2012 JAN27 AM IO: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 Y/CW, 

piigm9miHgu0 miuiigu0 puiiu 

Re: HPV Test Rule for Benzophenone (CAS# 119-61-9) under TSCA Section 4 Test Rule 

(76 FR 1067) 

Dear Mr. Campanella: 

The Benzophenone HPV Consortium of the 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 Consortium is acting on behalf of the following 

test sponsors : 

" Bio Accutech Inc. 

" Cytec Industries Inc. 

" Dow Chemical Company 

" International Flavors & Fragrances Inc. 

" 3M 

" RAHN USA 

" FUJIFILM North America Corporation, Graphic Systems Division - Sericol Unit 

In the attached consortium commitment forms, each company has agreed to act as a test sponsor 

and has authorized the Consortium to 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 NO CpI 

ameficanchemistry.com© 700 Second St ., NE I Washington, DC 20002 1 (202) 249.7000 
January 17, 2012 

Page 2 

Contact information for the Consortium is as follows: 

" Mr. William P. Gulledge, The American Chemistry Council, 700 2nd St. NE, Washington, 

DC 20002, bill-gulledge@americanchemistry.com. 

Sincerely, 

Attachments: 

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

CHEMICAL PRODUCTS & TECHNOLOGY DIVISION 

Commitment Form for 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 other costs associated with forming a Consortium in 

accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 

2011 . The total budget for the Consortium to perform the administrative activities is not 

expected to exceed All activities are expected to be performed in 2011 and 2012 

with the final submission to EPA on or before March 7, 2012. In making this 

commitment, we agree to paymo the Consortium's budget, based on average 

import volume over three years (2008-2010) . My organization agrees to participate in the 

Consortium in 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. 

ACC has 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 Consortium Participant(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 . 
AMERICAN CHEMISTRY COUNCIL 

CHEMICAL PRODUCTS & TECHNOLOGY DIVISION 

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 HPV Consortium and commits to provide funding for the 

administrative, testing, and other costs associated with forming a Consortium in 

accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011 . 

The total budget for the Consortium to perform the 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 

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. 

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 Consortium Participant(s) (Optional) 

Name 

Name (Typed)' Name (Typed) 

~N~t~( ~ 

Title Title 

Company Company 

_ w.'lso- u/u Al-A __ 

Address ,t,,(se,; ,tf J o,;pf,(v Address 

.4E 9-__'7l~ ~ 

Telephone Telephone 

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 . 
AMERICAN CHEMISTRY COUNCIL 

CHEMICAL PRODUCTS & TECHNOLOGY DIVISION 

0 

Commitment Form for Membership Participation and Funding of 

Benzophenone HPV Consortium 

My organization (indicated below) hereby joins the American Chemistry Council's 

(ACC) 13enzophenone HPV Consortium and cominits to provide funding for the 

administrative, testing, and other costs associated with forming a Consortium in 

accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011. 

The total budget for th Consortium to perform the 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 

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. 

not tax ded 

business expense for federal income ta 

this portion of your commitment is not deductible as an ordina 

ACC has 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 ACC are 

e as charitable contributions . 

Other Consortiuin Participant(s) (Optional) 

Name (Signed) 

,,Sr-7;f V/:-:: ~_JNt7S -1 (2A ~. 

Name 

Name (Typed) Name (Typed) 

Title Title 

,Q~-I--~f\f W A CaCP. 

Company Company 

10C)5 r-~ C C) nnm(j NS 

Address 1~uQa eA l C. ._ 6USo ~- Address 

630 S-S/ 4zzu . 

Telephone Telephone 

/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. 
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) i3enz ophenone 1-IP1' Consorttuczt anL: commits to provide fundirl~ for tile 

administrative, tcstit;t;, and other costs associated with forming .i Consort:um in 

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 perform the 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 

Consortium in 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 e stimated 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 ACC are 

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 form by November 4, 2011 to Bill Gulled,e, American Chernisrry 

Council, ?00 2nd St . NE, Washington, DC 20002. 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) hereby joins the American Chemistry Council's 

(ACC) Benzophenone 1-1PV Consortium and commits to provide funding for the 

administrative, testing, and other costs associated with forming a Consortium in 

accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011 . 

The total budget for the Consortium to perform the administrative activities is not 

expected to exceed i 1111 activities are expected to be performed in 2011 and 2012 

with the final submission to EPA on 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. 

-;an sk -lobbying.an4-'politica -,exp~n ttures~jo'whjc 11s - ectu 

y 

-7- 

e - Code~o 

~i 

-1 

. 

4..k6u" - 98 Abaenaed~a . PP 9$.- went .y, . 

--- - -- R~WA--ex -f -1 'd --I"' 'intbifteJaxpui ' - - - ---' _pose - .-_--u 6 fitrib- iffi 6 fis f 6A - CC : ar e ; : 

Consortium Representative Other Consortium Participant(s) (Optional) 

N -2ie a ~" s igned i- V Name 

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 form by November 4, 2011 to Bill GuIledge, American Chemistry 

Council, 700 2nd St. NE, Washington, DC 20002. 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) hereby joins the American Chemistry Council's 

(ACC) Benzophenone HPV Consortium and commits to provide funding for the 

administrative, testing, and other costs associated with forming a Consortium in 

accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011 . 

The total budget for the Consortium to perform the administrative activities is not 

expected to exceed 

= 

All activities are expected to be performed in 2011 and 2012 

with the final submission to EPA on or before March 7, 2012. In making this 

commitment, we agree to pay~to the Consortium's budget, based on average 

import volume over three years (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. 

While appreciating 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. 

ACC has estimated that 6% of the January 1, 2011 - December 31, 2011 fiscal year "dues 

Na-me (Signe 

Daniel Liebowitz 

Other Consortium Participant(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 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. 
AMERICAN CHEMISTRY COUNCIL 

CHEMICAL PRODUCTS & TECHNOLOGY DIVISION 

® 

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 HPV Consortium and commits to provide funding for the 

administrative, testing, and other costs associated with forming a Consortium in 

accordance with EPA's TSCA Section 4 test rule for benzophenone dated January 7, 2011. 

The total budget for the Consortium to perform the administrative activities is not 

expected to exceed~ All activities are expected to be performed in 2011 and 2012 

with the final submtsston to EPA 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 008-2010) . 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. 

ACC has estimated that 6°l0 of the January 1, 2011- December 31, 2011 fiscal year "dues 

and similar income' Is allocable to lobbying and political expenditures to which Section 

1 ' internal Revenue Code of 1966, as amended, applies. Consequently, 62 (e)(1) of the 

" portlot~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. 

Name (, gned) 

Other Consortium Participant(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) 573-3803 

Telephone Telephone 

October 28, 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) 243-6714.