U.S . ENVIRONMENTAL PROTECTION AGENCY 

 _ PRFMAN, F,Cr,IaF 

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in the Premanufacture Notice 

. 

GENERAL INSTRUCTIONS TS- P 0 1 

I=T 

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 complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or taxing 202-554-5603). 

If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226), P.O . 

360399M, Pittsburgh, PA 15251-6399, Attn . TSCA User fee. 

Part 1-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 to submit chemical identity information for you, but your submission will 

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

letter in support of your submission should reference your TS user fee identification 

number . You must submit an original and two copies of this notice including all test data . 

If you claimed any information as confidential, a single sanitized copy must also be 

submitted . 

Part 11-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part 11 . 

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

Part 11I - LIST OF ATTACHMENTS 

Attach additional sheets if there is not enough space to answer a question fully. Label 

each continuation sheet with the corresponding section heading . In Part II L list these 

attachments, any test data or other data and any optional information included in the 

notice . 

U.S . E.P .A . 401 M STREET, SW 

WASHINGTON, D.C . 20460 

101 

p .1 

Fonn Approved . O.M.B . No. 2070-0012 . Approval Expires 10-31-96 . 

Date of receipt 

AGENCY USE ONLY 

CS 

TEST DATA AND OTHER DATA 

You are 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 are related to the health and environmental effects on the manufacture, 

processing, distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

scientific literature . Complete test data (written in English), not summaries of data, 

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

identify whether test data is on the substance or on an analog. Also, the chemical 

composition of the tested material should be characterized. Following are 

examples of test data and other data . Data should be submitted according to the 

requirements of §720 .50 of the Premanufacture Notification Rule (40 CFR Part 

720). 

Test Data (Check Below any included in this notice) 

Environmental fate data D Yes " Other data E] Yes 

" Health effects data ® Yes Risk assessments 

" Environmental effects data 0 Yes Structure/activity relationships 

OPTIONAL INFORMATION 

You may include any information that you want EPA to consider in evaluating the new 

substance . On page 11 of this form, space has been provided for you to described 

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 TM EA. LV E . 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 fonn . 

CONFIDENTIALITY CLAIMS 

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

form, 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 

claim as confidential . If you claim information in the notices as confidential, you must 

also provide a sanitized version ofthe notice, (including attachmentsl. For additional 

instructions on claiming information as confidential, read the Instructions Manual . 

® Mark (x) if any information in this notice is claimed as confidential . 

cDn cnun,n 77tn IC ,D,.., c ncN 

Physical/Chemical Properties* 0 Yes Test data not in the possession 

or control of the submitter 

* A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One) 

® PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

LVE (Low Volume Exemption) (rg 40 CFR 723.50(c)(1) 

LOREX (Low Release'Low Exposure Exemption) (& 40 CFR 723 .50(c)(2) 

LVE Modification 

IS THIS A CONSOLIDATED PMN? 

LOREX Modification 

Yes 

N of chemicals 

(Prenotice Communication 4 required, enter #t on page 3) 

319944- 

09 JUN 19 

Company Sanitized 

1 

Docgme control umb4q - EPA case number/~ ~~ 

, 6 (f' T~'7ID~ 

D . ...1 .. .. ... . .- ...., . : . . .. .,r .: ... . .. ,.e cD A c,. ._.. 771 1) ~e 
Public reporting burden for this collection of information is estimated to average 1 10 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 

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

reducing this burden, to Chief, Information Policy Branch, PM-223, U.S . Environmental Protection Agency, 401 M . St ., S.W., Washington, D.C . 

20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503 . 

CERTIFICATION 

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

1 . The company named in Part I, section A, subsection 1 a of this notice form 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 information provided in this notice is complete and truthful as of the date of submission . 

3 . 1 am submitting with this notice all test data in my possession or control and a description of all 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, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 

statement that applies : 

® The Company named in Part 1, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 

F-1 The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 

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

F-1 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)(1) or a Low release 

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

statements : 

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 terms of 40 CFR 723.50. 

F~ The manufacturer is familiar with the terms of this section and will comply with those terms; and 

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

If this application is for an LVE in accordance with 40 CFR 723 .50(c)(1), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day 

review period . 

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance 

described herein . Any knowin g and willful misinterpretation is subject to criminal p enalty p ursuant to 18 USC 1001 . Confidential 

Signature and title of Authorized Official (Original Signature Required) Date 

X 

Signature of agent - (if applicable) Date 

.2 

EPA FORM 7710-25 (Rev . 5-95) Page 2 
p. 3 

Part I -- GENERAL INFORMATION 

Section A -- SUBMITTER IDENTIFICATION 

1a . Person Name of authorized official Position 

Submitting 

Notice (in U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

b. Agent (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

e. If you are submitting this notice as part of a joint submission, mark (X) this box. 

Joi nt Submitter (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

2. Technical Name of authorized official Position 

Contact (in X U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

3 . If you have had a prenotice communication (PC) concerning this notice 

and EPA assigned a PC Number to the notice, enter the number . Mark (X) -~ ® 

if none 

4 . If you previously submitted an exemption application for the chemical 

substance covered by this notice, enter the exemption number assigned by Mark (X) ~ ® 

EPA. If you previously submitted a PMN for this substance enter the if none PMN number assigned by EPA (i .e . withdrawn or incomplete).-~ 

5 . If you have submitted a notice of Bona fide intent to manufacture or import 

for the chemical substance covered by this notice, enter the notice number Mark (X) ~ ® 

assigned by EPA . ~ if none 

1 . ® Manufacture 2. ~ Import 

6. Type of Notice - Mark (X) Only Only 3. El Both 

Binding Option El Binding Option 

Mark (X) Mark (X) 

Mark () the "Confidential" box next to an subsection you claim as confidential 

Confidential 

EPA FORM 7710-25 (Rev . 5-95) Page 3 
p. 4 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on 

the ninth Collective Index (9CI) of CA nomenclature rules and conventions. 

Mark (X) the "Confidential" box next to an item you claim as confidential 

Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. 

If another person will submit chemical identity information for you (for either Item l or 2), mark (X) the box at the tight. ConfiIdentify the name, company, and address of that p erson in a continuation sheet . 0 dential 

1 . Class 1 or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

a. Class of substance - Mark (X) 1 [:] Class 1 or 2 [:] Class 2 

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances . 

For Class I substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA Preferred Name must 

be provided, which ever is appropriate based on CA 9C1 nomenclature rules and conventions) . 

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one) . 

Method 1 (CAS Inventory Expert Service - a copy of the Identification ~ Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

CAS# 

e . For a class 1 substance, provide a complete and correct chemical structure diagram. 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 of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure 

diaemm, as complete as can be known, if one can be reasonablv ascertained. 

****This page intentionally left blank.**** 

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

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

Part I -- GENERAL INFORMATION -- 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 of the polymer you intend to manufacture. 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and X 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC EI Other Fl : (Specify) 

i) lowest number average molecular weight : 

ii) maximum weight % below 500 molecular weight : 

iii) maximum weight % below 1000 molecular weight: 

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 infonnation. Mark ( X) the 

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

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

(2) - Mark (X) this column if entry in column (1) is confidential . 

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

(4) - Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the poly mer 

description on the TSCA Chemical Substance Inventory. 

(5) - Mark (X) this column if entries 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 manufactu red for 

commercial purposes . 

(7) - Mark (X) this column if entry in column (6) is confidential. 

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential 

(1) (2) (3) (4) (5) (6) (7) 

X % X % X 

X % X % X 

X % X % X 

X % X % X 

X % X % X 

X % X % X 

X °ia X % X 

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

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one). 

Method I (CAS Inventory Expert Service - a copy of the identification report ~ Method 2 (other source) X 

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this notice) 

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

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. 

X 

See Attachment 3 

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

EPA FORM 7710-25 (Rev . 5-95) Page 5 
p. 6 

Part I -- GENERAL INFORMATION -- 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 of the polymer you intend to manufacture. 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 

below [,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC E] Other 0: (Specify) 

i) lowest number average molecular weight: 

ii) maximum weight % below 500 molecular weight : 

iii) maximum weight % below 1000 molecular weight: 

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 

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of the polymer. 

. (2) - Mark (X) this column if entry in column (1) is confidential . 

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

(4) - Mark (X) the identity column 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 if entries 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. 

(7) - Mark (X) this column if entry in column (6) is confidential . 

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential 

(1) (2) (3) (4) (5) (6) (7) 

X °i° X X °i° X 

X °i° X X °i° X 

°i° °i° 

°i° °i° 

°i° °i° 

°i° % 

°i° °i° 

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

c . Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one). 

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

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this notice) 

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

c. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. 

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

EPA FORM 7710-25 (Rev . 5-95) Page 5 6~- 
p. 7 

Part I -- GENERAL INFORMATION -- Continued 

Section B--CHEMICAL IDENTITY INFORMATION--Continued 

3. Impurities 

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

CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." 

(b) - Estimate the maximum weight % of each im purity. If there are unidentified impurities, estimate their total weight %. 

Provide the 

Impurity and CAS Registry Number 

(a) 

Maximum 

percent 

(b) 

Confidential 

% X 

% 

% 

% 

% 

% _T % 

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

4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection I or 2. Confidential 

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

X 

5. Trade identification - List trade names for the new chemical substance identified in subsection t or 2. 

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

X 

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

the specific chemical identity of the 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. 

2-Propenoic acid, 2-methyl-, C12-15-branched and linear alkyl esters, telomers with Alkyl 2- 

[[(alkylthio)thioxomethyl]thio]-2-alkanoate, aminoalkyl methacrylate and alkyl methacrylate, tert-Bu 2- ethyl hexanoperoxoate-initiated 

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

7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry Number if available. 

Byproduct 

(I) 

CAS Registry Number 

(2) 

Confidential 

X 

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

EPA FORM 7710-25 (Rev . 5-95) Page 6 
p. 8 

Part I -- GENERAL INFORMATION -- Continued 

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: 

Mark (X) the "Confidential" box next to any item you claim as confidential . 

1 . 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 of production . 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, specify the volume and mark (x) in the bindin g box. If ranted, y ou are bound to this volume 

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

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

Mark (x) 

X 

2. Use Information -- You must make separate confidentiality claims for the description of the category of use, the percent of production 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 . (1) -- Describe each intended category of use of the new chemical substance by function and application . . 

(2) -- Mark (X) this column if entry column (1) is confidential business information (CBI). 

(3) -- Indicate your willingness to have the information provided in column (1) binding . 

(4) -- Estimate the percent of total production for the first three years devoted to each category of use. 

(5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI). 

(6) -- Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for 

commercial purposes at sites under your control associated with each category of use . 

(7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI). 

(8) -- Indicate % of product 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) binding . 

(9) -- Mark (X) this column if ent (ies) in column (8) is (are) confidential business information (CBI). 

Category of use (1) CBI B;nding 

Opuon 

Produc- CBI % in CBI % of substance expected per use CBI 

tion % Form- (8) 

(by function and application i .e. a dispersive dye Mu3 (<t ulation Site- Con-* Indus- Com- Binding for finishing polyester fibers) (2) (4) (5) (6) (7) limited sumer trial mercial Option (9) 

X 100% X 50% X 100 X 

n 

n u 

o n 

n a 

n 

n o 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed descri p tion of the use(s) o f thi s c h em i ca l su b stance i n consumer products . In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. 

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

b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the 

use Instructions Manual for examples of generic use descriptions . description Lubricant additive 

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

3. Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices Option 

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

Mark (x) 

® Mark (X) this box if you attach hazard information. 

EPA FORM 7710-25 (Rev. 5-95) Page 7 
p. 9 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

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

claim as confidential 

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you 

control . Importers do not have to complete this section for operations outside the U.S . ; however, you may still have reporting requirements if 

there are further industrial processin g or use o perations after import . You must describe these operations . See instructions manual 

l . Operation description Confia . Identity -- Enter the identity of the site at which the operation will occur. dential 

Name X 

Site address (number and street) 

City, County, State, ZIP code 

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

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

b. Type -- X 

Mark (X) DManufacturing OProcessing aUse 

c. Amount and Duration -- Complete 1 or 2 as a ro riate 

Maximum kg/batch (100°o new chemical Hours/batch Batches/year X 

substance) 

1 . Batch 18,750 28 4-8 

Maximum kg/batch (100% new chemical Hours/batch Batches/year 

substance) 

2. Continuous 

d. Process description El Mark (X) 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 kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and 

feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch.) . 

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance . 

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

EPA FORM 7710-25 (Rev . 5-95) Page 8 
p. 10 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued 

2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form 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 tilling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. 

(2) --Mark (X) this column if entry in column (l) is confidential business information (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 of a mixture) 

at the time of exposure . 

(7) -- Mark (X) this column if entry in column (5) is confidential business information (C131) . 

(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 information (CBI). 

(10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year. 

(12) -- Mark (X) this column if entries in columns (10) and (11) are confidential business infonnation (CBI). 

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu duration CBI 

m 

(i .e ., bag dumping, filling drums) Engineering Controls Option and % new Option Worker Hrs/day Days/yr 

Muk t`I substance Mat (x) s 

(1) (Z) (3) (4) (5) (6) (7) Expose (9) (t0) (tI) (IZ) 

d 

(8) 

X X X X 

X X X X 

X X X X 

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

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 . 

( I ) -- Enter the number of each release point identified in the process description, part 11, section A, subsection l d(3 ). 

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

(3) -- Mark (X) this column if entries in columns (1) 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, if any, 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 information (C131) . 

(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 (Publicl Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business infonnation (CBI). 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI 

Number released release 

( 1) (2a) (2b) e.g. cisck mr Binding (3) (4) (Sa) Mork(x) (Sb) (6) 

X X X 

2 X X X 

X X X 

(7) Mark (X) the ~ POTW provide name(s) below: CB1 

11 Navigable El Other - Specify provide NPDES # CBI 

destination(s) of waterway 

releases to water. 

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

EPA FORM 7710-25 (Rev . 5-95) Page 9 
p. 11 

Part II-- 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 ofprocessing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

ty pical operation common to these sites. Identify additional sites on a continuation sheet. 

1 . Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential . 

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

drums, rail cats, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity. (2) -- 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 if not used daily or per batch) . (3) -- Identify 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 

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

2. Worker Exposure/Environmental Release 

( l ) -- 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 of the new substance as fot7nulated when packaged or used as a final product . 

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

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

(12) -- Describe media of release 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 of the new substance to the environment. 

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

(3), (5), (8), (11), (13) and (l5) --Mark (X) this column if any of the proceeding entries are confidential business information (CBI). 

Letter # of CBI Duration CBI Protective Equip . / % in CBI Release Amount of CBI Media of Release CBI of 

ActWorkers 

Exposed 

of Engineering Controls/ Formi Number New & Control 

ivity 

Exposure Physical Form and o/a ulat on Substance Technology 

new substance Released 

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (106) (I1) (12) (13) 

( 14) -- Byproducts : (15) 

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

EPA FORM 7710-25 (Rev . 5-95) Page 10 
p. 12 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in this 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 of useful chemical components from wastes that would 

otherwise be treated or released as air emissions or water discharges, or land disposal. Descriptions of pollution 

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 non-environmental 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 of this 

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (1) 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. 

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

EPA FORM 7710-25 (Rev . 5-95) Page 11 
p. 13 

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/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to 

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

numbers of each attachment . 

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 an attachment in which you claim information as confidential . 

Attachment name Attachment 

a e number(s) 

Confidential 

Material Safety Data Sheet SDS 

14-19 

2. General comments 20 X 

3. Idealized structure 21 X 

4 . Inventory Expert Services Report 22 X 

5 . Occupational Exposure During Manufacture (Part II .A.2) 23-24 X 

6 . Worker Exposure (Part II .B.2) 25 X 

7 . Process Description 26 X 

8. Gel Permeation Chromatograms 27-34 X 

9. UV Spectrum 35-36 X 

10. Infrared Spectrum 37-39 X 

11 . NMR Analyses 40-42 X 

12 . Acute Oral Toxicity in the Rat 43-58 X 

13 . Reverse Mutation Assay "Ames Test" 59-91 X 

14 . Confidentiality Statement 92-101 X 

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

EPA FORM 7710-25 (Rev. 5-95) Page 12 
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. 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 formulations 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 

information 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) if 

provided 

Page 

number 

b 

( ) 

Value 

e) 

Measured o 

Estimate 

(M or E) 

Confideotial 

Mark(X) 

(d) 

Physical state of neat substance (s) X (1)- (g) M 

Vapor pressure 

@ Temperature °C Torr 

Density/relative density 0.9 g/cm3 E 

Solubility 

@ Temperature °C 

Solvent /L 

Solubility in water Temperature °C g/L 

Melting temperature 

Boiling / sublimation temperature cu torr pressure °C 

Spectra (UV-Vis, FTIR, NMR) X 35-42 M X 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

Volitalization from water 

Volitalization from soil 

_

pH @v concentration 

Flammability 

Explodability 

Adsorption / coefficient 

Other - Specify 

.14 

ATTACHMENT 

per_G 1111 
Pgge l of 6 

Material Safety Data Sheet 

TS-P0151T 

Prepared according to 29CFR 1910.1200. 

1 Chemical Product and Company Identification 

The Lubrizol Corporation 

29400 Lakeland Boulevard 

Wickliffe, Ohio 44092 

Tel: (440) 943-4200 

This material is to be used for research purposes only under the supervision of a technically qualified individual. The 

toxicological properties may have not been completely characterized. To determine your responsibilities under the Toxic 

Substances Control Act (TSCA), please see the Regulatory Information Section. If this material has been supplied to you 

under the terms of a secrecy or non-analysis agreement, the information included in this MSDS is hereby identified as 

"Confidential Information." 

Product Trade Name 

CAS Number 

Synonyms 

Generic Chemical Name 

Product Type 

Preparation/Revision Date 

Transportation Emergency 

Phone No. 

MSDS No. 

2 

Appearance 

Odor 

Principal Hazards 

TS-P0151T 

Unknown. 

None. 

Modified acrylic polymer 

Not applicable . 

16 June 2009 

FOR TRANSPORT EMERGENCY call CHEMTREC: (+1) 703-527-3887 (outside the 

U.S .), 1-800-424-9300 (in the U.S .) 

27340430-2512956-0027910-102103 

Hazards Identification 

Light amber liquid. 

Mild 

. This material has no known health hazards. 

See Section 11 for complete health hazard information. 

F 3 

Hazardous Ingredients 

4 

Eyes 

Composition/Information on Ingredients 

This material has no known hazards under applicable laws . 

First Aid Measures 

Flush with water at least 30 minutes. Get medical attention if eye irritation develops or 

persists . 

6/16/09 
Pgge $ of 6 

Skin 

Inhalation 

Oral 

Additional Information 

5 

Flash Point 

Extinguishing Media 

Firefighting Procedures 

Unusual Fire & Explosion 

Hazards 

F 6 

Spill Procedures 

7 

Pumping Temperature 

Maximum Handling 

Temperature 

Handling Procedures 

Maximum Storage 

Temperature 

Storage Procedures 

Loading Temperature 

8 

Exposure Limits 

Other Exposure Limits 

Engineering Controls 

Gloves Procedures 

Eye Protection 

Respiratory Protection 

Clothing Recommendation 

9 

Wash with soap and water. Get medical attention if irritation develops. Launder 

contaminated clothing before reuse. 

Remove exposed person to fresh air if adverse effects are observed. 

DO NOT INDUCE VOMITING. Get immediate medical attention. 

Note to physician: Treat symptomatically. 

Fire Fighting Measures 

> 110 °C, 230 °F PMCC (Minimum) 

C02, dry chemical, or foam. Water can be used to cool and protect exposed material . 

Recommend wearing self-contained breathing apparatus. Water may cause splattering. 

Not determined. 

rAccidental Release Measures 

Personal Protective Equipment must be worn, see Personal Protection Section for PPE 

recommendations. Ventilate area if spilled in confined space or other poorly ventilated areas. 

Prevent entry into sewers and waterways. Pick up free liquid for recycle and/or disposal . 

Residual liquid can be absorbed on inert material . 

Handling and Storage 

Not determined. 

Not determined. 

Keep containers closed when not in use. Wash thoroughly after handling . Empty container 

contains product residue which may exhibit hazards of product. , 

Not determined. 

No special storage precautions required . 

Not determined . 

Exposure Controls/Personal Protection 

None established 

Contains mineral oil. Under conditions which may generate mists, observe the OSHA PEL of 

5 mg per cubic meter, ACGIH STEL of 10 mg per cubic meter. 

Use with adequate ventilation. 

Use nitrile or neoprene gloves . 

Safety Glasses. 

Use NIOSH/MSHA approved respirator with a combination organic vapor and high 

efficiency filter cartridge if recommended exposure limit is exceeded . Use self-contained 

breathing apparatus for entry into confined space, for other poorly ventilated areas and for 

large spill clean-up sites. 

Long sleeve shirt is recommended. Launder contaminated clothing before reuse. 

Physical and Chemical Properties 

Flash Point > 110 °C, 230 °F PMCC (Minimum) 
Pa'ge 3 of 6 

Upper Flammable Limit 

Lower Flammable Limit 

Autoignition Point 

Explosion Data 

Vapor Pressure 

pH 

Specific Gravity 

Bulk Density 

Water Solubility 

Percent Solid 

Percent Volatile 

Volatile Organic Compound 

Vapor Density 

Evaporation Rate 

Odor 

Appearance 

Viscosity 

Odor Threshold 

Boiling Point 

Pour Point Temperature 

Melting / Freezing Point 

10 

Stability 

Decomposition Temperature 

Incompatibility 

Polymerization 

Thermal Decomposition 

Conditions to Avoid 

11 

Eye Irritation 

Skin Irritation 

Respiratory Irritation 

Dermal Toxicity 

Inhalation Toxicity 

Oral Toxicity 

Dermal Sensitization 

Not determined . 

Not determined . 

Not determined . 

Material does not have explosive properties . 

Not determined. 

Not determined. 

0.93 (15.6 °C) 

Not determined. 

Insoluble. 

Not determined . 

Not determined . 

Not determined . 

Not determined . 

Not determined. 

Mild 

Light amber liquid . 

Not determined. 

Not determined. 

Not determined. 

Not determined. 

Not determined . 

The above data are typical values and do not constitute a specification. Vapor pressure 

data are calculated unless otherwise noted. 

Stability and Reactivity 

Material is normally stable at moderately elevated temperatures and pressures. 

Not determined. 

Oxidizing agents . 

Will not occur. 

Smoke, carbon monoxide, carbon dioxide, aldehydes and other products of incomplete 

combustion. 

Not determined. 

[Toxicological Information 1 --- 

-- ACUTE EXPOSURE -- 

Not expected to cause eye irritation Based on data from components or similar materials. 

Not expected to be a primary skin irritant . Based on data from components or similar 

mateials . Prolonged or repeated skin contact as from clothing wet with material may cause 

dermatitis . Symptoms may include redness, edema, drying, and cracking of the skin . 

If material is misted or if vapors are generated from heating, exposure may cause irritation of 

mucous membranes and the upper respiratory tract. Based on data from components or 

similar materials. 

The LD50 in rabbits is > 2000 mg/Kg. Based on data from components or similar materials. 

No data available to indicate product or components may be a toxic inhalation hazard. 

The LD50 in rats is > 2000 mg/Kg. Based on actual data. 

No data available to indicate product or components may be a skin sensitizer . 
Pz'gA of 6 

Inhalation Sensitization No data available to indicate product or components may be respiratory sensitizers. 

-- CHRONIC EXPOSURE -- 

Chronic Toxicity No data available to indicate product or components present at greater than 1% are chronic 

health hazards. 

Carcinogenicity This product contains mineral oils which are considered to be severely refined and not 

considered to be carcinogenic under IARC. All of the oils in this product have been 

demonstrated to contain less than 3% extractables by the IP 346 test . 

Mutagenicity No data available to indicate product or any components present at greater than 0.1% are 

mutagenic or genotoxic. 

Reproductive Toxicity No data available to indicate either product or components present at greater than 0.1°/o that 

may cause reproductive toxicity . 

Teratogenicity No data available to indicate product or any components contained at greater than 0.1% may 

cause birth defects. 

-- ADDITIONAL INFORMATION -- 

Other No other health hazards known. 

12 Ecol ogical Information 

-- ENVIRONMENTAL TOXICITY -- 

Freshwater Fish Toxicity Not determined . 

Freshwater Invertebrates Not determined. 

Toxicity 

Algal Inhibition Not determined. 

Saltwater Fish Toxicity Not determined. 

Saltwater Invertebrates Not determined. Toxicity 

Bacteria Toxicity Not determined. 

Miscellaneous Toxicity Not determined. 

-- ENVIRONMENTAL FATE -- 

Biodegradation Adequate data is not available to estimate the biodegradation potential of this material . 

Bioaccumulation There is no data available to evaluate this material for bioconcentration. 

Soil Mobility Not determined . 

13 Disposal Considerations 

Waste Disposal This material, if discarded, is not a hazardous waste under RCRA Regulation 40 CFR 261 . 

Treatment, storage, transportation, and disposal must be in accordance with applicable 

Federal, State/Provincial, and Local regulations. 

14 I Transport Information 

ICAO/IATA I Not regulated. 

ICAO/IATA II Not regulated. 

IMDG Not regulated. 

IMDG EMS Fire Not applicable . 

IMDG EMS Spill Not applicable . 

IMDG MFAG Not applicable . 

6/16/09 
PAA of 6 

MARPOL Annex II 

USCG Compatibility 

U.S. DOT Bulk 

U.S. DOT Non-Bulk 

DOT NAERG 

TDG Bulk 

TDG Non-Bulk 

Mexico 

Mexico Non-Bulk 

Bulk Quantity 

Non-Bulk Quantity 

115 

USA 

Other TSCA Reg. 

EU 

Japan 

Australia 

New Zealand 

Canada 

Switzerland 

Korea 

Philippines 

China 

SARA Ext. Haz. Subst. 

SARA Section 313 

SARA 311 Classifications 

CERCLA Hazardous 

Substances 

FDA Approval 

Not determined. 

Not determined. 

Not regulated. 

Not regulated. 

Not applicable . 

Not regulated. 

Not regulated. 

Not regulated. 

Not regulated. 

85000 liters, 22457 gal. 

207.8 liters, 55 gal. 

Review classification requirements before shipping materials at elevated temperatures. 

Regulatory Information 

-- Global Chemical Inventories -- 

Requires notification in the U.S . Commercial shipments from Lubrizol's U.S . location must 

be exported to non U.S . customers only . Research and development quantities must bear 

special labels and shipping papers. Sample recipients must comply with the requirements for 

an R&D exemption under TSCA. 

None known. 

All components are in compliance with the EC Seventh amendment Directive 92 /32/EEC. 

This product requires notification in Japan. 

This product requires notification before sale in Australia. 

This product requires notification before sale in New Zealand. 

This product requires notification before sale in Canada. 

All components are in compliance with the Environmentally Hazardous Substances 

Ordinance in Switzerland. 

This product requires notification before sale in Korea. 

All components are in compliance with the Philippines Toxic Substances and Hazardous and 

Nuclear Wastes Control Act of 1990 (R.A. 6969). 

This product requires notification in China. 

-- Other U.S . Federal Regulations -- 

This product does not contain greater than 1 .0% of any chemical substance on the SARA 

Extremely Hazardous Substances list . 

This product does not contain greater than 1 .0% (greater than 0 .1% for carcinogenic 

substance) of any chemical substances listed under SARA Section 313. 

Acute Hazard No 

Chronic Hazard No 

Fire Hazard No 

Reactivity Hazard No 

None known. 

Not applicable . 

-- State Regulations -- 

Cal. Prop. 65 This product does not intentionally contain any chemicals known by the State of California to 

6/16/09 
PAA of 6 

cause cancer and/or birth defects. Moreover, we do not routinely analyze its products for 

impurities which may be such chemicals. 

-- Product Registrations --

U.S. Fuel Registration Not applicable . 

U.S . Dept of Agriculture This product has not been filed with the USDA to support H2 approvals. 

NSF Nonfood Compounds This product has not been filed with the NSF to support H1 or H2 approvals . 

Registration 

Finnish Registration 

Number 

Swedish Registration 

Number 

Norwegian Registration 

Number 

Not Registered 

Not Registered 

Not Registered 

Danish Registration Not Registered 

Number 

Swiss Registration Number Not Registered 

Italian Registration Number Not Registered 

Korean Registration 

Number Not Registered 

-- Other / International -- 

TDG Regulated Limit. None known. 

16 Other Information 

US NFPA Codes 

HMIS Codes 

Precautionary Labels 

Health Fire Reactivity Special 

1 1 0 ~ N/E 

(N/E) - None established 

Health Fire Reactivity 

1 1 0 

. This material has no known health hazards. 

Revision Indicators This MSDS has no revisions since 16 June 2009 

As the conditions or methods of use are beyond our control, we do not assume any responsibility and expressly disclaim any liability 

for any use of this product. Information contained herein is believed to be true and accurate but all statements or suggestions are made 

without warranty, expressed or implied, regarding accuracy of the information, the hazards connected with the use of the material or 

the results to be obtained from the use thereof. Compliance with all applicable federal, state, and local regulations remains the 

responsibility of the user. 

6/16/09 
ATTACHMENT 2 

General Comments 

Page 20 
ATTACHMENT 3 

Idealized Structure 

Page 21 
ATTACHMENT 4 

Inventory Expert Services Report 

Page 22 
ATTACHMENT 5 

Occupational Exposure During Manufacture (Part II .A.2) 

Pages 23-24 
ATTACHMENT 6 

Worker Exposure (Part II .B .2) 

Page 25 
ATTACHMENT 7 

Process Description 

Pages 26 
ATTACHMENT 8 

Gel Permeation Chromatogram 

Pages 27-34 
ATTACHMENT 9 

UV Spectrum 

Pages 35-36 
ATTACHMENT 10 

Infrared Spectrum 

Pages 37-39 
ATTACHMENT 11 

NMR Analyses 

Pages 40-42 
ATTACHMENT 12 

Acute Oral Toxicity in the Rat 

Pages 43-58 
ATTACHMENT 13 

Reverse Mutation Assay "Ames Test" 

Pages 59-91 
ATTACHMENT 14 

Confidentiality Statement 

Pages 92-101