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1200 Pennsylvania Ave. NW 

Washington, DC 20460 

202.564.8251 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

VIA FACSIMILE: 201-437-4801 

April 19,2012 

Attention: Glenn Merritt (201-437-4000) 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Subject: Follow-up to fax transmission of 4/13/12 (ePMA removal ofCBI claims regarding 

identified studies) 

Dear Mr. Merritt: 

This is sent to you pursuant our conversation of several minutes ago. In Larry Robinson's fax of 

April 13th while there is a waiver of confidential business information (CBI) claims in the 

identified studies there is a an assertion of copyright protections and some additional text that 

provides in part ... "Reproduction, reference, summarization, retransmission or other use of this 

copyrighted document. .. including electronic transmission, using the internet or email .... 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 per the 

TSCA activity are not to be made available in an Agency e-docket (electronic docket) or be 

included in EPA websites among the collection of TSCA health 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 of non-CBI materials submitted by entities subject to TSCA 

regulations (including the posting of such materials on government websites) and submitted by 

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 of the studies. 

Can you please confirm CPMA's intent? Many thanks. 

Scott M. Sherlock, Attorney Advisor 

Environmental Assistance Division 

Office of Pollution Prevention and Toxics 


340 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 .R Powder,

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 cm2 a rea on 3 malIes and 2 f emalIes. The rema In ing 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 cm2 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 wi th 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 1 E li! !1 I r WIWI] 1 11 i1L I

~ Page 2

____F~OULCIs~icy ~DS__Report No. T-1555

sdhviaonf nuton Intornatlonal

RESULTS:

Actual

Rabbit -No. Sex Body jWelqht Dose Mortality Autopsy

Initial Final gm day

kg kg

348 1-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 di scolorat ion (l ocalIized in region of appl icat ion)

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 tube
4,, -- Page 3

f31oCIIJ~ sdaey labS Report No. T-1555

a divson of nutrition international

OBSERVATIONS: One rabbit (134.85) lost weight (130g)

during the two-week test period.

AUTOPSY: See results.

CONCLUS ION: The Dermal L-Dj0 of the test material is

greater than .0 gm/kg.

__ __ __ CIO~ __ ~ 9,;

Ralph Wha&piro, Ph.D. Catherine Wo, Ph.D.

Director Study Supervisor

Toxi col og ist

'Arlene Stern bater to 10,a i

Quality Assurance Unit