Craig A. Rogerson 

Chairman, President & CEO 

Chemtura Corporation 

199 Benson Road 

Middlebury, CT 06749 

203-573-2220 tel 

203-573-2800 fax

December 17, 2009 

Lisa P. Jackson, Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW (1101A) 

Washington, D.C. 20460 

Re: DecaBDE Phase-Out Initiative 

Dear Administrator Jackson: 

Chemtura Corporation is pleased to join the DecaBDE Phase-Out Initiative. We have worked closely 

with your staff to help design the Initiative. We welcome the opportunity to help transition customers 

from decabromodiphenyl ether (decaBDE) to other alternatives. 

This Initiative continues Chemtura’s long-standing efforts with regard to protecting people and property 

from the hazards of fire in a sustainable manner. In 2003, Chemtura’s predecessor company, Great 

Lakes Chemical Corporation, announced that by the end of 2004 it would have voluntarily phased out 

all production of two other flame retardants that were widely used at the time, pentabromodiphenyl 

ether (pentaBDE) and octabromodiphenyl ether (octaBDE). The EPA commended Great Lakes for 

taking that action voluntarily and for doing so as expeditiously as possible. 

Since then, Chemtura (formed in 2005 from the joining together of Great Lakes Chemical Corporation 

and Crompton Corporation) has responded to the needs of our customers and concerns of other key 

stakeholders to introduce more sustainable flame retardants. We have sponsored or co-sponsored 

extensive health and environmental studies of various flame retardants. Chemtura offers a broad 

portfolio of flame retardants used in a wide variety of applications. We continually strive to bring new 

high performance and greener products to market. 

Chemtura will submit a detailed plan of year-over-year reductions in decaBDE production to the EPA. 

Chemtura commits to a complete phase-out of decaBDE production by the end of 2012 (except for 

certain uses discussed below). We will not stockpile inventories for future sale, and any inventory 

remaining will be sold no later than six months after the end of the phase-out period. 

The phase-out will focus initially on consumer applications such as electronics and home furnishings, 

followed by all other applications. Due to the stringent engineering requirements and risks associated 

with product changes in certain transportation and military applications, multiple levels of testing and 

certification are typically required. We expect that some of these uses may require up to 12 additional 

months to verify that alternatives provide an acceptable level of performance and fire safety. To the 

extent we are legally permitted, we will notify the EPA of any uses which require an extended time to 

phase out decaBDE. 

Based on these commitments, Chemtura commits to the following phase-out schedule: 

By Dec. 31, 2012: Discontinue production and sale of decaBDE for all applications except for 

certain transportation or military applications. 

By Dec. 31, 2013: Discontinue production of decaBDE for any remaining applications. 
Lisa P. Jackson, Administrator 

December 17, 2009 

Page 2

By six months after 

end of phase-out: Complete liquidation of any residual inventory of decaBDE. 

Chemtura will work closely with its customers to help transition them to alternatives. We will report 

annually on our progress, including the percentage decline in production and sales from the 2008 

baseline, and will inform the EPA when we have completed our phase-out. EPA contractors may 

obtain access to our reports subject to appropriate restrictions on disclosure of confidential 

information. 

We look forward to working with the EPA on this Initiative. 

Sincerely, 

Craig A. Rogerson 

Chairman, President & CEO 

 

cc: Stephen A. Owens 

Assistant Administrator for Pollution Prevention and Toxics 

U.S. EPA Office of Pollution Prevention and Toxics 

1200 Pennsylvania Avenue, NW (7401M) 

Washington, DC 20460 

Wendy Cleland-Hamnet, Director

U.S. EPA Office of Pollution Prevention and Toxics 

1200 Pennsylvania Avenue, NW (7401M) 

Washington, DC 20460