Attachment I: Suspension Report – Product List 

List of products: 

EPA Reg. No. 6390-25 – Vikol THP 

Vikon Chemical Company, Inc. 
ATTACHMENT II – REQUIREMENT LIST

Outstanding Product Chemistry And Acute Toxicity Data:

830.1550 Product identity and composition

830.1600 Description of materials used to produce the product

830.1620 Description of production process

830.1650 Description of formulation process

830.1670 Discussion of formation of impurities

830.1700 Preliminary analysis

830.1750 Certified limits

830.1800 Enforcement analytical method

830.6302 Color

830.6303 Physical state

830.6304 Odor

830.6313 Stability to normal and elevated temperatures, metals, and metal ions

830.6314 Oxidizing or reducing action

830.6315 Flammability

830.6316 Explodability

830.6317 Storage stability

830.6319 Miscibility

830.6320 Corrosion characteristics

830.6321 Dielectric breakdown voltage

830.7000 pH

830.7050 UV/Visible absorption

830.7100 Viscosity

830.7200 Melting point/melting range

830.7220 Boiling point/boiling range

830.7300 Density/relative density

830.7370 Dissociation constants in water

830. 7550 Partition coefficient (n-octanol/water) shake flask method

830. 7560 Partition coefficient (n-octanol/water), generator column method

830.7570 Partition coefficient (n-octanol/water), estimation by liquid chromatography

830.7840 Water solubility: Column elution method, shake flask method

830.7860 Water solubility, generator column method

830.7950 Vapor pressure

870.1100 Acute Oral Toxicity

870.1200 Acute dermal toxicity

870.1300 Acute inhalation toxicity

870.2400 Acute eye irritation

870.2500 Acute dermal irritation

870.2600 Skin sensitization
ATTACHMENT III - EXPLANATORY APPENDIX

On October 5, 2011, the Agency issued the Phase 5 Reregistration 

Eligibility Decision (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 products

containing triclosan (irgasan) used as an active ingredient to develop and submit 

certain data. The data/information were 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 Decision 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 

signed 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 in February 2012 to follow-up 

concerning the overdue data. Allen Whisnant of Vikon stated that Vikon

intended to voluntarily cancel their affected product (EPA Reg. No. 6390-25) but 

needed additional time for management discussions. In July, 2012, Vikon stated 

that the paper work still needed to be compiled. On October 9, 2012, over a year 

following issuance of the PDCI , Steven Snyderman of the Agency e-mailed Allen 

Whisnant of Vikon to request another status update concerning the expected 

request for voluntary cancellation. At that time Vikon stated they would be 

supporting the product. At Vikon’s request, on October 23, 2012, EPA supplied a 

courtesy duplicate copy of the PDCI 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 requested

information concerning 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 information 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 on 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.