ofthe new substance as fonnulated when packaged or used as a final product. 

(9) -- From the process diagram above, enter the number ofeach release point. Complete 9-13 for each release point identified. 

(10) -­ Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kglbatch). 

(12) -- Describe media ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration. POTW, or other (specify) 

and control technology, if any, that will be used to limit the release ofthe new substance to the environment. 

(14) -­ Identify byproducts which may result from the operation. 

(3), (5), (8, (II), 13) and (15) ­ Mark (X) this column ifany of the proceeding entries are confidential business information (CBI). 

Leue # of CHI Duration Of CBI Protective Equip. /Engineering Controls/Physical Form and/ % new substance % ill CSI 

of Worke!> Exposure FonnActi- Exposed ulation 

vity 

(I) (2) (3) (4a) (4b) (5) (6) (7) (8) 

D D 0 

I[ D 

D 

D r-­

Number 

Release 

[ Amount 

New 

of 

I[ ] 

CHI Media of Release & Control Technology Q Substance 

Released 

(9) lOa (lObi 12 13 

1 

0 

L 

0 

101 0 

14) -- Byproducts: (15) 

D 

0 Mark (X) Ihis box ifyou attach a continuation sheet, 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in the following section as confidential circle or bracket the specific information that you claim as confidential. 

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce or minimize potential risks 

associated with activities surrounding manufacturing, processing, use and disposal of the PMN substance. Please include new information 

pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new 

chemical substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, 

process and procedure modification, product reformulation, raw materials substitution, and/or inventory control. Recycling refers to the 

reclamation ofuseful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or 

land disposal. Descriptions ofpollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to 

compliance with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the information to 

assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or nonenvironmental areas (e.g., occupational or consumer exposure). In addition, information on the relative cost or performance characteristics of 

the PMN substance to potential alternatives may be provided. 

All information provided in this section will be taken into consideration during the review ofthis substance. See PMN Instructions 

Manual and Pollution Prevention Guidance manual for I/;uidance and examples. 

EPA FORM 7710-25 (Rev. 5-95) Page lOa 
PMN Page 11 ; Page 16 of 18 

Optional Pollution Prevention Information (Continued) Describe the expected net benefits, such as (I) an overall reduction in risk to 

human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation of waste materials 

through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental 

release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new 

chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new 

chemical substance may be a substitute for an existing substance that poses a greater overall risk to human health or the environment. 

CHI 

~ 

L J Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev. 5-95) Page 11 
PMN Page 12 ; Page 17 of 18 

Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form and test data and other data (including physical/chemical properties and 

structure/aetivity information), and optional information alter this page. Clearly identify the attachment and the section of the form to 

which it relates, if appropriate. Number consecutively the pages of any paper attachments. In the column below, enter the inclusive page 

numbers of each attachment. Electronic attachments can be identified by filename. 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on 

how to claim any information in an attachment as confidential. You must include with the sanitized copy of the notice form a sanitized 

version of any attaehment in which you claim information as confidential. 

# Attachment name 

MSDS 


1 


2 

3 


4 


5 


6 


7 


8 


1 9 

1 1 0 


11 


12 


13 

14 Technical Bullettin 

15 Air Pollution Reduction (Open literature) 

Attachment Filename 

6 

~ D 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

~ 

2 

15 

D 

D 

D 

D 

D 

r1Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number. 

EPA FORM 7710·25 (Rev. 5·95) Page 12 
PMN Page 13 ; Page 18 of 18 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice. IdentifY the property measured, the page of the notice on which the property appears, the value of the property, 

the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential. If the attachments 

are electronic, give the attachment number (found on page 12) at (b). The physical state of the neat substance should be provided. 

These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or 

fonnulations should be so noted (% PMN substance in _). You are not required to submit this worksheet; however, EPA strongly 

recommends that you do so, as it will simplifY review and ensure that confidential infonnation is properly protected. You should submit 

this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for submission of test data. 

Property 

(a) 

Mark (X 

ir 

provided 

Page Value 

number 

(b) (c) 

Measured 0 

Estimate 

(M orE) 

Conti· 

dential 

Mark: (X) 

(d) 

Physical state of neat substance [X] I2i(S) Dcn DCg) 0 

Vapor pressure 

@ Temperature °C [X] Torr 0 

Density/relative density [X] g/cm3 0 

Solubility 

@ Temperature °C 

Solvent 

D 

giL 

D 

Solubility in water@, Temperature °C [X] giL 0 

Melting temperature [X] °C 0 

Boiling / sublimation temperature@. torr pressure [X] °C 0 

Spectra [X] 0 

Dissociation constant D D 

Particle size distribution [X] 0 

Octanol / water partition coefficient [X] 0 

Henry's Law constant D D 

Volatilization from water D D 

Volatilization from soil D D 

pH@, concentration D D 

Flammability [X] 0 

E~lodability [X] 0 

Adsorption / coefficient D D 

Other - SpecifY [X] 0 

Other - Specify [Xl 0

D Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number. 

ATTACHMENT 

PAGE 13