- ETAD 

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ETAD North America 

Representing the North American Dyes Industry 

June 25, 2012 

p. 1 

Document Control Office (7407 M) 

Office of Pollution Prevention and Toxics (OPPT) 

Environmental Protection Agency 

EPA East Building, Room E6428 (202-564-8930) 

1201 Constitution Avenue, NW , 

Washington, DC 20460 

Attention: TSCA Section 4 

40 CFR 799.5087 

Docket ID Number EPA-HQ-OPPT-2007-0531 

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To Whom It May Concern : N 

RE: Testing of Certain High Production Volume Chemicals; Second Group of 

Chemicals. Federal Register 76 (5), 1067-1093, January 7, 2011 . 

C.I . Leuco Sulphur Black 1 (CAS No. 66241-11 -0) . 

In reference to our letter of May 24, 2012 pertaining to the subject test rule, this is to state that ETAD, on behalf of Clariant Corporation, is not claiming as CBI any of information submitted with that May 24 letter . This includes all subject matter, hard copies, and CDs 

contained in the May 24, 2012 submission. 

A letter from Clariant Corporation, enclosed here, confirms that none of the information submitted on May 24 is being claimed as CBI . Our May 24 letter of submission is also enclosed 

here for reference. 

The Ecological and Toxicological Association of Dyes and Organic Pigments 

Manufactures (ETAD) is an international technical organization that addresses the health, 

environmental and safety aspects of the global colorants industry. Headquartered in Basel, Switzerland, its members include the leading colorant manufacturers in Europe, Asia, and North America . Clariant Corporation is a member of ETAD. 

For further information concerning this submission to satisfy the requirements of the subject test rule, please contact the undersigned directly at 202-721-4154 or 

helmestO-socma .com . 

Sincerely, 

C. Tucker Hetmes, Ph .D. 

Executive Director 

ETAD North America 

cc: Paul Campanella CONTAINS NO CBI 

Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers 

1850 M Street, N.W., Suite 700 9 Washington, D.C. 20036 . (202) 721-4100 . Fax (202) 296-8120 9 www.etad .com 
ETAD 

ETAD North America 

Representing the North American Dyes Industry 

May 24, 2012 

Document Control Office (7407 M) 

Office of Pollution Prevention and Toxics (OPPT) 

Environmental Protection Agency 

EPA East Building, Room E6428 (202-564-8930) 

1201 Constitution Avenue, NW 

Washington, DC 20460 

Attention: TSCA Section 4 

40 CFR 799.5087 

Docket ID Number EPA-HQ-OPPT-2007-0531 

To Whom It May Concern: 

RE: Testing of Certain High Production Volume Chemicals; Second Group of 

Chemicals. Federal Register 76 (5), 1067-1093, January 7, 2011 . 

C.I . Leuco Sulphur Black 1 (CAS No. 66241 -11-0). 

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On behalf of Clariant Corporation, ETAD today is submitting the REACH registration 

dossier and associated study reports in compliance with the subject test rule for C. I . Leuco 

Sulphur Black 1 (CAS No. 66241-11-0). This submission is follow up to the study plan ETAD 

submitted by letter on May 4, 2012 (a copy of that letter is enclosed here). 

Accordingly, the following documents are included with this cover letter : 

" The May 4, 2012 study plan letter submitted by ETAD 

" A July 27, 2010 letter from the European Chemicals Agency (ECHA) confirming the completeness of Clariant's REACH registration dossier and REACH registration for C.I . Leuco Sulphur Black 1 (CAS No. 66241-11-0) 

" Clariant's REACH registration dossier submitted July 13, 2010 

" Freezing point study report : OECD 102 (melting point/melting range) - equivalent to : ASTM E 324-99 (capillary tube) 

" Vapor pressure study report: OECD 104 - equivalent to ASTM E 1782-08 (thermal analysis) 

" N-OctanoUwater partition coefficient study report . 

" Water solubility study report : Test method A6 of EU Regulation 440/2008 (i .e . OECD 105) -- a "shake flask" method equivalent to the Method A specified in the test rule as ASTM E 1148-02 (reapproved 2008). 

Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers 

1850 M Street, N.W., Suite 700 " Washington, D.C 20036 " (202) 721-4100 . Fax (202) 296-8120 " www.etad .com 

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CONTAINS NO CE3I 
" Ready biodegradation study report: C .4-D of EU Regulation 44012008 (OECD 301 F). This is a manometric respirometry test method equivalent to test method ISO 

9408:1999(E) listed in the test rule. Justification for the test method is provided in the accompanying dossier. 

" Acute toxicity to fish (Test Group 1) study report : OECD 203 - equivalent to ASTM E 729-96 (reapproved 2007). 

" Acute toxicity to Daphnia (Test Group 1) study report: OECD 202 - equivalent to ASTM E 729-96 (reapproved 2007). 

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al toxicity (Test Group 1) study report : OECD 201 - equivalent to ASTM E 1218- " 

" Acute (up/down) oral toxicity (rat) study report : OECD 423 -- equivalent to 40 CFR 

799.9110(d)(1)(i)(A)) . 

" Bacterial reverse mutation test (Ames test) study report : OECD 471 - equivalent to 40 

C FR 799.9510. 

" In vitro mammalian cell gene mutation test (Chinese hamster V79 cells) study report: OECD 476. 

" Repeated dose/reproduction/developmental toxicity (rats) study report of combined 

repeated dose toxicity study with reproduction/developmental toxicity screening test: OECD 422 (equivalent to 40 CFR 799.9365). 

" A CD containing electronic files of the ECHA letter and each of the specific study reports cited above. 

" A second CD containing electronic files of this cover letter, ETAD's May 4, 2012 study plan letter, and Clariant's REACH registration dossier. 

The Ecological and Toxicological Association of Dyes and Organic Pigments 

Manufactures (ETAD) is an international technical organization that addresses the health, 

environmental and safety aspects of the global colorants industry . Headquartered in Basel, Switzerland, its members include the leading colorant manufacturers in Europe, Asia, and North America. In North America, ETAD represents the dyes industry . Clariant Corporation is a member of ETAD. 

For further information concerning this submission to satisfy the requirements of the subject test rule, please contact the undersigned directly at 202-721-4154 or 

helmest(cD-socma.com. 

Sincerely, 

C. Tuc er Helmes, Ph. 

Executive Director 

ETAD North America 

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cc: Paul Campanella 
~ Clariant 

June 22, 2012 

Dr. C. T. Helmes 

Executive Director 

ETAD North America 

1850 M Street, NW Suite 700 

Washington, DC 20036 

Te1202-721-4154 /Fax 202-296-8120 

helmest(a)socma.com 

Clariant Corporation 

4000 Monroe Road 

Charlotte, NC 28205 

Daria Church 

Daria.churohlclariant .com 

.-_ 704.331 .7715 

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RE: Sulfur Black 1 - May 24 submission : Testing of Certain High Production Volume Chemicals; 

Second Group of Chemicals. Federal Register 76 (5), 1067-1093, January 7, 2011 . 

C.I . Leuco Sulphur Black 1 (CAS No. 66241-11-0). 

Dear Tucker: 

The information contained in our May 24 submission is now publicly available on the ECHA database under 

REACH. Clariant will make public the data contained in the EPA submission . Clariant maintains all intellectual 

property rights related to this data, including any copyright in underlying studies . All data compensation rights 

for use of this data are reserved . 

Please inform EPA that information submitted on May 24, relating to CL Leuco Sulphur Black 1 can be treated 

as non-CBI by the EPA. 

Please let me know if you have any questions . 

Sincerely, 

Daria E. Church 

Product Stewardship - NA 

Clariant Corporation 

4000 Monroe Road 

Charlotte, NC 28025 

704.331 .7720