U.S. ENVIRONMENTAL PROTECTION AGENCY

 TESTING OF CERTAIN

 HIGH PRODUCTION VOLUME CHEMICALS

 SECOND GROUP OF CHEMICALS

 ORAL COMMENTS ON A PROPOSED REGULATION

 MEETING

 UNITED STATES

 ENVIRONMENTAL PROTECTION AGENCY

 1201 CONSTITUTION AVENUE, NW

 EAST BUILDING

 WASHINGTON, D.C. 20460

 SEPTEMBER 9, 2010

 1:10 P.M.
EPA MEETING 09/09/10 CCR#16194-6 2

1 U.S. ENVIRONMENTAL PROTECTION AGENCY

2 TESTING OF CERTAIN HIGH PRODUCTION

3 VOLUME CHEMICALS

4 SECOND GROUP OF CHEMICALS

5 ORAL COMMENTS ON A PROPOSED REGULATION

6 September 9, 2010

7 MR. WILLIS: All right, why don't we go

8 ahead and get started, then? I'd like to welcome

9 everyone to this public meeting to offer comments on

10 the proposed HPV3 test rule. This covers 29 high

11 production volume chemicals and is the third in the

12 series of four test rules under section 4A(1)(b) of

13 TOSCA.

14 My name is Jim Willis. I'm Director of

15 the Chemical Control Division here at EPA. And let me

16 suggest there are microphones around the room in the

17 event people want to make statements here, so if you do

18 wish to make a statement, you should feel free to do

19 so, but use the microphone and please introduce

20 yourself beforehand.

21 The proposed rule was published on July

22 24th, and the comment period...well, sorry, this can't

23 be right...yeah, the comment period on this closed on

24 May 26th of 2010, and that's where we provided

25 opportunity for people to provide comment.
EPA MEETING 09/09/10 CCR#16194-6 3

1 We have two entities who wish to provide

2 comment here. Those are PETA, the People for Ethical

3 Treatment of Animals, and as well as the Nease

4 Corporation. Just so that everyone knows, we do have a

5 court reporter present who will record the proceedings

6 of the meeting, prepare a summary document that will

7 include hard copy of anything that is provided during

8 the course of the meeting today.

9 For us at EPA, after this meeting, we

10 will review the comments in aggregate, that is, all

11 those comments provided during the comment period and

12 comments received here before we finalize this test

13 rule.

14 So, if you make oral comments here, we'd

15 invite you to also leave any copies of your statement

16 with us so that we can ensure that we get it exactly

17 correctly.

18 And let me...first, let me say, are

19 there any questions on...on process?

20 (No response.)

21 MR. WILLIS: First, then, let me

22 invite...sorry...Joseph Mannupello from PETA to present

23 your comments.

24 MR. MANNUPELLO: I'm going to pass out

25 some handouts with my presentation and if I...
EPA MEETING 09/09/10 CCR#16194-6 4

1 MR. WILLIS: Podium, or I guess you

2 could probably...I could move the microphone over. You

3 could sit here and scroll through your slides if that

4 would be easier.

5 MR. MANNUPELLO: I'd like to thank the

6 Agency for the opportunity to present these comments on

7 behalf of People for the Ethical Treatment of Animals.

8 PETA has...can you not hear?

9 SPEAKER: We don't hear you very well.

10 MR. MANNUPELLO: I just wanted to thank

11 the Agency for the opportunity to present these

12 comments on behalf of People for the Ethical Treatment

13 of Animals. PETA and the Physicians Committee for

14 Responsible Medicine have commented on every test plan

15 submitted under the HPV challenge program for which

16 animal testing was proposed.

17 Once again, we're very concerned that

18 the Agency is still proposing to require extensive

19 animal tests for HPV chemicals, tests that, if

20 conducted, would add another 20,000 animals to the more

21 than 150,000 who have already been killed in the HPV

22 program.

23 SPEAKER: It's still very difficult to

24 hear you.

25 MR. MANNUPELLO: Okay. All right.
EPA MEETING 09/09/10 CCR#16194-6 5

1 SPEAKER: That's better.

2 MR. MANNUPELLO: Okay. So, in so doing,

3 the Agency ignores the primary animal welfare principle

4 enumerated in its October,1999 guidance to HPV program

5 participants. This advises HPV chemical sponsors to

6 conduct a thoughtful, qualitative analysis rather than

7 use a rote checklist approach, and it makes clear that

8 participants may conclude that there is sufficient

9 data, given the totality of what is known about a

10 chemical, including human experience, that certain

11 endpoints need not be tested.

12 While the Agency specifically agreed and

13 the White House committed to incorporate these animal

14 welfare principles into any subsequent test rules,

15 review of existing toxicity data and human experience

16 with the chemicals included in this test rule

17 demonstrates that, in many cases, the required tests

18 would add no useful information to what is already

19 known.

20 I'll consider the test requirements for

21 several of the included chemicals individually and

22 present relevant existing data we've located. I'll

23 also summarize additional information submitted by

24 manufacturers and reporters.

25 I'll begin with 1-tetracosanol and 1-
EPA MEETING 09/09/10 CCR#16194-6 6

1 hexacosanol. These two chemicals are listed in the

2 proposed rule as requiring fish and mammalian acute

3 toxicity tests and combined repeated dose toxicity

4 studies with reproduction developmental toxicity

5 screens. If conducted on both chemicals, these tests

6 would kill approximately 1600 animals.

7 We called the Agency's attention to the

8 fact that the aluminum salts of these chemicals are

9 included in the aluminum alkoxides category, sponsored

10 by the Soap and Detergent Association, or SDA. I

11 understand that SDA has recently changed its name to

12 the American Cleaning Institute.

13 In its test plan for this category, SDA

14 presented evidence that aluminum alkoxides rapidly

15 hydrolyze into alumina and the corresponding alcohols.

16 SDA already used data from these alcohols, including

17 tetra and hexacosanol to fulfill all endpoints for the

18 aluminum alkoxides. In addition, the supporting robust

19 summary, site summary for long-chain aliphatic

20 alcohols, and ICCA initiative category, includes both

21 alcohols. In its comments on this proposed rule, Sasol

22 North America...I'm not sure how to say that...compiled

23 relevant data from this summary.

24 Regarding aquatic toxicity, SDA argued

25 that these chemicals are unlikely to be toxic, due to
EPA MEETING 09/09/10 CCR#16194-6 7

1 their predicted insolubility. SDA provided water

2 solubility data, indicating a clear pattern of

3 decreasing values with increasing carbon chain length

4 and observed that alcohols with carbon chain lengths

5 above C16, including tetra and hexacosanol, are

6 insoluble.

7 Similarly, octanol water partition

8 coefficients increase with increasing carbon chain

9 length. SDA and Sasol estimated that these

10 values...they estimated these values to be 10.66 for

11 tetracosanol and 11.65 for hexacosanol.

12 Further, SDA observed that aliphatic

13 alcohols fit into the neutral organics class of

14 compounds and generally exert toxicity through a non15 polar narcosis mode of action. A clear pattern of

16 increasing toxicity was observed with increasing chain

17 length until approximately C14. Beyond this cutoff, no

18 toxicity was observed, because saturation occurs below

19 the concentration that is toxic to fish.

20 Sasol provided a summary and complete

21 study report for a company sponsored 96-hour acute

22 toxicity test on fathead minnows with C18 to 22

23 alcohols, completed in January of this year. No

24 mortality or overt signs of toxicity were observed at

25 the test concentration of 100 mg/l.
EPA MEETING 09/09/10 CCR#16194-6 8

1 In its test plan for the aluminum

2 alkoxides, SDA reported acute oral LD50 values in rats

3 greater than 5000 mg/kg body weight for both tetra and

4 hexacosanol. On the basis of a clear inverse

5 relationship between chain length and toxicological

6 properties as well as the lack or very low incidence of

7 reproductive or developmental toxicity across a wide

8 range of carbon chain lengths, SDA proposed no further

9 testing.

10 Similarly, Sasol concludes from this

11 observed pattern that it is reasonable to predict that

12 tetra and hexacosanol have even lower potential

13 toxicities than other alcohols in the category for

14 which health effects have already been reported.

15 Consequently, existing data can be used as conservative

16 predictors of the health effects of these alcohols.

17 In addition, Sasol notes that the health

18 effects database in the long chain alcohols...see its

19 initial assessment report...includes studies of C24

20 through 34 alcohols which is a mixture including

21 significant amounts of tetra and hexacosanol.

22 In its comments on the SDA test plan,

23 the Agency agreed that using data for the corresponding

24 alcohols to address the SIDS health effects and

25 environmental fate effects endpoints for the aluminum
EPA MEETING 09/09/10 CCR#16194-6 9

1 alkoxides was reasonable for the purposes of the HPV

2 program. The Agency also agreed that adequate data

3 were available on the alcohol hydrolysis products to

4 address the SIDS health effects endpoints.

5 Finally, Sasol notes that the amounts of

6 these substances imported recently have been

7 significantly less than 1 million pounds per year, that

8 these substances are both produced naturally and occur

9 commonly in mosses and...in mosses and other peat

10 forming plants, and that occupational exposure to and

11 environmental release of these substances is expected

12 to be minimal because of low volatility, the use of

13 protective clothing, and significant removal at waste

14 treatment facilities.

15 Since tetra and hexacosanol have already

16 been thoroughly evaluated as part of the aluminum

17 alkoxides category and the ICCA initiative long-chain

18 aliphatic alcohols category, their inclusion in the

19 proposed test rule is unnecessary, and they should be

20 removed.

21 The next chemical I'll address is

22 sulfurized 1-decene which is listed as requiring fish

23 and mammalian acute toxicity tests and a combined

24 repeated dose toxicity study with reproduction

25 developmental toxicity screen. These tests would kill
EPA MEETING 09/09/10 CCR#16194-6 10

1 approximately 800 animals.

2 Sulfurized decene was one of five

3 chemicals originally included in the Alkyl sulfides

4 category sponsored by the ACC's Health, Environmental,

5 and Regulatory Task Group. It was dropped from the

6 category in the final test plan revision.

7 In a personal communication, the ACC

8 explained that the panel dropped sponsorship, because

9 none of the members continue to manufacture or import

10 this chemical. In light of this information, the

11 Agency must verify that this chemical is still HPV.

12 In its comments on the original alkyl

13 sulfides category test plan, the Agency found the

14 category minimally acceptable for four of the

15 chemicals, including sulfurized decene. In particular,

16 the Agency believed that these chemicals were unlikely

17 to pose acute aquatic hazards, due to their high

18 hydrophobicity, and they suggested that the daphnia

19 chronic flow through test be done as an alternative for

20 the fish acute toxicity test unless measured water

21 solubilities were sufficiently low to eliminate the

22 need for chronic toxicity testing as well.

23 Regarding mammalian acute toxicity, the

24 Agency noted that the existing data show that the four

25 tested compounds are similar in that they have low
EPA MEETING 09/09/10 CCR#16194-6 11

1 acute toxicity by a variety of routes.

2 In its final test plan revision, HERTG

3 reported results from fish and mammalian acute toxicity

4 tests for several category members and from a 1-

5 generation reproductive toxicity study in rats

6 conducted for the propanol dodecatheon derivative.

7 While the Agency questioned the

8 selection of this chemical for health effects testing

9 in its comments, we urge the Agency to reconsider the

10 results of this study before requiring new repeated

11 dose and reproduction development toxicity studies for

12 sulfurized decene. In any case, fish and mammalian

13 acute toxicity tests are clearly unnecessary,

14 considering the alkyl sulfides category test plan

15 submission, and these tests should be removed from the

16 proposed test rule.

17 1-chloro-4-trifluoromethyl benzene, also

18 known as parachlorobenzotrifluoride or PCBTF, is listed

19 in the proposed test rule as requiring fish acute

20 toxicity and reproduction developmental toxicity

21 screening tests. These tests would kill approximately

22 800 animals.

23 In their comments, Brenntag North

24 America, Culla American, Miami Chemical, and Univar USA

25 as well as Special Materials Company, or SMC, in
EPA MEETING 09/09/10 CCR#16194-6 12

1 separate comments, cite data supplied to the Agency by

2 Occidental Chemical Corporation between 1983 and '85 in

3 fulfillment of a negotiated testing agreement. These

4 include data from acute toxicity tests in bluegill

5 sunfish and rainbow trout and from a GOP 2-generation

6 reproductive toxicity study in rats. The original

7 study reports are attached to these companies'

8 comments.

9 After evaluating these data, the Agency

10 concluded, in October 1985 in a Federal Register

11 notice, that the acute and subchronic environmental

12 effects of PCBTF on aquatic species were well

13 characterized and that additional testing was not

14 necessary. Similarly, the Agency concluded that data

15 from the reproductive toxicity study were sufficient to

16 reasonably predict the health effects of PCBTF and

17 raised no concerns for the need for additional testing.

18 These companies also note that the

19 National Toxicology Program has initiated a 90-day

20 inhalation study in rats and that a 2-year

21 carcinogenicity study and teratology tests in rats are

22 planned. In addition, SMC notes that data being

23 generated in response to REACH requirements is likely

24 to satisfy most or all of the Agency's data

25 requirements. At a minimum, the Agency must wait for
EPA MEETING 09/09/10 CCR#16194-6 13

1 the results from these tests before requiring

2 duplicative tests in this test rule.

3 1,2-dimethyl-3-nitrobenzene or 3NOX is

4 listed as requiring a mammalian acute toxicity test and

5 a combined repeated dose toxicity study with

6 reproduction developmental toxicity screen. These

7 tests would kill approximately 680 animals.

8 In its comments, BASF Chemical Company

9 notes that it believes that 3NOX is no longer an HPV

10 chemical, citing data from 2002 and 2006 inventory

11 update reporting periods that indicate that the

12 manufacture and import of this substance is well below

13 the 1 million pound threshold. BASF was the only known

14 3NOX reporter during these periods, and the annual

15 production volumes reported have been less than 100,000

16 pounds.

17 BASF also states that it has no plans to

18 exceed 100,000 pounds in the future. Again, the Agency

19 must verify that this chemical is still HPV.

20 In addition, a search of Toxline

21 returned an abstract from a 1994 German toxicology

22 assessment of the occupational safety of industrial

23 chemicals. 3NOX is described as being of low acute

24 toxicity on oral administration with LD50s in rats

25 greater than 2100 mg/kg body weight. In repeated dose
EPA MEETING 09/09/10 CCR#16194-6 14

1 toxicity testing, reduced weight gain and reduced feed

2 intake were observed only at the highest doses.

3 The Agency must review this study with

4 regard to acute and repeated dose toxicity. In

5 particular, it should be determined whether

6 reproductive organs were examined in the repeated dose

7 study.

8 In additional, BASF suggests that the

9 Agency may wish to review the test plan and robust

10 summary submitted by BASF previously on the surrogate

11 compound, 1,2-dimethyl-4-nitrobenzene or 4NOX. BASF

12 used several analogs, including 2,4-dimethyl-1-

13 nitrobenzene and 4-nitrotoluene to complete the SIDS

14 data set for this chemical. EPA found that adequate

15 development and reproductive toxicity data were

16 available for 4-nitrotoluene.

17 We urge the Agency to consider these

18 data with regard to 3NOX as well. It seems likely that

19 the weight of existing evidence is sufficient to

20 eliminate the requirement for a new developmental

21 reproductive toxicity study.

22 3-pentanone is listed in the proposed

23 rule as requiring a mammalian acute toxicity test and a

24 combined repeated dose toxicity study with reproduction

25 developmental toxicity screen. These tests would kill
EPA MEETING 09/09/10 CCR#16194-6 15

1 approximately 680 animals.

2 A search of fragrance raw materials

3 monographs returned a reproduction toxicity study of 3-

4 pentanone in mice. Reference is here. We also note

5 that the similar chemical, 2-pentanone, was sponsored

6 in the HPV program by Eastman Chemical Company. All

7 health effects data for 2-pentanone were fulfilled by

8 existing data, including data from the OECD number 421

9 reproduction developmental toxicity screen conducted

10 under GOP assurances.

11 We urge the Agency to consider these

12 data and data from other short chain aliphatic ketones

13 with regard to 3-pentanone. For example, methylethyl

14 ketone differs from 3-pentanone only in having a methyl

15 instead of an ethyl group. It is extremely well

16 studied, with numerous evaluations of reproduction

17 developmental toxicity.

18 Sodium 3-nitrobenzene sulfonate is

19 listed in the proposed test rule as requiring a

20 reproduction and developmental toxicity screening test.

21 This test would kill approximately 675 animals.

22 A search of Toxline returned an abstract

23 from a 1996 article in the Journal of the American

24 College of Toxicology which reported an oral LD50 in

25 rats of 5000 mg/kg body weight. In addition, a chronic
EPA MEETING 09/09/10 CCR#16194-6 16

1 oral toxicity study of a composite hair dye formulation

2 containing 2.25 percent sodium 3-

3 nitrobenzosulfonate...benzene sulfonate indicated

4 neither gross nor microscopic changes in beagle dogs.

5 The same hair dye formulation was not classified as a

6 reproductive toxicant in studies involving rats and

7 rabbits.

8 We also urge the Agency to consider the

9 possibility of read across from the sponsored HPV

10 program chemicals, benzene sulfonic acid and

11 hydroxybenzene sulfonic acid, for reproduction

12 developmental toxicity endpoints.

13 For the few remaining chemicals, I'll

14 summarize comments submitted by chemical companies with

15 regard to animal testing. All of the original comments

16 are available in the docket.

17 The first one I was going to talk about

18 is...is alkyl sulfonic acid, but we have a

19 representative from Nease here who I imagine is going

20 to be speaking about that, so I think I'll just skip

21 that. I guess I'm safe? All right.

22 For 2-propenoic acid, 2-carboxyethyl

23 ester or BCA, SOCMA confirmed that the combined

24 production volume is well below 1 million pounds and

25 unlikely to increase significantly. Rhodia,
EPA MEETING 09/09/10 CCR#16194-6 17

1 Incorporated has already submitted a CVI letter to the

2 docket with its production import volume data, and

3 Bimax, Incorporated is expected to follow suit. Since

4 BCA...BCEA is very likely no longer HPV, it should be

5 removed from the current test rule.

6 For methanesulfonamide or CD3, the

7 International Imaging Industry Association, or IAAA,

8 surveyed all companies that reported CD3 manufacture or

9 importation since 1986, using a list supplied by Darryl

10 Ballard of EPA on May 5th of this year. The result

11 was...was that with all known companies reporting, the

12 2009 production volume of CD3 was just under 436,000

13 pounds. Again, since this is significantly less than

14 the HPV threshold of 1 million pounds, CD3 should be

15 removed from the current test rule.

16 IAAA went on to summarize the data from

17 the...that the Agency requires in a static multi18 species screening test for acute toxicity. The LC50 in

19 fathead minnows was 1 to 10 mg/l while in the flow

20 through test, the dynamic LC50 was 3.6 mg/l.

21 IAAA also summarized results from

22 carcinogenicity studies in Syrian golden hamsters by

23 the oral and endotracheal routes of exposure. No

24 biologically significant treatment related effects were

25 noted. This was supported by repeated dose toxicity
EPA MEETING 09/09/10 CCR#16194-6 18

1 data for the analog, hydroxyethyl phenylenediamine

2 sulfide, from two oral exposure studies in rats.

3 With the exception of decreased body

4 weight gain at the high dose levels, no treatment

5 related effects were noted.

6 Reproductive organs were among those

7 examined in the carcinogenicity study with CD3. In

8 addition, IAAA summarized dominant lethal and

9 developmental toxicty studies for an analog conducted

10 by the oral route of exposure in rats.

11 The dominant lethal test used subchronic

12 dosing in males for the duration of its spermatogenic

13 process, followed by mating with untreated females. No

14 significant differences were noted in reproductive

15 parameters, suggesting that the analog did not induce

16 male reproductive toxicity.

17 In the developmental toxicity study, no

18 significant skeletal or visceral malformations were

19 noted, while the pregnancy rates for the mid and high20 dose groups were decreased. Internal toxicity

21 reflected in non-statistically significant decreases in

22 body weight occurred at the highest dose level.

23 For DMT residue, Invista notes that it

24 has already completed many of the studies identified in

25 the proposed test rule and intends to submit the final
EPA MEETING 09/09/10 CCR#16194-6 19

1 reports. Invista argues that the proposed combined

2 repeated dose reproductive developmental toxicity study

3 is not necessary, because there is minimal potential

4 for environmental release and human exposure.

5 The Agency should consider Invista's

6 exposure data and wait for the report that Invista will

7 submit before finalizing testing requirements for DMT

8 residue.

9 The American Coke and Coal Chemicals

10 Institute, or ACCCI, proposes creating a category for

11 the six coal tar substances. In addition, ACCCI

12 summarizes data for acute toxicity in fish and mammals

13 that is too voluminous to reproduce here as well as

14 several repeated dose and reproductive developmental

15 toxicity studies of coal tar and creosote.

16 ACCCI suggests a reasonable strategy for

17 conducting any additional testing that may be required

18 for coal tar substances. Tests would be conducted in a

19 step-wise fashion, focusing on one substance, and going

20 on to others only if it is determined that data from

21 that substance does not suffice to conduct read across

22 for the remaining coal tar substances.

23 The Agency must review the extensive

24 data provided by ACCCI and evaluate its proposals.

25 In conclusion, the Agency has not
EPA MEETING 09/09/10 CCR#16194-6 20

1 adequately considered the totality of what is known

2 about each of these chemicals before proposing new

3 animal tests. The Agency must thoroughly evaluate the

4 existing data we have cited for the chemicals included

5 in this proposed test rule as well as that submitted by

6 chemical manufacturers and importers.

7 We appeal to the Agency and to chemical

8 companies themselves to carefully evaluate all

9 available data to avoid conducting duplicative animal

10 tests, and we will be returning to the White House

11 Council on Environmental Quality to ask it to maintain

12 its 2000 commitment should the Agency fail to do so.

13 Thank you.

14 MR. WILLIS: All right, thank you very

15 much for your comments. Next, I would like to invite

16 Mr. Phillip Benes from the Nease Corporation.

17 MR. BENES: Thank you. Good afternoon.

18 I would like to thank the Agency for the time to listen

19 to my comments.

20 I'm going to talk about one chemical

21 only. The previous speaker talked about all of them.

22 We have one chemical that's on the list.

23 I wasn't sure about what format you all

24 wanted to see this in. What I'm going to do is we

25 submitted an oral comments...I'm sorry...in written
EPA MEETING 09/09/10 CCR#16194-6 21

1 comments back in May a report that we had contracted

2 through TERA to address the concerns of the testing

3 protocol. I'm going to highlight some things in that

4 in my report this afternoon and will be more than happy

5 to entertain any questions you might have.

6 But what I would like to do, if I can

7 figure out how to make this thing work...the green

8 button, forward button, the backwards button. Ah.

9 I would like to spend just a couple

10 minutes on my company, who we are. To you all, it's a

11 chemical. To us, it's our business, it's jobs, it's

12 people, so I want to spend just a couple of minutes on

13 that. I want to explain the rationale. We believe

14 that there is existing data on this compound as well as

15 a lot of work that was done on surrogate compounds. A

16 little bit on the evaluation of the SIDS endpoints that

17 were brought up in the proposed test rule. Talk a

18 little bit about what data is available and the

19 proposed testing protocol. I do have some references

20 available, and I do have attachments.

21 I brought most of these with me today.

22 You already should have those electronically, but I can

23 leave those with you today if you'd like me to, but a

24 lot of this work was based upon the surrogate work that

25 was done over the course of time.
EPA MEETING 09/09/10 CCR#16194-6 22

1 Para toluene sulfonic acid was an HPV

2 chemical that we were part of a consortium when the

3 first rule went through, and a lot of that is going to

4 be based upon that study that was done.

5 But we're...in the world of chemical

6 manufacturers, we're a little guy. We employ about 65

7 employees. We...our facility is in Harrison, Ohio. We

8 have one plant. We've been there since 1959, primarily

9 as a supplier to one of the large detergent companies

10 that happens to be just down the road from us.

11 But we're a chemical manufacturer. We

12 do batch sulfonation. That's what our expertise is,

13 and that is what our call to fame is. We make

14 primarily hydrotropes. Those are coupling agents that

15 go into detergents. We also participate in catalyst

16 market, alkyl and sulfonates, and then we have a

17 specialty line of chemicals.

18 Customers that we serve, these are

19 primarily detergent companies. We also sell to a lot

20 of the major chemical manufacturers that use some of

21 our...our compounds as catalysts in their production.

22 So, that's a little bit about who we are.

23 But what I wanted to talk to you today

24 about was the proposed test rule. The specific

25 compound is benzenesulfonic acid, dimethyl, or as we
EPA MEETING 09/09/10 CCR#16194-6 23

1 call it in our corporation, XSA90. That's

2 xylenesulfonic acid. We're shown on the IUR reporting

3 as a...in 2006 as an HPV manufacturer.

4 We chose not to sponsor this material

5 voluntarily, because we could not find anybody else

6 that was willing to stand with us. There is one other

7 manufacturer in North America that we're aware of, but

8 I don't believe that if this comes to pass, if a test

9 is required, I believe they will withdraw the chemical

10 from the marketplace.

11 The chemical extract service STM entry

12 does not specify the attachment of the methyl group.

13 Therefore, several isomers exist, and we try to address

14 that as well.

15 The compound that...that we're talking

16 about today is specifically that one, the dimethyl,

17 these are the relative surrogate compounds that we're

18 asking the Agency to consider. Both the acid form and

19 the salts forms of these materials exist as

20 xylenesulfonic acid, 4-toluene sulfonates, and then the

21 benzenesulfonic acids as well. A lot of work has been

22 done on those particular compounds.

23 Data for xylenesulfonic sulfonate was

24 used for mammalian toxicity endpoints. It has

25 precedence with high nucleic for xylenesulfonic acid
EPA MEETING 09/09/10 CCR#16194-6 24

1 and xylenesulfonate where one chemical is used as a

2 surrogate for another in appropriate studies.

3 The toxicological data for

4 paratoluenesulfonic acid...that was an HPV

5 compound...and toluenesulfonate were used as surrogate

6 data for the benzenesulfonic acids. Found the same

7 rationale and further supported by the consistency in

8 the results for endpoints where the data was available

9 for more than one area sulfonate. That was part of the

10 original HPV challenge program that we participated in.

11 One current evaluation was conducted by

12 TERA. That's Toxicology Excellence for Risk

13 Assessment. They are an independent consulting agency

14 that...that we hired and paid to put together the...the

15 report that we have submitted to you concerning our

16 written comments, and these are the parts of their

17 report that I'm talking about today.

18 And then the xylenesulfonic acid and

19 toluenesulfonic acid salts were part of the hydrotrope

20 screening initial data set that was done by OECD in

21 2005, and high nucleic and MSDS sheets were used for

22 reference as well.

23 The...the physicochemical endpoints are

24 fairly well known for this material. It is a solid at

25 room temperature, freely soluble in water. The data
EPA MEETING 09/09/10 CCR#16194-6 25

1 for the SIDS matrix table has been estimated and data

2 for paratoluenesulfonic acid and benzenesulfonic acid

3 has been approved for comparison.

4 We also used data measured or estimated

5 for xylenesulfonic acids, is not included as a salt,

6 versus the proteic acid would likely significantly

7 affect the measurements.

8 Data for benzenesulfonic acid and

9 paratoluenesulfonic acid are included, as these

10 substances are in their acid form.

11 For the measurement of each substance,

12 the effects of the varying amounts of methylation would

13 be likely to be less than the effects of the solid

14 versus the proteinated form. So, really what we're

15 talking about is the effect of one, two, or three

16 methyl groups.

17 The estimated data for xylenesulfonic

18 acid are consistent with small hydrophilic organic

19 compounds. Also, this chemical is very likely to

20 ionize in water and exists primarily as a salt in

21 aqueous media.

22 Concerning environmental fate, the

23 bioaccumulation data was available for the sodium

24 xylenesulfonate and is less than 2.3. The modified

25 serum OECD 301(b) test data is available for sodium
EPA MEETING 09/09/10 CCR#16194-6 26

1 xylenesulfonate and calcium xylenesulfonate and show 85

2 percent biodegradation value.

3 The half-life for reaction with hydroxy

4 radicals in the atmosphere were estimated. Results

5 show that increased methylation...an increase in

6 reaction with hydroxy radicals, and distribution in the

7 environment was estimated using the fugacity model,

8 including the epi suite based upon the k level 3

9 calculations and was greater than 99 percent remains in

10 the water form. So, it's...it's in the water form. It

11 does not end up in the sediment.

12 Concerning ecotoxicity, data for sodium

13 and calcium xylenesulfonate for fish, daphnia, and

14 green algae acute toxicity is available, and they were

15 all shown to be greater than 100 mg/l. Ecostar was

16 used to estimate the toxicity for xylenesulfonic acid,

17 and the estimated effect was greater than 1000 mg/l for

18 all species. Data for benzenesulfonic acid and

19 paratoluenesulfonic acid are also included in the data

20 set.

21 For mammalian toxicity, sulfonic acids

22 are very safe. They're comparable to sulfuric acid in

23 concentrated forms and would show local effect at the

24 site of contact. This association constant is low, and

25 therefore, absorption is expected to be low in the
EPA MEETING 09/09/10 CCR#16194-6 27

1 gastro and...and dermal tracts.

2 Since environmental exposure would most

3 likely be the deprobated form, xylene sulfates and

4 salts were used as surrogate endpoints. Absorbed

5 sulfonates are quickly distributed throughout the

6 system and rapidly excreted.

7 The LD50 in rats, based on a 14-day

8 study, was greater than 5000 mg per age and body

9 weight, and the interperitoneal LD50 was...that should

10 be...it's a typo...it should be...it was 500 mg/kg in

11 mice.

12 For genetic toxicity, there is no data

13 on this endpoint for xylenesulfonic acid. However, the

14 age and chromosomal aberration tests for sodium

15 xylenesulfonate are both negative.

16 For repeated dose testing, there's no

17 data for the acid form, but various data sets exist for

18 the sodium xylenesulfonate. There were 90-day rat

19 studies that were conducted, and you can read the

20 results up there. They're very positive. There were

21 no effects observed in mice orally exposed to doses,

22 again, fairly high dosing rates for the sodium

23 xylenesulfonate for 90 days.

24 The dermal studies resulted in NOAELs

25 800 mg in rats, 440 in male mice, 540 in female mice,
EPA MEETING 09/09/10 CCR#16194-6 28

1 and you can read the OEL levels further down the page

2 there. The two-year dermal study in mice and rats

3 found no effects at 700.7 mg per age and body weight

4 per day and 240 mg per age and body weight per day

5 respectively, also in mice and rats.

6 Concerning reproductive and

7 developmental toxicity, no data was available for

8 xylenesulfonic acid. However, a 90-day oral feeding

9 study in rats exposed to the salt, sodium

10 xylenesulfonate, showed no effects on reproductive

11 organs, and development study in rats resulted in an

12 NOAEL of 3000 mg/kg per body weight per day. That

13 would have been about 1000 mg exactly if you read the

14 material, and fetal toxicity of calcium

15 xylenesulfonate.

16 This kind of summarizes all the test

17 data that is available. The plus sign up here means

18 that this data is available currently. The read-across

19 can be found from some of the references that I

20 supplied.

21 So, basically, to conclude, it is our

22 opinion that there is adequate physio, chemical,

23 environmental, ecotox, and mammalian data that are

24 available today. In light of that available data, our

25 feeling is that no further testing is required.
EPA MEETING 09/09/10 CCR#16194-6 29

1 Based on the size of our company and the

2 fact that Nease is more than likely the only company to

3 be manufacturing this in commercial quantities, the

4 additional expense of doing all of this testing, not to

5 mention the number of animals as the representative

6 from PETA talked about a few minutes ago, killed,

7 basically, puts a significant financial burden on our

8 company that we have to look at whether or not it still

9 makes financial sense for us to commercially

10 manufacture this material. So, that would mean jobs as

11 well.

12 Additional testing on animals is not

13 necessary in view of the wealth of data available, and

14 additional data is available in the TERA report and the

15 appendices that have been provided before, and we'd be

16 happy to supply you with a copy today.

17 So, I ran through that pretty quick, but

18 that's...you should have seen everything before today

19 that I put up here. So, I hope that met your needs.

20 MR. WILLIS: All right, thank you very

21 much. That brings us to the end of those who have

22 requested the opportunity to comment. Let me invite

23 now if anyone else who did not register would like to

24 make a public comment at this point.

25 MS. BECK: Am I on?
EPA MEETING 09/09/10 CCR#16194-6 30

1 MR. WILLIS: You're on.

2 MS. BECK: Okay. I was wondering if it

3 would be possible or make sense to apply some of the

4 approaches that have been developed at the National

5 Center for Computational Toxicology here to these HPV

6 chemicals. It's clear that the Agency is interested in

7 developing new tools and moving toxicology forward.

8 So, it seems like this would be a great opportunity to

9 apply some of these new approaches.

10 And what I'm thinking is that instead of

11 proposing a rule that requires extensive animal testing

12 from the start, it would make a lot of sense to first

13 run the HPV chemicals in question through the TOX CAST

14 assays to obtain a profile of potential toxicity.

15 Then, you'd look at that profile along with all

16 the...seems like extensive existing data, according to

17 the presentations we heard today, to consider in a

18 weight of evidence approach to inform any additional

19 testing which could then be called for in the rule.

20 And I realize TOX CAST is in its

21 relative infancy and that the TOX signatures and

22 preactivity of the signatures are still being

23 evaluated, but the point of the HPV program, as

24 everyone knows, is to generate screening level data,

25 not necessarily, you know, definitive data, if such a
EPA MEETING 09/09/10 CCR#16194-6 31

1 thing exists. So, I would encourage the Agency to

2 think about whether TOX CAST and other tools at NCCT

3 could provide the necessary info for the purposes of

4 the HPV program.

5 And I know that EPA is already applying

6 TOX CAST, as it was used earlier this summer to assess

7 the oil dispersants that were used in the Gulf. Within

8 a month or so, they were tested, and we had tox

9 profiles for them from the TOX CAST software, and TOX

10 CAST has also been used to prioritize chemicals for

11 inclusion in the EDSP.

12 So, I guess I'm posing a question or

13 proposing that the Agency capitalize on those tools and

14 take this as an opportunity to use them for the HPV

15 chemicals that would provide staff outside of NCCT with

16 experience in looking at and interpreting new different

17 kinds of data than, you know, they're traditionally

18 used to looking at to make assessments and figure out

19 how to use it in guiding decision making.

20 So, I guess what I...my main point is I

21 think it's important to start using these other

22 approaches in order to refine them and facilitate

23 the paradigm shift in toxicology that EPA seems to be

24 trying to make.

25 MR. WILLIS: Thank you. Could you
EPA MEETING 09/09/10 CCR#16194-6 32

1 identify yourself?

2 MS. BECK: Oh, sorry. Nancy Beck, PCRM.

3 MR. WILLIS: All right, thank you. Any

4 other comments?

5 MR. DETTINGER: I have a question. I'm

6 Joe Dettinger with Bimax. What we're interested in is

7 the time frame on your decision for HPV chemical in

8 question, it's CAS number 24615-84-7. This is the

9 chemical that we submitted before, we do not believe it

10 is HPV.

11 MR. WILLIS: Sorry, was that a chemical

12 in the proposed rule?

13 MR. DETTINGER: Yes.

14 MR. WILLIS: Yeah. Well, we will

15 address that along with all of the other chemicals that

16 were listed in the proposed rule. What we need to do

17 is...is conclude our review of all of the comments

18 received on all of the chemicals plus the comments

19 received here in this discussion and then proceed with

20 finalizing the rule, taking into consideration all of

21 those comments.

22 So, I can't give you a...a specific

23 date, but it should be on the order of, I'd say, six to

24 nine months, roughly, to work through those issues and

25 run through our incredibly bureaucratic process.
EPA MEETING 09/09/10 CCR#16194-6 33

1 SPEAKER: You say six to nine months

2 before this Rule is finalized?

3 MR. WILLIS: Hopefully.

4 Optimistically. I tend to be optimistic. Please?

5 MR. GUNNULFSON: Just a question. Jeff

6 Gunnulfson from NPRA, and just a question. Will EPA be

7 making any exposure findings through a Pair-rule?

8 MR. WILLIS: Sorry, I'm not sure I

9 understand the question. Could you maybe rephrase

10 that?

11 MR. GUNNULFSON: Yes. Will there be

12 exposure findings in the final rule through a Pair13 rule, or if the next step you have to do is exposure

14 findings, what vehicle will you be doing...doing those?

15 MR. WILLIS: Sorry. Are you asking

16 whether we will do any additional rulemaking to support

17 making an exposure finding?

18 MR. GUNNULFSON: Yes.

19 MR. WILLIS: Yeah. We do not have any

20 additional information-gathering rulemaking planned at

21 this time.

22 MR. GUNNULFSON: Okay.

23 MR. WILLIS: That's, indeed, the

24 inventory update rule or IUR is largely tailor-made for

25 this sort of rulemaking, and doing test rules was one
EPA MEETING 09/09/10 CCR#16194-6 34

1 of our considerations in setting up the data elements

2 in...in the IUR.

3 Any further comments?

4 MR. HELMES: I'm Tucker Helmes from

5 ETAD. Any sense yet of when the final rule for the

6 second HPV test rule will be published? The...the

7 proposed rule was July of '08.

8 MR. WILLIS: Soon.

9 MR. HELMES: Soon?

10 MR. WILLIS: Soon, under 10 days,

11 probably.

12 MR. HELMES: Oh, really?

13 MR. WILLIS: Yeah.

14 MR. HELMES: Okay.

15 MR. WILLIS: But everybody's cleared it.

16 Right? Within a month. Optimistic again.

17 SPEAKER: What HPV Rule, I'm sorry?

18 MR. WILLIS: The HPV 2 final rule.

19 I don't think much further needs to

20 happen. It needs to be encoded for the Federal Register

21 and signed, but, again, these are...these are steps in

22 the process outside of our control.

23 Any further comments? Christina?

24 MS. FRANZ: Hi. Christina Franz. Can

25 you hear me? Okay, Christina Franz with the American
EPA MEETING 09/09/10 CCR#16194-6 35

1 Chemistry Council.

2 A couple of...of points. We certainly

3 support the Agency looking back at existing data such

4 as the presentations that were made here today and

5 utilizing that data. We certainly don't want industry

6 to have to spend any more money, test on any more

7 animals than necessary, and we certainly support the

8 animal welfare principles and Nancy's suggestion of the

9 computational TOX.

10 What I did want to ask a question about

11 was earlier, we had had you, Jim, over at ACC, and you

12 had noted a...had made a couple comments about the

13 Agency's thoughts about the fourth proposed rule on

14 additional HPV orphans, and you had mentioned possibly

15 using or issuing a SNUR on some of those HPVs, and I

16 was wondering if there's been any more development on

17 that and whether you could comment at all on it.

18 MR. WILLIS: Yeah, I'm not sure I can.

19 The...the draft HPV 4 rule isn't quite into Agency-wide

20 review yet, and so, it's a...it's a bit early to

21 predict formally what that will look like, but you're

22 correct, the Agency has considered doing test rules in

23 conjunction with significant new use rules so that in

24 those cases where chemicals may sort of slip under the

25 necessary numerics for the findings, they would still
EPA MEETING 09/09/10 CCR#16194-6 36

1 be captured in case they re...re-emerge as high2 production, high-exposure type chemicals.

3 So, currently, it's a...it's an approach

4 under consideration but remains to be seen if we will

5 actually issue rules along those lines.

6 MS. FRANZ: Thank you.

7 MR. WILLIS: Any further comments?

8 (No response.)

9 MR. WILLIS: All right, seeing none,

10 just a reminder there will be a transcript of this, and

11 that, together with any written documentation provided

12 here and comments received during the comment period

13 will all be in the docket for the rulemaking. And when

14 we finalize it, our responses to all of the comments

15 will also be included, of course.

16 Thank you very much, and the meeting is

17 adjourned.

18 (WHEREUPON, the Meeting was concluded at 2:01 p.m.)

19

20

21

22

23

24

25
EPA MEETING 09/09/10 CCR#16194-6 37

1 CAPTION

2 The foregoing matter was taken on the date, and at the

3 time and place set out on the Title page hereof.

4 It was requested that the matter be taken by the

5 reporter and that the same be reduced to typewritten

6 form.

7 Further, as relates to depositions, it was agreed by

8 and between counsel and the parties that the reading

9 and signing of the transcript, be and the same is

10 hereby waived.

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
EPA MEETING 09/09/10 CCR#16194-6 38

1 CERTIFICATE OF REPORTER

2 COMMONWEALTH OF VIRGINIA

3 AT LARGE:

4 I do hereby certify that the witness in the foregoing

5 transcript was taken on the date, and at the time and

6 place set out on the Title page hereof by me after

7 first being duly sworn to testify the truth, the whole

8 truth, and nothing but the truth; and that the said

9 matter was recorded stenographically and mechanically

10 by me and then reduced to typewritten form under my

11 direction, and constitutes a true record of the

12 transcript as taken, all to the best of my skill and

13 ability.

14 I further certify that the inspection, reading and

15 signing of said deposition were waived by counsel for

16 the respective parties and by the witness.

17 I certify that I am not a relative or employee of

18 either counsel, and that I am in no way interested

19 financially, directly or indirectly, in this action.

20

21

22

23

24 MARK REIF, COURT REPORTER / NOTARY

25 SUBMITTED ON SEPTEMBER 9, 2010
EPA MEETING 09/09/10 CCR#16194-6 39

0

08 34:7

1

1 5:25 9:7 11:4

13:13 16:24

17:14 17:19

1,2-dimethyl-3-

nitrobenzene

13:3

1,2-dimethyl-4-

nitrobenzene

14:11

10 17:19 34:10

10.66 7:10

100 7:25 26:15

100,000 13:15

13:18

1000 26:17 28:13

11.65 7:11

14-day 27:7

150,000 4:21

1600 6:6

1959 22:8

1983 12:2

1985 12:10

1986 17:9

1994 13:21

1996 15:23

1-chloro-4-

trifluoromethyl

11:17

1-decene 9:22

1-tetracosanol

5:25

2

2 34:18

2,4-dimethyl-1

14:12

2.25 16:2

2.3 25:24

2:01 36:18

20,000 4:20

2000 20:12

2002 13:10

2005 24:21

2006 13:10 23:3

2009 17:12

2010 2:6 2:24

2100 13:25

22 7:22

240 28:4

24615-84-7 32:8

24th 2:22

26th 2:24

29 2:10

2-carboxyethyl

16:22

2-generation 12:5

2-pentanone

15:5 15:7

2-propenoic 16:22

2-year 12:20

3

3 15:3 16:2 26:8

3.6 17:20

3000 28:12

301(b 25:25

34 8:20

3-nitrobenzene

15:18

3NOX 13:3 13:9

13:14 13:23

14:18

3-pentanone 14:22

15:13 15:14

4

4 35:19

421 15:8

436,000 17:12

440 27:25

4A(1)(b 2:12

4-nitrotoluene

14:13 14:16

4NOX 14:11

4-toluene 23:20

5

500 27:10

5000 8:3 15:25

27:8

540 27:25

5th 17:10

6

65 22:6

675 15:21

680 13:7 15:1
EPA MEETING 09/09/10 CCR#16194-6 40

7

700.7 28:3

8

800 10:1 11:22

27:25

85 12:2 26:1

9

9 2:6

90 27:23

90-day 12:19

27:18 28:8

96-hour 7:21

99 26:9

A

a...a 32:22

a...had 35:12

a...in 23:3

a...it's 35:20

36:3

aberration 27:14

Absorbed 27:4

absorption 26:25

abstract 13:21

15:22

ACC 10:7 35:11

ACCCI 19:10 19:11

19:16 19:24

acceptable 10:14

according 30:16

ACC's 10:4

acid 16:10

16:11 16:18

16:22 22:1 22:25

23:2 23:18 23:20

23:25 24:18

24:19 25:2

25:2 25:6 25:8

25:9 25:10 25:18

26:16 26:18

26:19 26:22

27:13 27:17 28:8

acid...that 24:4

acids 23:21

24:6 25:5 26:21

across 8:7 16:9

19:21

action 7:15

actually 36:5

acute 6:2 7:21

8:2 9:23 10:17

10:20 10:23 11:1

11:3 11:13 11:19

12:4 12:11

13:4 13:23

14:4 14:23 17:18

19:12 26:14

add 4:20 5:18

addition 6:18

8:17 12:22 13:20

15:25 18:8 19:11

additional 5:23

12:13 12:17 14:8

19:17 29:4 29:12

29:14 30:18

33:16 33:20

35:14

address 8:24

9:4 9:21 21:2

23:13 32:15

adequate 9:2

14:14 28:22

adequately 20:1

adjourned 36:17

administration

13:24

advises 5:5

affect 25:7

afternoon 20:17

21:4

age 27:8 27:14

28:3 28:4

agency 2:1 4:6

4:11 4:18 5:3

5:12 8:23 9:2

10:11 10:13

10:16 10:24 11:7

11:9 12:1 12:9

12:14 12:25

13:18 14:3

14:9 14:17 15:11

16:8 17:17

19:5 19:23 19:25

20:3 20:7

20:12 20:18

23:18 24:13 30:6

31:1 31:13

35:3 35:22

Agency's 6:7

12:24 35:13

Agency-wide 35:19

agents 22:14

aggregate 3:10

ago 29:6

agreed 5:12

8:23 9:2
EPA MEETING 09/09/10 CCR#16194-6 41

agreement 12:3

Ah 21:8

ahead 2:8

alcohol 9:3

alcohols 6:15

6:16 6:20 6:21

7:4 7:13 7:23

8:13 8:16 8:20

8:24 9:18

alcohols...see

8:18

algae 26:14

aliphatic 6:19

7:12 9:18 15:12

alkoxides 6:9

6:14 6:18 8:2

9:1 9:17

alkyl 10:3

10:12 11:14

16:18 22:16

already 4:21 5:18

6:16 8:14 9:15

17:1 18:24 21:22

31:5

alternative 10:19

alumina 6:15

aluminum 6:8

6:9 6:14 6:18

8:1 8:25 9:16

Am 29:25

America 11:24

23:7

America...I'm

6:22

American 6:12

11:24 15:23 19:9

34:25

among 18:6

amounts 8:21

9:5 25:12

analog 18:1

18:9 18:15

analogs 14:12

analysis 5:6

and...and 27:1

and...in 9:9

animal 4:16

4:19 5:3 5:13

16:15 20:3

20:9 30:11 35:8

animals 3:3 4:7

4:13 4:20 6:6

10:1 11:22

13:7 15:1

15:21 29:5 29:12

35:7

annual 13:14

anybody 23:5

anyone 29:23

anything 3:7

appeal 20:7

appendices 29:15

apply 30:3 30:9

applying 31:5

approach 5:7

30:18 36:3

approaches 30:4

30:9 31:22

appropriate 24:2

approved 25:3

approximately 6:6

7:17 10:1

11:21 13:7

15:1 15:21

aquatic 6:24

10:17 12:12

aqueous 25:21

are...these 34:21

area 24:9

argued 6:24

argues 19:1

article 15:23

assays 30:14

assess 31:6

assessment 8:19

13:22 24:13

assessments 31:18

association

6:10 17:7 26:24

assurances 15:10

atmosphere 26:4

attached 12:7

attachment 23:12

attachments 21:20

attention 6:7

available 9:3

14:16 16:16 20:9

21:18 21:20 24:8

25:23 25:25

26:14 28:7 28:17

28:18 28:24

28:24 29:13

29:14

avoid 20:9
EPA MEETING 09/09/10 CCR#16194-6 42

aware 23:7

B

backwards 21:8

Ballard 17:10

based 21:24

22:4 26:8 27:7

29:1

BASF 13:8 13:13

13:17 14:8 14:10

14:11

basically 28:21

29:7

basis 8:4

batch 22:12

BCA 16:23

BCA...BCEA 17:4

be...it 27:10

be...it's 27:10

beagle 16:4

Beck 29:25 30:2

32:2 32:2

beforehand 2:20

begin 5:25

behalf 4:7 4:12

believe 21:13

23:8 23:9 32:9

believed 10:16

believes 13:9

Benes 20:16 20:17

benzene 11:17

16:10

benzenesulfonic

22:25 23:21 24:6

25:2 25:8 26:18

better 5:1

Beyond 7:17

Bimax 17:3 32:6

bioaccumulation

25:23

biodegradation

26:2

biologically

17:24

bit 21:16 21:18

22:22 35:20

bluegill 12:4

body 8:3 13:25

15:25 18:3 18:22

27:8 28:3 28:4

28:12

Brenntag 11:23

brings 29:21

brought 21:17

21:21

burden 29:7

bureaucratic

32:25

business 21:11

button 21:8

21:8 21:8

C

C14 7:17

C16 7:5

C18 7:22

C24 8:19

calcium 26:1

26:13 28:14

calculations 26:9

capitalize 31:13

captured 36:1

carbon 7:3 7:4

7:8 8:8

carcinogenicity

12:21 17:22 18:7

carefully 20:8

CAS 32:8

case 11:12 36:1

cases 5:17 35:24

CAST 30:13

30:20 31:2

31:6 31:9 31:10

catalyst 22:15

catalysts 22:21

category 6:9 6:13

6:20 8:13 9:17

9:18 10:4 10:6

10:13 10:14 11:4

11:14 19:10

CD3 17:6 17:8

17:12 17:14 18:7

Center 30:5

certain 2:2 5:10

certainly 35:2

35:5 35:7

chain 7:3 7:4 7:8

7:16 8:5 8:8

8:18 15:12

challenge 4:15

24:10

changed 6:11
EPA MEETING 09/09/10 CCR#16194-6 43

changes 16:4

characterized

12:13

checklist 5:7

chemical 2:15 5:5

5:10 9:21

10:10 10:11 11:8

11:24 12:2

13:8 13:10 13:19

14:14 15:5

15:6 16:14

20:6 20:7

20:20 20:22

21:11 22:2

22:5 22:11 22:20

23:9 23:11

24:1 25:19 28:22

32:7 32:9 32:11

chemicals 2:3 2:4

2:11 4:19 5:16

5:21 6:1 6:5 6:8

6:25 10:3

10:15 10:16

13:23 16:10

16:13 19:9

20:2 20:4

22:17 30:6 30:13

31:10 31:15

32:15 32:18

35:24 36:2

Chemistry 35:1

chose 23:4

Christina 34:23

34:24 34:25

chromosomal 27:14

chronic 10:19

10:22 15:25

cite 12:1

cited 20:4

citing 13:10

class 7:13

classified 16:5

Cleaning 6:12

clear 5:7 7:2

7:15 8:4 30:6

cleared 34:15

clearly 11:13

closed 2:23

clothing 9:13

coal 19:9 19:11

19:15 19:18

19:22

coefficients 7:8

Coke 19:9

College 15:24

combined 6:3 9:23

13:5 14:24 16:23

19:1

comes 23:8

comment 2:22 2:23

2:25 3:2 3:11

29:22 29:24

35:17 36:12

commented 4:14

comments 2:5

2:9 3:10 3:11

3:12 3:14 3:23

4:6 4:12 6:21

8:22 10:12

11:9 11:23

12:1 12:8 13:8

16:14 16:15

20:15 20:19 21:1

24:16 32:4 32:17

32:18 32:21 34:3

34:23 35:12 36:7

36:12 36:14

comments...I'm

20:25

commercial 29:3

commercially 29:9

commitment 20:12

committed 5:13

Committee 4:13

commonly 9:9

communication

10:7

companies 12:7

12:18 16:14 17:8

17:11 20:8

22:9 22:19

company 7:21

11:25 13:8

15:6 21:10

29:1 29:2 29:8

comparable 26:22

comparison 25:3

complete 7:20

14:13

completed 7:23

18:24

composite 16:1

compound 14:11

21:14 22:25

23:15

compound...and

24:5

compounds 7:14
EPA MEETING 09/09/10 CCR#16194-6 44

10:25 21:15

22:21 23:17

23:22 25:19

computational

30:5 35:9

concentrated

26:23

concentration

7:19 7:25

concerned 4:17

concerning

24:15 25:22

26:12 28:6

concerns 12:17

21:2

conclude 5:8

28:21 32:17

concluded 12:10

12:14 36:18

concludes 8:10

conclusion 19:25

conduct 5:6 19:21

conducted 4:20

6:5 11:6 15:9

18:9 19:18 24:11

27:19

conducting

19:17 20:9

confirmed 16:23

conjunction 35:23

Consequently 8:15

conservative 8:15

consider 5:20

14:17 15:11 16:8

19:5 23:18 30:17

consideration

32:20 36:4

considerations

34:1

considered 20:1

35:22

considering 11:14

consistency 24:7

consistent 25:18

consortium 22:2

constant 26:24

consulting 24:13

contact 26:24

containing 16:2

continue 10:9

contracted 21:1

control 2:15

34:22

copies 3:15

copy 3:7 29:16

corporation 3:4

12:2 20:16 23:1

correct 35:22

correctly 3:17

corresponding

6:15 8:23

Council 20:11

35:1

couple 21:9 21:12

35:2 35:12

coupling 22:14

course 3:8

21:25 36:15

court 3:5

covers 2:10

creating 19:10

creosote 19:15

Culla 11:24

current 17:5

17:15 24:11

currently 28:18

36:3

Customers 22:18

cutoff 7:17

CVI 17:1

D

daphnia 10:18

26:13

Darryl 17:9

data 5:9 5:15

5:22 6:16 6:23

7:2 8:15 8:23

9:2 10:24 12:1

12:4 12:9

12:14 12:22

12:24 13:10

14:14 14:15

14:18 15:7

15:8 15:8

15:12 15:12 17:2

17:16 18:1

19:6 19:12 19:20

19:24 20:4

20:9 21:14 21:18

23:23 24:3

24:6 24:8

24:20 24:25 25:1

25:4 25:8

25:17 25:23

25:25 26:12
EPA MEETING 09/09/10 CCR#16194-6 45

26:18 26:19

27:12 27:17

27:17 28:7 28:17

28:18 28:23

28:24 29:13

29:14 30:16

30:24 30:25

31:17 34:1

35:3 35:5

database 8:18

date 32:23

day 28:4 28:4

28:12

days 27:23 34:10

decene 10:2 10:15

11:12

decision 31:19

32:7

decreased 18:3

18:20

decreases 18:21

decreasing 7:3

definitive 30:25

demonstrates 5:17

deprobated 27:3

derivative 11:6

dermal 27:1 27:24

28:2

described 13:23

detergent 6:10

22:9 22:19

detergents 22:15

determined 14:5

19:20

Dettinger 32:5

32:6 32:13

developed 30:4

developing 30:7

development 11:11

14:15 28:11

35:16

developmental 6:4

8:7 9:25 11:20

13:6 14:20 14:25

15:9 15:17 15:20

16:12 18:9 18:17

19:2 19:14 28:7

differences 18:14

different 31:16

differs 15:14

difficult 4:23

dimethyl 22:25

23:16

Director 2:14

discussion 32:19

dispersants 31:7

distributed 27:5

distribution 26:6

Division 2:15

DMT 18:23 19:7

docket 16:16 17:2

36:13

document 3:6

documentation

36:11

dodecatheon 11:6

dogs 16:4

doing...doing

33:14

dominant 18:8

18:11

done 10:19

21:15 21:25 22:4

23:22 24:20

dose 6:3 9:24

11:11 13:5 13:25

14:4 14:6

14:24 17:25 18:4

18:20 18:22 19:2

19:14 27:16

doses 14:2 27:21

dosing 18:12

27:22

draft 35:19

dropped 10:5 10:8

due 6:25 10:17

duplicative

13:2 20:9

duration 18:12

during 3:7 3:11

13:14 36:12

dye 16:1 16:5

dynamic 17:20

E

earlier 31:6

35:11

early 35:20

easier 4:4

Eastman 15:6

Ecostar 26:15

ecotox 28:23

ecotoxicity 26:12

EDSP 31:11
EPA MEETING 09/09/10 CCR#16194-6 46

effect 25:15

26:17 26:23

effects 8:14 8:16

8:18 8:24 8:25

9:4 11:8 12:12

12:16 15:7 17:24

18:5 25:12 25:13

27:21 28:3 28:10

electronically

21:22

elements 34:1

eliminate 10:21

14:20

else 23:5 29:23

employ 22:6

employees 22:7

encoded 34:20

encourage 31:1

endotracheal

17:23

endpoint 27:13

endpoints 5:11

6:17 8:25 9:4

16:12 21:16

23:24 24:8 24:23

27:4

ensure 3:16

entertain 21:5

entities 3:1

entry 23:11

enumerated 5:4

environment 26:7

environmental 2:1

8:25 9:11 10:4

12:11 19:4 20:11

25:22 27:2 28:23

EPA 2:15 3:9

14:14 17:10 31:5

31:23 33:6

epi 26:8

ester 16:23

estimate 26:16

estimated 7:9

7:10 25:1 25:4

25:17 26:4

26:7 26:17

ETAD 34:5

Ethical 3:2 4:7

4:12

ethyl 15:15

evaluate 19:24

20:3 20:8

evaluated 9:16

30:23

evaluating 12:9

evaluation

21:16 24:11

evaluations 15:16

event 2:17

everybody's 34:15

everyone 2:9

3:4 30:24

everything 29:18

evidence 6:14

14:19 30:18

exactly 3:16

28:13

examined 14:6

18:7

example 15:13

exceed 13:18

Excellence 24:12

exception 18:3

excreted 27:6

exert 7:14

exist 23:13 23:19

27:17

existing 5:15

5:22 8:15

10:24 14:19 15:8

20:4 21:14 30:16

35:3

exists 25:20 31:1

expected 9:11

17:3 26:25

expense 29:4

experience 5:10

5:15 31:16

expertise 22:12

explain 21:13

explained 10:8

exposed 27:21

28:9

exposure 9:10

17:23 18:2 18:10

19:4 19:6 27:2

33:7 33:12 33:13

33:17

extensive 4:18

19:23 30:11

30:16

extract 23:11

extremely 15:15
EPA MEETING 09/09/10 CCR#16194-6 47

F

facilitate 31:22

facilities 9:14

facility 22:7

fact 6:8 29:2

fail 20:12

fairly 24:24

27:22

fame 22:13

fashion 19:19

fate 8:25 25:22

fathead 7:22

17:19

Federal 12:10

34:20

feed 14:1

feeding 28:8

feel 2:18

feeling 28:25

female 27:25

females 18:13

fetal 28:14

figure 21:7 31:18

final 10:6 11:2

18:25 33:12 34:5

34:18

finalize 3:12

36:14

finalized 33:2

finalizing 19:7

32:20

Finally 9:5

financial 29:7

29:9

finding 33:17

findings 33:7

33:12 33:14

35:25

first 3:21

16:17 22:3 30:12

fish 6:2 7:19

9:22 10:20

11:3 11:12 11:19

19:12 26:13

fit 7:13

five 10:2

flow 10:19 17:19

focusing 19:19

form 23:18

25:10 25:14

26:10 26:10 27:3

27:17

formally 35:21

format 20:23

forming 9:10

forms 23:19 26:23

formulation

16:1 16:5

forward 21:8 30:7

fourth 35:13

fragrance 15:2

frame 32:7

Franz 34:24 34:24

34:25 36:6

free 2:18

freely 24:25

fugacity 26:7

fulfill 6:17

fulfilled 15:7

fulfillment 12:3

future 13:18

G

gain 14:1 18:4

gastro 27:1

generally 7:14

generate 30:24

generated 12:23

generation 11:5

genetic 27:12

German 13:21

given 5:9

golden 17:22

GOP 12:5 15:10

great 30:8

greater 8:3 13:25

26:9 26:15 26:17

27:8

green 21:7 26:14

gross 16:4

group 2:4 10:5

15:15 23:12

groups 18:20

25:16

guess 4:1 16:21

31:12 31:20

guidance 5:4

guiding 31:19

Gulf 31:7
EPA MEETING 09/09/10 CCR#16194-6 48

Gunnulfson 33:5

33:6 33:11 33:18

33:22

guy 22:6

H

hair 16:1 16:5

half-life 26:3

hamsters 17:22

handouts 3:25

happen 34:20

happens 22:10

happy 21:4 29:16

hard 3:7

Harrison 22:7

has...can 4:8

having 15:14

hazards 10:17

health 8:14

8:16 8:17 8:24

9:4 10:4 11:8

12:16 15:7

hear 4:8 4:9 4:24

34:25

heard 30:17

Helmes 34:4

34:4 34:9

34:12 34:14

HERTG 11:2

hexacosanol 6:1

6:17 7:5 7:11

8:4 8:12 8:21

9:15

Hi 34:24

high 2:2 2:10

10:17 18:4 18:19

23:25 24:21

27:22 36:1

highest 14:2

18:22

high-exposure

36:2

highlight 21:3

hired 24:14

hope 29:19

Hopefully 33:3

House 5:13 20:10

HPV 4:15 4:19

4:21 5:4 5:5 9:1

10:11 13:9 13:19

15:6 16:9 17:4

17:14 22:1

23:3 24:4

24:10 30:5 30:13

30:23 31:4 31:14

32:7 32:10

34:6 34:17 34:18

35:14 35:19

HPV3 2:10

HPVs 35:15

human 5:10 5:15

19:4

hydrolysis 9:3

hydrolyze 6:15

hydrophilic 25:18

hydrophobicity

10:18

hydrotrope 24:19

hydrotropes 22:14

hydroxy 26:3 26:6

hydroxybenzene

16:11

hydroxyethyl 18:1

I

I...my 31:20

IAAA 17:7 17:16

17:21 18:8

ICCA 6:20 9:17

I'd 2:8 4:5 32:23

identified 18:24

identify 32:1

ignores 5:3

I'll 5:20 5:22

5:25 9:21

16:13 16:20

I'm 2:14 3:24

16:21 20:20

20:24 21:3 24:17

30:10 31:12 32:5

33:8 34:4

34:17 35:18

imagine 16:19

Imaging 17:7

import 10:9 13:12

17:2

important 31:21

importation 17:9

imported 9:6

importers 20:6

in...in 34:2

incidence 8:6

include 3:7 12:4
EPA MEETING 09/09/10 CCR#16194-6 49

included 5:16

5:21 6:9 10:3

20:4 25:5 25:9

26:19 36:15

includes 6:20

including 5:10

6:16 7:5 8:20

10:15 14:12 15:8

26:8

inclusion 9:18

31:11

incorporate 5:13

Incorporated 17:1

17:3

increase 7:8

16:25 26:5

increased 26:5

increasing 7:3

7:8 7:16 7:16

incredibly 32:25

indeed 33:23

independent 24:13

indicate 13:11

indicated 16:3

indicating 7:2

individually 5:21

induce 18:15

industrial 13:22

industry 17:7

35:5

infancy 30:21

info 31:3

inform 30:18

information

5:18 5:23 10:10

informationgathering 33:20

inhalation 12:20

initial 8:19

24:20

initiated 12:19

initiative 6:20

9:17

insolubility 7:1

insoluble 7:6

instead 15:15

30:10

Institute 6:12

19:10

intake 14:2

intends 18:25

interested 30:6

32:6

Internal 18:20

International

17:7

interperitoneal

27:9

interpreting

31:16

introduce 2:19

inventory 13:10

33:24

inverse 8:4

Invista 18:23

19:1 19:6

Invista's 19:5

invite 3:15 20:15

29:22

invite...

sorry...Joseph

3:22

involving 16:6

ionize 25:20

is...is 16:18

32:17

isn't 35:19

isomers 23:13

issue 36:5

issues 32:24

issuing 35:15

it's 4:23 21:10

21:11 21:11

21:11 30:6 31:21

32:8 35:20 36:3

it's...it's 26:10

IUR 23:2 33:24

34:2

J

January 7:23

Jeff 33:5

Jim 2:14 35:11

jobs 21:11 29:10

Joe 32:6

Journal 15:23

July 2:21 34:7

K

ketone 15:14

ketones 15:12

kill 6:6 9:25
EPA MEETING 09/09/10 CCR#16194-6 50

11:21 13:7 14:25

15:21

killed 4:21 29:6

kinds 31:17

known 5:9 5:19

11:18 13:13

17:11 20:1 24:24

L

lack 8:6

large 22:9

largely 33:24

LC50 17:18 17:20

LD50 8:2 15:24

27:7 27:9

LD50s 13:24

leave 3:15 21:23

length 7:3 7:9

7:17 8:5

lengths 7:4 8:8

less 9:7 13:15

17:13 25:13

25:24

lethal 18:8 18:11

letter 17:1

level 18:22

26:8 30:24

levels 18:4 28:1

light 10:10 28:24

likely 12:23

14:18 17:4

25:6 25:13 25:19

27:3 29:2

line 22:17

lines 36:5

list 17:9 20:22

listed 6:1 9:22

11:18 13:4 14:22

15:19 32:16

listen 20:18

little 21:16

21:18 22:6 22:22

local 26:23

located 5:22

long 8:18

long-chain 6:19

9:17

longer 13:9 17:4

lot 21:15 21:24

22:3 22:19 23:21

30:12

low 8:6 9:12

10:21 10:25

13:23 26:24

26:25

lower 8:12

M

main 31:20

maintain 20:11

major 22:20

male 18:16 27:25

males 18:12

malformations

18:18

mammalian 6:2

9:23 10:23

11:3 11:12

13:4 14:23 23:24

26:21 28:23

mammals 19:12

Mannupello 3:22

3:24 4:5 4:10

4:25 5:2

manufacture

10:9 13:12

17:8 29:10

manufacturer

22:11 23:3 23:7

manufacturers

5:24 20:6 22:6

22:20

manufacturing

29:3

market 22:16

marketplace 23:10

material 23:4

24:24 28:14

29:10

materials 11:25

15:2 23:19

mating 18:13

matrix 25:1

may 2:24 5:8 14:9

17:10 19:17 21:1

35:24

maybe 33:9

me...first 3:18

mean 29:10

means 28:17

measured 10:20

25:4

measurement 25:11
EPA MEETING 09/09/10 CCR#16194-6 51

measurements 25:7

media 25:21

Medicine 4:14

meeting 2:9 3:6

3:8 3:9 36:16

36:18

members 10:9 11:4

mention 29:5

mentioned 35:14

met 29:19

methanesulfonamid

e 17:6

methyl 15:14

23:12 25:16

methylation 25:12

methylation...

an 26:5

methylethyl 15:13

mg 27:8 27:25

28:3 28:4 28:13

mg/kg 8:3 13:25

15:25 27:10

28:12

mg/l 7:25 17:19

17:20 26:15

26:17

Miami 11:24

mice 15:4 27:11

27:21 27:25

27:25 28:2 28:5

microphone 2:19

4:2

microphones 2:16

microscopic 16:4

mid 18:19

million 9:7 13:13

16:24 17:14

minimal 9:12 19:3

minimally 10:14

minimum 12:25

minnows 7:22

17:19

minutes 21:10

21:12 29:6

mixture 8:20

mode 7:15

model 26:7

modified 25:24

money 35:6

monographs 15:3

month 31:8 34:16

months 32:24 33:1

mortality 7:24

mosses 9:9 9:9

move 4:2

moving 30:7

MSDS 24:21

multi 17:17

N

Nancy 32:2

Nancy's 35:8

narcosis 7:15

National 12:19

30:4

naturally 9:8

NCCT 31:2 31:15

Nease 3:3 16:19

20:16 29:2

necessarily 30:25

necessary 12:14

19:3 29:13

31:3 35:7 35:25

negative 27:15

negotiated 12:3

neither 16:4

neutral 7:13

nine 32:24 33:1

nitrobenzene

14:13

nitrobenzosulfona

te...benzene

16:3

NOAEL 28:12

NOAELs 27:24

non 7:14

none 10:9 36:9

non-statistically

18:21

nor 16:4

North 6:22

11:23 23:7

note 12:18 15:4

noted 10:24 17:25

18:5 18:14 18:19

35:12

notes 8:17 9:5

12:22 13:9 18:23

notice 12:11

NPRA 33:6
EPA MEETING 09/09/10 CCR#16194-6 52

nucleic 23:25

24:21

numerics 35:25

numerous 15:16

O

obtain 30:14

Occidental 12:2

occupational 9:10

13:22

occur 9:8

occurred 18:22

occurs 7:18

octanol 7:7

October 12:10

October,1999 5:4

OECD 15:8 24:20

25:25

OEL 28:1

of...of 35:2

offer 2:9

Oh 32:2 34:12

Ohio 22:7

oil 31:7

Okay 4:25 5:2

30:2 33:22 34:14

34:25

on...on 3:19

opinion 28:22

opportunity

2:25 4:6 4:11

29:22 30:8 31:14

optimistic 33:4

34:16

Optimistically

33:4

oral 2:5 3:14 8:2

13:24 15:24 16:1

17:23 18:2 18:10

20:25 28:8

orally 27:21

order 31:22 32:23

organic 25:18

organics 7:13

organs 14:6

18:6 28:11

original 10:12

12:6 16:15 24:10

originally 10:3

orphans 35:14

others 19:20

our...our 22:21

outside 31:15

34:22

overt 7:24

P

p.m 36:18

page 28:1

paid 24:14

Pair 33:12

Pair-rule 33:7

panel 10:8

Para 22:1

parachlorobenzotr

ifluoride 11:18

paradigm 31:23

parameters 18:15

paratoluenesulfon

ic 24:4 25:2

25:9 26:19

participants

5:5 5:8

participate 22:15

participated

24:10

particular

10:15 14:5 23:22

partition 7:7

pass 3:24 23:8

pattern 7:2

7:15 8:11

PCBTF 11:18 12:12

12:16

PCRM 32:2

peat 9:9

pentanone 15:4

people 2:17

2:25 3:2 4:7

4:12 21:12

per 9:7 27:8 28:3

28:4 28:4 28:4

28:12 28:12

percent 16:2 26:2

26:9

period 2:23

3:11 36:12

period...well

2:22

periods 13:11

13:14
EPA MEETING 09/09/10 CCR#16194-6 53

personal 10:7

PETA 3:2 3:22 4:8

4:13 29:6

phenylenediamine

18:1

Phillip 20:16

Physicians 4:13

physicochemical

24:23

physio 28:22

plan 4:14 6:13

8:1 8:22 10:6

10:13 11:2 11:14

14:9

planned 12:22

33:20

plans 13:17

plant 22:8

plants 9:10

please 2:19 33:4

plus 28:17 32:18

Podium 4:1

point 29:24 30:23

31:20

points 35:2

polar 7:15

pose 10:17

posing 31:12

positive 27:20

possibility 16:9

possible 30:3

possibly 35:14

potential 8:12

19:3 30:14

pound 13:13

pounds 9:7

13:16 13:18

16:24 17:13

17:14

preactivity 30:22

precedence 23:25

predict 8:11

12:16 35:21

predicted 7:1

predictors 8:16

pregnancy 18:19

prepare 3:6

present 3:5

3:22 4:6 4:11

5:22

presentation 3:25

presentations

30:17 35:4

presented 6:14

pretty 29:17

previous 20:21

previously 14:10

primarily 22:8

22:14 22:19

25:20

primary 5:3

principle 5:3

principles 5:14

35:8

prioritize 31:10

probably 34:11

probably...I 4:2

proceed 32:19

proceedings 3:5

process 3:19

18:13 32:25

34:22

produced 9:8

production 2:2

2:11 13:15 16:24

17:2 17:12 22:21

36:2

products 9:3

profile 30:14

30:15

profiles 31:9

program 4:15 4:22

5:4 9:2 12:19

15:6 16:10 24:10

30:23 31:4

propanol 11:6

properties 8:6

proposals 19:24

proposed 2:5 2:10

2:21 4:16 6:2

6:21 8:8 9:19

11:16 11:19

14:22 15:19

18:25 19:1

20:5 21:17 21:19

22:24 32:12

32:16 34:7 35:13

proposes 19:10

proposing 4:18

20:2 30:11 31:13

PROTECTION 2:1
EPA MEETING 09/09/10 CCR#16194-6 54

protective 9:13

proteic 25:6

proteinated 25:14

protocol 21:3

21:19

provide 2:25

3:1 31:3 31:15

provided 2:24 3:7

3:11 7:1 7:20

19:24 29:15

36:11

public 2:9 29:24

published 2:21

34:6

purposes 9:1 31:3

puts 29:7

Q

qualitative 5:6

Quality 20:11

quantities 29:3

question 30:13

31:12 32:5

32:8 33:5 33:6

33:9 35:10

questioned 11:7

questions 3:19

21:5

quick 29:17

quickly 27:5

quite 35:19

R

rabbits 16:7

radicals 26:4

26:6

rainbow 12:5

raised 12:17

ran 29:17

range 8:8

rapidly 6:14 27:6

rat 27:18

rates 18:19 27:22

rather 5:6

rationale 21:13

24:7

rats 8:2 11:5

12:6 12:20 12:21

13:24 15:25 16:6

18:2 18:10

27:7 27:25

28:2 28:5 28:9

28:11

raw 15:2

re...re-emerge

36:1

REACH 12:23

reaction 26:3

26:6

read-across 28:18

realize 30:20

really 25:14

34:12

reasonable 8:11

9:1 19:16

reasonably 12:16

received 3:12

32:18 32:19

36:12

recently 6:11 9:6

reconsider 11:9

record 3:5

reduced 14:1 14:1

reference 15:4

24:22

references

21:19 28:19

refine 31:22

reflected 18:21

regard 14:4 14:18

15:13 16:15

Regarding 6:24

10:23

register 12:10

29:23 34:20

REGULATION 2:5

Regulatory 10:5

related 17:24

18:5

relationship 8:5

relative 23:17

30:21

release 9:11 19:4

relevant 5:22

6:23

remaining 16:13

19:22

remains 26:9 36:4

reminder 36:10

removal 9:13

removed 9:20

11:15 17:5 17:15

repeated 6:3 9:24
EPA MEETING 09/09/10 CCR#16194-6 55

11:10 13:5 13:25

14:4 14:6

14:24 17:25 19:2

19:14 27:16

rephrase 33:9

report 7:21

19:6 21:1 21:4

24:15 24:17

29:14

report...includes

8:19

reported 8:2 8:14

11:3 13:15 15:24

17:8

reporter 3:5

13:14

reporters 5:24

reporting 13:11

17:11 23:2

reports 12:7 19:1

representative

16:19 29:5

reproduce 19:13

reproduction

6:4 9:24 11:11

11:20 13:6 14:24

15:3 15:9

15:16 15:20

16:11

reproductive

8:7 11:5 12:6

12:15 14:6 14:15

14:21 16:6

18:6 18:14 18:16

19:2 19:14

28:6 28:10

requested 29:22

require 4:18

required 5:17

19:17 23:9 28:25

requirement 14:20

requirements 5:20

12:23 12:25 19:7

requires 17:17

30:11

requiring 6:2

9:22 11:10 11:19

13:1 13:4

14:23 15:19

residue 18:23

19:8

respectively 28:5

response 3:20

12:23 36:8

responses 36:14

Responsible 4:14

result 17:10

resulted 27:24

28:11

results 11:3

11:10 13:1 17:21

24:8 26:4 27:20

returned 13:21

15:3 15:22

returning 20:10

review 3:10

5:15 14:3 14:9

19:23 32:17

35:20

revision 10:6

11:2

Rhodia 16:25

right...yeah 2:23

Risk 24:12

road 22:10

robust 6:18 14:9

room 2:16 24:25

rote 5:7

roughly 32:24

route 18:10

routes 11:1 17:23

rule 2:10 2:21

3:13 5:16 6:2

6:21 9:19

11:16 11:19 13:2

14:23 15:19 17:5

17:15 18:25 20:5

21:17 22:3 22:24

30:11 30:19

32:12 32:16

32:20 33:2 33:12

33:13 33:24 34:5

34:6 34:7

34:17 34:18

35:13 35:19

rulemaking

33:16 33:20

33:25 36:13

rules 2:12 5:14

33:25 35:22

35:23 36:5

run 30:13 32:25

S

safe 16:21 26:22

safety 13:22

salt 25:5 25:20

28:9
EPA MEETING 09/09/10 CCR#16194-6 56

salts 6:8 23:19

24:19 27:4

Sasol 6:21 7:9

7:20 8:10 8:17

9:5

satisfy 12:24

saturation 7:18

screen 9:25

13:6 14:25 15:9

screening 11:21

15:20 17:18

24:20 30:24

screens 6:5

scroll 4:3

SDA 6:10 6:11

6:13 6:16 6:24

7:1 7:9 7:12 8:2

8:8 8:22

search 13:20 15:2

15:22

second 2:4 34:6

section 2:12

sediment 26:11

seeing 36:9

seems 14:18

30:8 31:23

seen 29:18 36:4

selection 11:8

sell 22:19

sense 29:9 30:3

30:12 34:5

separate 12:1

September 2:6

series 2:12

serum 25:25

serve 22:18

service 23:11

sets 27:17

setting 34:1

several 5:21 11:4

14:12 19:14

23:13

sheets 24:21

shift 31:23

short 15:12

showed 28:10

shown 23:2 26:15

SIDS 8:24 9:4

14:13 21:16 25:1

sign 28:17

signatures

30:21 30:22

signed 34:21

significant

8:21 9:13

17:24 18:14

18:18 18:21 29:7

35:23

significantly 9:7

16:25 17:13 25:6

signs 7:24

similar 10:25

15:5

Similarly 7:7

8:10 12:14

sit 4:3

site 6:19 26:24

six 19:11 32:23

33:1

size 29:1

skeletal 18:18

skip 16:20

slides 4:3

slip 35:24

small 25:18

SMC 11:25 12:22

SNUR 35:15

Soap 6:10

SOCMA 16:23

sodium 15:18 16:2

25:23 25:25

26:12 27:14

27:18 27:22 28:9

software 31:9

solid 24:24 25:13

solubilities

10:21

solubility 7:2

soluble 24:25

sorry 2:22 32:2

32:11 33:8 33:15

34:17

sorry...in 20:25

sort 33:25 35:24

speaker 4:9

4:23 5:1 20:21

33:1 34:17

speaking 16:20

Special 11:25

specialty 22:17

species 12:12
EPA MEETING 09/09/10 CCR#16194-6 57

17:18 26:18

specific 22:24

32:22

specifically 5:12

23:16

specify 23:12

spend 21:9

21:12 35:6

spermatogenic

18:12

sponsor 23:4

sponsored 6:9

7:21 10:4 15:5

16:9

sponsors 5:5

sponsorship 10:8

staff 31:15

stand 23:6

start 30:12 31:21

started 2:8

statement 2:18

3:15

statements 2:17

states 13:17

static 17:17

step 33:13

steps 34:21

step-wise 19:19

STM 23:11

strategy 19:16

studied 15:16

studies 6:4

8:19 11:11

16:6 17:22

18:2 18:9

18:24 19:15 24:2

27:19 27:24

subchronic

12:11 18:11

submission 11:15

submit 18:25 19:7

submitted 4:15

5:23 14:10 16:14

17:1 20:5

20:25 24:15 32:9

subsequent 5:14

substance 13:12

19:19 19:21

25:11

substances 9:6

9:8 9:11 19:11

19:18 19:22

25:10

suffice 19:21

sufficient 5:8

12:15 14:19

sufficiently

10:21

suggest 2:16

suggested 10:18

suggesting 18:15

suggestion 35:8

suggests 14:8

19:16

suit 17:3

suite 26:8

sulfates 27:3

sulfide 18:2

sulfides 10:3

10:13 11:14

sulfonate 15:18

16:3 23:23 24:9

sulfonates

22:16 23:20 27:5

sulfonation 22:12

sulfonic 16:10

16:11 16:18 22:1

26:21

sulfuric 26:22

sulfurized 9:22

10:2 10:15 11:12

summarize 5:23

16:14 17:16

summarized

17:21 18:8

summarizes

19:12 28:16

summary 3:6

6:19 6:19 6:23

7:20 14:10

summer 31:6

sunfish 12:5

supplied 12:1

17:9 28:20

supplier 22:9

supply 29:16

support 33:16

35:3 35:7

supported 17:25

24:7

supporting 6:18

sure 6:22 20:23

33:8 35:18
EPA MEETING 09/09/10 CCR#16194-6 58

surrogate 14:10

21:15 21:24

23:17 24:2

24:5 27:4

surveyed 17:8

Syrian 17:22

system 27:6

T

table 25:1

tailor-made 33:24

taking 32:20

talk 16:17

20:20 21:17

22:23

talked 20:21 29:6

talking 23:15

24:17 25:15

tar 19:11 19:15

19:18 19:22

Task 10:5

temperature 24:25

tend 33:4

TERA 21:2 24:12

29:14

teratology 12:21

test 2:10 2:12

3:12 4:14 5:14

5:16 5:20 6:13

7:22 7:25 8:1

8:22 9:19 10:6

10:13 10:19

10:20 11:2 11:14

11:16 11:19 13:2

13:4 14:9

14:23 15:19

15:20 15:21 17:5

17:15 17:18

17:20 18:11

18:25 20:5 21:17

22:24 23:8 25:25

28:16 33:25 34:6

35:6 35:22

tested 5:11 10:25

31:8

testing 2:2

4:16 8:9 10:22

11:8 12:3

12:13 12:17 14:1

16:15 19:7 19:17

21:2 21:19 27:16

28:25 29:4 29:12

30:11 30:19

tests 4:19 4:19

5:17 6:3 6:5

9:23 9:25 11:4

11:13 11:15

11:21 11:21 12:4

12:21 13:1

13:2 13:7

14:25 19:18 20:3

20:10 27:14

tetra 6:17 7:5

8:3 8:12 8:21

9:15

tetracosanol 7:11

thank 4:5 4:10

20:13 20:14

20:17 20:18

29:20 31:25 32:3

36:6 36:16

that...compiled

6:22

that...that 23:15

24:14

that's 2:24 5:1

20:22 22:12

22:22 23:1 24:12

33:23

that's...you

29:18

the...seems 30:16

the...that 17:17

the...the 24:14

24:23 34:6 35:19

themselves 20:8

therefore 23:13

26:25

there's 27:16

35:16

they're 26:22

27:20 31:17

third 2:11

thoroughly 9:16

20:3

thoughtful 5:6

thoughts 35:13

threshold 13:13

17:14

throughout 27:5

today 3:8 21:21

21:23 22:23

23:16 24:17

28:24 29:16

29:18 30:17 35:4

toluene 22:1

toluenesulfonate

24:5

toluenesulfonic

24:19
EPA MEETING 09/09/10 CCR#16194-6 59

tools 30:7 31:2

31:13

TOSCA 2:13

totality 5:9 20:1

tox 30:13 30:20

30:21 31:2

31:6 31:8 31:9

31:9 35:9

toxic 6:25 7:19

toxicant 16:6

toxicities 8:13

toxicity 5:15 6:3

6:3 6:4 6:24

7:14 7:16 7:18

7:22 7:24 8:7

9:23 9:24 9:25

10:20 10:22

10:23 11:1

11:3 11:5

11:11 11:13

11:20 11:20 12:4

12:6 12:15

13:4 13:5 13:6

13:24 14:1

14:4 14:15 14:21

14:23 14:24

14:25 15:3

15:9 15:17 15:20

16:1 16:12 17:18

17:25 18:16

18:17 18:20 19:2

19:12 19:15

23:24 26:14

26:16 26:21

27:12 28:7 28:14

30:14

toxicological 8:5

24:3

toxicology

12:19 13:21

15:24 24:12 30:5

30:7 31:23

toxicty 18:9

Toxline 13:20

15:22

tracts 27:1

traditionally

31:17

transcript 36:10

treatment 3:3 4:7

4:12 9:14

17:24 18:4

trout 12:5

try 23:13

trying 31:24

Tucker 34:4

two-year 28:2

type 36:2

typo...it 27:10

U

U.S 2:1

understand 6:11

33:9

Univar 11:24

unless 10:20

unlikely 6:25

10:16 16:25

unnecessary

9:19 11:13

untreated 18:13

update 13:11

33:24

upon 21:24 22:4

26:8

urge 11:9 14:17

15:11 16:8

USA 11:24

useful 5:18

utilizing 35:5

V

value 26:2

values 7:3 7:10

8:2

values...they

7:10

variety 11:1

various 27:17

varying 25:12

vehicle 33:14

verify 10:11

13:19

versus 25:6 25:14

view 29:13

visceral 18:18

volatility 9:12

volume 2:3 2:11

16:24 17:2 17:12

volumes 13:15

voluminous 19:13

voluntarily 23:5

W

wait 12:25 19:6

was...that 27:9

was...was 17:11
EPA MEETING 09/09/10 CCR#16194-6 60

wasn't 20:23

waste 9:13

water 7:1 7:7

10:20 24:25

25:20 26:10

26:10

We...our 22:7

wealth 29:13

we'd 3:14 29:15

weight 8:3

13:25 14:1 14:19

15:25 18:4 18:22

27:9 28:3 28:4

28:12 30:18

welcome 2:8

welfare 5:3

5:14 35:8

we're 4:17 22:6

22:11 23:2

23:7 23:15 23:17

25:14 32:6

we're...in 22:5

we've 5:22 22:8

WHEREUPON 36:18

whether 14:5 29:8

31:2 33:16 35:17

White 5:13 20:10

wide 8:7

willing 23:6

Willis 2:7 2:14

3:21 4:1 20:14

29:20 30:1 31:25

32:3 32:11 32:14

33:3 33:8

33:15 33:19

33:23 34:8 34:10

34:13 34:15

34:18 35:18 36:7

36:9

wish 2:18 3:1

14:9

withdraw 23:9

wondering 30:2

35:16

work 21:15

21:24 21:24

23:21 32:24

work...the 21:7

world 22:5

written 20:25

24:16 36:11

X

XSA90 23:1

xylene 27:3

xylenesulfonate

24:1 25:24

26:1 26:1

26:13 27:15

27:18 27:23

28:10 28:15

xylenesulfonic

23:2 23:20 23:23

23:25 24:18 25:5

25:17 26:16

27:13 28:8

Y

yet 34:5 35:20

yourself 2:20

32:1