U.S. ENVIRONMENTAL PROTECTION AGENCY 

SANITIZED 

ft 

~EPA PREMANUFACTURE 

NOTICE 

Form A roved. O.M.B. No. 2070-0012. Approval Ex ires 10-31-96. 

AGENCY USE ONLY Date of receipt 

'CES 

Company Sanitized 

IU Li I iii I d 

j' 

in the ?remanufacture Notice 

"0 

GENERAL INSTRUCTIONS 

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

not have actual data. 

Before you complete this form, you should read the "Instructions Manual for ?remanufacture Notification" (the Instructions Manual is available from the Toxic 

Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603). 

If a user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, 

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

360399M, Pittsburgh, PA 15251-6399, Attn. TSCA User fee. 

Part I-GENERAL INFORMATION 

You must provide the currently correct Chemical Abstracts (CA) Name of the new 

chemical substance, even if you claim the identity as confidential. You may authorize 

another person to submit chemical identity information for you, but your submission will 

not be complete and the review will not begin until EPA receives this information. A 

letter in support of your submission should reference your TS user fee identification 

number. You must submit an original and two copies of this notice including all test data. 

If you claimed any information as confidential, a single sanitized copy must also be 

submitted. 

Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

If there are several manufacture, processing, or use operations to be described in Part II, 

sections A and B of this notice, reproduce the sections as needed. 

Part IlJ- LIST OF ATTACHMENTS 

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

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

attachments, any test data or other data and any optional information included in the 

notice. 

OPTIONAL INFORMATION 

You may include any information that you want EPA to consider in evaluating the new 

substance. On page II of this form, space has been provided for you to described 

pollution prevention and recycling information you may have regarding the new 

substance. 

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

willingness to be bound to certain statements you make in this section, such as use, 

production volume, protective equipment ... This option is intended to reduce delays 

!hat routinely accompany the development of consent orders or Significant New Use 

Rules. Except in the case of exemption applications (such as TMEA, LVE, LOREX) 

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

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

does not by itself prohibit the submitter from later deviating from the information (except 

chemical identity) reported in the form. 

CONFIDENTIALITY CLAIMS 

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

form, mark (X) the confidential box next to !he information that you claim as 

confidential. To assert a claim in an attachment, circle or bracket the information you 

claim as confidential. If you claim information in !he notices as confidential. you must 

also provide a sanitized version of the notice. (including attachments). For additional 

instructions on claiming information as confidential, read the Instructions Manual. 

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

EPA FORM 7710-25 (Rev. 5-95) 

TEST DATA AND OTHER DATA 

You are required to submit all test data in your possession or control and to provide 

a description of all other data known to or reasonably ascertainable by you, if these 

data are related to the health and environmental effects on the manufacture, 

processing, distribution in commerce, use, or disposal of the new chemical 

substance. Standard literature citations may be submitted for data in the open 

scientific literature. Complete test data (written in English), not summaries of data. 

must be submitted if they do not appear in the open literature. You should clearly 

identifY whether test data is on the substance or on an analog. Also, the chemical 

composition of the tested material should be characterized. Following are 

examples of test data and other data. Data should be submitted according to the 

requirements of §720.50 of the ?remanufacture Notification Rule (40 CFR Part 

720). 

Test Data (Check Below any included in this notice) 

Environmental fate data D 

Health effects data D 

Environmental effects data D 

Physical/Chemical Properties* D 

Yes 

Yes 

Yes 

Yes 

Other data D Yes 

Risk assessments 

Structure/activity relationships 

Test data not in the possession 

or control of the submitter 

A physical and chemical properties worksheet is located on the last page of this form. 

TYPE OF NOTICE (Check Only One) 

C8J 

D 

D 

D 

D 

PMN (Premanufacture Notice) 

INTERMEDIATE PMN (submitted in sequence with final product PMN) 

SNUN (Significant New Use Notice) 

TMEA (Test Marketing Exemption Application) -~- .: 

LVE (Low Volume Exemption)@ 40 CFR 723.50(c)(l) 

D LOREX (Low Release/Low Exposure Exemption)@ 40 CFR 723.50(c)(2) 

D LVE Modification 

IS THIS A CONSOLIDATED PMN? 

# of chemicals 

D 

D 

LOREX Modification 

Yes 

(Prenotice Communication# required, enter# on page 3) 

Replaces previous editions of EPA Form 7710-25. 
Public' reporting burden for this collection of information is estimated to average II 0 hours per response, including time for reviewing 

instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of 

information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for 

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

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

CERTIFICATION 

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

1. The company named in Part I, 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 of the date of submission. 

3. I 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: 

[8J The Company named in Part I, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b ), or 

0 The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 

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

0 The Company named in Part I Section A is a small business concern under 40 CFR 700.43 and has remitted a fee of$100 

in accordance with 40 CFR 700.45(b ). 

If you are submitting a low volume exemption (L VE) application in accordance with 40 CFR 723 .50( c)( 1) or a Low release 

and low exposure exemption (LoRex) application in accordance with 40 CFR 723 .50( c )(2), check the following certification 

statements: 

0 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 of 40 CFR 723.50. 

0 The manufacturer is familiar with the terms of this section and will comply with those terms; and 

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

0 If this 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 of the expiration of the 30 day 

review period. 

Confidential 

EPA FORM 7710-25 (Rev. 5-95) Page 2 
3. 

4. 

5. 

6. 

Atlanta, GA 30339 

If you have had a prenotice communication (PC) concerning this 

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

If you previously submitted an exemption application for the chemical 

substance covered by this notice, enter the exemption number assigned by 

EPA. If you previously submitted a PMN for this substance enter the 

PMN number assigned by EPA (i.e. withdrawn or incomplleci'Ctc'r.).---+ 

If you have submitted a notice 

for the chemical substance covered by this notice, enter the notice 

assigned by EPA. 

I. 

Type of Notice- Mark (X) 

D 

Manufacture 

Only 

Binding Option 

Mark 

EPA FORM 7710-25 (Rev. 5-95) 

2. 

D 

Page 3 

Import 

Only 

Mark (X) 

if none 

Mark (X) 

if none 

Mark (X) 

if none 

Binding Option 

Mark (X) 

247-7403 

D 

D 

D 

3. D Both 
I. 

name of the substance based on 

conventions. 

a. 

If another person will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. 

the and address of that in a continuation sheet. 

substances (for definitions of class I and class 2 substances, see the Instructions Manual) 

Class of substance - Mark (X) I D Class I or 2 1:8] Class 2 

'-'ll'Ollll.'-a' name (Currently 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 orCA Preferred Name must 

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

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

1:8] Method I (CAS Inventory Expert Service- a copy of the Identification D Method 2 (Other Source) 

report obtained from the CAS Inventory Expert Services must be 

submitted as an attachment to this 

d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

CAS# 

e. For a class I substance, provide a complete and correct chemical structure diagram. For a class 2 substance- (I) List the 

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

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

diagram. as comolete as can be known. if one can be reasonablv ascertained. 

attach a continuation sheet. 

X 

X 

X 

X 

EPA FORM 77!0-25 (Rev. 5-95) Page 4 
Confidential 

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

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

below I ,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: GPC 0 Other 0: (Specify) 

i) lowest number average molecular weight: 

ii) maximum weight% below 500 molecular weight: 

iii) maximum weight% below 1000 molecular weight: 

You must make separate 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 (if a number exists) of each monomer or other reactant used in the manufacture of 

the polymer. 

(2) Mark (X) this column if entry in column (1) is confidential. 

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

(4) Mark (X) the identity column if you want a monomer or other reactant used at two 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. 

Mark this column if is confidential. 

Confi- Typical Confi-

% % 

% % 

% % 

% % 

% % 

% % 

% % 

or obtain the specified chemical identity information reported in this notice (check one). 

Method 1 (CAS Inventory Expert Service - a copy of the identification report 0 Method 2 (other source) 

obtained from CAS Inventory Expert Service must be submitted as 

as attachment to this 

d. The currently correct Chemical Abstracts (CA) name for the polymer that is TSCA Inventory listings for similar polymers. 

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

EPA FORM 7710-25 (Rev. 5-95) Page 5 
D Ma;k (X) this box if you attach a continutation sheet. 

Part I-- GENERAl IN.I'lHl.MATION --Continued 

Section B -- f'HFMif'AI UEl'l lNI<'URMATION- Continued 

3. Impurities 

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

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

(b) - Estimate the maximum weight% of each impurity. If there are unidentified ""f'u' iuto>, estimate their total weight%. 

Impurity and CAS Registry Number Maximum Contipercent dential 

(a) (b) 

% X 

% 

% 

% 

% 

% 

% 

[ J Mark (X) this box if you attach a w11tinuation sheet. 

4. Synonyms- Enter any chemical synonyms for the new chemical identified in subsection I or 2. Contidential 

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

5. Trade identification - List trade names for the new chemical substance identified in subsection I or 2. 

VERTEX 60SR 

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

6. Generic chemical name - If you claim chemical identify as wuuu-...Jtial, you must provide a generic name for your substance that reveals 

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

TSCA Chemical Substance Inventory, 1985 Edition, Appendix 8 for guidance on developing generic names. 

Magnesium Hydroxide surface treated 

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

7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the CAS Registry 

Number if available. 

~.rp(()u'"' CAS Regis~ Number Conti-

(2) dential 

X 

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

EPA FORM 7710-25 (Rev. 5-95) Replaces previous editions of EPA Form 7710-25. 
Part I-- GENERAL INFORMATION-- Continued 

Section C --PRODUCTION, IMPORT, AND USE INFORMATION: 

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 of production. Estimates should be on 100% new chemical 

substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 

kg/yr, specify the volume and mark (x) in the binding box. If granted, you are bound to this volume 

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Conti- Binding 

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

Mark (x) 

X 

2. Use Information -- You must make separate confidentiality claims for the description of the category of use, 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. (I) -- Describe each intended category of use of the new chemical substance by function and application .. 

(2) -- Mark (X) this column if entry column (1) is confidential business information (CBI). 

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

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

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

(6) -- Estimate the percent of the 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 of use. 

(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 entrv(ies) in column (8) is (are) confidential business information (CBI). 

Category of use (I) CBI Binding Produc- CBI %in CBI % of substance expected per use CBI 

Option tion% Form- (8) 

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

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

Flame Retardant % X % X X 

% % 

% % 

% % 

% % 

% % 

% % 

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in consumer products. 

In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this 

substance loses its identity in the consumer product. 

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

b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the 

use Instructions Manual for examples of generic use descriptions. 

description 

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

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

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

for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Mark (x) 

D Mark (X) this box if you attach hazard information. 

EPA FORM 7710-25 (Rev. 5-95) Page 7 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE 

Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any item you 

claim as confidential 

Complete section A for each type of manufacture, 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 

dential 

Site address (number and street) 

City, County, State, ZIP code 

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

additional sites on a continuation sheet, and if any of the sites have significantly different 

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

sites as attachments. 

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

b. Type--

Mark (X) 

I. Batch 

Maximum kg/batch ( 1 OO% new chemical Hours/batch 

substance) 

2. Continuous 

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

X 

X 

Use 

Batches/year X 

X 

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

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

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

feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not 

used daily or per batch.). 

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

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

EPA FORM 7710-25 (Rev. 5-95) Page 8 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

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

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

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

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

(2) --Mark (X) this column if entry in column (1) is confidential business information (CBI). 

(3) --Describe any protective equipment and engineering controls used to 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) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and% new chemical substance (if part of a mixture) 

at the time of exposure. 

(7) --Mark (X) this column if entry in column (5) is confidential 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). 

(10) and (11) --Estimate the maximum duration of the activity for any worker in hours per day and days per year. 

(12) --Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI). 

Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI #of CBI Maximu duration CBI 

m 

(i.e., bag dumping, filling drums) Engineering Controls Option and% new Option Worker Hrs/day Days/yr 

Mark(x) substance Mark(x) s 

(1) (2) (3) (4) (5) (6) (7) Expose (9) (10) (II) (12) 

d 

(8) 

X Safety Glasses, X X X 

Gloves 

X Safety Glasses, X X X 

Gloves 

X Safety Glasses, X X X 

Gloves 

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

3. Environmental Release and Disposal-- 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. 

( l) ·-Enter the number of each release point identified in the process description, part II, section A, subsection I d(3). 

(2) --Estimate the amount ofthe 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 (CBI). 

(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 (specify)) 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 of RCRA hazardous waste. On a continuation sheet, for 

each site describe any additional disposal methods that will be used and whether the waste is subject 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 if entries in columns (4) and (5) are confidential business information (CBI). 

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

NPDES numbers of the POTW (Publici Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential business information (CBI). 

Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI 

Number released release 

(1) (2a) (2b) e.g. stack air Binding 

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

1 X X 

2 X X 

3 X X 

4 X X 

5 X X 

6 X X 

7 X X 

(7) Mark (X) the D POTW provide name(s) below: c D Navigable D Other - Specify provide NPDES # CBI 

destination(s) of ~ waterway 

releases to water. NO RELEASE TO WATER 

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

EPA FORM 7710-25 (Rev. 5-95) Page 9 
Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do not have to complete this 

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

section B for each type of processing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the 

typical operation 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. 

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

drums, rail cars, tank trucks, etc). On the diagram, identify by letter 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 of all 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 of release, 

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

these sites on a continuation sheet): 

1 

#of sites 

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

2. Worker Exposure/Environmental 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 (if in 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. 

( 1 0) -- 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 kg/batch). 

(12) --Describe media of release 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, if any, that will be used to limit the release of the new substance to the environment. 

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

(3), (5), (8), (11), (13) and (15) --Mark (X) this column if any of the proceeding entries are confidential business information (CBI). 

Letter #of CBI Duration CBI Protective Equip. I o/o in CBI Release Amount of CBI Media of Release CBI 

of Workers of Engineering Controls/ Form- Number New & Control 

Act- Exposed Exposure Physical Form and % ulation Substance Technology 

ivity new substance Released 

(I) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (lOa) (lOb) (11) (12) (13) 

(14) -- Byproducts: (15) 

D Mark (X) this box if you attach a continuation sheet, 

EPA FORM 7710-25 (Rev. 5-95) Page 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 PMN 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 of useful chemical components from wastes that would 

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

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 of the 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 of production and/or improved operation efficiency of the 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. 

EPA FORM 7710-25 (Rev. 5-95) Page II 
D Mark (X) this box if you attach a continuation sheet. 

Part III-- LIST OF ATTACHMENTS 

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

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

which it relates, if appropriate. Number consecutively the pages of the 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 Instructions Manual for guidance on 

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

version of any attachment in which you claim information as confidential. 

Attachment name Attachment Confipage number(s) dential 

Material Safety Data Sheet 13-16 

Physical Properties 17-18 

Manufacturing Process 19-20 X 

CAS I ES Report 21 X 

Chemical Identity Information 22-24 X 

Risk Assessment 25-26 X 

D Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number. 

EPA FORM 7710-25 (Rev. 5-95) Page 12 
MATERIAL SAFETY DATA SHEET 

A FAMILY OF SOLUTIONS 

VERTEX 60SR 

REVISION NUMBER: 0.1 REVISION DATE: 16/Sep/2008 

1. IDENTIFICATION OF THE SUBSTANCE I PREPARATION AND COMPANY I 

UNDERTAKING 

PRODUCT NAME: 

MANUFACTURER: 

VERTEX 60SR 

J.M. Huber Corporation 

1 000 Parkwood Circle Suite 1 000 

Atlanta, GA 30339 

Tel: 678-247-7300 

EMERGENCY TELEPHONE: CHEMTREC: 800424-9300 or 703-527-3887 International 

INTERNET: www.hubermaterials.com. 

2. HAZARDS IDENTIFICATION 

EMERGENCY OVERVIEW: This is a non-combustible, odorless white powder. 

POTENTIAL HEALTH EFFECTS: 

EYE CONTACT: Dust may cause mechanical irritation to eyes. 

SKIN CONTACT: Dries skin and mucous membranes. 

INHALATION: Inhalation of dust may cause respiratory tract irritation. 

CARCINOGENICITY: This product is not listed as a carcinogen by the IARC, NTP or OSHA. 

3. COMPOSITION /INFORMATION ON INGREDIENTS 

%W/W 

100 

4. FIRST AID MEASURES 

EYE CONTACT: Hold eyelids apart and flush eyes with a steady, gentle stream of water for several minutes. 

SKIN CONTACT: Wash skin with soap and water. 

INHALATION: Remove person to fresh air. 

GENERAL ADVICE: In case of doubt or when symptoms persist, seek medical attention. 

VERTEX 60SR 1/4 
5. FIRE-FIGHTING MEASURES 

EXTINGUISHING MEDIA: Non-combustible. All extinguishing media can be used. Use suitable media appropriate for 

the surrounding fire. 

UNSAFE EXTINGUISHING MEDIA None. 

SPECIAL EXPOSURE HAZARDS: None. 

SPECIAL PROTECTNE EQUIPMENT: Firefighters should wear protective clothing and use equipment that is suitable for 

the materials involved in the surrounding fire. 

6. ACCIDENTAL RELEASE MEASURES 

PERSONAL PRECAUTIONS: Avoid dust formation. In case of exposure to high levels of airborne dust, wear a personal 

respirator in compliance with national legislation. 

ENVIRONMENTAL PRECAUTIONS: This product does not present any particular risk to the environment. Refer to 

applicable national, state and local regulations prior to washing in drain. 

CLEAN UP METHODS: Collect mechanically and or by ftushing with water. Avoid dry sweeping. Use water spraying or 

ventilated vacuum system to prevent dust formation. 

7. HANDLING AND STORAGE 

HANDLING: Avoid dust formation. Provide appropriate exhaust ventilation in places where dust is formed. In case of 

insufficient ventilation, wear suitable respiratory equipment. 

STORAGE: Store in a dry area. Keep containers closed and protect from physical damage. 

8. EXPOSURE CONTROLS I PERSONAL PROTECTION 

EXPOSURE LIMIT VALUES: 

COMPONENT{S) OSHA-TWA ACGIH TLV-TWA 

Magnesium Hydroxide. 10 mg/m3 10 mg/m3 

Respirable dust. 5 mg/m3 3 mg/m3 

Total dust. 15 mg/m3 10 mg/m3 

ENGINEERING CONTROLS: Use mechanical ventilation (dilution and local exhaust) to control exposure. 

EYE PROTECTION: Safety glasses with side shields. 

SKIN AND BODY PROTECTION: Use suitable protective clothing, gloves and footwear, selected with regard for use 

conditions and exposure potential. 

HAND PROTECTION: Impervious gloves chemical resistant. 

RESPIRATORY PROTECTION: In case of exposure to high levels of airborne dust, wear a respirator in compliance with 

national legislation. 

HYGIENE MEASURES: Handle in accordance with good industrial hygiene and safety practice. 

9. PHYSICAL CHEMICAL PROPERTIES 

VERTEX 60SR 2/4 
APPEARANCE: White powder ODOR: Odourless. 

pH: 8.4-10.2, 5% water suspension FLASH POINT: Non-combustible. 

DENSITY: 2.4 g/cm3, 20° C 

DECOMPOSITION TEMPERATURE: 200° C 

WATER SOLUBILITY: 11.7 mg/1 , 25° C 

10. STABILITY AND REACTIVITY 

STABILITY: Stable under ambient temperature (21 oc) and pressure (760 mm Hg). 

CONDITIONS TO AVOID: None 

MATERIALS TO AVOID: Strong Acids 

HAZARDOUS DECOMPOSITION PRODUCTS: None 

11. TOXICOLOGICAL INFORMATION 

ACUTE TOXICITY: No information available. 

EYE IRRITATION: Dust may cause mechanical irritation to eyes. 

SKIN IRRITATION: May dry skin and mucous membranes. 

SENSITIZATION: Does not cause sensitization. 

CHRONIC TOXICITY: No evidence of mutagenic, reproductive or carcinogenic effects. 

12. ECOLOGICAL INFORMATION 

ECOTOXICITY: No information available. 

13. DISPOSAL CONSIDERATIONS 

DISPOSAL: Dispose in accordance with local, state and national regulations. 

DOT: Not Regulated 

NFPA: 

HMIS: 

14. TRANSPORT INFORMATION 

15. REGULA TORY INFORMATION 

HEALTH: 1 

HEALTH: 1. 

FLAMMABILITY: 0 

FLAMMABILITY: 0. 

REACTIVITY: 0 

PHYSICAL HAZARD: 0. 

US TSCA: This product is not listed on the US TSCA Inventory and is to be used for Research and Development 

purposes under supervision of a technically qualified person. 

SARA 311/312 HAZARD: None 

SARA 313 SUBSTANCES: None 

CERCLA RQ: None 

VERTEX 60SR 
CLEAN AIR ACT: The components of this product are not regulated under any of the foUowing sections of the Clean Air 

Act: Section 111 Volatile Organic Compounds, Section 112 Hazardous PtM Polutants, Section 112 Statutory Air 

Pollutants, Section 112 High-Risk Pollutants, Section 112(r) Accidental Release Prevention Substances or Section 602 

Ozone Depleting Substance. As a powder prodlct, it would be regulated under Section 109 Criteria Pollutants 

particulates. 

PROPOSITION 65: This product contains no chemicals at levels known to the State of California to cause cancer or 

reproductive hazards. 

CO NEG: We certify that heavy metals defined as lead, mercury, cadmium and hexavalent chromium are not intentionally 

introduced to this product and with respect to lead, mercury, cadmium and hexavalent chromium, the incidental level of 

these four metals is less than 100 ppm. 

16. OTHER INFORMATION 

The information contained in this Safety Data Sheet to the best of J.M. Huber's knowledge and belief as of the date 

indicated is believed to be accurate and reliable. However, no representation, warranty or guarantee is implied or 

expressed regarding the accuracy, reliability or completeness of this information or the use of the product. Nothing 

contained herein should be construed as a recommendation to use this product in conflict with National or local 

regulations or existing patents covering any material or its use. 

END OF MATERIAL SAFETY DATA SHEET 

VERTEX 60SR 4/4 

~\1.-
PHYSICAL AND CHEMICAL PROPERTIES 

PROPERTY VALUE MEASURED CONFI 

OR ESTIMATE DENTIAL 

Physical state of Solid Observed 

neat substance 

Vapor pressure <0.1 mm Hg Usual for 

@20C minerals 

Density 2.36 g/cm3 Measured 

Solubility in Slightly Soluble Measured 

Water@ 20 C 

Flammability Flashpoint > Measured 

100 c 
i 

I 0 

I G) 

lj : = 

Of E :::s - () 

100 

80 

60 

40 

20 

Particle Size Distribution for Vertex 60 

(measured by Saturn DigiSizer® LLS instrument) 

0 

0.01 0.1 1 10 10

Diameter (microns) 

August15,2008 
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