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# rI OCSPP OPPT EAD 1200 Pennsylvania Ave. NW Washington, DC 20460 202.564.8251

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## - ntUNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D
.C., 20460



### VIA FACSIMILE: 201-437-4801 April 19,2012 Attention: Glenn Merritt (201-437-4000) OFFICE OF PREVE NTION, PESTICIDES AND TOXIC SUBSTANCES



### Subject: Follow-up to fax transmission of4/13/12 (ePMA

### removal ofCBI claimsregarding identified studies) 

### DearMr. Merritt: This is sent to you pursuant ourconversation ofseveral minutes ago. In Larry Robinson's fax of April 13th 

### while there is a waiver ofconfidential business information (CBI) claims in the identified studies there is a an assertion ofcopyrightprotections and some additional text that provides in part ... "Reproduction, reference, summarization, retransmission or other use ofthis copyrighted document.
..including electronic transmission, using the internet oremail
....is strictly prohibited
...." While we understand the basis for the copyright protections, we have a concern that the language in the fax might be interpreted to mean that ePMA is asserting that the studies submitted perthe TSCA activity are not to bemade available in an Agency e-docket (electronic docket) orbe included in EPA websites among the collection ofTSCAhealth and safety studies. We are thinking that the identified limitations noted in the fax are not intended to apply to EPA's normal procedures for the handling ofnon-CBI materials submitted by entities subject to TSCA regulations (including the posting ofsuch materials ongovernment websites) and submittedby such entities in order to comply with a TSCA requirement, but are rather intended to limit entities outside the government from the unauthorized use or appropriation ofthe studies. Canyou please confirm CPMA's intent? Many thanks.

Scott M. Sherlock, Attorney Advisor Environmental Assistance Division Office ofPollution Prevention and Toxics340 Commercdal Avenue Nowrunsick.N.J.08901 

### PRIMARY SKIN IRRITATION 201.645-1704

_ _ _ _ _ _ _ _ _ _ 

# fl -February-2-3,1981

REPORT NO.: 

### T-150 DATE OF TEST: February 

### 6, 1981 CLIENT: BASF WYANDOTTE CORPORATION > Wyandotte, Michigan 4.8192
PRODUCT IDENTIFICATION: Code BT-7150, Alkali Blue R Powder Lot #714.1-8033 PRODUCT DESCRIPTION: A dark blue powder. PSL NO.: E10202-1 CDDATE RECEIVED: February 2, 1981 ANIMALS: Six New Zealand Albino Rabbits from Cedar Knoll Farms. QUALITY ASSURANCE REFERENCE: 

## ,.A 123 SNOTEBOOK NO.: 81-1; page 1027 .G ENVIRONMENTAL CONDITIONS: C During the test period the rabbits were individually housed in stainless M steel wire bottomed cages in an environmentally controlled room. The C temperature was kept at 68 - 720F. The rabbits were exposed to 12 hours C of fluorescent light daily. Feed and water were provided ad-libitum. PROCEDURE: Primary Skin Irritation. FHSLA 16 CFR 1500. Six healthy rabbits were 

# 0

~ each uniquely identified and then prepared by clipping the trunk free of hair. Two 2.5 cm2 gauze patches were placed over intact skin and abraded skin on each rabbit. 0.5 gram* of the test material was placed under each patch. The patches were secured in place with adhesive tape. The entire trunk of each animal was wrapped with a rubberized elastic cloth to retard evaporation and as an aid in maintaining test patch position. The rabbits were then immobilized in head stocks for 24 hours, after which time the patches were removed. All test sites were washed to prevent further exposure. Skin lesions were evaluated at 24 and 72 hours and scored in accordance with FHSLA 16 CFR 1500.

The test material was mixed with corn oil I + form a 40% paste; and 1.3g of the prepared paste was placed under each patch.dO . 

### Z-X-Page 2 

# _pr~d ~ 

# 5d YCIL 

# ICI5Jb Report No. T-15 of dontum Inemond

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OBSERVATIONS: Not remarkable.

CONCLUSION: The test material is considered a mild primary skin irritant.

Catherine Wo, Ph.D. Ralph Sh iro. Ph.D. Study Supervisor Director Toxicologist

7~A~23 9i Arlehe Stern Date Qua] i ty *Assurance Uni1t

# prodPuct~ saeylb Page 3 * vwn .~nutituoi n~rna~nelReport No. 

### T-1504. RESULTS: Average Exposure Exposure

Time Unit 

### Erythema and Eschar Formation hours value intact Skin 24. 1.00 Do 72 

### 0.33 Abraded Skin 24 .1 Do 72 

### 0.33 Subtotal 2.83 Edema Formation Intact Skin 24. 0.83 Do 72 

### 0.33 Abraded Skin 24. 1.00 Do 72 

### 0.17 Subtotal 2.33 Total 5.16 Primary Irritation Score: 1.29 Primary Skin Irritation Score: 0.5 -non-primary irritant 0.6 - 2.0- mild primary irritant 2.1 - 5.0-moderate primary irritant S 5.1- severe primary irritant340 Commercial Avenue *~EU Now Bruns~wick. N.J. 08901 201-545-1704

FHSA PRIMARY SKIN IRRITATION Evaluation of Skin'Reactigns Value Erythema and eschar formation: No erythemna.............................................. 0 

# 0Very slight erythema (barely perceptible) ..................1 Well-defined erythema .................................... 2 Moderate to severe erythema 

### ............................... 3 

# CU Severe erythema (beet redness) to 51light 

### eschar formation (injuries in depth) .............

### 4 Edema formation: 

# INo edema ................................................. 0 

# O0Very slight edema (barely perceptible) .................... I Ca Slight edema (edges of area well defined by definite raising) ........................ 2 G Moderate edema (raised approximately 1 millimeter) 

### ........ 

### 3 Severe edema (raised more than 1 millimeter and extending beyond the area of exposure ... 

### 4 AR The "value" recorded for each reading is the average value of the V six or more animals subject to the test.