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fax: 202.564.8251 

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OCSPP OPPT EAD 

1200 Pennsylvania Ave. NW 

Washington, DC 20460 

202.564.8251 

Pages: 

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r- Urgent I- For Review I- Please Comme - Please Reply - Please Recycle -

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

VIA FACSIMILE: 201-437-4801 

April 19,2012 

Attention: Glenn Merritt (201-437-4000) 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Subject: Follow-up to fax transmission of 4/13/12 (ePMA removal ofCBI claims regarding 

identified studies) 

Dear Mr. Merritt: 

This is sent to you pursuant our conversation of several minutes ago. In Larry Robinson's fax of 

April 13th while there is a waiver of confidential business information (CBI) claims in the 

identified studies there is a an assertion of copyright protections and some additional text that 

provides in part ... "Reproduction, reference, summarization, retransmission or other use of this 

copyrighted document. .. including electronic transmission, using the internet or email .... is 

strictly prohibited .... " 

While we understand the basis for the copyright protections, we have a concern that the language 

in the fax might be interpreted to mean that ePMA is asserting that the studies submitted per the 

TSCA activity are not to be made available in an Agency e-docket (electronic docket) or be 

included in EPA websites among the collection of TSCA health and safety studies. 

We are thinking that the identified limitations noted in the fax are not intended to apply to EPA's 

normal procedures for the handling of non-CBI materials submitted by entities subject to TSCA 

regulations (including the posting of such materials on government websites) and submitted by 

such entities in order to comply with a TSCA requirement, but are rather intended to limit 

entities outside the government from the unauthorized use or appropriation of the studies. 

Can you please confirm CPMA's intent? Many thanks. 

Scott M. Sherlock, Attorney Advisor 

Environmental Assistance Division 

Office of Pollution Prevention and Toxics 


G4. Partition

Coefficient

G5. Water Solubility
CLAMIANT CORPORATION

PRODUCT SAFETY DEPARTMENT

COVENTRY, RHODE ISLAND 02816

FAX #: 401-823-2570

PHONE #!CINDY HEFFERNAN - 401-823-2138

MARY ELLEN MAXWELL - 401-423-2366

JANE WALTERS -401-823-2185

DATE: July 12,2006

TO: Glexi Merritt

LOCATION:

FAX #: M8540

FROM: MAEru len Ma~cweil

# OF PAGES (INCLUDtNG COVER SHEET)

Re: Pigmnt Blue 61

Clariant
-ZtClariant

C afln ProduKW (Dou~uand) GmnbH

CLAS Rhen-M&inL W&vtc HO"I

Team Lob 634, Dr. Rater At

Phone.:069-305 -

3 W Date: 10.07.2006

Page: I fromt 3

REP'ORT OF ANALYSIS

Sample: 1ignioni Blue 61 purified (Batch 07659)

Customer Dr. Ervnn Dietz Department; Product Safety

CLAS Order No: 06-05741 Lab Order No,: 0765

Remarks;

Determination of the solubility in water and in octanol at ambient temperature (method- see below).

Sample.- pure Pigment Blue 61

Residt.-

Tic solubility of the sample "Pigment Blue 61" in water at ambient temperature, determined under

the conditions as mentioned below, is 2.5 ;Ag per liter (a 0.25).

The solubility of the sample "Pigment Blue 61" in octanol at ambient temperature, determined

under tbe conditions as mentioned below, is 23.8 mg per liter (a -0.62).

Sample:

Pigment Blue 61 (P. B. 6 1)

Batch: 0765B

method-,

The analytical method for the determination is in agreement with the method that was agreed upon

at the "Analytical Exrperts Meeting" of ETAD (Base]) ont January 12, 2005.
_____ ___Clairant

C~avmr~ Pradukle (Deuftchinn QrnbH

CI.AS K 1Iarli, Wdk N8Chst

Tooan Lob G834. Dr. Ronor At

Ptiona.:06- 306 - 3589 Date: 10-07.20M6

Page: 2 from 3

Water:

About 15 mg of the test sample were suspended in 30 ml) water (bi dest.) in a sample flask (staxidard

flask for the Bfiehi Rack R-24, volumne 30 ml (Art.-No. 038469)) and were shaken for two hours at

30*C (+/. 20C) on a "Btlchi Syncore Polyvap" (laboratory shaking machine) with 400 rpm. Then

shaking was continued at ambient temperature (25 - 260C) for 70 hours, followed! by filtration

through a u1.05 Am membrane filter (Fa. Schleicher und Schuell, NC 05, Ref.-No.; 402110) (on the

filter there remained a residue of not dissolved colorant).

The resulting clear solution was measured by UV-vis spectrometry and the absorption was dewemined at X 596 rn. The concentration of the sample could be determined by applying the LambertBeer rule. The below attached calibration curve of Pigment Blue 61 in octanol (Aldrich,

spectropliotornetric grade) was used for tha purpose.

The deterninationi was repeated for three times.

Indivifua results

Absorption

_____(d - 10cm) pg l

al 0.002365 J.2.5

a2 0.002704 2.8

3 0.002074__ 2.3j

About 15 mg of the test sample were suspended in 30 ml ocianol (Aldrich, spectrophotomtetric

grade) in a sample flask (standard flask for the Btlchi Rack R-24, volumne 30 ml (Art.-No. 038469))

and were shaken for two hours at 30C (+/- 20C) on a "Btlchi Syncore Polyvap" (laboratory shaking

mnachine) with 400 rpm. Then shaking was continued at ambient temperature (25 - 26*C) for 70

hours, followed by filtration through a 0.2 pim membrane filter (Pa. Schlicher und Schuell, TE 35,

Ref-No.: 411411I) and then through two 0.2 pim membrane filters (Fa. Schleicher und Schuell, TE

35, Ref.-No.: 411411) (on the filter there remained a residue of not dissolved colorant).

The resulting clear solution was measured by UV-Vis spectrometry and the absorption was determined at X,,,n 594 nm. The concentration of the sample could be determined by applying the Lambert-Beer rule. The below attached calibration curve of Pigment Blue 61 in octanol (Aldrich.4

spectrophorometric grade) was used for that purpose,

The determination was repeated for three times.

Individual results

7-' Absorption

(d- I cm

dilution 1:5), mg

al 0.56704 23.3

a2 0.57481 23.6

a3 0,59544 24.5
Clariarit

Oaanut Prudu~de (PVetSChlan) GnMtb

CLAS Rheif-Milif, WeuIc Ilbc

Team Lob G834, Dr. Rainier Az

Ph"u. '059 - 305 - 3659 Dat: 10.07.2006

Pag;: 3 fromn3

(Calikration: Pigment Blue 61 in octapol (for water):

Calbration, curve Pig9ment Blue 61lIn octenol

0.00 0,10 0.15 0,20 0.25 0.N OM5 0.40

W"1CIOD" t S PRO: 41 an1

Calibrationi: Pigment Blue 61 in octanol (for octaofl:

Calibration curve Pigment Blue 61 in octanol

7.0- _ _

6.0

0. 0.A 0,10 0,16 0,20 0,25 0,30 0.35 0.40 0.4 0.50 .6 0.0110 O.N07 0,75 0.10

Brebon ot I pig: d. a- Ie

Purification of samph;

The purification was done by extraction of Reflex-Blau R (Batch: Pt. Ni. 77/04) with hexan at

ref lux temperature for 5 h.

Dr. Rainer