Brenntag North America, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

June 25, 2014

Paul Lewis, PH.D., Chief

Chemical Information and Testing Branch

United States Environmental Protection Agency

Office of Chemical Safety and Pollution Prevention

Washington, DC 20460

RE: (TSCA Section 4- Docket Identification Number EPA-HQ-OPPT-2007-0531) Letter-ofIntent-To-Test and Study Plan

Dear Mr. Lewis,

In reference to your correspondence received on April 25, 2014, Brenntag North 

America, Inc., (Brenntag) hereby submits this letter-of-intent-to-test for 2,4-Hexadienoic Acid, 

(2E,4E)- (AKA Sorbic Acid) (CASRN 110-44-1). Applicable testing will be conducted as stipulated 

within the Final Rule (76 FR 1067) issued on January 7, 2011 (Testing of Certain High Production 

Volume Chemicals; Second Group of Chemicals) (HPV2 Test Rule).

Brenntag has contracted GEI Consultants in Denver, Colorado to complete the 

applicable testing in accordance with ASTM E 1218-04 procedures. A representative sample of 

Sorbic Acid will be collected by Brenntag personnel and sent to GEI for testing. Upon 

completion, a final report will be submitted to your agency on or before June 1, 2015 as 

stipulated within your April 25, 2014 correspondence. 

Brenntag is submitting this letter-of-intent-to-test and study plan prior to the specified 

date of June 30, 2014. Applicable testing and submission of a final report will be submitted to 

your agency on or before June 1, 2015. Therefore, it is our understanding that Brenntag has 

come into compliance with the test rule. 
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

If you have any questions or require additional information, feel free to contact me at 

317-454-7226 or email swiram@brenntag.com.

Respectfully Submitted,

Shawn P. Wiram

Director Safety, Health & Environment

Brenntag North America, Inc.
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

TSCA Section 4- Study Plan

Brenntag North America, Inc.

2,4-Hexadienoic Acid, (2E, 4E)- (AKA Sorbic Acid) (CASRN 110-44-1)

In reference to 40 CFR 790.50, Brenntag North America, Inc. submits this study plan 

for Sorbic Acid as follows:

790.50 (c)(1)(i)- Identity of Test Rule: Docket Identification Number EPA-HQ-OPPT-2007-0531

790.50 (c)(1)(ii)- Specific Test Requirements: C6- Toxicity to Plants (Algae) ASTM E 1218-04e1

790.50 (c)(1)(iii)(A)- Name & Address of Test Sponsor:

Brenntag North America, Inc.

5083 Pottsville Pike

Reading, PA 19605

790.50 (c)(1)(iii)(B)- Responsible Administrative Official:

Name: Shawn P. Wiram, Director of Environmental Health & Safety

Address: Brenntag North America, Inc.

3111 North Post Road

Indianapolis, Indiana 46226

Telephone: Office- (317) 454-7226

Cell- (484) 824-0268

790.50 (c)(1)(iii)(C)- Contact for Oral & Written Communication with EPA

Name: Shawn P. Wiram, Director of Environmental Health & Safety

Address: Brenntag North America, Inc.

3111 North Post Road

Indianapolis, Indiana 46226

Telephone: Office- (317) 454-7226

Cell- (484) 824-0268
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

790.50 (c)(1)(D)(1)- Testing Facility & Project Manager Information:

Testing Facility: GEI Consultants, Inc. / Ecological Division

4601 DTC Boulevard, Suite 900

Denver, Colorado 80237

Project Manager: Natalie Love, Laboratory Manager

Telephone: (303) 264-1070

790.50 (c)(1)(D)(2)- Brief Summary of Professional Qualifications:

Mrs. Love is the Laboratory Manager for GEI with ten years of lab experience including 

bioassessments, habitat surveys, analysis of data and field work. She has extensive experience 

in the formulation of QA/QC procedures and staff operations for lab facilities. Mrs. Love has a 

B.A. Degree in Environmental, Population and Organismic Biology from the University of 

Colorado (Boulder). She also holds Level 1 & 2 RMWQAA Certifications. 

Note: GEI Consultants have completed Sorbic Acid aquatic testing under a previous TSCA 

Section 4 test rule issued on March 16, 2006 (Federal Register/Volume 71, Number 51) (Docket 

Identification Number EPA-HQ-OPPT-2005-0033). 

790.50 (c)(1)(iv)- Chemical Substance Identity & Data:

Chemical Name: 2,4-Hexadienoic Acid, (2E, 4E)- (AKA Sorbic Acid)

CAS Number: 110-44-1

Percentage: 100%

Physical & Chemical Properties:

 Appearance: White Powder

 Odor: None

 Vapor Pressure @ 20o C: <0.001 hPa

 Density @ 20o C: 1.2 g.cm3

 Solubility in water @ 20o C: 1.6 g/l
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

 pH (1.6 g/l) @ 20o C: 3.3

 Melting Point: 132-135o C

 Boiling Point: 170o C (decomposition)

 Self-Igniting: >120o C (wire basket)

 Flash Point: Not Applicable

 Partition Coefficient: 132 log POW @ pH 

Stability & Reactivity:

 Stability: Stable

 Hazardous Polymerization: Will not occur.

 Incompatibility: Avoid contact with oxidizing agents.

 Hazardous Thermal Decomposition Products: Thermal decomposition will produce 

oxides of carbon.

Sorbic acid is regulated by the Food, Drugs and Cosmetics Act (21 CFR 182.3089) and is rated as 

Generally Regarded as Safe (GRAS).

790.50 (c)(1)(v)- Study Protocol:

Testing will follow procedures as defined within ASTM E 1218-04, Standard Guide for 

Conducting Static Toxicity Tests with Microalgae as required under the EPA Final Rule.

Chronic toxicity testing on the microalgae species Pseudokirchneriella subcapitata will be 

conducted. Prior to instituting a full scale test, range finding testing as described in the ASTM 

Method will be conducted to determine an appropriate dilution series for the full scale test.

Full scale testing will be conducted with a control and five concentrations with each 

concentration containing four replicates. These tests will produce statistical endpoints of an 

IC50 (concentration that causes 50% reduction in growth) and NOEC/LOEC (No- and LowestObserved-Effect-Concentration). A reference toxicant test will also be conducted to verify 

organism health. All results will be summarized in a report including the required QA/QC 

information and copies of the raw data sheets.
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

790.50 (c)(1)(vi)- Schedule of Testing Completion:

 June 30, 2014: Representative sample of Sorbic Acid was collected from Brenntag stock 

material and sent to GEI Consultants for applicable testing.

 Q4- 2014: GEI Consultants will complete applicable testing during Q4 of 2014.

 January 2015: Testing results and applicable lab supporting documentation is scheduled 

for completed by the end of January.

 February 2015: Brenntag North America will submit analytical findings to the EPA.