Attachment I : Suspension Report – Product List

List of products:

EPA Reg. No. 6390-25 – Vikol THP

Vikon Chemical Company, Inc.A TTACHMENT II

– REQUIREMENT LIST

Outstanding Product Chemistry And Acute Toxicity Data:

830.1550 Product ident ity a n d composition 830.1600 Description of materials used to produce the product 830.1620 Description of production process 830.1650 Description of formulat i on process 830.1670 Discussion of formation of im p urities 830.1700 Preliminary analysis 830

. 1750 Certified l imits 830

. 1800 Enforcement analyt ic al method 830.6302 Color 830.6303 Physical state 830.6304 Odor 830.6313 Stability to norma l and elevated temperatures, metals

, and metal ions 830.6314 Oxidizing or reducing a c tion 830.6315 F l ammabi l ity 830.6316 Explodability 830.63 1 7 Storage stability 830

. 6319 Miscibility 830

. 6320 Corrosion characteristics 830

. 6321 Dielectric breakdown vo l tage 830.7000 pH 830.7050 UV /V isible absorpt ion 830.7100 Viscosity 830.7200 Melti n g poin t/ melting range 830.7220 Boiling point/ boiling range 830.7300 Density/relative density 830

. 7370 Dissociation constants in wa t e r 830. 7550 Partition coefficient (n

- octano l / water) shake flask method 830. 7560 Partition coefficient (n

- octanol/water), generator column method 830

. 7570 Partition coefficient (n

- octano l/ wate r )

, est im ation by li qu id chromatography 830.7840 Water solubility: Column elution method, shake flask method 830

. 7860 Water sol u bility

, genera t or co l umn method 830.7950 Vapor pressure 870

. 1100 Acute Or al Toxicity 870.1200 Acute dermal toxicity 870.1300 Acute inhalation toxicity 870

. 2400 Acute eye irritation 870.2500 Acute dermal irritation 870.2600 Skin sensitizationATTACHMENT III

- EXPLANATORY APPENDIX

On October 5, 2011

, the Agency issued the Phase 5 Reregistration Eligibility D ecision (RED) Product Data Call

- In Notice pursuant to sections 3(c)(2)(B) and 4(g)(2)(B) of FIFRA which required the registrants of prod uct s containing triclosan (irgasan) used as an active ingredient to develop and submit certain data. The data/information w ere determined to be necessary to satisfy the reregistration requirements of section 4(g). Failure to comply with the requirements of a Phase 5 Reregistration Eligibility D ecision Product Data Call

- In Notice (PDCI) is a basis for suspension under section 3(c ) ( 2 ) ( B) of FIFRA.

Vikon Chemical Company, Inc. (Vikon) received the triclosan RED/PDCI

, as evidenced by the US Postal Service domestic return receipt card which was si gned and dated on November 1, 2011

. The 90

- day response to the PDCI was due on January 5, 2012 but was never received by the Agency

. Vikon was contacted by phone by Steven Snyderman i n February 2012 to follow

- up
c o n cerning the overdue data. Allen Whisnant of Vikon stat ed that Vikon intended to voluntarily cancel th eir affected product (EPA Reg. No. 6390

- 25) but needed additional time for management discussions. In July

, 2012, Vikon stated that the paper work sti ll needed to be compiled. On October 9, 2012, over a year following issuance of the P DCI , Steven Snyderman of the Agency e

- mailed Allen Whisnant of Vikon to request a nother status update concerning the expected request for voluntary cancellation. A t th at time Vikon stated they would be support ing the product . At Vikon’s request, on October 23, 2012, EPA supplied a courtesy duplicate copy of the P DCI to Vikon

, but also stated that all of the PDCI deadlines remained as timed from when Vikon received the PDCI in 2011 and that no extensions had been granted. On January 16, 2013, the Agency sent Vikon another email stating that the 90

- day response to the PDCI and the studies required by the PDCI remained overdue. On January 21, 2013

, Vikon request ed inform ation c on cerning data sharing options , to which the Agency responded

. On January 22, 2013 , the Agency sent Vikon a letter in which it stated that the product was not in compliance with the PDCI and that, unless Vikon complied by sending the required infor mation within ten days following its receipt of the Agency’s letter, a Notice of Intent to Suspend would be issued. Vikon received the January 22, 2013 letter o n January 28, 2013, as evidenced by a United States Postal Service domestic return receipt card , which was signed and dated by William T. Salssori. To date there has been no response from the registrant.

To date, the 90

- day response, 8

- month response, and the product specific data required for this product have not yet been received by the Agency

. Therefore, this Notice of Intent to Suspend is being issued.