Brenntag North America, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

March 3, 2015

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) Revised Study 

Plan

Dear Mr. Lewis,

On February 17, 2015, Brenntag was notified by GEI Consultants that they are unable to 

perform the testing per EPA prescribed protocol. Therefore, Brenntag has contracted with 

Smithers Viscient in Wareham, Massachusetts to conduct the applicable testing. 

Attached is a revised study plan that reflects the change in lab services.

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: Smithers Viscient LLC

790Main Street

Wareham, MA 02571

Project Manager: Katherina Softcheck, Study Director

Telephone: (508) 295-2550

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

Ms. Softcheck is a Biologist II, specializing in Ecotoxicology with Smithers. Smithers Viscient has 

performed standard guideline and higher-tier environmental studies for over 40 years.

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

 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 
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100

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.

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

 Week of February 23, 2015: Representative sample of Sorbic Acid was collected from 

Brenntag stock material and sent to Smithers Viscient for applicable testing.

 Week of March 9, 2015: Smithers Viscient will complete applicable range find testing.

 Week of March 23, 2015: Smithers Viscient will begin definitive testing.

 May 2015: Smithers Viscient to issue testing report and Brenntag North America will 

report to EPA.
Brenntag, Inc.

5083 Pottsville Pike

Reading PA 19612

Phone: (610) 926-6100