Re: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 

(COPS-1). 

Chuantung Lin to: Paul Campanella 11/13/2012 02:19 PM

Cc: Tracy Williamson, Myrta Christian, David Brooks, John Schaeffer

History: This message has been replied to and forwarded.

Hi Paul,

The HPV3 Test Rule requires A1, A2, A3, A4, and A5 testing (P/C endpoints) for [52556-42-0} (assumes 

a pure substance (99%) is available) . If the sponsor of this chemical insists that the pure substance is 

not possible to obtain in commerce, then there is no points to perform these P/C endpoints testing. The 

reasons are the following:

1) The test substance/sample is always in a 40% aqueous solution not the pure substance at all ;

2) The test of A1 (M.P.), A2 (B.P.), and A3 (V.P.) will be all on the aqueous sample, the results will be not 

relevant to the endpoints HPV3 Test Rule is aiming for to fulfill the P/C data gap. All the test result on the 

aqueous sample solution (i.e, using AkzoNobel AHPS product) will be for the solvent (in this case, is 

water) and not for COPS-1.

3) Since the sample solution contains ~40% of COPS-1 (in ~52-57 % of water), the minimum water 

solubility of COPS-1 should be >40% and therefore, don't require additional testing for this endpoint at all. 

We could use 40% for the water solubility endpoint.

4) As the sponsor indicated that the Log Kow value will be expected to much less than 0 (i.e., very 

soluble). The EPI's estimation shows around "-5.0". It will not be necessary to test this endpoint.

Base on these facts and the sponsor's reasoning of no 99% pure of substance is available for this test 

substance, ICB recommends that these five P/C endpoints should be dropped from testing.

Whether using the 40% solution as the test sample for biodegradation issue and other toxic endpoints 

testing are EAB and RAD's calls.

Let me know if you have further question on this matter. Thanks!

Daniel 

______________________________________________________

Dr. Daniel Chuantung Lin 

Industrial Chemistry Branch

Office of Chemicals Safety and Pollution Prevention

US EPA

1200 Pennsylvania Ave., NW (7406M)

Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, 

EPA East, Room#:5133E, Washington, DC 20460]

202-564-8584 (direct)

202-564-8740 (branch)

202-564-8679 (fax)
Paul Campanella Daniel, Tucker Helmes believes this is what you... 11/12/2012 08:25:47 PM

From: Paul Campanella/DC/USEPA/US

To: Chuantung Lin/DC/USEPA/US@EPA

Date: 11/12/2012 08:25 PM

Subject: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Daniel, Tucker Helmes believes this is what you need to make the analysis. If this is not sufficient please 

let me know. Thanks.

----- Forwarded by Paul Campanella/DC/USEPA/US on 11/12/2012 08:21 PM -----

From: Tucker Helmes <HelmesT@socma.com>

To: Paul Campanella/DC/USEPA/US@EPA

Cc: David Brooks/DC/USEPA/US@EPA, John Schaeffer/DC/USEPA/US@EPA

Date: 11/12/2012 09:04 AM

Subject: RE: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Paul,

Attached is an amended AHPS analysis summary sheet providing the CAS number for AHPS (same as for

COPS‐1).  This should give you what you need.

Tucker

Dr. C. T. Helmes

Senior Director

Society of Chemical Manufacturers and Affiliates

1850 M Street, NW Suite 700

Washington, DC 20036

Tel 202-721-4154 / Fax 202-296-8120

helmest@socma.com

From: Campanella.Paul@epamail.epa.gov [mailto:Campanella.Paul@epamail.epa.gov] 

Sent: Friday, November 09, 2012 11:26 AM

To: Tucker Helmes

Cc: Brooks.David@epamail.epa.gov; Schaeffer.John@epamail.epa.gov

Subject: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Tucker , can you provide the information that Dr. Lin is asking for. Thanks.

Paul J. Campanella, Ph.D.
Chemical Information and Testing Branch

Chemical Control Division

U.S. Environmental Protection Agency

Washington, D.C. 

202-564-8091

----- Forwarded by Paul Campanella/DC/USEPA/US on 11/09/2012 11:25 AM -----

From: Chuantung Lin/DC/USEPA/US

To: Paul Campanella/DC/USEPA/US@EPA

Cc: David Brooks/DC/USEPA/US@EPA, Tracy Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA

Date: 11/09/2012 11:15 AM

Subject: Re: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Hi Paul,

When I tried to compare the two products (COPS-1; CASRN 52556-42-0) and AlzoNobel AHPS (no 

CASRN & Chemical identity), I found it is impossible to do. The sponsor only stated that "Akzo’s product

is called AHPS but is identical to COPS-1". I need the full Chem ID (CASRN & CA Index Name) for 

AkzoNobel AHPS in order to decide whether these two chemicals are indeed the same chemical. Could 

you ask the sponsor to provide such information?

Daniel

_________________________________________

Dr. Daniel Chuantung Lin 

Industrial Chemistry Branch

Office of Chemicals Safety and Pollution Prevention

US EPA

1200 Pennsylvania Ave., NW (7406M)

Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, 

EPA East, Room#:5133E, Washington, DC 20460]

202-564-8584 (direct)

202-564-8740 (branch)

202-564-8679 (fax)

-----Paul Campanella/DC/USEPA/US wrote: -----

To: Chuantung Lin/DC/USEPA/US, David Brooks/DC/USEPA/US

From: Paul Campanella/DC/USEPA/US

Date: 11/08/2012 04:07PM

Subject: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Daniel and David. Here is an issue we have run into before. The purity of the test substance. This is 

particularly important just now because the consortium has ordered the animals and wants to start testing 

the week of Nov 27-30. If we can give them a quick read on this they will go ahead. If not they will have to 

delay the start up and go through all the paperwork of asking for an extension of the date to submit test 

data etc. I hope we can provide them a answer in a reasonable time. Thanks for your help.
Paul J. Campanella, Ph.D.

Chemical Information and Testing Branch

Chemical Control Division

U.S. Environmental Protection Agency

Washington, D.C. 

202-564-8091

----- Forwarded by Paul Campanella/DC/USEPA/US on 11/08/2012 04:04 PM -----

From: Tucker Helmes <HelmesT@socma.com>

To: Paul Campanella/DC/USEPA/US@EPA

Date: 11/08/2012 03:59 PM

Subject: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Paul,

Following up on our phone call just now re. HPV3 EPA Review of Testing Plans for CASRN 

52556-42-0 (COPS-1), I attach some pertinent information including the COA of the COPS-1 test 

material which will be supplied by Bimax. The second attachment (CONFIDENTIAL) is conformation of 

the sample purity from Bimax. 

For comparison, the last four attachments provide analysis of AHPS by AkzoNobel, another member of 

the consortium. Akzo’s product is called AHPS but is identical to COPS-1. The AkzoNobel analysis is 

backed up by an nmr and analytical determination methods. You can see that COPS-1 and AHPS are 

virtually identical in composition and purity. Both are representative of the typical commercial product of 

the subject test substance produced by consortium members.

As COPS-1 is a salt, achieving 99% purity is not feasible. It would require commercial 

recrystallization units which are costly to purchase and the energy cost of running it on a 

commercial scale cost prohibitive for industrial uses. It would also require specialized 

dry handling capabilities at the polymerization step. This makes no sense when the sole 

use of the COPS-I is to further polymerization reactions into aqueous polymers. In this 

case, the manufacture of dry monomer does not seem relevant to the exposure 

component of risk assessment.

Please let me know if when discussing this with your colleagues you have further 

questions. Naturally we’d like to get this program moving to comply with the timeline and 

avoid the lengthy process of requesting a test rule modification through the docket 

office.

Thanks very much for your help in this matter. Looking forward to hearing back from 

you.

Tucker 

Dr. C. T. Helmes

Senior Director

Society of Chemical Manufacturers and Affiliates

1850 M Street, NW Suite 700
Washington, DC 20036

Tel 202-721-4154 / Fax 202-296-8120

helmest@socma.com

(See attached file: COA bimax 081312.pdf)(See attached file: COPS-1 purity 110812.docx)(See 

attached file: AkzoNobel AHPS analysis.pdf)(See attached file: AkzoNobel COPS GC 

Chromatogram.pdf)(See attached file: AkzoNobel Memo on Analytical Methods to Analyze AHPS

Monomer 120106.doc)(See attached file: AkzoNobel QCTM 711 Determination of residual Allyl Glycidyl 

Ether (AGE) and 3-Allyloxy-12-Propanediol (GAE) in Monomer AHPS by Gas Chromatography.doc)

(See attached file: COA bimax 081312.pdf)(See attached file: COPS-1 purity 110812.docx)(See 

attached file: AkzoNobel AHPS analysis.pdf)(See attached file: AkzoNobel COPS GC

Chromatogram.pdf)(See attached file: AkzoNobel Memo on Analytical Methods to Analyze 

AHPS Monomer 120106.doc)(See attached file: AkzoNobel QCTM 711 Determination of 

residual Allyl Glycidyl Ether (AGE) and 3-Allyloxy-12-Propanediol (GAE) in Monomer AHPS 

by Gas Chromatography.doc)