HUNTSMA N 

Enriching lives through innovation 

RECEIVED 

OPPT CBIC 

20I3MAY 21 PH6--00 

May 17, 2013 OPPT-2011-0182 

By: EMAIL and FEDEX 

Ms. Katherine Sleasman 

U.S. EPA 

1200 Pennsylvania Ave. NW 

Mail Code 7405M 

Washington DC 20460 

Tel: 202-564-7716 

email: sleasman.katherine@epa.gov 

Dear Ms. Sleasman: 

As requested, attached is a sanitized version of the Substantiation Questions to 

accompany CBI information submitted in response to EPA's Voluntary information 

Request for Information Relating to Curing Rates for Polyurethanes Products". 

Sincerely, 

Monica Karamagi ( j 

Regional Marketing and Industry Affairs Manager 

Enclosure 

6 3 1 30000035/ S 

Company Sanitized 

10003 Woodloch Forest Drive, The Woodlands, Texas 77380 j 

Tel.: 281-719-6000 Fax.: 281-719-6416 www.huntsman.comi 

8QNNNSD& INDEXED ' 

BY: PAULA 
p. 2 

Responses to the Substantiation Questions to accompany Company 

Confidential document titled "Huntsman International LLC's Response to 

EPA's Voluntary Information Request for Information Relating to Curing Rates 

for Polvurethanes Products". 

1. Is your company asserting this confidential business information (CBI) claim on 

its own behalf? If the answer is no, please provide company name, address 

and telephone number of entity asserting claim. Yes 

2. For what period do you assert your claim(s) of confidentiality? If the claim is to 

extend until a certain event or point in time, please indicate that event or time 

period. Explain why such information should remain confidential until such 

point. 

We are requesting that this information be held confidential indefinitely, 

3. Has the information that you are claiming as confidential been disclosed to any 

other governmental agency, or to this Agency at any other time? No. 

4. Briefly describe any physical or procedural restrictions within your company 

relating to the use and storage of the information you are claiming CBI. 

5. If anyone outside your company has access to any of the information claimed 

CBI, are they restricted by confidentiality agreement(s). If so, explain the 

content of the agreement(s). 

6. Does the information claimed as confidential appear or is it referred to in any of 

the following: 

a. Advertising or promotional material for the chemical substance or the 

resulting and product; No 

b. Material safety data sheets or other similar materials (such as technical data 

sheets) for the substance or resulting end product (include copies of this 

information as it appears when accompanying the substance and/or product 

at the time of transfer or sale); No 

c. Professional or trade publications; No or 

Company Sanitized 
p. 3 

d. Any other media or publications available to the public or to your 

competitors. No 

If you answered yes to any of the above, indicate where the information 

appears, include copies, and explain why it should nonetheless be treated as 

confidential. 

7. Has EPA, another federal agency, or court made any confidentiality 

determination regarding information associated with this substance? If so, 

provide copies of such determinations. No 

8. Describe the substantial harmful effects that would result to your competitive 

position if the CBI information is made available to the public? In your answer, 

explain the causal relationship between disclosure and any resulting substantial 

harmful effects. Consider in your answer such constraints as capital and 

marketing cost, specialized technical expertise, or unusual processes and your 

9. Has the substance been patented in the U.S. or elsewhere? Is a patent for the 

substance currently pending? No 

10, Is this substance/product commercially available and if so, for how long has it 

been available on the commercial market? Yes. Huntsman has been selling 

MDI since 1999. The predecessor, ICI, has been selling MDI in Americas 

region since 1978. 

a. If on the commercial market, are your competitors aware that the substance 

is commercially available in the U.S.? Yes 

b. If not already commercially available, describe what stage of research and 

development (R&D) the substance is in, and estimate bow soon a market 

will be established. N/A 

Page 2 of 3 
p. 4 

11. 

c. What is the substance used for and what type of product(s) does it appear 

in. MDI, methylene diphenyl diisocyanate is used to produce a wide variety 

of commercial available polyurethane products e.g., rigid polyurethane foam 

for insulation, composite wood binders, automotive seating, furniture, 

bedding, appliance insulation etc. 

Describe whether a competitor could empio> 

recreate the substance? 

to identical 

12. Do you assert that disclosure of this information you are claiming CBI would 

reveal: 

a. confidential processes used in manufacturing the substance; Yes -

confidential formulas are listed in some cases 

b. if a mixture, the actual portions of the substance in the mixture; Yes - see 

above or 

c. information unrelated to the effects of the substance on human health or the 

environment? Yes, the confidential information is unrelated to human health 

or environmental effects. 

If your answer to any of the above questions is yes, explain how such 

information would be revealed. Chemical formulas and customer identities are 

disclosed in many cases. 

13. Provide the Chemical Abstract Service Registry Number for the product, if 

known. Is your company applying for a CAS number now or in the near future? 

If you have applied for a CAS number, include a copy of the contract with CAS. 

No 

MDI-101-68-8 

Polymeric MDI - 9016-87-9 

14. Is the substance or any information claimed CBI the subject of FIFRA 

regulation or reporting? If so, explain. No 

Page 3 of 3 
p. 5 

Moseley, Pamela 

From: 

Sent: 

To: 

Subject: 

Attachments: 

Sleasman, Katherine 

Monday, May 20, 2013 9:27 AM 

Moseley, Pamela 

FW: Huntsman International LLC's Sanitized Version of the Substantiation Questions- Docket 

- EPA-HQ-OPPT-2011-0182 

Sanitized Version of the Substantiation Questions.pdf 

FYl - For your records. 

-Katherine 

from : Michelle M Koenig rmailto:michelle m koenia@huntsman.com] 

Sent: Friday, May 17, 2013 6:07 PM 

To: Sleasman, Katherine 

Cc: Monica N Karamagi 

Subject: Huntsman International LLC's Sanitized Version of the Substantiation Questions 

Submitted on behalf of Monica Karamagi of Huntsman International LLC. 

l