Document Control Officer 

Office of Pollution Prevention and Toxic 

Substances, 7407 

U.S . EPA 

1201 Constitution Ave., NW 

Washington, DC 20460 

June 22, 2005 

/I= u./ A41' 04"~ 

,)65- 63q CD 

W 

RE: Premanufacture Notice TS-05CR01 c~ 

co 

I Dear Sir or Madam: 

On behalf of the [ 

] is hereby submitting in accordance with 40 CFR Section 720.50 the 

attached Premanufacture Notice (PMN) TS-05CR01 for review . 

In accordance with 40 CFR Section 700.45(b), the fee of $2,500 .00 has 

been submitted (see attached copy of check) . 

This PMN notification contains confidential business information (CBI). 

Accordingly, in addition to the submission of the original notification and two 

copies, a single sanitized copy is also provided. 

Finally, the PMN form used is an electronic version purchased from 

CMA. The document showing EPA approval of the form is attached . 

If there are any questions regarding this submission, please do not 

hesitate to contact me at [ ] . 

Sincerely, 

l [ 

Attachments 

] 

Company Sanitized 

c.~ 
U.S . ENVIRONMENTAL PROTECTION AGENCY 

:.FpA 

TEST DATA AND OTHER DATA 

PREMANUFACTURE 

NOTICE 

You are required to submit all test data in your possession or control and to provide a 

description of all other data known to or reasonably ascertainable by you, if these 

data are related to the health and environmental effects on the manufacture, 

processing, distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

scientific literature . Complete test data (written in English), not summaries of data, 

must be submitted if they do not appear in the open literature. You should clearly 

identify whether test data is on the substance or on an analog . Also, the chemical 

composition of the tested material should be characterized . Following are examples 

of test data and other data . Data should be submitted according to the requirements 

of §720.50 of the Premanufacture Notification Rule (40 CFR Part 720) . 

Zh*any Sanitized 

r i 

nter the total number ot pages 

n the Premanufacture Notice 

GENERAL INStittftTIONS 

. 

You must provide all information requested in this form to the extent that it is known to or reasonably ascertain 

have actual data. 

AGENCY USE ONLY 

ble by you. Make reasonable Wmates if you do not 

Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603). 

If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226, P.O . 360399M, 

Pittsburgh, PA 15251-6399, Ann. TSCA User fee. 

Part I-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 

chemical substance, even if you claim the identity as confidential . You may authorize 

another person to submit chemical identity information for you, but your submission will 

not be complete and the review will not begin until EPA receives this information. A 

letter in support of your submission should reference your TS user fee identification 

number. You must submit an original and two copies of this notice including all test data . 

If you claimed any information as confidential, a single sanitized copy must also be 

submitted . 

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part Il, 

sections A and B of this notice, reproduce the sections as needed . 

Part III- LIST OF ATTACHMENTS 

Attach additional sheets if there is not enough space to answer a question fully. Label 

each continuation sheet with the corresponding section heading . In Part III, list these 

attachments, any test data or other data and any optional information included in the 

notice. 

Test Data (Check Below any included in this notice) 

Environmental fate data 0 Yes " Other data ® Yes 

" Health effects data 0 Yes Risk assessments 

" Environmental effects data [I Yes Structure/activity relationships 

OPTIONAL INFORMATION 

You may include any information that you want EPA to consider in evaluating the new 

substance. On page 11 of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new 

substance . 

So-called "binding" boxes are included throughout this form for you to indicate your 

willingness to be bound to certain statements you make in this section, such as use, 

production volume, protective equipment . . . This option is intended to reduce delays 

that routinely accompany the development of consent orders or Significant New Use 

Rules . Except in the case of exemption applications (such as TMEA, LVE, LOREX) 

where certain information provided in such notification is binding on the submitter when 

the Agency approves the exemption application, checking a binding box in this notice 

does not by itself prohibit the submitter from later deviating from the information (except 

chemical identity) reported in the form . 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential . To assert a claim on the 

form, mark (X) the confidential box next to the information that you claim as 

confidential . To assert a claim in an attachment, circle or bracket the information you 

claim as confidential . If you claim information in the notices as confidential, you must 

also provide a sanitized version of the notice . (includina attachments) . For additional 

instructions on claiming information as confidential, read the Instructions Manual. 

® Mark (x) if any information in this notice is claimed as confidential. 

EPA FORM 7710-25 (Rev . 5-95) 

Physical/Chemical Properties* ® Yes Test data not in the possession 

or control of the submitter 

* A physical and chemical properties worksheet is located on the last page of this form. 

TYPE OF NOTICE (Check Only One) c~ 

® 

D. 2 

Form Approved . O.M.B . No. 2070-0012. Approval Expires 10-31-96 . 

Date of receipt 

PMN (Premanufacture Notice) 

crl 

C= 

INTERMEDIATE PMN (submitted in sequence with finQl.producTPI4Nj 

C? --1 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) .,_.., - '-

LVE (Low Volume Exemption) @ 40 CFR 723 .50(c)(IbD 

LOREX (Low Release/Low Exposure Exemption) @ 40 CFR 723 .50(c)(2) 

LVE Modification 

IS THIS A CONSOLIDATED PMN? 

# of chemicals 

LOREX Modification 

Yes 

(Prenotice Communication # required, enter # on page 3) 

Replaces previous editions of EPA Form 7710-25. 

~ e 7 ,:2 . Y ~ Q , 
Public reporti,ng burden for this collection of information is estimated to average 110 hours per response, including time for reviewing instructions, 

searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send 

comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to 

Chief, Information Policy Branch, PM-223, U.S . Environmental Protection Agency, 401 M. St ., S.W., Washington, D.C . 20460; and to the Office 

of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C . 20503. 

CERTIFICATION 

I certify that to the best of my knowledge and belief : 

1 . The company named in Part 1, section A, subsection la of this notice form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part 1, 

Section B. 

2. All information provided in this notice is complete and truthful as of the date of submission. 

3. I am submitting with this notice all test data in my possession or control and a description of all other data known to or 

reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule. 

Additional Certification Statements : 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 

statement that applies: 

® The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 

0 The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 

700.43) in accordance with 40 CFR 700.45(b), or 

The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of $100 in 

accordance with 40 CFR 700.45(b) . 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723 .50(c)(1) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements : 

The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 

purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723 .50. 

0 The manufacturer is familiar with the terms of this section and will comply with those terms ; and 

0 The new chemical substance for which the notice is submitted meets all applicable exemption conditions . 

0 If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period . 

The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An knowing and willful misinterpretation is subject to criminal penalt y pursuant to 18 USC 1001. Confidential Signature and title of Authorized Official (Original Signature Required) Date 

X 

Signature of agent - (if applicable) Date 

X 

3 

EPA FORM 7710-25 (Rev . 5-95) 
Part I -- GENERAL INFORMATION 

Section A -- SUBMITTER IDENTIFICATION 

1 a . Person Name of authorized official Position 

Submitting 

Notice (in U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code 

b. Agent (if Name of authorized official Position 

applicable) 

X 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

c. If you are submitting this notice as part of a joint submission, mark (X) this box. 

Joint Submitter (if Name of authorized official Position 

applicable) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

2. Technical Name of authorized official Position 

Contact (in 

X U.S .) 

Company 

Mailing address (number and street) 

City, State, ZIP Code Telephone Area Code Number 

3 . If you have had a prenotice communication (PC) concerning this notice 

and EPA assigned a PC Number to the notice, enter the number. Mark (X) - -i 

if none 

4 . If you previously submitted an exemption application for the chemical 

substance covered by this notice, enter the exemption number assigned by 

EPA If i l b i d PMN f i 

Mark (X) -- 

. you prev ous y su m tte a or th s substance enter the El X if none PMN number assigned by EPA (i.e. withdrawn or incomplete) .--~ 

5. If you have submitted a notice of Bona fide intent to manufacture or import 

for the chemical substance covered by this notice, enter the notice number 

assi ned b EPA g y . -~ 

Mark (X) -- El X if none 

6. 

. ~ 

Type of Notice - Mark (X) 

1 Manufacture 2. ® Import 

Only Only 3. ~ Both 

Binding Option ~ Binding Option 

Marx (X) 

Mark Q the "Confidential" box next to an subsection you claim as confidential 

Confidential 

EPA FORM 7710-25 (Rev . 5-95) Pao,-Y 
p. 5 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION: You must provide a currently correct Chemical Abstracts (CA) name of the substance based on 

the ninth Collective index (9Cl) of CA nomenclature rules and conventions . Mark (X) the "Confidential" box next to an item you claim as confidential 

Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items . 

If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right. ConfiIdentif the name, compan y, and address of that person in a continuation sheet. 0 dential 

1 . Class 1 or 2 chemical substances (for definitions of class 1 and class 2 substances, see the Instructions Manual) 

a. Class of substance - Mark (X) 1 [:] Class 1 or 2 [:] Class 2 

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances . 

For Class 1 substances a CA Index Name must be provided . For Class 2 substances either a CA Index Name or CA Preferred Name must 

be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions) . 

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one) . 

® Method 1 (CAS Inventory Expert Service - a copy of the Identification E] Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this notice) 

d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

X 

CAS# - 

X 

e. For a class 1 substance, provide a complete and correct chemical structure diagram. For a class 2 substance - (1) List the immediate 

precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the 

range of composition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure diaQram, as complete as can be known, if one can be reasonablv ascertained. 

® Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Pag ,5-A- 
Page,4-° 
Paae ~ 
p. 8 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 

2. Polymers (For a definition of polymer, see the Instructions Manual .) Confidential 

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. 

Indicate maximum weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 

below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC ~ Other Ej : (Specify) not applicable 

i) lowest number average molecular weight: 

ii) maximum weight % below 500 molecular weight: 

iii) maximum weight % below 1000 molecular weight: 

Mark (X) this box if you attach a continuation sheet. 

b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the 

"Confidential" box next to any item you claim as confidential 

(1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

(2) - Mark (X) this column if entry in column (1) is confidential . 

(3) - Indicate the typical weight percent of each monomer or other reactant in the polymer. 

(4) - Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

(5) - Mark (X) this column if entries in columns (3) and (4) are confidential . 

(6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

commercial purposes . 

(7) - Mark (X) this column if en in column (6) is confidential. 

Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential 

(1) (2) (3) (4) (5) (6) (7) 

% 

% % 

%a % 

% % 

Mark (X) this box if you attach a continuation sheet. 

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one) . 

Method 1 (CAS Inventory Expert Service - a copy of the identification report ~ Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this notice) 

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers . 

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained. 

~ Mark (X) this box if you attach a continutation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Pagv< 
p. 9 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 

3. Impurities 

(a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. 

CAS Registry Number if available. If there are unidentified impurities, enter "unidentified." 

(b) - Estimate the maximum weight % of each impurity. If there are unidentified impurities, estimate their total weight %. 

Provide the 

Impurity and CAS Registry Number 

(a) 

Maximum 

percent 

(b) 

Confidential 

% 

% 

% 

% 

% 

% 

% 

® Mark (X) this box if you attach a continuation sheet. 

4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. Confidential 

Mark (X) this box if you attach a continuation sheet. 

X 

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

Mark (X) this box if you attach a continuation sheet. 

X 

6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals 

the specific chemical identity of the new chemical substance to the maximum extent possible . Refer to the 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

Metal silicate 

Mark (X) this box if you attach a continuation sheet. 

7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry 

Number if available. 

Byproduct 

(1) 

CAS Registry Number 

(2) 

Confidential 

X 

Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page,,6' 
p. 10 

Page 
p. 11 

Part I -- GENERAL INFORMATION -- Continued 

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION: 

Mark (X) the "Confidential" box next to an item you claim as confidential . 

1 . Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum 

production volume for any consecutive 12-month period during the first three years of production . Estimates should be on 100% new chemical 

substance basis . For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 

k / r, specify the volume and mark (x) in the binding box. If ranted, y ou are bound to this volume 

Maximum first 12-month production (kg/yr) 

(100% new chemical substance basis) 

Maximum 12-month production (kgfyr) 

(100% new chemical substance basis) 

Contidential Binding 

Option 

Mark (x) 

X 

2. Use Information --You must make separate confidentiality claims for the description of the category of use, the percent of production volume 

devoted to each category, the formulation of the new substance, and other use information . Mark (X) the "Confidential" Box next to any item 

you claim as confidential . 

a. (1) -- Describe each intended category of use of the new chemical substance by function and application. . 

(2) -- Mark (X) this column if entry column (1) is confidential business information (CBI). 

(3) -- Indicate your willingness to have the information provided in column (1) binding . 

(4) -- Estimate the percent of total production for the first three years devoted to each category of use. 

(5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI). 

(6) -- Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for 

commercial purposes at sites under your control associated with each category of use. 

(7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI). 

(8) -- Indicate % of product volume expected for the listed "use" sectors . Mark more than one box if appropriate . Mark (X) to indicate 

your willingness to have the use type provided in (8) binding. 

(9) -- Mark (X) this column if entry(ies) in column (8) is (are) confidential business information (CBI). 

Category of use (1) CBI Binding 

Option 

Production % CBI % in 

FormCBI % of substance expected per use (8) CBI 

(by function and application i .e . a dispersive dye 

for finishin g polyester fibers) (2) 

M~k (xl 

(3) (4) (5) 

ulation 

(6) (7) 

Sitelimited Con-* 

sumer 

Industrial 

Commercial Binding 

Option (9) 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products . 

In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this 

substance loses its identity in the consumer product. 

E]Mark (X) this box if you attach a continuation sheet. 

b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category . Read the 

use Instructions Manual for examples of generic use descriptions . 

description 

toner additive 

~ Mark (X) this box if you attach a continuation sheet. 

3. Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other 

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices 

for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. 

Binding 

Option 

Mark (x) 

® Mark (X) this box if you attach hazard information. 

EPA FORM 7710-25 (Rev. 5-95) Page 

/11i 
p. 12 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (x) the "Confidential" box next to any item you 

claim as confidential 

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you 

control . Importers do not have to complete this section for operations outside the U.S . ; however, you may still have reporting requirements if 

there are further industrial processin g or use operations after import. You must describe these operations . See instructions manual 

1 . Operation description Confia. Identit y -- Enter the identity of the site at which the operation will occur. dential 

Name 

not applicable, PMN substance will be imported 

Site address (number and street) 

City, County, State, ZIP code 

If the same operation will occur at more than one site, enter the number of sites . Identify the 

additional sites on a continuation sheet, and if any of the sites have significantly different 

production rates or operations, include all the information requested in this section for those 

sites as attachments . 

Mark (X) this box if you attach a continuation sheet. b. Type -- 

Mark (X) E]Manufacturing OProcessing E]Use 

c. Amount and Duration -- Complete 1 or 2 as appropriate 

Maximum kg/batch (1oo% new chemical Hours/batch Batches/year 

substance) 

1 . Batch 

Maximum kg/batch (100% mw cheirieal Hours/batch Batches/year 

substtnce) 

2. Continuous 

d. Process description 0 Mark (X) to indicate your willingness to have your process description binding. 

(1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g . 5 gallon pails, 55 gallon 

drum, rail car, tank truck, etc.). 

(2) Provide the identity , the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and 

feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch.) . 

(3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 

not applicable, PMN substance will be imported 

~ Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) 

Pag51'r 

l~ 
. Tart II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER -- Continued 

2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical substance, 

number of works exposed, and duration of activity . Mark (X) the "Confidential" box next to any item you claim as confidential . 

(1) --Describe the activities (i .e . bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. 

(2) --Mark (X) this column if entry in column (1) is confidential business information (CBI). 

(3) -- Describe any protective equipment and engineering controls used to protect workers. 

(4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. 

(5) -- Indicate the physical form(s) of the new chemical substance (e .g ., solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) 

at the time of exposure . 

(7) --Mark (X) this column if entry in column (5) is confidential business information (CBI). 

(8) -- Estimate the maximum number of workers involved in each activity for all sites combined. 

(9) --Mark (X) this column if entry in column (8) is confidential business information (CBI). 

(10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year . 

(12) --Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). 

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu 

m 

duration CBI 

(i .e ., bag dumping, filling drums) Engineering Controls Option and % new Option Worker Hrs/day Days/yr 

Mark (x) substance Mark (x) 

(1) (2) (3) (4) (5) (6) (7) Expose (9) (l0) (11) 

d 

(8) 

not applicable, PMN 

substance will be imported 

~ Mark (X) this box if you attach a continuation sheet. 

3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential . 

(1) --Enter the number of each release point identified in the process description, part II, section A, subsection l d(3) . 

(2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch). 

(3) --Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI). 

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to 

which the new substance will be released from that release point. 

(5) --a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for 

each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b. Estimate 

the amount released to the environment after control technology (in kg/day). 

(6) --Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). 

(7) --Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

NPDES numbers of the POTW (Publicl Owned Treatment Works) . Mark (X) if the POTW name or NPDES # is confidential business information (CBI). 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) Cut 

Number released release 

(1) (2a) (2b) e g A .~ air Binding 

(3) (4) (Sa) Mark (x) (Sb) (6) 

not applicable, PMN substance will be 

imported 

(7) Mark (X) the 

El POTW provide name(s) below: 

CBI 

1:1 Navigable ~ Other -Specify provide NPDES # CBI 

destination(s) of waterway 

releases to water. 

Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) Page 

1111 
p. 14 

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control . Importers do not have to complete this 

section for operations outside the U.S ; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate 

section B for each type of processing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

typ ical operation common to these sites. Identify additional sites on a continuation sheet. 

1 . Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential . 

(1) -- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 gallon pails, 55 gallon 

drums, rail cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity . (2) -- Provide the identity, the approximate weight 

(by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all 

products, recycle streams, and wastes . Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points of release, 

including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # of sites (remember to identify the locations of 

these sites on a continuation sheet): 

# of sites 

See page 10a 

® Mark (X) this box if you attach a continuation sheet. 

2. Worker Exposure/Environmental Release 

(1) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) -- Estimate the number of workers exposed for all sites combined . 

(4) --Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year . 

(6) -- Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to 

protect workers. 

(7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. 

(9) -- From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified. 

(10) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch). 

(12) -- Describe media of release i .e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other 

(specify) and control technology, if any, that will be used to limit the release of the new substance to the environment. 

(14) -- Identify byproducts which may result from the operation. 

(3), (5), (8), (11), (13) and (15) -- Mark (X) this column if an of the proceedin g entries are confidential business information (CBI). 

Letter # of CBI Duration CBI Protective Equip . / % in CBI Release Amount of CBI Media of Release CBI 

of Workers of Engineering Controls/ Form- Number New & Control 

Act- Exposed Exposure Physical Form and % ulation Substance Technology 

ivit 

y new substance Released 

(1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (lOb) (11) (12) (13) 

see page 10a 

14) -- Byproducts : L 

(15) 

none 

I ® Mark (X) this box if you attach a continuation sheet, 

EPA FORM 7710-25 (Rev . 5-95) Page 1,11 

1'/) 1 
p. 15 
p. 16 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim information in this section as confidential circle or bracket the specific information that you claim as confidential . 

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce 

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal 

of the PMN substance. Please include new information pertinent to pollution prevention, including source 

reduction, recycling activities and safer processes or products available due to the new chemical substance. 

Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological 

modification, process and procedure modification, product reformulation, raw materials substitution, and/or 

inventory control. Recycling refers to the reclamation of useful chemical components from wastes that would 

otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution 

prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance 

with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the 

information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting 

of risks to other environmental media or non-environmental areas (e .g ., occupational or consumer exposure). In 

addition, information on the relative cost or performance characteristics of the PMN substance to potential 

alternatives may be provided. 

All information provided in this section will be taken into consideration during the review of this 

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the 

volume manufactured ; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a 

reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in 

the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical 

substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing 

substance that poses a greater overall risk to human health or the environment. 

E] Mark (X) this box if you attach a continuation sheet. 

EPA FORM 7710-25 (Rev . 5-95) 
p. 17 

Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form and test data and other data (including physical/chemical properties and 

structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to 

which it relates, if appropriate . Number consecutively the pages of the attachments . In the column below, enter the inclusive page 

numbers of each attachment . 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential . Read the Instructions Manual for guidance on 

how to claim any information in an attachment as confidential . You must include with the sanitized copy of the notice form a sanitized 

version of any attachment in which you claim information as confidential . 

Attachment name Attachment 

a e number(s) 

Confidential 

Material Safety Data Sheet MSDS 

14-17 

Main properties 13,18 

X-ray diffraction chart 19-20 

Powder diffraction file 21 

Phase diagrams 22 

Water elution test 23 

CASIES Inventory Report 24 

Chemical structure diagram 4a 

Manufacturing process 4b 

Impurities list 6a 

Operation Description 10a 

CMA electronic PMN form documentation 25 

PMN fee documentation 26 

1:1 Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number . 

EPA FORM 7710-25 (Rev. 5-95) 
p. 18 

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice . Identify the property measured, the page of the notice on which the property appears, the value of the property, 

the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . The physical 

state of the neat substance should be provided . These measured properties should be for the neat (100% pure) chemical substance. 

Properties that are measured for mixtures or formulations should be so noted (% PMN substance in -). You are not required to 

submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential 

information is properly protected. You should submit this worksheet as a supplement to your submission of test data . This worksheet 

is not a substitute for submission of test data . 

Property 

(a) 

Mark 

(X) if 

provided 

Page 

number 

(b) 

Value 

(~) 

Measured o 

Estimate 

(M or E) 

Conedenrial 

Mark (X) 

(~) 

Physical state of neat substance X 15 X- (s) - (1) - ( ) M 

Vapor pressure 

@ Temperature °C Torr 

Specific gravity X 16 3.2 M 

Solubility 

@ Temperature °C 

Solvent 

Solubility in water @ Temperature °C X 16 insoluble E 

Meltin g temperature X 16 1,890 °C M F 

Boilin g / sublimation tem erature@ torr pressure 

Spectra 

Dissociation constant 

Particle size distribution 

Octanol / water partition coefficient 

Henry's Law constant 

Volitalization from water 

Volitalization from soil 

H@ concentration 

Flammability 

Ex lodabilit 

Adsorp tion / coefficient 

Other - Specify 

ATTACHMENT 

PAGE,.B"' 
p. 19 

Material Safety Data Sheet 

1 . Chemical Product Identification 

Material Identification 

Formula : [ 

Grade : See Trade names and Synonyms 

Trade names and Svnonvms~ 

2. Product Composition 

Product Classification :Magnesium Silicate 

Components CAS Number Percent 

100 

3. Hazard Identification 

Warning : 

" May cause mechanical eye irritation. 

Protective Measures: 

" Avoid contact with the eyes. 

" Use in well ventilated areas. 

" Do not breathe dust. 

Revised May 17, 2005 

4. First Aid Measures 

Inhalation : 

" Remove person to fresh air. If breathing is difficult, provide oxygen and seek medical 

attention 

Eye Contact: 

" Rinse eyes immediately with water for at least 15 minutes. See a physician. 

Skin Contact: 

" Wash skin thoroughly with soap and water. See a physician if irritation persists . 

Ingestion: 

" Provide symptomatic treatment and seek prompt medical attention. 

5. Fire Fighting Methods 

" Flash Point :Not applicable 

" Method :Not applicable 
p. 20 

Extinguishing Media / Fire Fighting Procedures : 

" Use the following extinguishing media when fighting fires involving this material: water 

fog, foam, dry chemical or carbon dioxide. 

Unusual Hazards: 

" Normal precautions for dusts should be provided. Avoid high concentrations of dust 

air. 

6. Accidental Release Measures 

Release Response: 

" Minimize dusting. CAUTION: May cause a slippery condition when wet. Sweep / shovel up and transfer 

into a suitable container for re-use or disposal . 

Personal Protective Equipment: 

" Wear a air-purifying respirator equipped with filters for protection against dusts and 

mists. 

Wear cotton or canvas gloves . 

Wear safety glasses. 

7. Handling And Storage 

Handling: 

" Avoid high concentrations of dust in air through the use of ventilation or other suitable 

controls . 

Storage: 

" This material is not hazardous under normal operating conditions . 

8. Exposure Control Information 

Occupational Exposure Limits : 

ACGIH-TLV OSHA-PEL 

Forsterite Not applicable Not applicable 

Engineering Control Measures: 

" Use local exhaust ventilation if airborne concentrations exceeded recommended 

exposure limits . 

Personal protection Equipment: 

" Respiratory : 

Use an air-purifying respirator equipped with filters for protection against dusts and 

mists . 

" Hand: 

Use cotton or canvas gloves . 

" Eye: 

Eye protection worn must be compatible with respiratory protection system employed. 

Other Control Measures : 

" Use good industrial hygiene practices. Wash hands and face before eating and drinking. 

9. Properties 

" Appearance : White powder 

" Odor : None 

" pH : Not applicable 

Page 

(f rage-2) 

7 -j 
p. 21 

" Boiling point : Not applicable 

" Melting point : 1890 °C 

" Specific Gravity : 3 .2 

" Solubility in water : Insoluble 

" Vapor density : Not applicable 

" Vapor Pressure : Not applicable 

" Volatile by Volume : 0% 

10. Reactivity Information 

Conditions To Avoid: 

Not applicable . 

Hazardous Polymerization : 

Hazardous Polymerization will not occur. 

Hazardous Decomposition: 

Hazardous decomposition will not occur. 

Stability: 

This material is stable under normal operating conditions . 

11 . Health / Toxicity Information 

Health Hazards 

Effects of Acute Exposure 

" Inhalation : 

Inhalation of dust can cause irritation of the nose, throat, and lungs. 

" Eye Contact: 

Like any foreign body, particles can cause mechanical irritation . 

Skin Contact: 

This material can cause irritation if not promptly washed from the skin . 

Skin Absorption : 

This product is not expected to be absorbed though intact skin . 

Ingestion: 

This material is not expected to produce adverse effects . 

Effects of Chronic Over Exposure : 

As with any nuisance dust, long-term exposure to concentrations above the 

recommended exposure limits may overload the lung clearance mechanism and cause 

adverse lung effects and shortness of breath . 

Listed as a suspected or known carcinogen on: 

- IARC :No 

Medical Conditions Aggravated: 

Respiratory disorders. 

Toxicity Information 

Not applicable 

Page"~ 

(Page-3) 

a/ 
p. 22 

12. Environmental Hazards: 

Environmental Hazards : 

" None known. 

13. Disposal Considerations 

" Dispose of in accordance with local, state, and federal regulations . Use a licensed waste 

handler. 

14. Transportation 

Shipping Name :Magnesium Silicate 

Label :Not applicable 

Hazard Class :Not regulated 

Packing Group :Not applicable 

UN# :Not applicable 

15. Regulatory Information 

Chemical Inventories: 

In compliance denotes that all components are on the inventory or exempt. 

European Inventory :In Compliance 

Japanese Inventory :In Compliance 

Korean Inventory :In Compliance 

Other Regulatory Information: 

No data available 

End of MSDS 
p. 23 

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p. 26 
p. 27 

Page 
p. 28 

Paae 
Inventory Expert Service 

A di-isien of the American Chemical Society 

INVENTORY EXPERT SERVICE REPORT 

YES-ORDER NMER : 86974 

REGISTRY NtTBBER o C 

CA INDEX NAM 

7 

Phone: ROD-631-1894, 614-447-3270 

Fax; 614-447-3747 

E-maH: answers@cas.org 

Internet: http:llw-w.as.org/Suppondciicnc.hcml 

Plaare yZint the ibave CA Iadex Name oss the appiopriate page of your PM . 

eooln 

If thin boae ~,s checked, CAS has made corraaeioa(a) markvfl in rod to 

your TES order . Please make the smn correction(B) to yoltr pM before 

rn4mittiag it to the Epik . 

2540 Olanqmgy Rl~cr Road " PO. Box 1343 " CWuntbA Ohio 43210.03)4 

5dD Lvtc L14 qTe Ydd 0=L0 NOW SO/9T/SO 
PreManufacture Notice and 

Notice of Commencement Forms 

EPA. Form 7710-25 (Rev. 5-95) 

EPA Form 7710-56 (Rev. -96) 

Installation and Use .Instructions 

MS Word 6. Ofor Windows 

U.S. EPA Approved December 12,1996 

by Anthony Cheatham 

TSCA Data Administration Section 

CM ° ResponsibieCare' 

A Public Commitment 
p. 31