Univar 17425 NE Union Hill Road Redmond, \VA 98052 USA +1425 8119 3400 T +I 42 5 889
3 -46 F January 27, 2014 By Federal Exoress OPPT Document Control Office U.S. Environmental Protection Agency EPA East Building RoomE6428 1201 Constitution Ave., NW Washington, DC 20460 Attention: TSCA Section

4 CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION Re: Letter of Intent to Conduct Testing Submitted by Univar USA Inc. under the TSCA Section

4 Test Rule on the Testing of Certain High Production Volume Chemicals: Second Group D-erythro-Hex-2-enonic
acid, .gamma.-lactone, monosodium salt CAS RN 6381-77-7 (Sodium erythorbate) Docket Identification No. EPA-HQ-OPPT-2007-0531;

40 CFR 799.5087 Dear Sir/Madam: Through this letter, Univar USA Inc. (Univar or the Company) submits
to the U.S. Environmental Protection Agency (EPA or the Agency) the Company's notice of intent to conduct testing on the chemical substance, D-erythro-Hex-2-enonic
acid, .gamma.- lactone, monosodium

salt [CAS RN 6381-77-7], under the Agency's Toxic SubstancesU.S. Environmental Protection Agency January 27, 2014 Page2
CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION 

### Control Act (TSCA) Section 4(a)(l)(B) test rule published
on January
7, 2011.

1 

### 76 Fed. Reg. 1067. Univar submits this notice in accordance with this final rule, the regulations set forth at 40 CFR 799.5087, and 40 C.F.R. Part 790. For purposes of this letter, this chemical substance

is identified by its synonym, sodium erythorbate. 

### As a matter of background, this final test rule addresses
19 high production volume (HPV) chemicals that went unsponsored under the Agency's voluntary HPV Chemical Challenge Program. One of the 19 chemicals identified
in the rule is sodium erythorbate. The rule requires manufacturers, importers, and processors
of these HPV chemicals

to conduct testing to obtain screening level data for human health effects, environmental effects, chemical fate, and physical/chemical properties. The Agency has issued this test rule under its TSCA Section 4(a)(l)(B) authority based on its belief that HPV compounds, including sodium erythorbate,
are "produced

in substantial quantities; there is or may be substantial human exposure
to them; existing data are insufficient

to determine
or predict their health and environmental effects; and testing
is necessary

to develop such data."

2 

### In general, the final rule identifies the following studies on sodium erythorbate: • n-OctanoVWater Partition Coefficient • Ready Biodegradation • Aquatic Toxicity Testing (acute toxicity
to fish, acute toxicity
to Daphnia, 

### toxicity
to plants (algae))

3 

### Because Univar has not yet begun importing sodium erythorbate with the intent to sell it for TSCA purposes, the specific dates, as set forth in the final rule, for the submission
of the letter of intent and test reports are not applicable.

4
·5 

### On the other hand, the overall timeframe by which final test reports are to be submitted continues
to apply starting from the time which the letter of intent to test is received by the Agency. The final rule states that test reports are due 13 months after the rule's effective date. Univar understands, however, that EPA is requesting

a 12-month timeframe

in the case where

a company was not a manufacturer

or importer of a test rule chemical substance

at the time of the rule's effective date and subsequently submits its letter of intent to test after this date. Univar 1 The CA Index Name and identity appearing on the TSCA Inventory
is: D-erythro-Hex-2-enonic
acid, .gamma.-lactone, sodium salt (1: I)
. 2 76 Fed. Reg. 1,069. 3 Because the n-octanoVwater partition coefficient

is expected
to be significantly less than 4

. 2 based on the compound's high water solubility, Test Group

1 is expected
to apply

. 4 Upon EPA's receipt of this letter of intent to test, Univar plans to begin importing this substance for both TSCA purposes and for continuing exempt FDA purposes. 5 The HPV2 test rule (unlike the HPV3 rule) did not specify

a deadline for the submission
of study plans to the Agency

.U

.S. Environmental Protection Agency January 27, 2014 Page3
CONTAINS NO CONFIDENTIAL BUSINESS INFORMATION concurswith the Agency's requestand will submit final test reports12 months after EPA's receipt of this letter of intent totest. This final testrule does not specify the timing by which study plans aretobe submitted toEPAfor review.
If acceptable

tothe Agency, the Company will submit such study plans within 60 days of EPA's receipt ofthis letter of intent totest. * *

* Wethank youin advance for yourconsideration

of this letter. Forall questions and comments concerning this matter, please contactUnivar's TSCA consultant: Mr.John V. Massingale Greenwich Chemical Consulting, Inc. 3300 PGA Boulevard, Suite635 Palm Beach Gardens, FL33410 Telephone: (561) 578-8110 Facsimile: (561) 578-8120 E-mail: john@ grcci.com Sincerely,

• **'f(~N(Y+** Karina Gilje Regulatory Analyst cc:Mr

.J. Massingale

-Greenwich Chemical Consulting Mr.J. Schaeffer- EPA