Univar 

17425 NE Union Hill Rd. 

Redmond, WA 98052 

USA 

T 425 889-3707 

F 425 889-3760 

www.univarusa .com 

March 8, 2011 

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REC'D MAR 15 2011 

CONTAINS NO CONFIDENTIAL 

BUSINESS INFORMATION 

By Federal Express 

Document Control Office (7407M) 

Office of Pollution Control and Toxics 

U .S . Environmental Protection Agency 

EPA East Building 

Room E6428 

1201 Constitution Ave ., NW 

Washington, DC 20460 

Attention : TSCA Section 4 

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Re: Letter of Intent to Conduct Testing Submitted by Univar USA under the TSCA Section 4 

Test Rule on the Testing of Certain High Production Volume Chemicals: Second Group 

Ethanedioic acid [CAS RN 144-62-7] 

Docket Identification No. EPA-HO-OPPT-2007-0531 ; 40 CFR 799.5087 

Dear Sir/Madam : 

Through this letter, Univar USA Inc . (Univar or the Company) submits to the U .S. Environmental 

Protection Agency (EPA or the Agency) the Company's intent to conduct testing on the chemical 

substance, ethanedioic acid [CAS RN 144-62-7], under the Agency's Toxic Substances Control Act (TSCA) Section 4(a)(1)(B) test rule published on January 7, 2011 . Univar files its intent to conduct 

testing in accordance with this final rule and the regulations set forth at 40 CFR 799.5087. 

The Company understands that this letter of intent to conduct testing must be received by EPA on or 

before March 9, 2011 . In the Agency's final rule, this date was incorrectly identified as February 7, 

2011, but corrected in a technical correction published by EPA on January 26, 2011 .2 

As a matter of background, this final test rule addresses 19 high production volume (HPV) chemicals 

that went unsponsored under the Agency's voluntary HPV Chemical Challenge Program. One of the 

19 chemicals identified in the rule is ethanedioic acid .3 The rule requires manufacturers, importers, 

1 76 Fed. Re~g. 1067 . 

2 76 Fed. Re. 4549. 

3 This compound is also identified as oxalic acid . CONTA!Nr `-`-) CBI 
p. 2 

and,processors of these HPV chemicals to conduct testing to obtain screening level data for human 

health effects, environmental effects, chemical fate, and physical/chemical properties. 

The Agency has issued this test rule under its TSCA Section 4(a)(1)(B) authority based on its belief 

that HPV compounds, including ethanedioic acid, are "produced in substantial quantities; there is or 

may be substantial human exposure to them; existing data are insufficient to determine or predict 

their health and environmental effects; and testing is necessary to develop such data."4 

In general, the final rule identifies the following studies on ethanedioic acid: 

. 

. 

Melting Point 

Boiling Point 

Vapor Pressure 

Water Solubility 

Ready Biodegradation 

Aquatic Toxicity Testing (acute toxicity to fish, acute toxicity to Daphnia, toxicity to plants (algae))' 

In Vitro Mammalian Chromosomal Aberration Test 

* * 

Univar, therefore, submits its intent to conduct testing on ethanedioic acid in accordance with the final 

rule described herein and the regulations set forth at 40 CFR 799.5087. 

For all questions and comments concerning this matter, please contact Univar's TSCA consultant: 

Mr. John V. Massingale 

Greenwich Chemical Consulting, Inc. 

3300 PGA Boulevard, Suite 635 

Palm Beach Gardens, FL 33410 

Telephone : (561) 578-8110 

Facsimile : (561) 578-8120 ' 

E-mail: john ,grcci .com 

Sincerely, 

Thomas Biggs 

Director of International Sourcing 

cc: Ms . K. Gilje - Univar 

Mr. J. Massingale - Greenwich Chemical Consulting 

+ _Id . at 1069. 

5 Test Group 1 .