# 2012JAN27 AMIO:p52 

# American' -, Chemistry Council

January 17, 2012 Mr. Paul Campanella Chemical Control Division (7405M) Office of Pollution Prevention and Toxics U .S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460- 0001 j

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Re: HPVTest Rule for Benzophenone (CAS# 119-61-9) under TSCA Section 4Test Rule (76 FR 1067) Dear Mr . Campanella: The Benzophenone HPV Consortiumofthe American Chemistry Council hereby notifies EPA of its intent to respond to EPA for the testing of benzophenone in accordance with the above referenced test rule. In stating this intent, the Consortiumis acting on behalf of the following test sponsors : " BioAccutech Inc. " Cytec Industries Inc. " Dow Chemical Company " International Flavors &Fragrances Inc. " 3M " RAHN USA " FUJIFILMNorth America Corporation, Graphic Systems Division - Sericol Unit In the attached consortiumcommitment forms, each company has agreed to act as a test sponsor and has authorized the Consortiumto respond to the test order on benzophenone as principal sponsor on its behalf. While agreeing to sponsor all required testing, the companies reserve the right to invoke the cost reimbursement procedures prescribed by EPA in the event that a satisfactory cost-sharing agreement cannot be achieved or that some manufacturers or importers are not identified until after testing has been initiated.



# CONTAINS NOCpI ameficanchemistry.com© 700 Second St ., NE I Washington, DC 20002 1 (202) 249.7000

### January 17, 2012

Page 2 Contact information for the Consortiumis as follows: " Mr. WilliamP. Gulledge, The American Chemistry Council, 7002nd St. NE, Washington, DC 20002, bill-gulledge@americanchemistry.com .Sincerely,

Attachments:

americanchemistry.com© 700Second St ., NE I Washington, DC 20002 1 (202) 249.7000

### AMERICAN CHEMISTRY COUNCIL CHEMICAL PRODUCTS & TECHNOLOGY DIVISION Commitment Formfor Membership Participation and Funding of

Benzophenone HPV Consortium My organization (indicated below) herebyjoins the American Chemistry Council's (ACC) Benzophenone HPVConsortiumand commits to provide funding for the administrative, testing, and other costs associated with forming a Consortium in accordance with EPA's TSCA Section 4test rule for benzophenone dated January 7, 2011 . The total budget for the Consortiumto performthe administrative activities is not expected to exceed All activities areexpected to be performed in 2011 and 2012 with the final submission to EPAon or before March 7, 2012. In making this commitment, we agree to paymothe Consortium's budget, based on average import volume over three years (2008-2010) . My organization agrees to participate in the Consortiumin accordance with ACC's or ganizational Bylaws and policies, including the requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and expressly made a part of this commitment form . While appreciating the opportunity, my company declines to participate. ACChas estimated that 6%a of the January 1, 2011- December 31, 2011 fiscal year "du es and similar income" is allocable to lobbying and political expenditures to which Section 162 (e)(1) of the Internal Revenue Code of 1986, as amended, applies. Consequently, this portion of your commitment is not deductible as an ordinary and necessary business expense for federal income tax purposes. Further, contributions to ACC are not tax deductible as charitable contributions. Consortiuqn Representative Other ConsortiumParticipant(s) (Optional) Name (Signed) Name Mark Fukavama Name (Typed) Name (Typed) Director of Toxicology - Title Title International Flavors & Fragrances Inc . Company Company 800 Rose Lane, Union Beach, NJ 07735_ Address Address 7;i2-203-8139_ Telephone Telephone November 8, 2011__ - Date Date Please return signed form by November 4, 2011 to Bill Gulledge, American Chemistry Council, 700 2nd St. NE, Washington, DC 20002. For any questions, please contact Bill Gulledge (202) 249-6714.

### AMERICANCHEMISTRY COUNCIL CHEMICAL PRODUCTS &TECHNOLOGY DIVISION

0 

### Commitment Formfor Membership Participation and Funding of Benzophenone HPV Consortium My organization (indicated below) hereby joins the American Chemistry Council's (ACC) Benzophenone HPV Consortium and commits to provide funding for the administrative, testing, and othercosts associated with forming a Consortiumin accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011 . The total budget for the Consortiumto performthe administrative activities is not expected to exceed ~All activities are expected to be performed in 2011 and 2012 with the final submission to EPA o or before March 7, 2012. In making this commitment, we agree to pay o the Consortium's budget, based on average import volume over three years (2008-2010) . My organization agrees to participate in the Consortiumin accordance with ACC's organizational Bylaws and policies, including the requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and expressly made a part of this commitment form . White appreciating the opportunity, my company declines to participate. ACC has estimated that 6%of the January 1, 2011 - December 31, 2011 fiscal year "dues and similar income" is allocable to lobbying and political expenditures to which Section 162 (e)(1) of the Internal Revenue Code of 1986, as amended, applies. Consequently, this portion of your commitment is not deductible as an ordinary and necessary business expense for federal income tax purposes. Further, contributions to ACC are not tax deductible as charitable contributions. Consortium Representative Other ConsortiumParticipant(s) (Optional) Name Name (Typed)' Name (Typed) ~N~t~( ~ Title Title Company Company



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## .4E ~ 9-__'7l~ Telephone Telephone Date Date Please return signed formby November 4, 2011 to Bill Gulledge, American Chemistry Council, 7002nd St . NE, Washington, DC 20002. For any questions, please contact Bill Gulledge (202) 249-6714.

### AMERICAN CHEMISTRY COUNCIL CHEMICAL PRODUCTS &TECHNOLOGY DIVISION

0 

### Commitment Formfor Membership Participation and Funding of Benzophenone HPV Consortium My organization (indicated below) hereby joins the American Chemistry Council's (ACC) 13enzophenone HPV Consortiumand cominits to provide funding for the administrative, testing, and other costs associated with forming a Consortiumin accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011 . The total budget for th Consortiumto performthe administrative activities is not expected to exceed All activities are expected to be performed in 2011 and 2012 with the final submission to GPA on or before March 7, 2012. In making this commitment, we agree to pay . o the Consortium's budget, based on average import volume over three years-2010) . My organization agrees to participate in the Consortiumin accordance with ACC's organizational Bylaws and policies, including the requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and expressly made a part of this commitment form . While appreciating the opportunity, my company declines to participate.

not tax ded business expense for federal income ta this portion of your commitment is not deductible as an ordina ACChas estimated that 6%of the January 1, 2011-December31, 2011 fiscal year "dues and similar income" is allocable to lobbying and political expenditures to which Section 162 (e)(1) of the Internal Revenue Code of 1986, as amended, applies. Consequently, necessary purposes. Further, contributions to ACCare e as charitable contributions. Other Consortiuin Participant(s) (Optional) Name (Signed) ,,Sr-7;fV/:-

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# /o-2-6-o20 1 ( Date Date Please return signed form by November 4, 2011 to Bill Gulledge, American Chemistry Council, 700 2"'' St. NE, Washington, DC 20002. For any questions, please contact Bill Gulledge (202) 249-6714

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### AMERICAN CHI-MISTIO COUNCIL CHEMICAL PRODUCTS &TECI-INOL.OGY DIVISION Conuliitment I'UI'lll for NNlembershih Participation and Funding of

I3cnzollhenolle IIPWConSortiutll My orga :uzatinn (indicated beloW) h( r )Oins tliP :ktne: icnz1 Cliemistrt~ CoiinCil's (ACC) i3enzophenone 1-IP1' Consorttuczt anL: commits to provide fundirl~ for tile administrative, tcstit;t;, and other costs associated with forming .i Consort :umin accordance with EPA's T5CA Sect :on 4 test rule for benzoplienome dated Januar} " 7, 2011 . Thc total bud 1~t for the Consortiu : :r to performthe administrative activities is not expected to exceed ~All activities are ezpected to be perfvrmed in 2011 and 201? with the final subnussion to EPA on or before March', 2012. lr making tlitti commitment, we agree to pay~o the ConSortiuwii's biidl ;,t, lui~~~.l oil dvcrage irnport volume over three yearsw('20~Ob'-2010) . N1y orga :uzat;on agrees to Participate in the Consortiumin accordarnce with :1CC's organizational Bylaws and policies, including Llle requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and e .pre,~,lti made a hart of this commitment for- . : : While aFhrec<~ting the opportunity, my company declines to Participate. ACC has estimated that 6",',+ of the January 1, 2011 - December 31, 2011 fiscal eat "clues and similar inconte" is allocablo to lobbying and political expenditures to which Section 162 (e)(I) of the Internal Revenue Code of 1986, as amended, applies. Consequently, this portion of your commitnient is not deductible as an ordinary and necessary business expense for federal income tax purposes. Fuither, contributions to ACCare not tax deductible as charitable contributions. Consortium Uepres,~nlative Other Consortium Participant(s) (Optional)

i l~ame (Signed) ' Name Briana Hat'en Name (1'yped) Name ("Typed) Sr . Re_t ; :aaa~r~~ Affairs tiuner-, isor Title Title ;,%t Company Company Company 3Ll Center, 131d

.`, '_'36-1B-10 St . Paul, A4iti 351-1-1-100ti Address Addiess 651-733-7766 Telephone Telephone October, 26, '_'011 Date Date Please return signed formby November 4, 2011 to Bill Gulled,e, American Chernisrry Council, ?002nd St . NE, Washington, DC 20002 . For any questions, please contact Bill Gulledge (202) 249-6714.

### AMERICANCHEMISTRY COUNCIL CHEMICAL PRODUCTS &TECHNOLOGY DIVISION

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0 

### Commitment Form for Membership Participation and Funding of Benzophenone HPV Consortium My organization (indicated below) hereby joins the American Chemistry Council's (ACC) Benzophenone 1-1PV Consortiumand commits to provide funding for the administrative, testing, and other costs associated with forminga Consortiumin accordance with EPA'sTSCA Section 4test rule for benzophenone dated January 7, 2011 . The total budget for the Consortiumto perform the administrative activities is not expected to exceed i1111 activities are expected to be performed in 2011 and 2012 with the final submission to EPAon or before March 7, 2012. In making this commitment, we agree to pay to the Consortium's budget, based on average import volurne over three years 200 -2010) . My organization agrees to participate in the Consortium in accordance with ACC's organizational Bylaws and policies, including the requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and expressly made a part of this commitment form . While appreciating the opportunity, my company declines to participate.

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- eCode~o ~i-1 .98 Abaenaed~a 4 ..k6u" - . PP 9$ .- went .y, . ---- -- --I"' ' - - - ---' - fitrib- 6 f - CC: e;: R~WA--ex -f -1 'd 'intbifteJaxpui se -_--u 6 iffi fis 6A ar _po. ConsortiumRepresentative Other ConsortiumParticipant(s) (Optional)

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# 41,ivt, ./ Jeffrey Hafer Name (Typed) Name (Typed) Product Sustainability Leader Title Title Dow Chemical Company Company 727 Norristown Road,Spring House PA Address Address 215-619-5552 Telephone Telephone 10/28/2011 Date Date Please return signed formby November 4, 2011 to Bill GuIledge, American Chemistry Council, 7002ndSt. NE, Washington, DC 20002 . For any questions, please contact Bill Gulledge (202) 249-6714 .

### AMERICANCHEMISTRY COUNCIL CHEMICAL PRODUCTS &TECHNOLOGY DIVISION

®

0 

### Commitment Formfor Membership Participation and Funding of Benzophenone HPVConsortium My organization (indicated below) herebyjoins the American ChemistryCouncil's (ACC) Benzophenone HPVConsortiumand commits to providefunding for the administrative, testing, and othercosts associated with forming a Consortium in accordance with EPA's TSCASection 4test rule for benzophenone datedJanuary 7, 2011 . The total budget for the Consortium to performthe administrative activities is not expected to exceed = All activities areexpected to be performed in 2011 and 2012 with thefinal submission to EPAon or before March 7, 2012. In making this commitment, we agree to pay~to theConsortium's budget, basedon average import volume over threeyears (2008-2010) . My organization agrees to participate in the Consortium

in accordance with ACC's organizational Bylaws and policies, including the requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and expressly made a part of this commitment form . Whileappreciating the opportunity, my company declines to participate . and similar income" is allocable to lobbying and political expenditures to which Section 162 (e)(1) of the Internal Revenue Code of 1986, as amended, applies. Consequently, this portion of your commitment is not deductible as an ordinary and necessary business expense for federal income tax purposes. Further, contributions to ACC are not tax deductible as charitable contributions. ACChas estimated that 6% of the January 1, 2011 - December 31, 2011 fiscal year "dues

Na-me (Signe Daniel Liebowitz Other ConsortiumParticipant(s) (Optional) Name Name (Typed) Name (Typed) Regulatory Compliance Manager, Americas - Title Title Cytec Industries Inc

. Company Company 78 Rivergate Drive, Wilton, CT 06897 Address Address (203 834-0426 Telephone Telephone October 25, 2011 Date Date Please return signed formby November 4, 2011 to Bill Gulledge, American Chemistry Council, 7002nd St. NE, Washington, DC20002 For any questions, please contact Bill Gulledge (202) 249-6714 .

### AMERICAN CHEMISTRY COUNCIL CHEMICAL PRODUCTS &TECHNOLOGY DIVISION

®

0 

### Commitment Form for Membership Participation and Funding of Benzophenone HPV Consortium My organization (indicated below) herebyjoins the American Chemistry Council's (ACC) Benzophenone HPVConsortiumand commits to provide funding for the administrative, testing, and other costs associated with forming a Consortium in accordance with EPA'sTSCA Section 4 test rule for benzophenone dated January 7, 2011 . The total budget for the Consortiumto performthe administrative activities is not expected to exceed~All activities areexpected to be performed in 2011 and 2012 with the final submtsston to EPAon or before March 7, 2012. In making this commitment, we agree to pay ~othe Consortium's budget, based on average import volume over three years 008-2010) . My organization agrees to participate in the Consortiumin accordance with ACC's organizational Bylaws and policies, including the requirements set out in the Protocols for Products Divisions Groups, which is attached hereto and expressly made a part of this commitment form . Whileappreciating the opportunity, my company declines to participate. ACChas estimated that 6°l0of the January 1, 2011- December 31, 2011 fiscal year "dues and similar income' Is allocable to lobbyingand political expenditures to which Section 1 ' internal Revenue Code of 1966, as amended, applies. Consequently, 62(e)(1) of the "portlot~ofyour commitment is not deductible as an ordinary and necessary business'expensefor federal income tax purposes. Further, contributions toACCare not tax deductible ascharitable contributions.

Name (, gned) Other ConsortiumParticipant(s) (Optional) L~~f ,/ ~ 

# 14 Consortium Representative Name Craig Poggenpohl Name (Typed) Name (Typed) EHS Manager Title Title Fuiifilm North America Corporation Company Companti20 W . 14Lh Ave., N

._ Kansas City, MO

. 64116 Address Address (913) 5 73-3803 Telephone Telephone October 28, 2

011 Date Date Please return signed formby November 4, 2011 to Bill Gulledge, American Chemistry Council, 700 2nd St . NE, Washington, DC 20002. For any questions, please contact Bill Gulledge (202) 243-6714 .