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OCSPP OPPT EAD 

1200 Pennsylvania Ave. NW 

Washington, DC 20460 

202.564.8251 

Pages: 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

VIA FACSIMILE: 201-437-4801 

April 19,2012 

Attention: Glenn Merritt (201-437-4000) 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Subject: Follow-up to fax transmission of 4/13/12 (ePMA removal ofCBI claims regarding 

identified studies) 

Dear Mr. Merritt: 

This is sent to you pursuant our conversation of several minutes ago. In Larry Robinson's fax of 

April 13th while there is a waiver of confidential business information (CBI) claims in the 

identified studies there is a an assertion of copyright protections and some additional text that 

provides in part ... "Reproduction, reference, summarization, retransmission or other use of this 

copyrighted document. .. including electronic transmission, using the internet or email .... 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 per the 

TSCA activity are not to be made available in an Agency e-docket (electronic docket) or be 

included in EPA websites among the collection of TSCA health 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 of non-CBI materials submitted by entities subject to TSCA 

regulations (including the posting of such materials on government websites) and submitted by 

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 of the studies. 

Can you please confirm CPMA's intent? Many thanks. 

Scott M. Sherlock, Attorney Advisor 

Environmental Assistance Division 

Office of Pollution Prevention and Toxics 


340 Commercdal Avenue

Now runsick. N.J. 08901 PRIMARY SKIN IRRITATION 201.645-1704 _ _ _ _ _ _ _ _ _ _

f l -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.: E 10202-1

CDDATE RECEIVED: February 2, 1981

ANIMALS: Six New Zealand Albino Rabbits

from Cedar Knoll Farms.

QUALITY ASSURANCE REFERENCE: 123 ,.A 

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:

0 Primary Skin Irritation. FHSLA 16 CFR 1500. Six healthy rabbits were ~ each uniquely identified and then prepared by clipping the trunk free

of hair. Two 2.5 cm 2 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

dontum of Inemond -

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 *As surance 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 irritant
340 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.