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 Substances 
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. 
to EPA for review. If acceptable to the Agency, the Company will submit such study 

plans within 60 days of EPA's receipt of this letter of intent to test. 

* * * 

We thank you in advance for your consideration of this letter. For all questions and 

comments concerning this matter, please contact Univar's TSCA consultant: 

Mr. John V. Massingale 

Greenwich Chemical Consulting, Inc. 

3300 PGA Boulevard, Suite 635 

Palm Beach Gardens, FL 33410 

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