p. 1 

August 16, 2004 

Document Control Officer 

Office of Pollution Prevention and Toxic 

Substances, 7407 

U.S. EPA 

1201 Constitution Ave., NW 

Washington, DC 20460 

Company Sanitized 

RE: Significant New Use Notice (SNUN) TS-04NEG1 

Dear Sir or Madam: 

On behalf of the [ 

] is hereby submitting in accordance with 40 CFR Section 721.25 the 

attached Significant New Use Notice (SNUN) TS-04NEG1 for review. 

The SNUN substance is regulated under 40 CFR §721.9892. 

In accordance with 40 CFR Section 700.45(b), the fee of $2,500.00 has 

been submitted (see attached copy of check). 

This SNUN notification contains confidential business information (CBI). 

Accordingly, in addition to the submission of the original notification and two 

copies, a single sanitized copy is also provided. 

Finally, the PMN form used is an electronic version purchased from CMA. 

The document showing EPA approval of the form is attached. 

If there are any questions regarding this submission, please do not hesitate 

to contact me at [ ]. 

Sincerely, 

Attachments 

7;7 004 
II II 

\<Mitix 

4 I I I II 101 4 1 1 101 101 101 101 101 14 1 11 II 

Document Control Officer 

Office of Pollution Prevention and Toxic 

Substances, 7407 

U.S. EPA 

1201 Constitution Ave., NW 

Washington, DC 20460 

RE: Significant New Use Notice (SNUN) TS-04NEG1/SN-04-03: 

Additional Exposure Information 

Dear Sir or Madam: 

On behalf of the [ 

] is hereby submitting additional exposure information for the 

Significant New Use Notice (SNUN) TS-04NEG1/SN-04-03 that is under review. 

The additional exposure information is found on pages 10c-f. In addition, 

the following corrected SNUN form pages are included: pages 1, 10, 12. 

This SNUN notification contains confidential business information (CBI). 

Accordingly, three confidential copies and a single sanitized copy are provided. 

If there are any questions regarding this submission, please do not hesitate 

to contact me at [ ]. 

Sincerely, 

Company Sanitized 

SO 3 

"--To 

CD 

Attachments 

gr September 7, 2004 

(V L1 r7fc7 a 

p. 2 
Form Approved. O.M.B. No. 2070-0012. Approlcla Expires 10-31-96 

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

Date of receipt 

gEPA PREMANUFACTURE 

NOTICE 

FOR NEW CHEMICAL SUBSTANCES 

PECFIVTD 

04 SEP --7 10: 3 ■ loo DOCUMENT CONTROL OFFICER 

OFFICE OF POLLUTION PREVENTION 

AND TOXIC SUBSTANCES, 7407 

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

WASHINGTON, D.C. 20460 

When 

completed 

send this 

form to 

Enter the total number of pages 27 

in the Premanufacture Notice 

Document control number I PA case mimber 

GENERAL INSTRUCTIONS TS - 0 4 

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 faxing 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 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 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 II — 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 III — 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 HI, list these 

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

notice. 

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 descfibed 

pollution prevention and recycling information you may have regarding the new 

substance. 

So-called "bindine 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 

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, von must 

also provide a sanitized version of the notice. (including attachments). For additional 

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

I,X1 Mark (x) if any information in this notice is claimed as confidential. 

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 0 Yes Other data 0 Yes 

• Health effects data 0 Yes Risk assessments 

• Environmental effects data 0 Yes Structure/activity relationships 

• 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) 

LI PMN (Premanufacture Notice) 

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

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

LVE (Low Volume Exemption) @ 40 CFR 723.50(W) 

LOREX (Low Release/Low Exposure Exemption) (a) 40 CFR 723.50(c)(2) 

LVE Modification I I LOREX Modification 

IS THIS A CONSOLIDATED PMN? I j Yes 

# of chemicals 

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

Aftk_Ato7g 75- 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 
gEPA PREMANUFACTURE 

NOTICE 

11 1 111 11 1 1' 5' 11 it ' ll 

4 (i 4 ■1 ■J 

TYPE OF NOTICE (Check Only One) 

LVE Modification I I 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

z SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) 

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

LOREX (Low Release/Low Exposure Exemption) @4(t).-.CFR 723.50(c)(2) 

LOREX Modification 

Form Approved. 0.MB. No. 2070-0012. Ap eival Expires 10-31-96 

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

Date of receipt 

ICES Company Sanitized 

r 

in the Premanufacture Notice 

GENERAL INSTRUCTIONS TS - 

• 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 faxing 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 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 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 II — 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 III — 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 III, list these 

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

notice. 

OPTIONAL INFORMATION 

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

substance. On page I I 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 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 

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 of the notice (including attachments). For additional 

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

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

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 anoear 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 0 Yes Other data 0 Yes 

Health effects data 0 Yes Risk assessments 

Environmental effects data 0 Yes Structure/activity relationships 

Physical/Chemical Properties* 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. 

IS THIS A CONSOLIDATED PMN? Yes 

# of chemicals 

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

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 

7,7st3 64 
Public reporting burden for this collection of information 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 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 la of this notice form 

commercial purpose, other than in small quantities solely for research and 

Section B. 

2. All information provided in this notice is complete and truthful as of the 

3. I am submitting with this notice all test data in my possession or control 

reasonably ascertainable by me as required by §720.50 of the Premanufacture 

Additional Certification Statements: 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, 

statement that applies: 

intends to manufacture or import 

development, the substance identified 

date of submission. 

and a description of all other data known 

Notification Rule. 

check the following user fee certification 

specified in 40 CFR 700.45(b), or 

for an Intermediate PMN (defmed @ 

40 CFR 700.43 and has remitted 

with 40 CFR 723.50(c)(1) or a 

723.50(c)(2), check the following 

the new chemical substance for commercial 

under the terms of 40 CFR 723.50. 

with those terms; and 

applicable exemption conditions. 

the manufacturer intends to commence 

1 year of the date of the expiration of 

ed facts regarding the chemical substance 

USC 1001. 

for a 

in Part I, 

to or 

40 CFR 

a fee of $100 in 

Low release 

certification 

the 30 day 

I The Company named in Part I, Section A has remitted the fee of $2500 

fl The Company named in Part I, Section A has remitted the fee of $1000 

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

The Company named in Part I Section A is a small business concern under 

accordance with 40 CFR 700.45(b). 

If you are submitting a low volume exemption (LVE) application in accordance 

and low exposure exemption (LoRex) application in accordance with 40 CFR 

statements: 

The manufacturer submitting this notice intends to manufacture or import 

purposes, other than in small quantities solely for research and development, 

The manufacturer is familiar with the terms of this section and will comply 

The new chemical substance for which the notice is submitted meets all 

If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), 

manufacture of the exempted substance for commercial purposes within 

review period. 

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipa 

described herein. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 Confidential 

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

X 

Signature of agent - (if applicable) Date 

X 

EPA FORM 7710-25 (Rev. 5-95) Page 2 
Part I -- GENERAL INFORMATION 

Section A — SUBMITFER IDENTIFICATION ConfiMark 0 the "Confidential" box next to any subsection you claim as confiden ial dential 

la. Person Name of authorized official 

Submitting 

Notice (in U.S.) 

Position 

X 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

b. Agent (if Name of authorized official Position 

applicable) X 

Company 

Mailing address number and street) 

City, State, ZIP Code Telephone At es Code Number 

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

fl 

Joint Submitter (if Name of authorized official 

applicable) 

Position 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code N umber 

2. Technical Name of authorized official 

Contact (in 

U.S.) 

Position 

X 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Arca Code Number 

3. II 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 

EPA. If you previously submitted a PMN for this substance enter the .■ 

Mark (X) —0Pif none 

PMN number assigned by EPA (i.e. withdrawn or incomplet,). • 

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 

assigned by EPA. • 

Mark 

, 

(X) —10. 

if none 

1. Manufacture 

6. Type of Notice - Mark (X) Only 

1 Binding Option 

2. Import 

Only 

Binding Option 

Mark (X) 

3. 130th 

EPA FORM 7710-25 (Rev. 5-95) Page 3 
P. 7 

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 any item you claim as confidential 

Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) 

If another person will submit chemical identity information for 

Identify the name, company, and address of that person in a continuation 

as appropriate. Complete all other items. 

you (for either Item 1 or 2), mark (X) the box at the right. 

sheet. ■ 0 

con ndential 

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

a. Class of substance - Mark (X) I Class 1 or 2 Class 2 X 

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

For Class 1 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 9CI nomenclature rules and conventions). 

X 

c Please identify which method you used to develop or obtain the 

Method 1 (CAS Inventory Expert Service - a copy of the 

report obtained from the CAS Inventory Expert Services 

submitted as an attachment to this notice) 

specified chemical identity information reported in this notice: (check one). 

Identification Method 2 (Other Source) 

must be 

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

X 

CAS# 

X 

c. For a class 1 substance, provide a complete and correct chemica 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 

diagram. as comnlete as can he known, if one can be reasonably ascertained. 

See page 4a 

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

EPA FORM 7710-25 (Rev. 5-95) Page 4 
STN Easy: Display Page Pave 1 of 2 • 

Display without Links I Return to Results 

Display from REGISTRY 

ANSWER 1 @ 2004 ACS on STN 

REGI.ERY 

Search for information related to CAS RN L 3n these categories: 

• Agriculture [$2.00] 

• Biotechnology [$2.00] 

• Business [$2.00] 

• Chemical Catalogs [$2.00] 

• Chemistry References [$2.00] 

Restricted to: 

Page 4a 

http://stneasy.cas.org/tmp/20040813/802870-1015413984-200/493491957.html 8/13/2004 
P. 9 

Part I -- GENERAL INFORMATION -- Continued 

Section B — CHEMICAL IDENTITY INFORMATION — Continued 

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

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer 

Indicate maximum weight percent of low molecular weight species (not including residual 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC 

i) lowest number average molecular weight: 

you intend 

monomers, reactants, 

Other : (Specify) 

to manufacture. 

or solvents) below 500 and 

not applicable 

Confidential 

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 

(I) - 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 

(I) 

Contidential 

(2) 

Typical 

composition 

(3) 

Identity 

Mark (X) 

(4) 

Confidential 

(5) 

Maximum 

residual 

(6) 

Confidential 

(7) 

% % 

% % 

% % 

% % 

% % 

% % 

% % 

LI 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) 

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. 

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

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

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

6 
p. 10 

. 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. Provide the 

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

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

Impurity and CAS Registry Number 

(a) 

Maximum 

percent 

(13) 

Contiderwal 

X 

'N) 

% 

% 

% 

% 

I I 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. ConncicnHal 

X 

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

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

Eli 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. 

Alkylated urea 

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

7. I typroducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry 

Number if available. 

Byproduct 

(1) 

CAS Registry Number 

(2) 

Confidential 

X 

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

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

7 
p. 11 

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 

kg/yr, specify the volume and mark (x) in the binding box. If granted, you are bound to this volume 

Maximum first 12-month production (kg/yr) 

(100% new chemical substance basis) 

Maximum 12-month production (kg/yr) 

(100% new chemical substance basis) dential 

Conti- Binding 

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. (I) -- 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 entry(ies) in column (8) is (are) confidential business information (CBI). 

Category of use (1) 

(by function and application i.e. a dispersive dye 

for finishing polyester fibers) 

CBI 

(2) 

Binding 

Option 

Mark (x) 

(3) 

Production % 

(4) 

CBI 

(5) 

% in 

Formulation 

(6) 

CBI 

(7) 

% of substance expected per use 

(8) 

CBI 

(9) 

Site1 imited Con-* 

sumer 

Industrial Cornmercial Binding 

Option 

X 

04., 

X 

cvn 

X X 

04., % 

oh, cv,, 

04 0A 

.4, % 

% % 

04 ox, 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in 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. riMark (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 printing ink ingredient 

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 

information 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 of the new substance. List in part III hazard information you include. 

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

Binding 

Option 

Mark (x) 

EPA FOR/vl 7710-25 (Rev. 5-95) Page 7 
p. 12 

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 processing or use operations after import. You must describe these operations. See instructions manual 

1. Operation description 

a. Identity -- Enter the identity of the site at which the operation will occur. 

Confitlential 

Name 

not applicable 

Site address (number and street) 

City, County, State, ZIP code 

If the same operation will occur at more than one site, enter the number 

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

production rates or operations, include all the information requested 

sites as attachments. 

of sites. Identify the 

significantly different 

in this section for those 

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

b. Type -- 

Mark (X) flManufacturing LjjlProcessing EUse 

c. Amount and Duration -- Complete 1 or 2 as appropriate 

1. Batch 

maximum kg/batch (100% new chemical 

substance) 

Hours/batch Batches/year 

2. Continuous 

Maximum kg/batch (100% new chemical 

substance) 

Hours/batch Batches/year 

d. Process description 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 

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 

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

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. 

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

gallon 

and 

if not 

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

(1) -- 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 (1) 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 information provided in column (3) or (5) binding. 

(5) -- Indicate the physical form(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 (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 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 co umns (10) and (11) are confidential business information (CBI). 

Worker activity 

(i.e., bag dumping, filling drums) 

(1) 

CBI 

(2) 

Protective Equipment/ 

Engineering Controls 

(3) 

Binding 

Option 

Mark (x) 

(4) 

Physical forms(s) 

and % new 

substance 

(5) 

Binding 

Option 

Mark (x) 

(6) 

CBI 

(7) i 

# of 

Worker 

S 

Expose 

d 

(8) 

CBI 

(9) 

Maximu 

m 

duration CBI 

(12) 

Hrs/day 

(10) 

Days/yr 

(11)

not applicable 

I I 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 information. 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 I 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 information (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 (CBI). 

(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 information (CBI). 

Release 

Number 

( 1) 

Amount of new substance 

released 

( '131 

(3) 

Media of 

release 

e.g. stack dir 

(4) 

Control technology and efficiency (you may wish to optionally attach efficiency data) CBI 

(6) 

(2a) (2b) 

(5a) 

Binding 

Mark (X) (5b) 

not applicable 

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

destination(s) of 

releases to water. 

CBI Navigable Other - Specify 

waterway 

provide NPDES # ('13I 

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

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

1 0 
p. 14 

. 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 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. 

I. 

[ 

(1) 

(by 

products, 

including 

these 

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

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

drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) — Provide the identity, 

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

recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Identify by number 

small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify 

sites on a continuation sheet): 

1 

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

as confidential. 

gallon pails, 55 gallon 

the approximate weight 

etc) and all 

the points of release, 

the locations 

[ I 

of 

# of sites 

■ 

2. Worker Exposure/Environmental Release 

(1) --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 form 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 formulated 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 (15) -- Mark (X) this column if any of the proceeding entries are confidential business information (CBI) 

Letter 

of 

Activity 

(1) 

# of 

Workers 

Exposed 

(2) 

CBI 

(3) 

Duration 

of 

Exposure 

CBI 

(5) 

Protective Equip. / 

Engineering Controls/ 

Physical Fo rm and % 

new substance 

(6) 

% in 

Formulation 

(7) 

CBI 

(8) 

Release 

Number 

(9) 

Amount of 

New 

Substance 

Released 

CBI 

(11)

Media of Release 

& Control 

Technology 

(12)

CBI 

(4a) (4b) (10a) (10b) (13)

X X X X X 

X X X X X 

(14) -- Byproducts: (15)

X 

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

EPA FORM 7710-25 (Rev. 5-95) Page 10 
t g 

p. 15 
p, 16 
p. 17 

Page 10c 
p. 18 

Page 10d 
p. 19 

Page 1 e 
p. 20 

Page 10f 
p. 21 

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. 

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

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

'If. 
p. 22 

Part HI -- 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 any attachment in which you claim information as confidential. 

Attachment name Attachment 

page number(s) 

Confidential 

Material Safety Data Sheet (MSDS) 

1 4-1 8 

Use and exposure information 1 Oa - f 

Chemical identity information 4a 

SNUN fee documentation 19 

CMA electronic PMN form documentation 20 

Physical and chemical properties 13 

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 
p. 23 

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 

SNUN substance = 45-55% concentration (a) 

Mark 

(X) if 

provided 

Page 

number 

(b) 

Value 

(c) 

Measured or 

Estimate 

(M or E) 

Contidential 

Mark (X) 

(d) 

Physical state of neat substance X 16 (s) X__ (1) (8) M 

Vapor pressure 

@ Temperature °C Torr 

Density/relative density X 16 1.06 g/cm3 M 

Solubility 

@ Temperature ac 

Solvent g/I, 

Solubility in water @ Temperature °C X 17 SOLUBLE E 

Melting temperature X 16 0.6 °C 

M 

Boiling / sublimation temperature@ ton pressure X 16 99.6 °C M 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

Volitalization from water 

Volitalization from soil 

pH@ concentration @25°C X 16 8.5-10.0 M 

Flammability: FLASH POINT X 16 NONE M 

Explodability 

Adsorption / coefficient 

Other - Specify 

ATTACHMENT 

PAGE 13 
] 

MATERIAL SAFETY DATA SHEET 

1. Product and Company Identification 

p. 24 

July 9.2004 

2. Composition/Information on Ingredients 

Substance or Preparation 

Preparation 

Chemical Nature 

3. Hazards Identification (Most Important Hazard. 

Adverse Human Health Effects 

. [Ink] 

Inhalation — Vapors and / or mists which may be formed at elevated temperatures may be irritating to eyes. 

Skin — Contact with skin may result in mild irritation. 

Ingestion — May be harmful if swallowed. 

Eyes — Contact with eye result in irritation. 

Page 14 

GOM-21-QA-0-04-01 Ver. I 

l 7 
p. 25 

July 9.2004 

[Ingredients] 

r 

Inhalation - No adverse affects expected. 

Skin — No adverse affects expected. 

Ingestion — No adverse affects expected. 

Eyes — Not identified as an irritant in rat studies. 

3 

Contact with eye and skin may result in irritation. 

May be harmful if absorbed through the skin. 

3 

onsider not hazard compound for industrial use. 

But contact repeatedly with eye and skin may result in irritation. 

Inhalation may result cough, headache, fatigue and drowsiness. 

E 

Contact with eye may result in irritation. 

4. First-Aid Measures 

Inhalation 

Remove subject to ventilated fresh air. Consult physician if necessary. 

Skin Contact 

Wash thoroughly with soap and water. 

Eye Contact 

Try to remove with eye drops or flush with water. If unsuccessful, get medical attention. 

Ingestion 

Wash mouth with water and get medical advice. 

5. Fire-Fighting Measures 

Extinguishing Media 

• Water, CO2 , Dry Chemical and others 

Specific Method 

No special fire protecting method is required. 

6. Accidental Release Measures 

Personal Precautions 

Waterless hand cleaners followed by washing with soap and water readily remove product from skin. 

Environment Precautions 

Especially nothing 

Page 15 GOM-21-QA-0-04-01 Ver.1 
p. 26 

July 9.2004 

7. Handling and Storage 

All employees who handle this ink should be trained to handle safety. 

Handling (technical measures, precautions, safe handling material) 

Prohibition of dropping and throwing 

Storage (technical measures storage conditions, packaging material) 

Keep out of reach of children and do not drink ink. Do not store ink in high or freezing temperature. 

Keep ink out of direct sunlight. Do not store ink with acids,oxidizing agents or explosives. 

Store with container tightly closed. Store containers in a cool, dry location, away from direct sunlight or 

freezing temperature. 

8. Exposure Controls / Personal Protection 

Respiratory Protections 

Use with adequate ventilation to avoid breathing vapors or mists minimal exposure vapors or mists 

generated by this ink. 

None required under normal conditions of use. 

Hand Protection 

Wear light-weight plastic or rubber gloves for routine industrial use. 

Eye Protection 

Wear appropriate protective eyeglasses or safety goggles. 

Skin and Body Protection 

Remove contaminated clothing immediately. 

None required under normal conditions of use. If protection is needed, chemical protective clothing made 

from natural rubber are generally acceptable. 

9. Physical and Chemical Properties. 

Physical State 

Form: Solvent type ink 

Color: L 

Odor: No strong odor is allowed. 

Information 

pH : 8.5-10.0 Measuring Temperature. ( °C) : 25°C 

Bpiling Point (CC) : 99.6°C (JIS-K2233) 

Flash Point ( °C) : Flash Point is not detected.(JIS-K2265) No.126 will not burn. 

Ignition Temperature (r) : 410 °C (ASTM-659) 

Melting Point ( °C) : 0.6°C (JIS-K2249) 

Explosion Properties : This product is considered non explosive material under normal use condition. 

Vapor Pressure (pa) : Not Determined Measuring Temperature. ( °C) 

Vapor Density (AIR=1) : Not Determined 

Density (g / cm 3) : 1.06 (JIS-K2249) Measuring Temperature. 15/4(r) 

Page 16 GOM-21-QA-0-04-01 Ver.1 

1 9 
p. 27 

July 9.2004 

Solubility 

Water Solubility (g / soluble Water Solubility Measuring Temp ( °C) 

Other Solvent name 

Other Solvent Solubility (g / L) 

Other Solvent Solubility Measuring Temperature ( °C) 

Octanol / Water Partition Coefficient : Not known 

10. Stability and Reactivity 

Stability 

Stable 

Conditions to Avoid 

None. 

Materials to Avoid 

Acid and strong oxidizer can cause a reaction. 

Hazardous Decomposition Products 

Carbon oxides, nitrogen oxides in fire. 

Combustible liquid. Material may burn, producing irritating and poisonous gases. 

Li 

Flammable, Vapor /air mixtures are explosive. 

11. Toxicological Information 

Acute Toxicity 

Acute Oral Toxicity 

: No data 

Acute Dermal Toxicity 

: No data 

Acute Inhalation Toxicity 

: No data 

Sensitization 

Acute Skin Irritation : No data 

Acute Eye Irritation : No data 

Acute Allergenic Effects : No data 

Carcinogenicity : The I )ontained in this product corresponds to IARC(2B). 

12. Ecological Information 

Persistence / Degradability : Not known 

Bioaccumulation 

Not known in bioaccumulation. 

GOM-21-QA-0-04-01 Ver.I 

Page 17 

otO 
p. 28 

July 9.2004 

Ecotoxicity 

Acute Toxicity for Fish : Not known 

Acute Toxicity for Daphnia : Not known 

Algae Inhibition Test : Not known 

Environmental Effects 

No data available. 

13. Disposal Consideration 

Dispose of waste material in accordance with local, state and federal pollution regulations. 

14. Transport Information 

This ink is subject to the following transportation regulations as indicated: 

IATA: Not regulated 

DOT: Not regulated 

ADR: Not regulated 

Singapore land transport: Not regulated 

15. Regulation Information 

US EPA TSCA Inventory: All ingredients are listed on TSCA inventory. 

Dis subject to SNUR under 40C.F.R. section 721.9892 and to 12(b) export 

notification reporting requirements. 

EU Notification: All ingredients are listed on EINECS. 

In section 15 also include the danger symbol, R-Phrases (Risk phrases) and S-phrases (Safety Phrases). 

EU classification of ink as a whole is not determined yet. 

Metal present in ink at concentration > 0.1ppm 

[Na] = 165ppm 

16. Other Information 

None 

Page 18 

GOM-21-QA-0-04-01 Ver.1 
p. 29 

Page 

Ps.).DEL UXE BUSINESS rnPivi:- 1+800 -32H-O3CY VFA305 
PreManufacture Notice and 

Notice of Commencement Forms 

EPA Form 7710-25 (Rev. 5-95) 

EPA Form 7710-56 (Rev. -96) 

installation and Use Instructions 

MS Word 6.0 for Windows 

U.S. EPA Approved December 12, 1996 

by Anthony Cheatham 

TSCA Data Administration Section 

CM' Vi Responsible Care ® 

A Public Commitment 

Page 

cZ 

p. 30