Bayer Material Science 

December 18, 2012 

e7507~() 

RECEIVED 

OPPT CBIC 

2012 DEC 27 AM 6: 00 

OPPT -2011-0182 

Bayer MateriaiScience LLC 

100 Bayer Road 

Pittsburgh, PA 15205-9741 

Phone: 

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--------~ VIA CERTIFIED U.S. MAIL 

U.S. Environmental Protection Agency 

Office of Pollution Prevention and Taxies 

Document Control Office (7407M) 

Docket# EPA-HQ-OPPT-2011-0182 

1200 Pennsylvania Avenue NW 

Washington DC 20460 

PUBLIC 

FAX: 

e-mail: 

llllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll 

63130000018/S 

Re: Letter dated September 19, 2012 - Voluntary Information Request for 

Isocyanate Cure Characteristics 

To Whom It May Concern: 

We are writing in response to the Request for Information Letter (the 11RFI"), which we received 

September 26, 2012. In it, EPA requests 11the following information related to MDI and TDI, as 

well as aliphatics, such as hexamethylene diisocyanate (HDI): 

1. The curing time required to chemically react all diisocyanate functional groups. 

2. The amount of time required, prior to and after a product has fully cured, to safely reoccupy or use an area where diisocyanates have been reacted (including expected 

exposures to diisocyanates, other formulation additives, and/or reaction products 

formed)." 

The RFI requests a broad array of data types and sources, including 11Studies, memos, 

unpublished data or any other documents [that may be] in [our] possession relating to curing 

time and re-occupancy" time. 

The information herein is being provided in good faith for informational purposes only, without warranty or guarantee except as expressly 

provided in any written sales agreement between you and Bayer MateriaiScience LLC (BMS). By providing this information, you are not in any 

way released from the obligation to independently verify the information and to evaluate BMS products for your intended uses and purposes. 

The application, use and/or processing of BMS products and any products which are manufactured using BMS products on the bases of any 

information being provided herein are beyond the control of BMS and are the sole responsibility of the customer. 

Company Sanitized 
As mentioned in previous correspondence, Bayer MateriaiScience LLC ("BMS") intends to 

cooperate with EPA in responding to this RFI; however, during our initial file review it became 

apparent that BMS would not be able to complete a search of its files and prepare responses 

for EPA within the 60-day window requested by EPA. Thus, BMS requested and was granted (via 

letter from Ms. Maria J. Doa on November 14, 2012) a 30-day extension. 

BMS has enclosed, under cover of this letter, information responsive to the RFI and considers 

certain portions of the responsive information to be Confidential Business Information and 

therefore has provided EPA with an (i) unredacted, confidential set of the responsive 

documents, (ii) a redacted, public set ofthe responsive documents and (iii) a document 

substantiating BMS' claim of Confidential Business Information. 

In performing this voluntary action, BMS has conducted a good faith search of its files and 

provided copies of documents responsive to the RFI, as BMS interprets the RFI. 

BMS notes that it may have in its possession, custody or control documents or data owned by 

parties other than BMS, which BMS possesses under the terms of one or more confidentiality 

agreements. BMS has not provided those documents or data to EPA in response to the RFI. 

Further, BMS reserves the right to evaluate additional documentation that it becomes aware of 

or later determines to be responsive to the RFI. If BMS makes such a determination, it will 

supplement its response to the RFI. 

If EPA has questions about 

of the RFI, please contact 

Sincerely, 

Enclosures 

onses to its RFI, or wishes to discuss BMS' inte 

via email at 

PUBLIC 
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