# BayerMaterialScience

December 18, 2012**e7507~()** 

# RECEIVED OPPT CBIC 

## 2012DEC27 AM 6: 00



# OPPT-2011-0182 Bayer MateriaiScience LLC 100 Bayer Road Pittsburgh, PA 15205-9741 Phone:



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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 MayConcern: We are writing in response to the Request for Information Letter (the 11

### RFI"), which we received September 26, 

### 2012. In it, EPA requests 11

### the following information related to MDI and TDI, as well as aliphatics, such as hexamethylene diisocyanate (HDI): 

### 1. The curingtime required to chemically react all diisocyanate functional groups. 2. The amount oftime required, priorto and after a product has fully cured, to safely reoccupy or use an area where diisocyanates have been reacted (including expected exposures to diisocyanates, otherformulation additives, and/or reaction products formed)." The RFI requests a broad array ofdata types and sources, including 11

### Studies, 

### memos, unpublished data or any other documents [that may be] in [our] possession relating to curing time and re-occupancy" time.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 orguarantee 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 foryour 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 ofthe customer. 

# Company SanitizedAs mentioned in previous correspondence, Bayer MateriaiScience LLC 

### ("BMS") intendsto cooperate with EPA in respondingtothis RFI; however, during our initial file review it became apparentthat BMS would not be able to complete a search of its files and prepare responses for EPA within the 60-daywindow requested by EPA. Thus, BMS requested and was granted (via letterfrom Ms. Maria J. Doa on November 14, 2012) a 30-day extension. BMS has enclosed, under cover ofthis letter, information responsive tothe RFI and considers certain portions ofthe responsive information to be Confidential Business Information and therefore has provided EPA with an (i) unredacted, confidential set ofthe responsive documents, (ii) a redacted, public set ofthe responsive documents and (iii) a document substantiating BMS' claim ofConfidential Business Information. In performingthis voluntary action, BMS has conducted a good faith search ofits files and provided copies ofdocuments responsive tothe RFI, as BMS interpretsthe RFI. BMS notesthat it may have in its possession, custody or control documents ordata owned by parties otherthan BMS, which BMS possesses undertheterms ofone or more confidentiality agreements. BMS has not provided those documents or data to EPA in response to the RFI. Further, BMS reserves the rightto evaluate additional documentation that it becomes aware of or laterdeterminesto be responsive tothe RFI. If BMS makes such a determination, itwill supplement its response tothe RFI. If EPA has questions about ofthe RFI, please contact Sincerely,

Enclosures onses to its RFI, orwishes to discuss BMS' inte via email at



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