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

- of

Intent

- To

- Test and Study Plan

Dear Mr. Lewis,

In reference to your correspondence received on April 25, 2014, Brenntag North America, Inc., (Brenn tag) 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 Hi gh 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 A cid 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 let ter

- 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 i nto 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

- 04 e1

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: Br enntag 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

- 0268Brenntag, Inc.

5083 Pottsville Pike Reading PA 19612
Phone: (610) 926

- 6100 790.50 (c)(1)(D)(1)

- Testing Facility & Project Manager Information:

T esting 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 operati ons 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 aquat ic 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

- Hexad ienoic Acid, (2E, 4E)

- (AKA Sorbic Acid)
CAS Number: 110

- 44

- 1 Percentage: 100% Physical & Chemical Properties:

 Appearance: White Powder

 Odor: None

 Vapor Pressure @ 20 o C: <0.001 hPa

 Density @ 20 o C: 1.2 g.cm 3

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

5083 Pottsville Pike Reading PA 19612
Phone: (610) 926

- 6100  pH (1.6 g/l) @ 20 o C: 3.3

 Melting Point: 132

- 135 o C

 Boiling Point: 170 o C (decomposition)

 Self

- Igniting: >120 o C (wire basket)

 Flash Point: Not Applicable

 Partition Coefficient: 132 log POW @ pH

Stability & Reactivity:

 Stability: Stable

 Hazardous P olymerization: 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 Fin al 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 dil ution 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
IC 50 (concentration that causes 50% reduction in growth) and NOEC/LOEC (No

- and Lowest

Observed

- 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 cop ies 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 E PA.