Re:HPV3for CASRN for CASRN for CASRN22527-63-5 22527-63-5 22527-63-5 -Submission of Test Plan by Eastman Submission of Test Plan by Eastman Submission of Test Plan by Eastman 

Chemical for review . Chemical for review . 

Chuantung Lin Chuantung Lin to: Paul Campanella 02/21/2012 03:16 PM

Cc: John Schaeffer, Marcus Aguilar, Tracy Williamson, Myrta Christian

From: Chuantung Lin/DC/USEPA/US

To: Paul Campanella/DC/USEPA/US@EPA

Cc: John Schaeffer/DC/USEPA/US@EPA, Marcus Aguilar/DC/USEPA/US@EPA, Tracy 

Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA

History: This message has been replied to.

1 attachment

20120220_Test Plan for HPV 22527-63-5_Final.pdf

To: Campanella.Paul@epamail.epa.gov

Cc: Schaeffer.John@epamail.epa.gov, Aguilar.Marcus@epamail.epa.gov, 

Williamson.Tracy@epamail.epa.gov, Christian.Myrta@epamail.epa.gov

Hi Paul,

I have reviewed the attached document sent by the sponsor of the HPV test chemical. Basically, the three 

chemicals on the products mixture are the three diesters of 2,2,4-trimethyl-1,3-pentanediol. There are 

mixture diester (the titled HPV test chemical; 22527-63-5), dibenzoate (68052-23-3), and diisobutyrate 

(6846-50-0). 

From the chemical structural view point,, these three are very close analogs to each other and they are 

made by reacting the diol with benzoic acid and isobutanoic acid in the same reaction . These three 

related chemicals also have similar estimated values on some physical chemical properties . Based on 

this fact, it is fine to accept the sponsor's proposed approach to use the products that sold commercially 

as the test substance for obtaining the measured values of A1, A2, A3, A4, and A5 endpoints for the titled 

HPV test chemical.

Let me know if you have any question on this matter.

Daniel

______________________________________________________

Dr. Daniel Chuantung Lin 

Industrial Chemistry Branch

Office of Chemicals Safety and Pollution Prevention

US EPA

1200 Pennsylvania Ave., NW (7406M)

Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, 

EPA East, Room#:5133E, Washington, DC 20460]
202-564-8584 (direct)

202-564-8740 (branch)

202-564-8679 (fax)

Paul Campanella---02/21/2012 11:39:33 AM---Daniel., I am sending this test plan from Eastman for 

your review. You have commented on an earlier

From: Paul Campanella/DC/USEPA/US

To: Chuantung Lin/DC/USEPA/US

Cc: John Schaeffer/DC/USEPA/US@EPA, Marcus Aguilar/DC/USEPA/US

Date: 02/21/2012 11:39 AM

Subject: HPV 3 for CASRN 22527-63-5 - Submission of Test Plan by Eastman Chemical for review.

Daniel., I am sending this test plan from Eastman for your review. You have commented on an earlier 

question from Eastman and they have modified the test plan accordingly. They have requested a 

modification dealing with purity of the test substance. Eastman is anxious to start the testing as soon as 

possible. Can you please give me an estimate as to when this review will be available . Thanks. 

Paul J. Campanella, Ph.D.

Chemical Information and Testing Branch

Chemical Control Division

U.S. Environmental Protection Agency

Washington, D.C. 

202-564-8091

----- Forwarded by Paul Campanella/DC/USEPA/US on 02/21/2012 11:37 AM -----

From: "Velsor, Leonard Wayne" <lvelsor@eastman.com>

To: Paul Campanella/DC/USEPA/US@EPA

Cc: "Shrum, Gary" <glshrum@eastman.com>

Date: 02/20/2012 03:36 PM

Subject: Attn 40 CFR 799.5089 for CASRN 22527-63-5 - Submission of Test Plan

Paul,

A copy of our test plan was sent by overnight mail today but I've attached a PDF copy in advance. I 

believe information responsive to Dr. Lin's request is in the content of the letter. Gary Shrum, Eastman's 

Director of Product Safety and Health will be your primary contact going forward .

Thanks,

Leonard

-----Original Message-----

From: Paul Campanella [mailto:Campanella.Paul@epamail.epa.gov] 

Sent: Tuesday, February 14, 2012 4:11 PM
To: Velsor, Leonard Wayne

Subject: RE: [I] Re: Attn 40 CFR 799.5089 for CASRN 22527-63-5: Request for clarification from EPA 

reviewer

Leonard, below is an additional request from our reviewer Dr Daniel Lin .

Can you please respond to me so that I will not lose any information in

the exchange and we will try and get this settled quickly . Thanks.

Hi Paul,

In order to respond the sponsor's question correctly on this matter: we

need to know the contents of actual product that Eastman proposed to use

for the testing. I assume that the proposed product contains the

mixture of regioisomers of the test rule substance, 22527-63-5 (i.e.,

2,2,4- vs. 2,4,4-trimethylpentyl; which will be treated as a Class 2

chemical substance or a mixture of isomers). If the sponsor could

provide the detail formulation information of the product which is to be

used in the testing, we could have a clear picture to comment on such

approach. If the product contains only such two structural isomers

(2,2,4 and 2,4,4- ) without other components, then it should be fine to

use that product mixture for testing to obtain the required data for the

physical chemical endpoints required under the HPV test rules .

Therefore, could you ask the sponsor to provide us the contents of the

product formulation that will be used in the testing?

Daniel

___________________________________________________

Dr. Daniel Chuantung Lin

Industrial Chemistry Branch

Office of Chemicals Safety and Pollution Prevention

US EPA

1200 Pennsylvania Ave., NW (7406M)

Washington, DC 20460

Paul J. Campanella, Ph.D.

Chemical Information and Testing Branch

Chemical Control Division

U.S. Environmental Protection Agency

Washington, D.C.

202-564-8091

From: "Velsor, Leonard Wayne" <lvelsor@eastman.com>

To: Paul Campanella/DC/USEPA/US@EPA

Date: 02/10/2012 01:44 PM

Subject: RE: [I] Re: Attn 40 CFR 799.5089 for CASRN 22527-63-5
Dear Dr. Campanella,

 Eastman will be submitting its test plan next week for propanoic

acid, 2-methyl-, 3-(benzoyloxy)-2,2,4-trimethylpentyl ester (CASRN

22527-63-5). As we mentioned in our Letter of Intent, Eastman acquired

the company that manufacturers this substance in 2010 and to the best of

our knowledge, no comments were filed in response to the proposed rule.

As a result, we expect to propose some modifications to the testing

requirements and wanted to provide the agency with advanced notice of

one significant modification we expect to propose to assist you with the

review.

 Subsequent to our submission of the Letter of Intent, we have

discovered that the substance notified in the test rule was not produced

as an individual substance but rather as part of a reaction mass for

commercial products. As the pure substance is not sold into commerce,

and we are uncertain if the product could be refined to achieve the 99%

purity required under the rule, we intend to propose that the studies

designated in the test plan be conducted on the actual Eastman product

that contains the test rule substance. We look forward to discussing

this issue with you following the submission of our test plan .

Sincerely,

Leonard Velsor

-----Original Message-----

From: Paul Campanella [mailto:Campanella.Paul@epamail.epa.gov]<mailto:[

mailto:Campanella.Paul@epamail.epa.gov]>

Sent: Thursday, December 22, 2011 1:04 PM

To: Velsor, Leonard Wayne

Subject: [I] Re: Attn 40 CFR 799.5089 for CASRN 22527-63-5

Thanks for sending a copy of this Letter of Intet to Test to me. Please

continue to send me electronic versions of anything you submit to the

docket. This often will speed up reviews and transfer of information as

we go forward.

Paul J. Campanella, Ph.D.

Chemical Information and Testing Branch

Chemical Control Division

U.S. Environmental Protection Agency

Washington, D.C.

202-564-8091

(See attached file: 20120220_Test Plan for HPV 22527-63-5_Final.pdf)