p. 1 

0 1011-5- 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# 333 r// J7 

U.S . Environmental Protection Agency 

Document Control Office (DCO) 

EPA East Building, Room 6428 

1201 Constitution Ave., NW 

Washington, DC. 20004-3302 

March 8, 2011 ~~piqiHi`~u0 ~gui~upi,,uiWi 

Subject: Exemption from Test Rule 

Cytec Industries Inc. (Cytec), an importer of benzophenone; CASRN 119-61-9, 

respectively requests an exemption from testing 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 
Available Test 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 (OECD TG 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) 

Conclusions from these 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 

LC50 was 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 EC50 was > 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 LC50 was 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 from conducting 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