Crai g A

. Rogerson

Cha i rman, President & CEO

Chemt u ra C o rporati on

199 Bens on Ro ad
Middlebury

, CT 06749

203-573-22 20 tel

203-573-28 00 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 Deca BDE 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, announ ced that by the end of 2004 it w ould have voluntarily phased out all production of two other flame retardants t hat were widely used at the time, pentabromodiphenyl ether (pentaBDE) and oc tabromodiphenyl 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 join ing together of Great Lake s Chemical Corporation and Crompton Corporation) has responded to the nee ds 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-ye ar 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 fo r future sale, and any inventory remaining will be sold no later than six mont hs after the end of t he phase-out period.

The phase-out will focu s initially on consumer applications su ch as electronics and home furnishings, followed by all other applications. Due to the st ringent engineering requirements and risks associated with product changes in certain transportation and mi litary 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 r equire an extended time to phase out decaBDE.

Based on these commitments, Chemtura commi ts 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 1 7 , 2009 Page 2

By six months after end of pha se -out: Compl e te liqu i dation of any resid ual inve ntory of deca B DE.

Chemtura will work closely with it s customers to help transition them to alternati v es. We will report

annu ally on o u r progress, inclu d i ng the percenta ge d e clin e in pro d u ction a nd sa les from the 2 008 baseline, and will inform the EPA when we have com p leted our phase-out. EPA contractors may

obtain a c cess to our rep o rt s su bje c t to appro p ri at e re stri ctions o n disclo sure of confid ential

information.

W e look forward to working wi th the EPA on this Initiative.

Since r ely,

Crai g A. Rog e rson Chai rma n , Presid ent & CEO

cc: Stephen A. Owen s Assi stant Ad ministrator for Pollution Pre v ention and T o xics
U.S. EPA Offi ce of Pollution Prevention and Toxics

1200 Pen n syl v ania Avenue , NW (7 401M )

Wa shin gton, DC 20 460

Wen d y Clela nd-Ham net, Dire cto r U.S. EPA Offi ce of Pollution Prevention and Toxics

1200 Pen n syl v ania Avenue , NW (7 401M )

Wa shin gton, DC 20 460