1

Schaeffer, John

To: John Schaeffer

Subject: Response to Harcos Chemicals regarding review for CASRN 31138-65-5

From: Lin, Chuantung 

Sent: Thursday, February 26, 2015 12:59 PM 

To: Schaeffer, John 

Cc: Njo, Heather; Williamson, Tracy; Christian, Myrta 

Subject: Re: Response to Harcos Chemicals regarding review for CASRN 31138-65-5 

Hi John, 

Sorry for the delay. This case must have slipped away from my to do list during recent snow weather 

conditions. 

The followings are ICB's responses to the tested results sent from the sponsor of HPV 2 test chemical, Sodium 

glucoheptonate (CASRN 31138-65-5): 

 

ICB has reviewed the test results and the related test methods used to determine the Pour Point (in lieu of 

Melting Point/Freezing Point), Boiling Point, Water Solubility, and the estimated Log P value of Sodium 

glucoheptonate (CASRN 31138-65-5) required under the TSCA Section 4 Test Rule for HPV Group 2 

chemicals. In a pre-testing communication between EPA and the Sponsor of this test chemical, EPA has

agreed with the Sponsor of this test chemical to use whatever "dried" sample they could get in their testing 

(due to 100% of dried sample could not be easily obtained). The test samples used to obtain these P/Chem 

data endpoints were ~50% aqueous solution as indicated in its moisture content test (which was determined 

to be 49.5% w/w (495 g/kg) in test result submitted by the Sponsor). Therefore, the test sample was a "liquid" 

form, instead of solid, and the Pour Point test is used for Freezing Point/Melting Point endpoint. 

ICB reviewer agrees with these test results and they could also be accepted to fulfill the HPVC 2 Test Rule's 

requirements for the P/Chem data endpoints (A1, A2, A4, and A5). However, ICB reviewer suggests to indicate 

that the test result of 117 ± 1 °C at 102.9 kPa (partially boils from this temperature) for the Boiling Point 

provided by the sponsor should be treated as the "decomposing temperature", instead. The "Pour Point"

value could be used in lieu of the Melting Point./Freezing Point. it is expected the melting point and boiling 

point of neat/dried salt compound to be very high (even decomposing before melting or boiling). An 

estimated Log P value is accepted per previous agreement between EPA and the Sponsor of this test chemical.

Please let me know if you have any other questions on this matter. 

Thanks! 

Daniel 

Daniel (Chuantung) Lin, Ph.D.
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Chemist, Industrial Chemistry Branch 

Office of Pollution Prevention and Toxics 

US EPA 

1200 Pennsylvania Ave., NW (7406M) 

[Deliveries to: 1201 Constitution Ave., NW, EPA East (WJC) 5133E] 

Washington, DC 20460 

202-564-8584 (direct) 

202-564-8740 (branch) 

202-564-8679 (fax)

----- Forwarded by Chuantung Lin/DC/USEPA/US on 02/12/2015 01:24 PM -----

From: Chuantung Lin/DC/USEPA/US

To: Paul Campanella/DC/USEPA/US@EPA, 

Cc: David Brooks/DC/USEPA/US@EPA, John Schaeffer/DC/USEPA/US@EPA, Tracy Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA

Date: 08/15/2012 04:18 PM

Subject: Re: Fw: Response to Harcos Chemicals regarding review for CASRN 31138-65-5

Hi Paul,

After I discussed with Tracy on this HPV2 test chemical, ICB agrees that the company could just go ahead to test the 

required P/C endpoints with whatever "dried" sample they could get. For the nature of salt compounds such as sodium 

glucoheptonate (CASRN 31138-65-5), it is expected the melting point and boiling point be very high (even decomposing 

before melting or boiling). They could just report the decomposition temperature with the dried sample they could 

obtain. As for the water solubility of this salt compound, we expect that it should excess 50% level (due to the commercial 

product they could get was in 50% or greater aqueous solution). They could just go ahead doing the testing on those P/C 

endpoints as required by the Test Rule. Log P value could be estimated as indicated in the testing requirements for this 

chemical. 

For other toxic endpoints, RAD should be able to address this question (to use the dried sample that they could get) from 

their perspectives.

Daniel

_____________________________________________________

Dr. Daniel Chuantung Lin 

Industrial Chemistry Branch 

Office of Chemicals Safety and Pollution Prevention

US EPA 

1200 Pennsylvania Ave., NW (7406M) 

Washington, DC 20460 

[Deliveries to: 1201 Constitution Ave., NW, 

EPA East, Room#:5133E, Washington, DC 20460] 

202-564-8584 (direct) 

202-564-8740 (branch) 

202-564-8679 (fax)