p. 1 

# 01011-5- 2-W 7-0531 

# CYTEC ~~~CCtVFi) IDPP?` f'PSIc Cytec Industries Inc. Product Stewardship &Regulatory Affairs 1937 West Main Street 

### Stamford, CT 06904 

## 1 I MAR -9 A1111 : 56 

# mk# 333r//J7 U .S. Environmental Protection Agency Document Control Office (DCO) EPA East Building, Room6428 1201 Constitution Ave., NW Washington, DC

. 20004-3302 March 8, 2011 

# ~~piqiHi`~u0~gui~upi,,uiWi Subject : Exemption fromTest Rule Cytec Industries Inc. (Cytec), an importer of benzophenone; CASRN 119-61-9, respectively requests an exemption fromtesting as specified in the U .S. Environmental Protection Agency's Final Rule outlined in Federal Register, Volume 76, No. 5, Friday, January 7, 2011, Rules and Regulations, Testing of Certain High Production Volume Chemicals; Second Group of Chemicals. Cytec requests this exemption based on the fact that testing for the requested endpoints has been conducted and results of this testing is already available in the public domain. Identity of the test rule : 40 CFR 799 .5087 Chemical Identity: Methanone, diphenyl ; CASRN 119-61-9 Testing Requirements: Ready Biodegradation If log KOW

< 4.2; Test Group 1 is required : " Acute Toxicity to Daphnia " Toxicity to Plants (Algae) If log KOW

> 4 .2; Test Group 2 is required: " Chronic Toxicity to Daphnia " Chronic Toxicity to Plants (Algae) Basis for testing exemption: The required test data are available in the literature. A summary and reference to the test data is listed below : NJ co



# CONTAIM

;~ livo C8I

### AvailableTest Data Summary:

The Log KOW

of CARRN 119-61-9 is <4.2 (Source: US EPA EPIWIN), therefore, ready biodegradation, acute toxicity to daphnia and toxicity to plants (algae) are required to be conducted under the Final Rule. According to the Japanese National Institute of Technology, the biodegradation of CASRN 119- 61-9 is published in the Official Bulletin of Economy, Trade and Industry (Former title: The Official Bulletin of the Ministry of International Trade and Industry, also known as MITI, (published before Jan .6, 2001)) and a summary of these results is currently found at the following location: http://www

.safe.nite.go.ip/data/hazkizon/pk e kizon disp.html?k no=0497 

### The study details are summarized below : Test substance CASRN 119-61-9 Test method MITI-I (OECDTG 301C), 14 day duration Year 1992 Concentration 100 ppm(mg/1) ~ Results ~ __------ BOD 0% degradation in conclusion, based on this study, the CASRN 119-61-9 is not readily biodegradable. In addition, environmental fate, including biodegradation, acute daphnia and acute plant (algae) studies are summarized in the European REACH IUCLID dossier for substance 119-61-9. The dossier can be located at the following location: http://apps .echa .europa .eu/registered/data/DISS-9875cc3a-73ed-5dcf-e044- 00144f67d031/showtree6722 .html?treeUuid=DISS-9875cc3a-73ed-5dcf-e044- 00144f67d031%2FDISS-9875cc3a-73ed-5dcf-e044-00144f67d031 The REACH dossier outlines the biodegradation study described in the MITI publication referenced above. The REACH dossier concludes "the study conducted according to OECD Guideline 301C, benzophenone proved not to be readily biodegradable (0% biodegradation after 14 d) . The study is regarded as valid although some details were not reported." The REACH dossier summarizes three acute daphnia studies. Study details are summarized below : Test method Endpoint Effect Nominal or Concentration Basis for Remarks Source (date) (duration) concentration Measured based on effect OECD 202 EC50 0.28 mg/L Measured Active mobility 95%CL : Publication: (24 h) (initial) ingredient 0.21-0.37 Environ .Sci . (a.i .) mg/L technol . 25, 695 -702(1991) OECD 202 EC50 >10 mg/I No data Test material mobility none Peer-reviewed (48 hr) database (2010) US EPA LC50 7.6 mg/L measured Active mortality 95%CL Publication: The ~

### 2nd ed . (initial) ingredient was not Science of the

EPA/600/4- (a.i .) calculable Total 89/001 and Environment, supplement Supplement, EPA/600/4- 799-808 89/001A (1993) (24 hr) 

### Conclusionsfromthese daphnia studies are listed hereunder :

D

D D In a 24 hr acute toxicity study, water fleas (Daphnia magna) < 24h old were exposed to benzophenone . Applied test substance concentrations were not reported. The 24-hr LC50was 0.28 mg a .i ./L (959'a CL: 0.21-0.37 mg/L) . Parameters enabling assessment of validity criteria (control results; dissolved oxygen content in test vessels) were not reported. Test duration not in compliance with guideline. In a 48-h acute toxicity study, water fleas (Daphnia magna) were exposed to benzophenone according to OECD Guideline 202 (Daphnia sp. Acute Immobilisation Test) . The 48-hr EC50was > 10 mg test material/L. In a 24 h acute toxicity study, water fleas (Ceriodaphnia dubia) < 24hr old were exposed to benzophenone under static conditions. Test concentrations were not reported . The 24-hr LC50was 7.6 mg a .i ./L. The REACH dossier summarizes one algae study. Study details are summarized below : Test method Endpoint Effect Nominal or Concentration Basis for Remarks Source (date) (duration) concentration Measured based on effect OECD 201 EC50 3 .5 mg/L no data test material growth none Peer-reviewed (72 hr) rate database (2010) OECD 201 NOEC 1 mg/I no data test material growth none Peer-reviewed (72 hr) rate database (2010)

In conclusion, in a 72 hour acute toxicity study, the cultures of Pseudokircheneriella subcapitata were exposed to benzophenone in accordance with the OECD Guideline 201 (Alga, Growth Inhibition Test) . The ECSOvalues based on growth rate was 3 .5 mg test material/L. The NOEC values based on growth rate was 1 .0 mg test material/L. This toxicity study is classified as reliable with restrictions and satisfies the guideline requirements for an algae growth inhibition study. As the results of requested studies for CASRN 119-61-9 are publicly available, Cytec requests an exemption fromconducting tests required by the U.S. Environmental Protection Agency's Final Rule outlined in Federal Register, Volume 76, No. 5, Friday, January 7, 2011, Rules and Regulations, Testing of Certain High Production Volume Chemicals; Second Group of Chemicals. 

### Name of Applicant : Cytec Industries Inc . 5 Garret Mountain Plaza Woodland Park, NJ 07424

### Contact Person: Daniel Liebowitz Cytec Industries Inc. 1937 West Main Street Stamford, CT 06904 203-321-2259 Sincerely, FOR CYTEC INDUSTRIES INC. Daniel Liebowitz Regulatory Compliance Manager Americas