U.S. ENVIRONMENTAL PROTECTION AGENCY 


3EPA 


\\ h"fl 

u.mpk:tl.!d 


".... nd thl'< 


hlJlnl<l 

iEnter the total number ofP.ages 

I 

: 

PREMANUF ACTURE 

NOTICE 

FOR NEW CHEMICAL SUBSTANCES Comoany Sanitized 

inthePremanufactureNot~ic~·e~·________I~____~~~~~~1r:;;H~~~r.r;ry;~~~-J~~,.lI~~~a-~"~Ma~~~~I\~t-i:-t~~~~~~~ 

You must provide all information requested in this form to the extent that it is known to or reasonably ascertainable by you. 

not have actual data. 


Before you complete this form. you should read the "Instructions Manual tor Premanuiactllre Notification" (the Instructions Manual is available from the Toxic 


Substances Control Act (TSeA) Information Service by calling 202-554-1404. or faxing 202-554-56(3) 


If" user iee has been remitted for this notice (40 CFR 7(J0.45), indicate in the boxes above the TS·user iee identification number you have genemted. Remember, 


your user fee ID number must also appear on your corresponding fee remittance. which is sent to EPA. HQ Accounting Opemtions Bmnch (PM-226), P.(J 


360399M. Pittsburgh, PA 15251-6399, Attn. TSeA Lser iee. 


Pa" III~~ LIST OF ATTACHMENTS 

Attach additional sheets ifthere is not enough space to answer a question fully. Label 

each continuation sheet with the corresponding section heading, In Part nt list these 

attachments. any test data or other data and any optional inlormation included in the 

norice. 

OPTIONAL L"'FOR1vlATION 

You may include any information that you want EPA to com;jder in evaluating the new 

substmce, On page 11 of[hi s form, space ha:;. been provided for you to described 

poltution prevention and recycling intormation you may have regarding the new 

suhstance·, 

So-callee "binding" boxes are included throughout this form for you to indicate your 

wiHingness to be hound to cenain statemenU you make in this section. suer as use. 

production vojume~ prorectlve equipment, This option is intended to reduce delay::; 

that routinely accompany the development of consent orders or Significant '!'iew l;se 

Rule,. Except in the ca« ofexemption appiicatlOns (such as TMEA, LVE, LOREX) 

where certain information provided in such notification is hinding on the submitter when 

the Agency approves the exemption application, checking a binding box in thIS notice 

does!)Qt by itselfprohibit the submitter from later deviating irom the intormation textep: 

chemical identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as contidentiaL To assert a claim on the 

torm. mark (Xl the contidential box next to the intormation thaI you claim as 

contidentiaL To assert a claim in an attachment. circle or bracket the InfOrmation vou 

claim a:; confidentiaL If you c~aim iniormatlQll.jn the notices as..contideI1~ial. you.~ust 

also pro\'ide ~ sanitize~L~rsion ..9fthe nqJice. (in~J.!ldi:Qg1l1t~chITl~m. For additional 

insrructions on daiming intormation as contidentiaL read the Instructions ManuaL 

~ Mark (x) if any information in this notice is claimed as confidential. 

PUBLIC NON- CONFIDENTIAL VERSION 

Copy 1 of 1 

rest Data (CheCK Below any included in this notIce) 

Environmental tate data 0 Yes Other data 0 

Health ell'ects data 0 Yes Risk as.sessments 

Environmental eftects data 0 Yes Structure/activity re tarionshtps 

Physical/Chemical Properties' fiSI Yes Test data not in the posseslllOD 

or control ofthe 5uhmltter 

A physical and chemical propenies. "vorksheer is located on the last page ofthis torm. 

TYPE OF "OTICE (Check Only One) 

~ 

D 


D 


D 

D 

D 

D 

PMN (Premanufacture Kotice) 


NTER.\.fEDlA TE PMN (subm:ned in sequence 'With tinal product PMN) 


~1JN (Signillcant Xew Use Notice) 


TMEA (Test Marketing Exemption Applic"cion) 


LVE (LowVoiume Exemption) 40CFR 723.'-;0(c)(I) 


~ 

LOREX (Low Release/Low Exposure Exemption)@ 4@R 723.50(0)(1) 

LVE Modification D 

IS THIS A CO"lSOLlDATED P~1K? D 

# of chemicals 

(Prenotice Communication # required, enter 

...." 

LOREX MOriiiiion 0::;0 

_.-< "Up, 

"";JCJ Yes N -If'l1 \..::J ::r:< 

On page 3) !'! .:-:' rn

a O 

o 

0Li~ 1)/0 

(\(12~ 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 771 0·25. 

/ 

Public reporting burden tor this collection of information is estimated to average 110 hours per response, including time for reviewing 

instructions, searching existing data sources, gathenng and matntamtng the data needed, and completing and reVIeWIng the collectIOn of 

information. Send comments regarding the burden estimate or any other aspect ofthis collection of in/ormation, including suggestions for 

reducing this burden, to Chief, Information Policy Branch, PM-223, US. Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 

20460; and to the Office ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

CERTIFICATION 

1 certify that to the best of my knowledge and belief: 

1. 	 The company named in Part 1, section A, subsection 1 a of this notice form intends to manufacture or import for a 

commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, 

Section B. 

2. 	 All information provided in this notice is complete and truthful as ofthe date ofsubmission. 

3. 	 1 am submitting with this notice all test data in my possession or control and a description of all other data known to or 


reasonably ascertainable by me as required by §720.50 of the Premanufacture Notification Rule. 


Additional Certification Statements: 

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification 


statement that applies: 


~ The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or 


o The Company named in Part I, Section A has remitted the fee ofSl 000 for an Intermediate PMN (defined @ 40 CFR 


700.43) in accordance with 40 CFR 700.45(b), or 


o The Company named in Part I Section A is a small business concem under 40 CFR 700.43 and has remitted a fee of $1 00 

in accordance with 40 CFR 700,45(b). 

If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(I) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification 

statements: 

o The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial 


purposes, other than in small quantities solely for research and development, under the terms of40 CFR 723.50. 


o 	The manufacturer is familiar with the terms ofthis section and will comply with those terms; and 

o 	The new chemical substance for which the notice is submitted meets all applicable exemption conditions. 

o Ifthis application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence 

manufacture of the exempted substance for commercial purposes within 1 year of the date oftbe expiration ofthe 30 day 

review period. 

Tbe accuracy of tbe statements you make in tbis notice sbould renect your best prediction of tbe anticipated facts regarding tbe cbemical substance 

described berein. Any kno"'ing and willful misinterpretation is subject to criminal penaUv pursuant to 18 USC 1001. Confidential 

Signature and title of Authorized Official (Original Signalure Required) Date 

.s~crt.I\/'A- E.. ~ S' /1" I 0'-

Sharronn E. Etter, Director of Regulatory Affairs 

02 

Part I-GENERAL INFORMATION 

Section A - SUBMITTER IDENTIFICAnON 

Mark 0 the "Confidential" box next to any subsecrion you claim as confidemial 	 Confila. 	Person 


Submitting 


Notice (in U.S.) 


b. 	 Agent (if 


applicable) 


c. 	 If you are 'U~'HUUU'.~ 

Joint Submitter (if 

applicable) 

2. 

Contact (in 

U.S.) 

3. 

number, 

. 

5. 

L Manufacture 2. Import 6. Type ofNotice - Mark (X) Only Only 3. 0 Both

o Binding Option 0 Binding Option 

Mark (X) Mark (X) 

Name ofauthorized official 

A Division of W 

Mailing address (number and street) 

City, State, ZIP Code 

as part ofa joint 'U{)JW»lon, mark (X) this 

Name of authorized 

Company 

Mailing address and street) 

Code 

Name ofauthorized official 

Sharronn E. Etter 

Company 

Adrian, MI, 49221 

Ifyou have had a prenotice communication (PC) concerning this 

notice and EPA assigned a PC Number to the notice, enter the .. 

you an exemption apIJll<.;:allCID 

chemical substance covered by this notice, enter the exemption 

Telepbone 

number assigned by EPA. Ifyou previously submitted a PMN " .. Ifyou have submitted a notice ofBona fide intent to manufacture 

or import for the cbemical substance covered by this notice, enter 

the notice number assigned by EPA. III' 

Position 

Director 

elepbone 

Mark (X) 

ifnone 

if none 

Mark (X) 

.. 

Mark (X) 

ifnone 

III' 

.. 

EPA FORM 7710-25 (Rev. 5-95) 	 Replaces previous editions ofEPA Form 7710-25. 

03 
Part I - GENERAL INFORMA nON - Continued 

Section B •• CHEMICAL IDE~TITY INFORMATIO~: You must provide a currently correct Chemical Abstracts (CA) name ofthe substance based on 

the ninth Collective Index (9CI) ofCA nomenclature rules and conventions. 

Mark (X) the "Confidential" box next to any item you claim as confidential 

Complete either item I (Class I or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. 

If another person will submit chemical identity information for you (for either Item I or 2). mark (X) the box at the right. ConfiIdentify the name, company, and address of that person in a continuation sheet. .. 0 dential 

1. Class I or 2 chemical substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

a. 	 Class of substance· Mark (X) 0 Class I or 2 0 Class 2 

b. 	 Ch name correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. 

For Class I substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must 

be provided, which ever is appropriate based on CA 9CI nomenclamre rules and conventions). 

c. which method you used to develop or obtain the specified chemical identity information reported in this notice: 

o 	 Method I (CAS InveDlory Expert Service a copy of the Identification 0 Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submi to this 

and CAS Registry Number (ifa number already exists for the substance) 

CAS# 

e. 	 For a class I substance, a complete and correct SlfUcmre diagram a class 2 (I) st the 

precursor substances with their respective CAS Registry Numbers. (2) Describe the namre of the reaction or process. (3) Indicate the 

range ofcomposition and the typical composition (where appropriate). (4) Provide a correct representative or partial chemical strucmre 

diagram. as complete as can be known. if one can be reasonably ascertatned. 

NOT APPLICABLE 

o Mark (X) this box ifyou attach a continuation sheet. 

04 

The currently correct Chemical Abstracts 

Part I - GENERAL INFORMATION -- Continued ~Se-c-d-o-D-B-----C-H-E-M--IC~'A-L~ID~E~N=T=IT=\~'~I~N=F~O=R=M7A~T~IO~N~---C~ondnued 

Confidential 

2. Polymers (For a definition of polymer, see the Instructions Manual.) 

a. 	 Indicate the number-average weight of the lowest molecular weight composition ofthe polymer you intend to manufacture. 


Indicate maximum weight percent oflow molecular weight species (not including residual monomers, reactants, or solvents) below 500 and 


below 1.000 absolute molecular weight ofthat composition. 


Describe the methods of measurement or the basis for your estimates: GPe 0 Other 0: (SpecifY) 

i) lowest number average molecular weight: 

ii) maximum weight % below 500 molecular weight: 


iii) maximum weight % below 1000 molecular weight: 


attach a continuation sheet . 

You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the 

"Confidential" box next to any item you claim as confidential 

(I) 	 Provide the specific chemical name and CAS Registry Number (ifa number exists) ofeach monomer or other reactant used in the manufacture of 

the polymer. 

(2) 	 Mark (X) this column if entry in column (l) is confidential. 

(3) 	 Indicate the typical weight percent of each monomer or other reactant in the polymer. 

(4) 	 Mark (X) the identity column ifyou want a monomer or other reactant used at fWO weight percent or less to be listed as part of the polymer 

description on the TSCA Chemical Substance Inventory. 

(5) 	 Mark (X) this column if entries in columns (3) and (4) are confidential. 

(6) 	 Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for 

commercial purposes. 

this column if is confidential. 

Confi- Typical 

% 

% 

% 

% 

obtained from CAS Inventory Expen Service must be submiued as 


as attachment to See Attachment II 


d. 	 name for the polymer that is consistent TSCA lnventory listings for similar pOlyrnel:s. 

e. a correct representative or partial chemical structure diagram, as 	 one can be reasonably ascertained. 

EPA FORM 7710-25 (Rev. 5-95) 	 Replaces previous editions ofEPA Form 7710-25. 

05 

identified in subsection I or 2. 

None 

o Mark (X) this box ifyou attach a continuation sheet. 

5. Trade names for the new chemical substance identified in subsection I or 2. 

SILRES EP 100 

o Mark (X) this box ifyou attach a continuation sheet. 

6. Generic chemical name If you you must provide a generic name for your substance that reveals 

the specific chemical identiry of the new chemical substance to the maximum extent possible. Refer to the 

TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. 

Not Applicable 

% 

Number ifavailable. 

Byproduct 

(l 

Methanol 

Mark (X) this box ifyou attach a continuation sheet. 

CAS Registry Number 

(2 

67-56-1 

Confidential 

(a) 	 IdentiiY each impurity that may be reasonably anticipated to be presem in the chemical substance as manufactured for commercial purpose. Provide the 

CAS Registry Number if available. If there are unidentified impurities. enter "unidentified." 

the . % of each .. 	 %. 

% 

attach a cominuation sheet. 

Describe any byproducts resulting from tbe manufacture, processing, use, or disposal oftbe new substance. Provide the CAS Registry 

EPA FORM 7710-25 (Rev. 5-95) 	 Replaces previous editions ofEPA Form 7710-25. 

06 
Part I -- GENERAL INFORMATJON -- Continued 

I Section C -- PRODUCTlON, IMPORT, AND USE INFORMATION: 

I Mark (X) the "Confidential" box next to any item you claim as confidential. 

1. Production volume ­ Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum 

production volume for any consecutive 12-month period during the first three years ofproduction. Estimates should be on 100010 new chemical 

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 

~O,OOO kg/yr, specify the volume and mark (x) in the binding box. Ifgranted, you are bound to this volume 

• Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Confi- Binding 

I 

(l 00% new chemical substance basis) (100% new chemical substance basis) dential Option 

Mark (x) I

I 

i I 

2. Use Information -- You must make separate confidentiality claims for the description ofthe category ofuse, the percent of production volume 

devoted to each category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item 

you claim as confidential. 

a. (1)­ Describe each intended category of use ofthe new chemical substance by function and application .. 

(2) -­ Mark (X) this column ifentry column (l) is confidential business information (CBI). 

(3) ­ Indicate your willingness to have the information provided in column (l) binding. 

(4) -­ Estimate the percent oftotal production for the first three years devoted to each category of use. 

(5) -­ Mark (X) this column ifentry in column (4) is confidential business information (CBI). 

(6) -­ Estimate the percent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for 

commercial purposes at sites under your control associated with each category ofuse. 

(7) -­ Mark (X) this column if entry in column (6) is confidential business information (CBI). 

(8) Indicate % of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate 

your willingness to have the use type provided in (8) binding. 

(9) -­ Mark (X) this column if entryfies) in column (8) is (are) confidential business information (CBI). 

Category of use (I) I CB! Binding I Produc- CB! -I %in I CBI i % ofsubstance expected per use ICBl 

Option , tion % Form­ (S) 

(by function and application i.e. a dispersive dye Mark (x) ulation I Site- Con-· Indus- Com­ ! Binding 

for finishing polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercial Option (9) I 

Binder for silicone coatings X I X 

I I 

I I ! 

: I 

% % i

I l I 

%, % : ! 

%1 T I 

% I l i 

I i I ! 

1 1 i I 

% % 

I I i I I 

I %1 % I i I ! 

I %1 % I I I 

I 

I • If you .h~veidentified ~ "consumer" use. pleas~ provide on a continuation sheet a detailed des~ription ofthe use(s) of this chemical substa?ce In consumer products, I 


In addition Include estImates of the concentration of the new cheIDIcal substance as expected In consumer products and descnbe the cheIDIcal reactions b y which this 


substance loses its identity in the consumer product. 

C81Mark (X) this box if you attach a continuation sheet - Please See See Attachment 5. 

b, Generic Ifyou claim any category ofuse description in subsection 2a as confidential, enter a generic description ofthat category. Read the 

use Instructions Manual for examples ofgeneric use descriptions. 

description NONE 

o Mark (X) this box ifyou attach a continuation sheet 

3. Hazard Information -- Include in the notice a copy ofreasonable fucsimiJe of any hazard warning statement, label, material safety data sheet, or other 

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices 

for the safe handing, transport, use, or disposal ofthe new substance, List in part III hazard information you include. 

Binding 

Option 

Mark (x) 

C8l Mark (X) this box ifyou attach hazard information -. Please See Attachment 6. 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Form 7710-25. 

07 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

~ 

i Section A __ INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the «Confidential" box next 10 any item you 

claim as confidential I ~_o_~~l,~te section A for each type ofmanufacture, processing, or use operation involving the new chemical substance at industrial sites you 

• control. Importers do not have to complete this section for operations outside the U.S.; however, you may still have reporting requirements if 

, there are further industrial or use after' You must describe these See instructions manual 

1. Confiofthe site at which the will occur. dentia! 

Name 

Wacker Silicones, A Division of Wacker Chemical Corporation 

s (number and street) 

3301 Sutton Road 

City, County, State, ZIP code 

Adrian, Lenawee, MI, 49221 

If the same operation occur at more than one site, enter the number of sites. identifY the 


additional sites on a continuation sheet, and ifany ofthe sites have significantly different 


production rates or operations, include all the information requested in this section for those 


sites as attachments. 


b. 

1. Batch 

Maximum kglbatch (100% new chemical 

substance) I 

2. Continuous 

d. Process description Mark (X) to indicate your willingness to have your process description binding. 

Batches/year 

Batches/year 

(l) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails. 5S gallon 

drum, rail car, tank truck, etc.). 

(2) Provide the identity, the approximate weight (by kglday or kglbatch on a 100% new chemical substance basis), and entry point of all starting materials and 

feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot 

used daily or per batch.). 

(3) Identify by number the points ofrelease, including small or intermittent releases, to the environment of the new chemical substance. 

Ftavv materials 

vveighed and added to 

the reactor 

Sample 

OM 

OM 

Samples are stored and eventually 

sent for incineration 

I0 Mark (X) this box if you attach a continuation sheet. 

OM 

Methanol distilled 

and recycled 

Closed Fteactor 

OM 

Solvent clean out 

vvith xylene 

2 OM 

CM 

U sed so lvent is drummed and sent 

Product is 

packaged into 

220 kg drums 

Key: 

OM= Open Manual Process 

CM= Closed Manual process 

for incineration 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Fonn 7710-25. 

08 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER - Continued 

2. 	 Occupational Exposure -- You musl make separate confidentiality claims for the description of worker activity, physical form of Ihe new chemical substance, 

number ofworks exposed, and duration of activity, Mark (X) the "Confidential" box next to any item you claim as confidential. 

(I) -- Describe the activities (i.e, bag dumping, tote filling. unloading drums, sampling. cleaning, etc,) in which workers may be exposed 10 the subslance, 

(2) -- Mark (X) this column if entry in column (I) is confidential business information (CBI). 

(3) Describe any protective equipment and engineering controls used 10 protect workers. 

(4) and (6) Indicate your willingness to have the information provided in column (3) or (5) binding. 

(5) --Indicate the physical form(s) oflhe new chemical substance (e.g., solid: crystal, granule, powder, or dusl) and % new chemical subslance(ifpart ofa mixture) 

at Ihe time of exposure. 

(7) -- Mark (X) this column if entry in column (5) is confidenlial business information (CBI). 

(8) Estimate the maximum number of workers involved in each activity for all sites combined. 

(9) -- Mark (X) this column if entry in column (8) is confidential business information (CBI). 

I 

I 

(I0) and (II) -- Estimate the maximum duration 0 f . the acllVlty r. or any wor k er 10 hours per day an d days per year. 

(12) __ Mark (X) this column if entries in columns (10) and (II) are confidential business infonnation (CBij. 

Worker activity 

: 

CBI Protective Equipment! I Binding Physical forms($) BUldUlg I CBI #of IC~ Maximu duration CBI I m 

(i.e., bag dumping. filling drums) Engineering Controls Option and % new OptIOn I Workers I Hrs/day Dayslyr Mark (x) substance Mark (x) Exposed 

(2) I (9) (4) I (5) (6) (7) (10) (1) (3) (8) (11) I (12) 

Sampling from the reactor i Safety glasses, gloves ! I I 1 0.5 

I I I 

Reactor clean out I Safety.glasses, gloves I I 1 1 

I & respirator I I i 

Drumming of reactor clean Safety glasses, gloves l I 

I 1 1 1 

nllt ~olvent I & respirator I I 

Packaging of final product Safely glasses. gloves 

I I 

1 

I 

2 , 

I i i I , I i I 

i I I L 

~ark (X) this box ifyou attach a continuation sheet. 

3. Environmental Release and Dis posal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance 

released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. 

(I) -- Enter the number of each release point identified in the process description, pan II, section A, subsection Id(3). 

(2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch). 

(3) -- Mark (X) this column if entries in columns (I) and (2) are confidential business information (CBl). 

(4) --IdentifY the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration. POTW, or other(spedfY» to 

which the new substance will be released from that release point. 

(5) -- a. Describe control technology, if any. and control efficiency that will be used to limit the release of the new substance to the environment. For releases 

disposed of on land, characterize the disposal method and state whether it is approved for disposal ofRCRA hazardous waste, On a continuation sheet, for 

eacb site describe any additional disposal metbods that will be used and whetber the waste is sul:!ject to secondary or tertiary on-site treatment. b. Estimate 

the amount released to the environment after control technology (in kg/day). 

(6) -- Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CB!). 

(7) --IdentifY tbe destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or 

><PDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) ifthe POTW name or NPDES # is confidential business information (CBI). 

Release Amount of new substance I CBI! 

Media of I Control technology and efficiency (you may wish to optionally attach efficiency data) csr 

I Number released release 

0) (2a) (2b) 

(3) I 

e.g.md air Binding 

( 4) (Sa) Mark (X) (Sb) (6) 

1 0 Incineration 

I 

Hazardous waste incineration 0 

i : 

2 

I 

0 i 

I 

Incineration I Hazardous waste incineration 1 0 I 

I I i 

I I

i 

I 

i 

I 

I 

I 

(7) Mark (X) the D POTW provide narne(s) below: D Navigable D Other - SpecifY provide ><PDES # : CBI I 

destination(s) of waterway 

releases to water. 

: 

0 Mark (X) this box ifyou attach a continuation sheet. I 

09 

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing oruse operations involving the new chemical substance at sites you do not controL Imponers do not have to complete this 

section for operations outside the U.S.; however, you must repon any processing or use activities after impon. See the Instructions Manual. Complete a separate 

section B for each type ofprocessing. or use operation involving the new chemical substance. Ifthe same operation is performed at more than one site describe the 

typical o~eration common to these sites. IdentifY additional sites on a continuation sheet. 

1. Operation Description -- To claim information in this section as confidential, circle or bracket the specific information that you claim as confidential. 

(I) -- Diagram the major unit operation steps and chemical conversions, including interim storage and Iranspon containers (specifY - e.g. 5 gallon pails, 55 gallon 

drums, rail cars, tank trucks, etc). On the diagram, identifY by leiter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight 

(by kg/day or kg/batch, on an 100% new chemical substance basis), and entry point ofal! feedstocks (including reactants, solvents and catalysts. etc) and all 

products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Identify by number the points ofrelease, 

including small or intermittent releases, to the environment ofthe new chemical substance. (4) Please enter the # of sites (remember to identifY the locations of 

these sites 00 a continuation sheet): 

# ofsites 

'­ .-/ 

Pigments and other 

additives 

"----_/ 

---­Drwnmingof 

EP 100 final coating 

Transferred 

to mixer B ,.. D formulation 

(10-40%) 

'-------­ E 3 

.'\Closed 

Mixer 

A 1 C 2 

Sent to commercial 

customer (contractors) for 

spray application (10-40%) 

Drums are Mixer cleaned with a solvent, 

recycled drummed and sent for 

incineration 

I 0 Mark (X) this box if you attach a continuation sheet. 

I 

I 

I 

I 

2. Worker ExposurelEnvlronmentai Release 

(I) From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) -- Estimate the number of workers exposed for all sites combined. 

(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year. 

(6) -- Describe physical form of exposure and % new chemical substance (ifin mixture), and any protective equipment and engineering controls, if any, used to 

protect workers. 

(7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. 

(9) -- From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified. 

(10) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kglbatch). 

(12) Describe media ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other 

(specify) and control technology, iEany, that will be used to limit the release of the new substance to the environment. 

(J 4) -- Identify byproducts which may result from the operation. 

(3), (5), (8), (l1), (13) and (15) -- Mark (X) this column ifanv of the !>foceeding entries are confidential business information (CBl). 

Letter I # of I CBI I Duration CB1l Protective Equip. I I % in I CBI Release I AmoW11of TCBI 

of , Workers : ,of ,Engineering Controls! Fonn- Number I' New ' 

A~- , Exposed 1 ! Exposure ! Physical Form and % 'ulatlon Substance I' 

lVlty i I I new substance I' Released 

(I) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (lOa) (lOb) (It) ! 

A 1 I 1.0 I ~ Safety glasses, I 1 1 ! 0 I 

i I I gloves. i 

B 1 1.0 

CI 1 2.0 

D 1 I 1.0 

I 

L I

E , 

2 6.0 I j 

I 

I 

ISafety glasses, I 

gloves. I" 

i 

i 

I 

I 

l~afety glasses, gloves, 

land respirator 

NA 

ISafety glasses, gloves 110-40% 

• 1 

ISafety glasses, gloves, 110-40% 

'and resnirator 

NA NA 

2 0 

I 

NA NA 

i 

3 0 

l I 

: 

NA , 

i 

NA 

NEG i 

Media ofRelease 

& Control 

Technology 

CBI 

(12) (13) 

Drums are I 

recycled . 

NA 

(14) -- Byproducts: Some methanol 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Form 77 10-25. 

10 
OPTIONAL POLLUTION PREVENTION INFORMATION 


To claim information in this section as confidential circle or bracket the specific information that you claim as confidential. 

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce 

or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal 

of the Pl'v1N substance. Please include new information pertinent to pollution prevention, including source 

reduction, recycling activities and safer processes or products available due to the new chemical substance. 

Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological 

modification, process and procedure modification, product reformulation, raw materials substitution, and/or 

inventory control. Recycling refers to the reclamation ofuseful chemical components from wastes that would 

otherwise be treated or released as air emissions or water discharges, or land disposal. Descriptions ofpollution 

prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance 

with existing regulatory requirements and can be either quantitative or qualitative. The EPA is interested in the 

information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting 

of risks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure). In 

addition, information on the relative cost or performance characteristics ofthe PMN substance to potential 

alternatives may be provided. 

All information provided in this section will be taken into consideration during the review of this 

substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

examples. 

Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the 

volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a 

reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in 

the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical 

substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing 

substance that poses a greater overall risk to human health or the environment. 

1. The new substance provides high weather and chemical resistance to coatings. This reduces the 


need for frequent repainting of the underlying substrate. 


2. The new substance will replace applications, which require the use of urethane technology. 

Urethane based coatings can have small quantities of free isocyanates present. 

3. Our plan is to eventually eliminate the use of xylene as an additive thereby offering a low voe 

coating to replace the currently used high voe containing coatings. 

4. The new substance provides a coating composition in which the crosslinking mechanism is 

primarily an addition reaction, which renders fewer byproducts as compared to cold blended silicone 

polymers. 

J1 


i 
I 

I 

Part 1I1-- LIST OF ATTACHMENTS 

Attach continuation sheets for sections ofthe form and test data and other data (including physical/chemical properties and 


structure/activity information), and optional information after tills page. Clearly identify the attachment and the section ofthe form to 


which it relates, if appropriate. Number consecutively the pages ofthe attachments. In the column below, enter the inclusive page 


numbers of each attachment. 

Mark (X) the "Confidential" box next to any attachment name you claim as confidential. Read the lnstructions Manual for guidance on 

: how to claim any information in an attachment as confidential. You must include with the sanitized copy ofthe notice form a sanitized 

I version of any attachment in which you cla:::i:::m:..;i::.:n:.:.:fo::.:.rm-:=a.::ti7on~as:....c:.:·0:.::n:.::fi:.::d;.;;,en:::t;::ia:.:1.:.-..______--------.---:----:-----.--:::---::--1 

Attachment name 

I. 


: 2. CAS Inventory Expert Service Report, Part I, Section B, Subsection 2(c) 17-18 

19-20 

21-24 

5. Technical Bulletin, Part I, Section C, Subsection 2(a) 1 25-37 ~ I 

6. MSDS, Part I, Section C, Subsection 3 

17. 

I 

I 

l 

38-46 

47-56 

8. Human Health and Environmental Impact Assessment 57-58 

i I I 

~ I I 

I 

I ! 

I 

I I I 

I I 

o Mark eX) this box ifyou attach a continuation sheet. Enter the attachment name and number. 

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions ofEPA Form 7710-25. 

12 
PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

To assist EPA '5 review ofphysical and chemical properties data, please complete the following worksheet for data you provide and 

include it in the notice. IdentifY the property measured, the page of the notice on which the property appears, the value oftbe property, 

the units in which the property is measured (as necessary), and whether or not the propeny is claimed as confidential. The physical 

state ofthe neat substance should be provided. These measured propenies should be for the neat (100% pure) chemical substance. 

Propenies thaI are measured for mixtures or formulations should be so nOled (% PMN substance in _). You are not required 10 

submit this worksbeet; however, EPA strongly recommends that you do so, as it will simplifY review and ensure that confidential 

information is properly protected. You should submit this worksheet as a supplement 10 your submission oftest data. This worksheet 

is not a substitute for submission oftest data. I 

Propeny I Mark IPage Value r:asured 0 Conft- \ I Estimate dennal I I (Xl ii number Mark (X) I provided, (b) (c) \ 

I (a) (d) i ' (MorE) 

I 1 i 

I Physical state of neat substance X 43 (s) X (I) (~) I M I , I 

I 

I 

I Vapor pressure 

@ T em,l2erature °C Torr I i I I I I

Density/relative density glcm3

Solubility 


@ Temperature °C 
 X I 43 \ Insoluble E 

Solvent 

Dissociation constant 

Particle size distribution 

Octanol! water artition coefficient 

Henr 's Law constant 

Volitalization from water 

Volitalization from soil 

I 

L I 

~ng / sublimation temperature@~ torr ressure 

S ectra: C,H,Si-NMR 

I 

I 

pH@ concentration 100% X I

I 

43 I PH=7 i M I 

I 

I Flammability-Flash Point I X 43 39F E I

-I j Explodability I , , I 

I Adsorption I coefficient I

I 

: 

Other - Specify 


VOC : X 
 43 i 170 gil Calc. I

! Viscosity @2 25C I X 43 I 1 31.8 mPa*s M 

PH X 43 7 M I I I 

1 3 

ATIACHMENT 1 


- 14­
J 5 

16 

ATIACHMENT 2 


Part 1, Section B, Subsection 2(c)-Chernical Identity Information 

CAS INVENTORY EXPERT SERVICE REPORT 

-17 ­
-. . 

jJ[/Ui"\ L/\: "~U!:U';;;,~;, :)/(' ("\: /: iL~' -;~·...,;.L_}2b: !f Uw L -.. ~. "-- ......_... ~ .:../ -.;;.;;:;-, lJ \.;;:II 

A division of the Amcric;J.n Chemical Society Phone: 800-63 1-1884. 614-':.17-3870 

Fax: 614-447-3747 

E-mail: J.llsw~rs@c:<ls.org 

Internet hrtp:l/www.cas.ofr.ISupport/dicllt.html 

INVt:N'rORY EXP£RT SRRVn:l!: REPOR'T' 

IES-ORDER NUMBER: 65681 

Siloxanes and Silicones, 

di-Me, polymers with Ph sil:.esquioxanes, hydrolyzed. reaction products 

wit.h t. rime thoxy r3- (ox.iranylmcthoxy) propyl] silane 

mh':hiS box is checked, CAS has made (lOl'T6Ction(s:) marl~ed in red to M your lES order. Please make the same eorrectioll(S) to your l."li<ilJ l)C;liore 

submitting it to the EPA. 

1 8 
ATIACHMENT3 


-19­
20 

ATIACHMENT4 


- 21 ­
22 

23 

24 

ATTACHMENT 5 

Part 1, Section C, Subsection 2(a)-Production and Use Information 

TECHNICAL BULLETIN 

- 25­
ATTACHMENT 5 

Part 1, Section C, Subsection 2(a)-Production and Use Information 

TECHNICAL BULLETIN 

The new polymer, SILRES EP 100 will be manufactured in the USA by Wacker Silicones, A Division 

of Wacker Chemical Corporation located in Adrian, Michigan. SILRES EP 100 will be manufactured 

as a binder for use in formulating industrial coating formulations. The new substance will be blended 

with xylene (10-30%) and packaged in 440 lb. drums (220 kg). 

The new polymer will be formulated by industrial customers with other resins or crosslinkers which 

will react with the epoxy groups on the new polymer to form a silicone-epoxy coating. The amount of 

the new substance blended with the blending resin or crosslinker will depend on the desired 

performance of the finished coating. Typically the amount of the new substance in the formulated 

products will be 10-40%. Pigments, fillers, extenders and other additives may be added to enhance 

the performance of the finished coating. 

The finished coatings are sold to commercial contractors who will apply the coating by spraying. 

Please see the attached Technical Bulletin for further details. 

- 26­
SILRES EPIOO 


General Information 

SILRES EPIOO is a 

glycidoxy functional silicone polymer, 

which is used as a binder to increase UV 

resistance of coating formulations. This 

patented* technology combin~s the 

chemical resistance and adheSIon of an 

epoxy resin with the UV and high 

temperature resistance of a silicone 

polymer into one product. 

The high degree of epoxy functionality 

on the SILRES EP 1 00 make it ideal for 

developing low VOC (volatile organic 

compounds), room temperature curable 

coatings, which have little to no film 

shrinkage. The incorporation of a 

glycidoxy group directly to the silicon 

through a Si-C bond increases the 

resistance of the polymer to hydrolysis. 

Use Information 

SILRES EPIOO has a weight per epoxy 

of between 250-350gleq., which make it 

highly reactive with nuc1eophiles such as 

phosphoric acid, amine and amino 

functional curing agents. The degree of 

replacement of organic binder should be 

determined through laboratory 

evaluations. The replacement of the 

entire polymer side of 2 pack systems 

with the SILRES EPIOO will increase 

the UV resistance of the coating. 

, "'" 

Wacker Silicones 

The silicone polymer is only a portion of 

the coating formulation, and therefor by 

using special pigments, extenders and 

hardeners maximum UV resistance can 

be obtained. The White Guide 

formulation utilizes exterior grade 

titanium dioxide from Dupont. There 

are other pigment suppliers with the 

same type of product which can be used. 

The hardeners which can be used are 

amine functional sHanes with different 

degrees of alkoxy functionality, 

phosphoric acid, acid functional 

acrylates, amines. 

The hardness and dry time of the co~ting 

can be either increased or decreased 

based on the type of hardener used, and 

the epoxy to hydrogen ratio. The use of 

a linear or flexible hardener, such as 

leffamine D400 with a 1: 1 amine to 

epoxy equivalent ratio, will increase the 

flexibility of the coating, and prevent 

cracking. 

The use of trialkoxy amino functional 

silanes (see table) as the hardener require 

an epoxy to hydrogen equivalent weight 

ratio of 8: 1 to minimize cracking. 

Decreasing the epoxy to hydrogen ratio 

to 1: 1 decreases the dry time to less than 

four hours. Note that the latter ratio will 

have a tendency to crack if alkoxy 

functional arninosilanes are used as the 

hardener. 

The use of acid functional acrylic 

polymers as the hardener in polysiloxane 

systems will also improve UV 

resistance, chemical resistance, and 

adhesion of the coating. The acid to 

27 

Wacker Silicones 

epoxy ratio should be kept at 1: 1 (see decrease to .9: 1 will effect the 

table). An increase to 1.1: 1 or a performance of the finished product. 

TyplcaIPr()perfJes 

Properties Characteristics 

Appearance Clear liquid 

Color Light amber 

Solids (wt.%) >80% 

Viscosity (cps) 500-1000 

~ght eer eeox:y eguivalents (grams/mole) 250-350 

Storage stability (months) 6 

White Guide Formulation Using Amine Functional Silanes: 


Part A 

Component Amount 

SILRES EPt00 145.00 

DupontR960 145.00 

Grind to obtain a Hegman of >7 

Let down of Part A 

ADDID 160 1.16 

Total 291.16 

PartB 

Component Amount 

Part A 296.16 

ADDID900 23.56 

Mix Part A with Part B until homogeneous or completely dispersed and apply to 

substrate. 

28 

Wacker Silicones 

Physical Testing and Accelerated Testing of White Guide Formulation 

Using Amine Functional Sflanes: 

Test Result Method 

Initial Gloss (60 degree) 95 ASTM D 523-89 

Pencil Hardness F ASTM D 3363-74 

Chemical Resistance: ASTM D 4752-87 

IPA >50 

MEK >50 

QUV B-872 hours ASTMD4587 

Delta E 1.4 

Gloss Retention (60degree) 90% 

DryFilm Thickness (mils) 2.12 Electro Physik 

The coatings were applied to cold rolled steel panels using a wire wound rod and allowed 

to dry at room temperature for 24 hours. 

* U.S. Patent Application Serial No. 09/339,141 filed on June 24, 1999 

29 

Wacker Silicones 

White Guide Formulation Using Jeffamine D400: 

Part A 

Component Amount 

SILRES EPIOO 150.00 

Dupont R960 135.00 

Grind to obtain a Hegman of >7 

Total 28500 . 

PartB 

Component Amount 

.. Part A - 285.00 

leffamine D400 53.80 

Mix Part A with Part B until homogeneous or completely dispersed and apply to 

substrate. 

P hysical Test Data of White Guide Formulation Using Jeffamine D400: 

Test Result Method 

Initial Gloss (60 degree) 89 ASTM D 523-89 

Pencil Hardness 2B-F ASTM D 3363-74 

Chemical Resistance: ASTM D 4752-87 

IPA >100 

MEK >]00 

Boiling water Pass 

Dry Film Thickness (mils) 1.66 Electro Physik 

30 

Wacker Silicones 

White Guide Formulation Using JefTamine D230: 

Part A 

Component Amount 

SILRES EPIOO 150.00 

Dupont R960 135.00 

Grind to obtain a Hegman of >7 

Total 28500 

PartB 

Component Amount 

Part A 285.00 

leffamine D230 29.07 

Mix Part A with Part B until homogeneous or completely dispersed and apply to 

substrate. 

P hysical Test Data of White Guide Formulation Using Jeffamine D230: 

Test Result Method 

Initial Gloss (60 degree) 84 ASTM D 523-89 

Pencil Hardness B-F ASTM D 3363-74 

Chemical Resistance: ASTM D 4752-87 

IPA >100 

MEK >100 

Boiling water Pass 

Dry Film Thickness (mils) 3.01 Electro Physik 

31 

Wacker Silicones 

White Guide Formulation Using Jeffamine T403: 

Part A 

Component Amount 

SILRES EPIOO 150.00 

DupontR960 135.00 

Grind to obtain a Hegman of >7 

Total 28500 

PartB 

Component Amount 

Part A 285.00 

Jeffamine T403 38.24 

Mix Part A with Part B until homogeneous or completely dispersed and apply to 

substrate. 

P hysical Test Data of White Guide Formulation Using JefTamine T403: 

Test Result Method 

Initial Gloss (60 degree) 91 ASTM D 523-89 

Pencil Hardness HB-H ASTM D 3363-74 

Chemical Resistance: ASTM D4752-87 

IPA >100 

MEK >100 

Boiling water Pass 

Dry Film Thickness (mils) 4.0 Electro Physik 

32 

Wacker Silicones 

White Guide Formulation Using Paraloid AE 1285: 

rtA 


mponent 
 Amount 

SILRES EPIOO 60.05 

Du ont R960 155.09 

Grind to obtain a He man of >7 111.94 

Total 327.08 

PartB 

Component Amount 

Part A 71.77 

Paraloid AE 1285 98.75 

Total 170.52 

Mix Part A with Part B until homogeneous or completely dispersed and apply to 

substrate. 

P hysical Test Data of White Guide Formu)ation Using Paraloid 

AE 1285: 

Test Result Method 

Initial Gloss (60 degree) 91 ASTM D 523-89 

Pencil Hardness HB-F ASTM D 3363-74 

Chemical Resistance: ASTM D 4752-87 

IPA >100 

MEK >100 

Boiling water Pass 

Dry Film Thickness (mils) 4.0 Electro Physik 

Table of Chemical Resistance: 


.... 33 

Wacker Silicones 

Chemical Resistance of SILRES EPIOO 

HCL, Ammonium Sulfuric Acid, Phosphoric Sodium 

cone Hydroxide, 98.08% Acid, conc Hydroxide, 

cone 50% 

Epon 828 wI 0400 Strong defect No change Strong Defect Strong Defect Slight Defect 

Epon 828 wI Slight Defect No change Strong Defect Strong Defect Slight Defect 

Paraloid 

AI iphatic Urethane Slight Defect ~nge Strong Defect Slight Defect Slight Defect 

Drying Time: 1 Day Strong Defect Slight Detect Strong Defect Strong Defect No Change 

SILRES EP100 wI 

0400 

Drying Time: 1 Day Strong Defect Slight Detect Strong Defect Slight Defect No change 

SILRES EPloo wI 

Paraloid 

Drying Time: 7 Days Strong Defect No Change Strong Defect Strong Defect No Change 

SILRES EP100 wI 

0400 " , . 

Drying Time: 7 Days Slight Defect No Change Slight Defect Slight Defect No Change 

SILRES EP100 

w/Paraloid 

The two controls were the Aliphatic Urethane and Epoxy Systems. All 

the panels were dried for 7 days, however the SILRES EPIOO also 

shows a 1 day room temperature dry. 

Graph of Accelerated Test Results 

34 

f Gloss VB au,rs E"xposure 

100 

90 

80 

70 

-

& 60 

0 

e

.... 50 

0 

a 40 

30 

20 

10 

0 

0 

b-, 

" ~ 

\\'\ \ ~ 

\ , 

"'--~ 

\ ~ ----. --­ ~ '­ ---­ \ -­ \ 

\ .\ 

\ '---a. 

""t­

"'" 

500 1000 1500 2000 2500 

W 

fa 

"i 

Q 

--­Formulation B -+-Formulation C 

-+-Commercial Urethane - Formulation w/Paraloid 

3 

2.5 

2 

1.5 - 1 

0.5 

0 

0 500 1000 1500 2000 

Exposure Time (total hours) 

....-Formulation w/D230 -e- Formulation wID400 Formulation wrr403 

......Commercial Urethane - Formulation w/Paraloid 

35 
waCKer Silicones 

3000 

2500 

.-. 

a. 2000 CJ 

--­

~ 

-­(I) 1500

0 

CJ 

(I) 

- 1000 > 

500 

0 

Viscosity of White Paint 

0 60 120 180 240 300 


Time (m inutes) 

36 

" 

Safety and Handling 

For specific information regarding safe handling of this material, 

please refer to the Material Safety Data Sheet. 

Storage and Shelf-Life 

The shelf life of (SILRES EPlOO) is 

between 6 months and the date of shipment 

provided it its stored in a closed container. 

Ordering Information 

(SILRES EPlOO) is available in 440 

lb. Drums. Truckload orders and technical inquiries may be 

directed to: 

Wacker Silicones Division 

3301 Sutton Road 

Adrian, Mk::bigan 4922 I -9397 

Phone: 1 866 260-4538 

in Michigan: (517) 264-8569 

For orders less than a truddoad call: 

Seegott Incorporated 

10040 Auro....Hudson Rd 

Streetsboro. ()If 44241 

330-528-0800 

ToU Free: 888-SEEOOTI 

(733-4688) 

For infonnation on other Wacker products call toll free 

1 800 248-0063. 

Wacker Silicones Division is a domestic manufacturer of basic 

silicone materials for industry. Products include silicone fluids 

and emulsions, antifoam and release agents, room temperature 

vulcanizing (R1V) sealants and adhesives, heat curable rubber 

(HeR), liquid silicone rubber (LSR), masonry water repellents, 

paint raw materials, paper release coatings. and textile finishes. 

Our Representative in Canada: 

Seegott of Canada. Inc. 

4263 Sherwoodtowne Blvd .• Suite 200 

Mississauga. ON L4Z 1 Y5 

Canada 

Telephone Numbers: 

Toll Free: 1-866-445-5501 

Phone: 1-905-281-9508 

Fax: 1-905-281-0908 

Because we _ roresee or c:0IIIr0I die \'8rIed conditiolls .... whicb !his information 

IIIId ow- mau:rials ma), be used, we do aoI IUUlIIIIee the applicability or -InC)' of Ihis 

information or the suitability of 0IIf ..ur.eria1s in an)' specific situaIion. SIIIIjIIeI_ 

provided and USUS sbO\lld rnaI!e Ihcir 0.... """" ID delemli"" the svitability of our maIa'IaIa 

for their specifIC JlIlIPO$OS. This malerilll is provided wilhoul ~."idler expeIIIIeCI or 

implied. of fitneu roc a specific PUrpD5C and nodIio& beaU abaII be conSlnlcd as a 

rccommeodatiOil for _ which iafringe v.oIid pBIOIIlS or as e_1I:ndiag a license .... vaJid 

paII!Ills. 

(9) Wacker SiJicoaes Di'risioa 

~. Wicker Ciemical Corp.

U 3301 Suttoo Road 

Q..1iIy Maa_'- Adrian, Michigan 49221·9397 

~,,:,:>=!. (517) 264-8500 

I 800 248.0063 

. FAJ(:(SI7)264-8246 

37 

ATIACHMENT6 

Part 1, Section C, Subsection 3-Production and Use Information 

MATERIAL SAFETY DATA SHEET ON THE NEW SUBSTANCE 

- 38­
Material Safety Data Sheet I'WACKER! 

Material: 	 EP 100 (SILRES) SILICONES 

Version: 1.0 (Us) Date 	of print: 28.01.2002 Date of last alteration: 28.01.2002

1.1 Identification of the substance or 	preparation: 

commercial product name: 	 EP 100 (SILRES) 

Product group: 	 R&D Material, Silicone Resin 

1.2 	 company/undertaking identification: 

Manufacturer/distributor: 	 Wacker Chemical Corporation 


3301 Sutton Road 


Adrian. MI 49221-9397 


USA 


Customer information: 	 Customer Care Center: 

Tel (517) 264-8240 

Fax (517) 264 8740 

hours of operation: 

monday through friday, 8 am to 5 pm 

Corporate website www.wackersilicones.com 

Emergency telephone no. (24h): (517) 264-8500 


Transportation emergency: (800) 424 9300 (CHEMTREC, USA) 


(703) 527-3887 (CHEMTREC, international) 

(613) 996 6666 (CANUTEC, Canada) 

This MSDS was prepared by the Wacker Silicones Regulatory Affairs and Product Safety (RAPS) 

Department. 

-product upon INHA ­

monomer, - impurity, VUL - by-product upon vulcanization. *** Note: Cl - IARC carcinogen, 

C2 - NTP carcinogen, C3 - OSHA carcinogen, NH - non-hazardous, R - reproductive toxin. 

3.1 	 Hazards classifications 

HMIS® rating (product as packaged): 

Health: 2* Fire: 3 React!vity: 1 PPE: H 

Note: Respiratory protection is only recommended in the event that ventilation or engineering 

controls are unable to maintain exposures below recommended levels; or in the event of a spill 

or other emergency response situation. (HMIS codes are based on contact with the product as 

packaged and any hydrolysis by-products, if present.) Hazardous Materials Identification System 

and HMIS are registered trademarks of the National Paint and Coatings Association. 

Canadian WHHIS Classification: B2, D2A 

3.2 	 Emergency overview and potential hazards 

Signal Word: 

WARNING 

Physical Hazards: 


Flammable liquid and vapor. 


Acute health effects 

Page: 

39 
Material Safety Data Sheet I[WACKERI 

Material: 	 EP 100 (SILRES) SILICONES 

Version: 1.0 (US) Date 	of print: 28.01.2002 Date of last alteration: 28.01.2002

Eye contact: 


Causes eye irritation. 


Skin contact: 


May cause skin irritation. 


Inhalation: 


May cause respiratory tract irritation. 


Mucous membrane contact: 


May cause mucous membrane irritation. 


Ingestion: 


May enter the lungs during swallowing or vomiting and cause damage. 

Addtional information on acute health effects: 

Ingestion is not expected during industrial use. This is a research and development material. 

The exact composition, health and physical hazards are unknown. This sample must be handled by 

or under supervision of a technically qualified person. Use prudent laboratory practices when 

handling the material. This product contains methylpolysiloxane which can release formaldehyde 

vapors when heated to temperatures over 302 OF in air. The amount of formaldehyde generated 

will depend on the quantity and surface area of the material, the processing temperature, and 

the duration and nature of the process. Formaldehyde is a potential cancer hazard, causes 

irritation and sensitization of the skin and respiratory system, causes eye and throat 

irritation, and is acutely toxic. Safe conditions of use can be ensured by monitoring and 

controlling vapor concentrations in accordance with 29 CFR 1910.1048. Overexposure to high 

levels of vapor causes Central Nervous System (CNS) effects. This material can enter the lungs 

during swallowing or vomiting & cause lung inflammation and/or damage (aspiration hazard). 

3.3 	 Further information: 


Chronic health effects: 


Prolonged and repeated skin exposure may cause defatting, drying, and cracking. 


Medical conditions which may be aggravated by exposure: 


None 


Target organs affected: 


Liver, Kidneys, Blood and Blood Producing Organs, Heart and Circulatory System. 


Signs and symptoms of Exposure: 


Refer to Acute Health Effects, listed above. 


Carcinogens/Reproductive toxins: 


There are no carcinogenic ingredients present at or over 0.1% in this material. This material 


does not contain any reproductive toxins at or above OSHA or WHMIS reportable levels. 


See section 11 for Toxicological Information, if any. 

4.1 	 General information: 


Get medical attention if irritation occurs or if breathing becomes difficult. Remove 


contaminated clothing and shoes. 


4.2 	 After inhalation: 

If inhaled remove to fresh air. If not breathing, give artificial respiration. If breathing is 

difficult give oxygen. 

4.3 	 After contact with the skin: 

If contact with skin, immediately flush skin with plenty of water for at least 15 min. 

4.4 	 After contact with the eyes: 

If contact with eyes, immediately flush eyes with plenty of water for at least 15 min. Keep 

eyelids well open to rinse the whole eye surface and eyelids with water. 

4.5 	 After swallowing: 

For Ingestion, do not attempt to induce vomiting. If conscious, have them rinse their mouth 

with water but do not give anything to drink. Give activated charcoal in a premixed suspension, 

if available. If unconscious place and transport in stable s~deways position. 

5.1 Flammable properties: Method 

Flash point............•.•........... : 4 ·C (39 °Fl (Not Specified) 

Page: 

40 
Material Safety Data Sheet I[WACKERi

Material: 	 EP 100 (SILRES) SILICONES 

Version: 1.0 (US) Date 	of print: 28.01.2002 Date of last alteration: 28.01.2002

NFPA 	 Hazard Class (comb./flam.liquid): IB 

5.2 	 Fire and explosion hazards: 

Vapors are heavier than air and may travel along the ground, be moved by ventilation systems, 

settle in pits or low areas, and be ignited by ignition sources distant from the handling 

point. The material is lighter than water, burning spilled material will float on top of any 

water released from hose or sprinkler systems spreading the fire beyond the initial fire 

response area. Material supports combustion. Hydrolyzes on contact with moisture releasing 

ignitable vapors. Ignitable vapors may be released during processing or curing. 

5.3 	 Recommended extinguishing media: 

AFFF alcohol compatible foam. Carbon dioxide. Dry chemical. Water may be used to cool tanks and 

structures adjacent to the fire. 

5.4 	 Unsuitable extinguising media: 

Water. 

5.5 	 special exposure hazards arising from the substance or preparation itself, combustion products, 

resulting gases: 


Hazardous combustion products: Various hydrocarbon fragments , carbon dioxide , formaldehyde , 


carbon monoxide , silicon dioxide . 


5.6 	 Fire fighting procedures: 

Full turn-out gear and Self Contained Breathing Apparatus (SCBA) should be worn when fighting 

large fires. 

6.1 	 Precautions: 

Shut down all sources of ignition in the area of the spill. Warn others in the area and notify 

appropriate response personnel, if necessary. Have any persons who are not involved in the 

spill response leave the area. Turn on all exhaust ventilation units and open any outside doors 

and windows to help clear vapors from the area. Secure the area. Obtain appropriate PPE, 

supplies, and equipment prior to attempting any response. 

HAZWOPER PPE Level: C 

6.2 	 Containment: 

Use loose absorbant material or prefabricated socks to dike around small quantities of spilled 

material (incidental spills). If safe to do so, stop the leak at its source. Cover openings to 

underground drains and sewers. 

Spills of material which could reach surface waters must be reported to the United States Coast 

Guard National Response Center's toll free phone number (800) 424-8802. 

6.3 	 Methods for cleaning up: 

In the event of a large spill, this material will float on the water's surface. Use nonsparking equipment to clean up spills of flammable materials. Liquids may be recovered using 

suction devices or pumps. If flammable, only air driven or properly rated electrical equipment 

should be used. Use absorbant materials to pick up residual liquids. 

Page: 

41 
Material Safety Data Sheet 

[WACKERI 

Material: EP 100 (SILRES) SILICONES 

Version: 1.0 (US) Date 	of print: 28.01.2002 Date of last alteration: 28.01.2002

7 . I 	 Handling 

Precautions for safe handling: 

Keep container closed when not in use. When filling containers of flammable liquids use a dip 

tube to bottom fill the container and minimize free fall and splashing which could lead to a 

build up of static electricity. When transferring flammable liquids between metal containers, 

ground and bond the containers to drain off and equalize their static electric charges and 

reduce the potential for static sparks to occur. Use with adequate ventilation. This product 

contains methylpolysiloxane which can release formaldehyde vapors when heated to temperatures 

over 302 of in air. This is a research and development material and must be handled under the 

supervision of a technically qualified person. Hydrolyzes on contact with moisture releasing 

ignitable vapors. 

Precautions against fire and explosion: 

Keep 	away from heat, sparks and flame. Flammable, combustible or explosive air· vapor mixtures 

may be present in partial or uncleaned empty containers. Protect against the build-up and 

discharge of static electricity by grounding and bonding all processing vessels and transfer 

equipment. Open containers with care as flammable hydrogen gas may be present. Do not smoke 

during handling or use. Where feasible maintain the temperature of flammable or combustible 

liquids at least 30° F below their Flash Point. Do not weld, cut. or grind on empty containers. 

7.2 	 Storage 

Conditions for storage rooms and vessels: 

Nitrogen blanket, pad, or purge containers to prevent flammable air-vapor mixtures from forming 

in the container headspace. Do not store flammable liquids in plastic IBCs (i.e. Intermediate 

Bulk containers or plastic tote tanks). Containers used to dispense flammable liquids should be 

equipped with flash arrestors and self closing spigots. 

Further information for storage: 

Do not weld, cut, or grind on empty containers. Store flammable liquids in a cool, dry, fire 

protected storage area, free from sources of ignition. away from compressed or liquid oxygen, 

oxidizing agents, strong inorganic acids, and organic peroxides Store in the original 

container. Store in a cool, temperature regulated location. Store in a well ventilated area to 

limit the accumulation of vapors released from vented or unsealed containers. Store in a dry 

location to prevent exposure to water or moist air. 

8.1 	 Engineering controls 

ventilation: 

General ventilation sufficient to provide I CFM per square foot of floor area or 6 room air 

exchanges per hour is recommended. 

Local exhaust: 

Local exhaust ventilation which meets the requirements of ANSI Z9.2 is recommended to control 

airborne contaminants at the point of use. 

8.2 	 Associate substances with specific control parameters such as limit values 

Threshold limit values 

8.3 	 Personal protection equipment (PPE) 

Respiratory protection: 

Respiratory protection is only necessary if long term or high level exposures are likely to 

occur. A NIOSH approved air purifying respirator equipped with universal multi· contaminant, 

multi'gas/vapor cartridges and at least P'99 solid/aerosol particulate filters is recommended 

if overexposure to dusts, mists, or vapors could occur. If eye-irritating dusts or vapors are 

present, a full-face respirator should be worn. 

Hand protection: 

Viton rubber or Silvershield / 4H laminate gloves 

Page: 

42 
Material Safety Data Sheet 

IrWACKERI 

Material: 	 EP 100 (SILRES) SILICONES 

Version: 1.0 Date 	of print: 28.01.2002 Date of last alteration: 28.01.2002 (US) 

Eye protection: 


Safety glasses with side shields. Additional eye and face protection, splash-proof goggles, 


hood, full-faced respirator, or face shield is reco~~ended if splashing could occur. 


Other protective clothing or equipment: 


Additional skin protection, such as SARANEX coated Tyvek apron, over-sleeves, lab coat, 


coveralls, or protective suit should be worn if splashing could occur. Provide eye bath and 


safety shower. 


8.4 	 General hygiene and protection measures: 

Avoid breathing dust/vapor/mist/gas/aerosol. Avoid contact with eyes, skin and clothing. Wash 

thoroughly after handling. 

9.1 	 Appearance 

Form....... , ......................... : 

Colour............................... : 

Odour................................ : 

9.2 	 Safety parameters 

Flash point. ......................... : 

Solubility in water.................. : 


pH-Value ....................... , ..... : 


Viscosity............................ : 


9.3 	 Further information 

Percent Volatiles ................... : 

VOC ................................. : 

liquid 

yellow 

aromatic, Petroleum Hydrocarbon (Solvent) 

Method 

4 °C (39 0 F) (Not 

Specified) 

Insoluble 

7 

31.8 	mPa*s 

17 % 

170 gil (calculated 

value) 

10.0 	General information: 

Stable under normal conditions of use. 

10.1 	Conditions to avoid; 

Although this product is not expected to react with commonly used materials of construction and 

process equipment, it is advised that any rubber or plastic items such as hoses and gaskets be 

tested prior to large scale processing to ensure there is 

durability. Keep away from incompatible substances. Heat, 

ignition. 

10.2 	Materials to avoid; 

Water. oxidizing materials (oxygen, oxidizers, peroxides, 

slowly on contact with water. 

10.3 	Hazardous decomposition products: 

Ethanol is released upon contact with water. 

10.4 	Further information; 

Hazardous polymerization cannot occur. 

11.1 General information: 

no degradation of performance or 

open flames, and other sources of 

etc.). This material hydrolyzes 

Toxicological testing has not been conducted with this material. 

12.1 	Information on elimination (persistence and degradability) 

none known 

12.2 	Behaviour in environmental compartiments 

none known 

12.3 	Ecotoxicological effects: 

Page: 

43 
Material Safety Data Sheet 

[WACKERI 

Material: EP 100 (SILRES) SILICONES 

Version: Date 	of print: 28.01.2002 Date of last alteration: 28.01.2002 1.0 (US) 

none 	known 

12.4 	Further ecological information 

General information: 


No ecological data exists for this material. 


13.0 	RCRA Waste Classification: 

DOOl (Ignitable) 


This classification applies only to the material as it was originallY produced. 


13.1 	Product disposal 

Recommendation: 

If this material becomes a waste, it is considered a hazardous waste due to its ignitability. 

Material designated for disposal should be segregated from any substances or materials 

specified in Sect. 10 "Stability and reactivity". Material that cannot be used or chemically 

reprocessed should be disposed of at an approved facility in accordance with any applicable 

regulations under the Resource Conservation and Recovery Act (RCRA). State and local 

regulations may be more stringent than those under RCRA. 

13.2 	Packaging diposa1 

Recommendation: 


Uncleaned packaging should be treated with the same precautions as the material. Packaging 


should not be reused to hold another material due to the potential for reaction between 


residual product and the new material. 


14.1 	US DOT & CANADA TDG SURFACE 

Valuation...........•........ : Hazardous product 


proper Shipping Name .....•... : Flammable liquid, n.o.s. 


Technical name ...•...••.•... : (xylene) 


Class .•..•..........•....•... : 3 


UN no ............•..•....... : 1993 


Packaging Group .............. : II 


LabeL .........•...••..•..... : **TL:flammable liquid/3 


NAERG Page ................... : 128 


Corrosive to Steel or Aluminum: Not corrosive to steel or aluminum. 


14.2 	Transport by sea IMDG-Code 

Valuation•............•...... : classification not determined 

14.3 	Air transport ICAO'TI/IATA-DGR 

Valuation ..•...........•..... : classification not determined 

15.1 	U.S. Federal regulations 

TSCA inventory status and TSCA information: 


The TSCA status of this material has not been determined. Until the status is determined it is 


for R&D use only. 


TSCA 12(b) Export Notification: 


This material does not contain any TSCA 12(b) regulated chemicals. 


SARA 302 EHS Chemicals: 


This material does not contain any SARA extremely hazardous SUbstances. 


Page: 

44 
Material Safety Data Sheet 

[WACKERI 

Material: EP 100 (SILRES) SILICONES 

Version: 1.0 (US) Date of print: 28.01.2002 Date of last alteration: 28.01.2002

SARA 311/312 Hazard Class: 


Immediate (acute) health hazard. Delayed (chronic) health hazard. Fire hazard. 


HAPS: 


1330-20-7 Xylene 


15.2 U.S. State regulations 

California Proposition 65 Carcinogens: 


This material does not contain any chemicals known to the state of California to cause cancer. 


California Proposition 65 Reproductive Toxins: 


This material does not contain any chemicals known to the state of California to cause 


reproductive effects. 


Massachusetts substance List: 


1330-20-7 Xylene 


New Jersey Right-to-Know Hazardous Substance List: 


1330-20-7 Xylene 


Pennsylvania Right-to-Know Hazardous Substance List: 


1330-20-7 Xylene 


15.3 Canadian regulations 

This product has been classified in accordance with the Hazard criteria of the CPR and the MSDS 

contains all the information required by the CPR. 

WENIS Hazard Classes: 


E2, D2A 


DSL Status: 


This material or one or more of its components is not listed on the Canadian Domestic 


Substances List. 


Canadian Ingredient Disclosure List: 


This material contains no listed components. 


15.4 Other international regulations 

Details of international registration status 

Listed on the following inventories: 

16.1 Additional information: 

This Material Safety Data Sheet (MSDS) meets the requirements of the Federal OSHA Hazard 

Communication Standard (29 CFR 1910.1200). This product has been classified according to the 

hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all of the 

information required by the CPR. This information relates to the specific material designated 

and may not be valid for such material used in combination with any other materials or in any 

process. Such information is to the best of our knowledge and belief accurate and reliable as 

of the date compiled. However, no representation, warranty or guarantee expressed or implied, 

is made as to its accuracy, reliability or completeness. It is the user's responsibility to 

satisfy himself as to the suitability and completeness of such information for his own 

particular use. We do not accept liability for any loss or damage that may occur from the use 

Page: 

45 
Material Safety Data Sheet I[WACKERj 

Material: EP 100 (SILRES) SILICONES 

Date Date of last alteration: 28.01.2002 of print: 28.01.2002 Version: 1.0 (US) 

of this information. Nothing herein shall be construed as a recommendation for uses which 

infringe valid patents or as extending a license under valid patents. This MSDS provides 

selected regulatory information on this product, including its components. This is not intended 

to include all regulations. It is the responsibility of the user to know and comply with all 

applicable rules, regulations and laws relating to the product being used. 

16.2 Glossary of Terms: 

ppm - Parts per Million ACGIH . American Conference of Governmental SARA superfund Amendments and Reauthorization Act 

Industrial Hygienists STEL . Short Term Exposure Limit DOT Department of Transportation TSCA - Toxic Substances Control Act 

hPa - Hectopascals TWA - Time Weighted Average mPa's - Milli Pascal seconds WHMIS - canadian workplace Hazardous Materials OSHA - Occupational safety and Health Administration 

Identification system PEL - Permissible EXposure Limit 


Common name
 Flash point determination methods Tagliabue (Tag) closed cup ASTM D56 Cleveland open cup ASTM D92. DIN 51376, ISO 2592 PenskY'Martens closed cup ASTM D93, DIN 51758, ISO 2719 Setaflash or Rapid closed cup ASTM D3278, DIN 55680, ISO 3679 Abel-pensky closed cup DIN 51755 

16.3 conversion table: 

1 hPa ' 0.75 ~ 1 mm Hg = 1 Torr; 1 bar = 1000 hPa Pressure: 

1 mPa'S = 1 Centipoise (Cp) viscosity: 

Page: 

46 
ATIACHMENT7 


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50 

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52 

53 

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56 

ATTACHMENT 8 


HUMAN HEAL TH AND ENVIRONMENTAL IMPACT ASSESSMENT 

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ATIACHMENT8 

HUMAN HEAL TH AND ENVIRONMENTAL IMPACT ASSESSMENT 

INTRODUCTION: 


The new polymer is a phenyl silsesquioxane reacted with a glycidoxy silane. [It contains unreacted 

monomers. There is no toxicological data available on the new polymer but one of the monomers has 

been studied extensively. The actual molecular weight of the new polymer is between 750 and 5000. 

When the coating products are formulated using the new polymer, hardeners such as aminosilanes 

are used to form an epoxy-polyslloxane composition. To increase the rate of crosslinking reaction, 

catalysts can be used. Flow additives and pigments and other additives can also be added. The 

resulting coating can be sprayed applied without additional solvents if desired. The final coating 

product cures at ambient temperatures. The new polymer cures to form a U. V. light, heat and 

corrosion resistant coating by crosslinking at room temperature through the epoxy groups by way of 

an addition reaction. The reaction will continue until all the reactive groups have been depleted or the 

molecular weight of the polymer increases to where it is no longer mobile. 

HUMAN HEALTH ASSESSMENT 

The two monomers used to produce the new polymer have a low vapor pressure and therefore there 

is little potential for inhalation exposure. One monomer is a highly reactive, rapidly hydrolyzing 

chemical and therefore has to be handled very carefully to maintain its integrity. While there is some 

animal evidence of a necrotizing effect following dermal exposure with this monomer, it is more likely 

that hydrolysis after skin contact will occur resulting in the formation of high molecular weight 

polymers incapable of penetrating the skin barrier thus excluding systemic availability. Ingestion of 

the new polymer is not considered to be a relevant route of exposure. If there were some ingestion by 

accident, it is expected that the material would hydrolyze and polymerize in the stomach. Since this 

would be expected to occur rapidly, there would be little chance for absorption from the gut. 

Commercial application of the coatings containing the new polymer, is usually accomplished by 

spraying. This requires the use of a respirator and protective clothing due to the solvents and other 

additives used. Once the coating is applied and fully cured (usually within 4 hours) the new polymer is 

fully crosslinked and incorporated into the coating. 

ENVIRONMENTAL IMPACT ASSESSMENT 

The potential for environmental impact in manufacturing and formulating of the coatings is minimized 

by the use of incineration. In the commercial application area, any unintentional releases into the 

environment would be minimized by the ability of this material to polymerize quickly and to form high 

molecular weight polymers or to form less reactive end groups. Once the coating is applied and fully 

cured (usually within 4 hours) the new polymer is fully crosslinked and incorporated into the coating. 

- 58­