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# rI OCSPP OPPT EAD 1200 Pennsylvania Ave. NW Washington, DC 20460 202.564.8251

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## - ntUNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D
.C., 20460



### VIA FACSIMILE: 201-437-4801 April 19,2012 Attention: Glenn Merritt (201-437-4000) OFFICE OF PREVE NTION, PESTICIDESAND TOXIC SUBSTANCES



### Subject: Follow-up to fax transmission of4/13/12 (ePMA

### removal ofCBI claimsregarding identified studies) 

### DearMr. Merritt: This is sent to you pursuant ourconversation ofseveral minutes ago. In Larry Robinson's fax of April 13th 

### while there is a waiver ofconfidential business information (CBI) claims in the identified studies there is a an assertion ofcopyrightprotections and some additional text that provides in part ... "Reproduction, reference, summarization, retransmission or otheruse ofthis copyrighted document...including electronic transmission, using the internet oremail....is strictly prohibited...." While we understand the basis for the copyright protections, we have a concern that the language in the fax might be interpreted to mean that ePMA is asserting that the studies submitted perthe TSCA activity are not to bemade available in an Agency e-docket (electronic docket) orbe included in EPA websites among the collection ofTSCAhealth and safety studies. We are thinking that the identified limitations noted in the fax are not intended to apply to EPA's normal procedures for the handling ofnon-CBI materials submitted by entities subject to TSCA regulations (including the posting ofsuch materials ongovernment websites) and submittedby such entities in order to comply with a TSCA requirement, but are rather intended to limit entities outside the government from the unauthorized use or appropriation ofthe studies. Canyou please confirm CPMA's intent? Many thanks.

Scott M. Sherlock, Attorney Advisor Environmental Assistance Division Office ofPollution Prevention and Toxics340 Cormercia Avenu Now BrunewicK N.J-0690 2014545-1704 ACUTE DERMIAL TOXICITY Mlarch 

### 9, 1981
REPORT NO.: 

### T-1 

### 555 CLIENT: BASF WYANDOTTE CORPORATION Wyandotte, Mlichigan 

### 48192

DATE OF TEST: March 8. 

### 1981 PRODUCT IDENTIFICATION: Code 

### BT-7150, Alkali Blue .RPowder, Lot 17141-8033 

# CUPRODUCT DESCRIPTION: A dark blue powder.



# (~)PSL NO.: E10202-1
DATE RECEIVED: February 2, 

### 1981 ANIMALS: Ten New Zealand Albino Rabbits weighing 

# c~u 

# i 2.30-3.50 gm/kg from Cedar Knoll Farms. 4) DIET: Fisher Rabbit Pellets C NOTEBOOK NO.: 81-1; page 

### 1,113 S QUALITY ASSURANCE REFERENCE: Q.A. 1, 2, 3 ENVIRONMENTAL CONDITIONS: 'S During the test period the animals were housed in individual stainless

Ssteel wire bottomed cages in an environmentally controlled room. The temperature was kept at 

### 680 - 720F. They were exposed to 12 hours of fluorescent Ilight 

### (8 A.M. - 

### 8 P.M.) and 12 hours of darkness 

### (8 P.M. - 

### 8 A.M.) daily. The animals were housed I per cage. Feed and water were provided ad-libitum after dosing. PROCEDURE: Acute Dermal Toxicity. FHSLA 

### 16 CFR 1500. The rabbits were prepared by clipping the skin of the trunk free of hair. Epidermal abrasions were made over a 

### 5-6 cm 2 area on 3 malIes and 2 femalIes. The remaIning f ive rabbits were not abraded. A non-permeable patch containing 2.0 gmfk* body weight of the test material was placed over a 

### 4-5 cm 2 area on air rabbits. The patches were secured in place with tape and an elastic sleeve. The rabbits were immnobilized 

### in head stocks for 24 hours at which time the patches were removed and the rabbits returned to their cages. Feed and water were provided ad-libitum. The rabbits were observed for 14 days. Gross necropsies were performed on all mortal ities and on all surv/ivors at terminal sacrifice. At the end of the test period individual final body weights were recorded.
The test material was mixed wellI with water to form a 33.3% paste; and a 

### 6.0 gm/kg body weight of the prepared test material was placed under each patch on all rabbits.'2I" =r L - T-_-'rfL'I 'U !1E 

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## 1 

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~ Page 2 

# ____F~OULCIs~icy ~DS__Report 

## No. T-1555 sdhviaonf nutonIntornatlonal RESULTS:
Actual Rabbit -No. Sex Body jWelqht Dose Mortality Autopsy Initial Final gm day kg kg 3481-abraded M2.43 2.65 14.6

-- DL; OK 3482-abraded M 2.60 2.88 15.6 -- PH; DL; C 3483-abraded 11 2.64 3.02 15.8 -- NR 3484. M 2.43 2.84 14.6 -- NR 

### 3485 M 2.61 2.48 15.7 --- IMD; Sub 3486-abraded F 2.41 2.77 

### 14.5
-- HOFT; MI. 3487-abraded F 3.00 3.04 18.0 -- N 

### 3488 F 2.34 2.73 14.0 --- E F, MT 3489 F 3.06 3.16 18.3 --- MR 3490 F 2.34 3.00 14.0

-- NR *The test material was mixed wellI with water to form a 33.3% paste; and a 6.0 gm/kg body weight of the prepared test material was placed under each patch on all rabbits. Sub QO - Subcutaneous disoloration (localized in region of application) IMD - Intramuscular discolorat ion (l ocalIized in region of application) NRt - Not remarkable DL - Discolored liver (25%) DK - Discolored kidney PH - Pulmonary hemorrhage ML - Mottled liver E & MT - Enlarged and mottled thymus HOFT - Hemorrhage of ovary & fallopian tube4,, -- Page 3 

# f31oCIIJ~ 

# sdaey labS Report No. T-1555 adivsonofnutrition international
OBSERVATIONS: One rabbit (134.85) lost weight (130g) during the two-week test period.

AUTOPSY: See results.

CONCLUS ION: The Dermal L-Dj 0 of the test material is greater than .0 gm/kg.

__ __ __ __ CIO~ 

### ~ 

# 9,; Ralph Wha&piro, Ph.D. Catherine Wo, Ph.D. Director Study Supervisor Toxicologist

'ArleneStern bater 

### 10,a to i Quality Assurance Unit