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1850 M Street NW • Suite 700 • Washington, DC • 20036

Phone: 202-721-4157 • Fax: 202-296-8120

September 4, 2015

Document Control Office (7405M)

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

Attention: 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, Sulfated, Sodium Salt, CAS 

No. 68187-76-8

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 

Sulfated 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 & Affiliates (SOCMA), is pleased to provide 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, Sulfated, sodium Salt, CAS No. 68187-76-8:

Afton Chemical Corporation

Manufacturers Chemical, LLC

Emerald Carolina Chemical LLC

The SCO has conducted testing in accordance with the EPA-approved Test Plan and offers the 

following studies:
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1850 M Street NW • Suite 700 • Washington, DC • 20036

Phone: 202-721-4157 • 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 Properties of Castor Oil, Sulfated, Sodium Salt, 75%

3. Acute Toxicity Study in Daphnia 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, Sulfated, Sodium Salt, 75%

6. Assessment of Acute Oral Toxicity with Castor Oil, Sulfated, Sodium Salt, 75% in the Rat 

(Up and Down Procedure)

7. Evaluation of the Mutagenic Activity of Castor Oil Sulfated, Sodium Salt, 75% in the

Salmonella typhimurium Reverse Mutation Assay and the Escherichia coli Reverse 

Mutation Assay (With Independent Repeat)

8. Evaluation of the Ability of Castor Oil, Sulfated, Sodium Salt, 75% to Induce 

Chromosome Aberrations 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 

Toxicity Screening Test of Castor Oil, Sulfated, Sodium Salt, 75% in Rats by Oral Gavage

These studies are being submitted in electronic format on a CD due to difficulties encountered 

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

Enclosed: Castor Oil, Sulfated, Sodium Salt; Test Plan Studies