11111111111111 11I11III SANITIZED SUBMISSION 

PMN2011P1 PMN Page 1 

Form Approved. 12 and 2070-0038 

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY 

@E F IIIIIIIJIII1!1111,~lli !IIIIIIIIIIII~ 1111111111111111111)1111!IIII~ I' III: 

When 

completed, 

send this 

form to 

.. 

EPA, tzut conSlltUllon Ave .... ASHINGTON, D.C. 20460 ntact Numbers: 202-564-8930119.40 

Submission Re ort Number 

AG-E110202924773944 

Total Number of Pa es User Fee Pa ment 10 Number TS Number 

39 3800016053 AG1002 

GENERAL INSTRUCTIONS 

• 	 You must provide alllntomlation requested In 11111 form \0 the e)(\ent that it Is known 10 or reasonably ascertainable by you. Make reasonable estimates if you do not, have adual data. 

• 	 aefore you complete this form, you should read \he 'Instructions Manual for PremanufaClUre Notification" (tho Instructions Manual i$ available from the Toxic Substances Control At;. 

(TSCA) Information SeNlce by ceiling 202-554-1"04, or fal<ing 202.554-56(3). 

• 	 If a user fee has been remitted for Ihi$ notice (-'0 CFR 700.45), Indicate In the boxes above the T5-user fee identificetion number you have generated. Remember, your user fee 10 number 

mUM also appear on your corresponding fee remittance. For m8l'ing address information see \he Help instructions in the e-PMN tool. 

Part 1- GENERAL INFORMAnON 

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 anotlher 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. For all 

Section 5 Notice submissions (paper or electronic) you must 

submit an original notice including all test data; if you claimed any 

information as confidential. an original sanitized copy must also be 

submitted. 

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL 

RELEASE 

Ifthere are several manufacture. processing, or use operations \0 

be described in Part II. sections A and B of this notice, reproduce 

the sections as needed. 

Part 111- LIST OF ATTACHMENTS 

For paper submissions, attach additional sheets ifthere is not 

enough space to answer a question fully. Label each continuation 

sheet with the corresponding section heading. In Part III. list these 

at1achments, 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 11 of this form. space has 

been provided for you to describe pollution prevention and 

recycling information you may have regarding the new substance. 

"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 ... The intention is to reduce delays that routinely 

accompany the development of consent orders or Significant New 

Use Rules. CheCking a "binding" box in a PMN does not by itself 

prohibit the submitter from later deviating from the information 

(except chemical identity) reported in the form; however, in the 

case of exemption applications (such as TMEA, LVE. LOREX) 

certain information prollided in such notifications is binding on the 

submitter when the Agency approves the exemption application, 

especially if the production volume "binding" box is chosen in a 

LVE. 

CONFIDENTIALITY CLAIMS 

You may claim any information in this notice as confidential. To 

assert a claim on the form. mari{ (X) the confidentiat box next to 

the information that you claim as confidential. To assert a claim in 

an attachment, circle or bracket the information you claim as 

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 manufaclure, 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 jfthey do not appear jn the ooen 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 Premanufadure Notification Rule (40 CFR Part 720). 

Test Data (Check Below any Included In this notice) 

o 	Environmental fate data 	 o other Data

o 	Health effects data 	 o Risk Assessments 

o 

Enllironmental effects data Structure/activity relationships 

Physical/Chemical Properties (A physical and chemical properties worksheet is 

o 	 o 

located on the last page of this form.) 

o Test data not in the possession or control of the submitter 

TYPE OF NOnCE (Check Only One) 

o PMN (Premanufaclure Notice) 

o SNUN (Significant New Use Notice) 

o TMEA (Test Marketing Exemption Application) 

o LVE (Low Volume Exemption) @ 40 CFR 723.S0(c)(1) I""-..) 

o 	 C) 

LOREX (Low Releasellow Exposure Exemption) @ 40 CFR ~0(c)(2) 

o --" 

LVE Modification 

o LOREX Modification 

o Mock SubmiSSion 

o Mark (X) if pending Letter of Support 

IS THIS A CONSOLIDATED PMN (YIN)? 

conlidential. If you claim information in the notices as conlidential, 

you must also provide a sanitized version of the notice (including 

attachments). For additional instructions on claiming information 

as confidential, read the Instructions Manual. 

# of chemicals or polymers (Prenotice Communication # required, enter # on 

p.3). 

Marl< (X) if any information in this notice is claimed as confidential. 

EPA FORM 7710·25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

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PMN2011P2 	 PMN Pa e 2 

The public reporting and recordkeeping burden for this collection of infonnation is estimated to average 93 hours per response. Send 

comments on the Agency's need for this infonnation, the accuracy of the provided burden estimates. and any suggested methods for 

minimizing respondent burden. including through the use of automated collection techniques to the Director, Collection Strategies 

Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB 

•control number in any correspondence. Do not send the completed EPA Fonn 7710-25 to this address. 	 . 

• CERTIFICATION -- A printed copy of this signature page, wi~ original signature, must be submitted 

with CD or paper submission. 

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

1. The company named in Part I, section A, subsection 1a ofthis notice form intends to 


manufacture, import or process 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: 

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

The Company named in Part I, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @40 CFR 700.43) in o accordance with 40 CFR 700,45(b). or 

The Company named in Part I Section A is a small business concem under 40 CFR 700.43 and has remitted a fee of $100 in o accordance with 40 CFR 700.45(b). 

If you are submitting a Low Volume Exemption (LVE) 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: 

The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, o other than in small quantities solely for research and development, under the terms of 40 CFR 723.50. 

o The manufacturer Is familiar with the terms of this section and will comply with those terms; and 

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

If this application is for an LVE in accordance with 40 CFR 723.50(c)(1). the manufacturer intends to commence manufacture of o the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period. 

The accuracy of the statements you make in this notice should reflect your best prediction of the 

Confidential 

· misrepresentation is subject to criminal penalty pursuant to 18 USC 1001. 

Signature and title of 

• antiCipated facts regarding the chemical substance described herein. Any knowing and willful 

Date 

· Signature Required) 

• Authorized Official (Original 

EPA FORM 7710-25 (Rev. 6-09) 	 Replaces previous editions of EPA Form 7710-25 
1111111111111' 11I~1I1111 SANITIZED SUBMISSION 

PMN2011P3 PMN 3 


I:li'lr!,ne] 

I • 

Mali< (X) the '-'Or box neX!: to any "ubsection you claim as I 

1a. rt:n:.ufI ~,' Notice (in U.S.) 

Name of Authorized Official (first) XXX (last) XXX 

: Position XXX : 

Company XXX 00 i Mailing Address (number & street) XXX 

! City XXX I State IPostal Code XXX 

: email XXX 

b. Agent (if Applicable) 

Name of Authorized Official (first) (last) 

: Position 

Company 

i Mailing Address (number & street) D

r City l State IPostal Code 

ie-mail li~;;;~d~'~~ea code) i 

c. Joint Submitter (if t) l,;O~IIUtmlli:1I 

i If you are submitting this notice as part of a joint submission, mali< (X) : I [ ] 

Name of Authorized Official (first) (last) 

Position 

Company D • Mailing Address (number & street) 

I City IStale IPostal Code 

! e-mail Telephone 

(include area code) 

2. T........... co ..... ~) ,",U' IIIUC'"'''' 

i Name of Authorized Official (last) XXX 

I Position XX 

Company XXX 

Mailing Address (number & street) 00 XXX 

i City XXX IState IPostal Code XXX 

i 

e-mail XXX :i~~~~~';;~~ea codel XXX 

If you have had a prenotice communication (PC) concerning XXX Mark (X) if none l,;OI"lIlUC'IUCI' 

3. this notice and EPA assigned a PC Number to the notice, 

enter the number. D 00

If you previously submitted an exemption application for the xxx Mark (X) if none CorIllYC'IU'" chemical substance covered by this notice, enter the 

: 4. exemption number assigned by EPA. If you previously 

submitted a PMN for this substance enter the PMN number D 00

assiQned by EPA (I.e, I or incomoletel. 

If you have submitted a notice of Bona fide intent to XXX Mark (X) if none ConiiaenIlal 

5. manufacture or import for the chemical substance covered 

by this notice, enter the notice number assigned by EPA. D 00

6. Tvpe of Notice - Mark (X) 

Manufacture Only D Import Only [XJ 1. 

Binding Option 

2. 3. Both D D Binding Option D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Fo~ 7710-25 


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1. Class 1 or 2 chemical substances (for definitions of class 1 and class 

2 substances, see the Instructions Manual) 

a. Class of substance - Mark 

Class 1 

o 

SANITIZED SUBMISSION 

o 

Class 2 CBI 

o o 

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar 0 

substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA 

on current CA rules and 

Enter Attachment filename for Part I. Section B. 1. e. 

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PMN2011P4A PMN Page4a 

For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe 

the nature ofthe reaction or process. (3) Indicate the range of composition and the typical composition (where appropriate). Confidential 

e. (1) List the immediate precursor substance names with their respective CAS Registry Numbers. D 

Enter Attachment filename for Part I, Section B, 1. e. (1) D e. (2) Describe the nature of the reaction or process. D 

Enter Attachment filename for Part I. Section B. 1. e. (2) I D e. (3) Indicate the range of composition and the typical composition (where appropriate). D 

Enter Attachment filename for Part I, Section B. 1. e. (3) I D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 


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PMN2011P5 PMNPageS 

Part I -- GENERAL INFORMATION - Continued 

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued 

2. Polymers (For a definition of polymer, see the Instructions Manual.) Confidential 

a. Indicate the number-average weight ofthe 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) IX]

below 500 and below 1,000 absolute molecular weight of that composition. 

Describe the methods of measurement or the basis for your estimates: 

GPC D I Other (Specify Below) D I 

Specify Other: 

(i) lowest number average molecular (ii) maximum weight % below 500 molecular (iii) maximum weight % below 1000 molecular 

weight: weight: weight: 

XXX XXX XXX 

Enter Attachment filename for Part I. Section S, 2. a. I [ ] 

b. You must make separate confidentiality 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 

(1) - 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) - Choose ·yes· from drop down menu 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. 

(7) - Mark (Xl this column if entry in column (6) is confidential. 

Monomer or other reactant specific chemical name Typical Incl Max 

CSI composition identity residual CSI (1) (2) '(3) (4) (6) (6) (71. 

XXX X XXX X XXX X 

CAS Registry Number (1) IXXX 

XXX X XXX X XXX X 

CAS Registry Number (1) IXXX 

XXX X XXX X XXX X 

CAS Registry Number (1) IXXX 

XXX X XXX X XXX X 

CAS Registry Number (1) IXXX 

XXX X XXX X XXX X 

CAS Registry Number (1) IXXX 

Mark (X) this box if the data continues on the next page. [XJ 

EPA FORM 7710-25 (Rev, 6-09) Replaces previous editions of EPA Form 7710-25 


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PMN2011 P5-1 PMN Page 5 (1) 

Part 1-- GENERAL INFORMATION - Continued 

Section B .- CHEMICAL IDENTITY INFORMATION - Continued 

2. Polymers (For a definition of polymer. see the Instructions ManuaL) Confidential 

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

below 

Indicate 

500 

maximum 

and below 

weight 

1 000 

percent 

absolute 

of low 

molecular 

molecular 

weight 

weight 

of that 

species 

composition. 

(not including residual monomers. reactants. or solvents) D

DeScribe the methods of measurement or the basis for your estimates: 

GPC D I Other (Specify Below) D I 

Specify Other: 

(i) lowest number average molecular (ii) maximum weight % below 500 molecular (iii) maximum weight % below 1000 molecular 

weight: weight: weight: 

Enter Attachment filename for Part I, Section B. 2. a. I l J 

b. You must make separate confidentiality 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 

(1) - 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) - Choose "yes" from drop down menu 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. 

(7) • Mark (X) this column if entry in column (6) is confidential. 

Monomer or other reactant specific chemical name 

~ Typical Include in Max 

n identity CBI residual CBI (1) (3) (4) (5) (6) (7) 

XXX X XXX X XXX X 

CAS Registry Number (1) IXXX 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

CAS Registry Number (1) I 

Mark (X) this box if the data continues on the next page. D 

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PMN2011P5A PMN Page 5a i c. Please identify which method you used to develop 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 obtained 

from CAS Inventory Expert Service must be 

submitted as an attachment to this notice) 

Enter Attachment filename for Part I, Section B, 2. c. 

IES Order 

Number 

151056-2 

(other source) 

Method 2 D 

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

polymers. 

xxx 

CAS Registry Number (if a number already exists for the substance) xxx 

CSI 

D 

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

ascertained. 

Enter Attachment filename for Part I, Section B, 2. e. D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 


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PMN2011P6 PMN Page 6 

Part I -- GENERAL INFORMATION -- Continued 

Section B -- CHEMICAL IDENTITY INFORMATION - 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 impurities, estimate their total weight %. 

CAS Registry Maximum Confi- Impurity (a) Number Percent % dential Cal Cb) 

XXX XXX XXX X 

XXX XXX XXX X 

I 

Mark (X) this box if the data continues on the next page. D I·c';~~(;f~'t 

Enter Attachment filename for Part I, Section B, 3. I D 

4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. 

none D 

Enter Attachment filename for Part I. Section B. 4. I D 

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2. 

XXX [R] 

Enter Attachment filename for Part I. Section B. 5. I [ ] 

6. Generic chemical name - If you claim chemical identify as confidential. 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 B for guidance on developing generic names. 

Perfluoroalkylethyl methacrylate copolymer. salt. 

Enter Attachment filename for Part I. Section S, 6. I 

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

CAS Registry Number if available. 

Byproduct (1) CAS Registry Number Confi­

(2) dential 

XXX XXX X 

Mark (X) this box if the data continues on the next page. [ ] 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 


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PMN2011P7 PMN P age 7 

Part I -- GENERAL INFORMATION -- Continued 

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

The Information on this page refers to consolidated chemical number(s): J1 [ J 2 [ 3 J4 [ 5 J6 

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 kgfyr, specify the 

I volume and mark (x) in the binding box. If granted, you are bound to this volume. 

Maximum first 12-month production (kglyr) Maximum 12-month production (kglyr) Confidential Binding Option 

(100% new chemical substance basis) (100% new chemical substance basis) Mark (X) 

XXX XXX [Xl D 

Enter Attachment filename for Part I, Section C, 1. I eBI [ J 

2. Use Information ­ You must make separate confidentiality daims 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. (1) -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 (1) 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 entry(jes) in column (8) is (are)"confidential business information (CBI). 

Category of use (1) Binding Prod "loin 0/0 of substance expected per use 

(by function and application i.e. a dispersive dye for CBI Option uction CBI Form- CBI (8) CBI 

finishing polyester fibers) Mark (X) % ulation Si!~ Con- I_rial Com· Bi'lding 

(2) (3) (4) (6) (6) (7) Iimlcd sumer' mercia! Option (9) 

XXX X XXX X XXX X XXX XXX XXX XXX X 

I 

• 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 in dude 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. 

Mark (X) this box if the data continues on the next page. D 

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

description Read the Instruction Manual for examples of generic use descriptions. 

I Paper treatment 

... 

I Enter Attachment filename for Part I, Section C, 2. b. I eBI D 

3. Hazard Information - Indude in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety 

data sheet, or other information which will be provided to any person who is reasonably likely to be exposed to this substance Binding Option 

regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part ((( Mark (X) 

hazard information you indude. 

Mark (X) this box if you attach hazard information. [R] 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 


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PMN2011P8 

Complete section A for each type of re, processing, or use operation the new 

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 processing or use operations after import. You must describe these operations. See 

1. 

xxx 

Name 

Site address (number and 

street) 

City 

the site at which the will occur. 

County 

ZIP code 

the number of sites. Identify the additional 

significantly different production rates or 

as 

D Use 

c. Amount and Duration ­ Complete 1 or 2 as appropriate 

Hoursfbatch 

1. Batch 

Hours/day 

2. Continuous 

d. 

steps transport 

pails, 55 gallon drum, car, tank truck, etc.). 

D 

Batcheslyear 

Oays/year 

Confidential 

D 

D 

D 

D 

D 

(2) Provide the identity, the approximate weight (by kgfday or kgfbatch 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) by number the points of release, including small or intermittent releases, to the environment ofthe new chemical substance. If 

to two media at the same a second release number for the medium. 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 

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PMN2011P8A PMNPage 8a 

Diagram ofthe major unit operation steps. 

Confidential 

D 

Enter Attachment filename for Part II, Section A, 1. d. I [ ] 

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PMN2011P9 PMN Page 9 

Part 11- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

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

The Information on pages 9 and 9a refer to consolidated chemical number(s): 01 l 2 l J3 04 l 5 [ ] 6 

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

substance, number of workers exposed, and duration of activity. Mark (X) the ·Confidential' box next to any item you claim as confidential. 

(1) - Describe the activities (Le. 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 infonnation provided in column (3) or (5) binding. 

(5) - Indicate the physical fonn(s) of the new chemical substance (e.g., solid: crystal, granule. powder, or dust) and % new chemical substance flf 

part of a mixture) at the time of exposure. 

(7) - Mark (X) this column if entries in columns (3) and (5) are confidential business infonnation (CBI). 

(8) - Estimate the maximum number ofworkers 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 infonnation (CBI). 

Worker activity Protective Equipment! Binding Physical Binding #of Maximum Duration (I.e., bag dumping. filling CBI OptIon form(s) Option CBI Workel"ll CBI CBI 

drums) Engineering Controls MarklXl &%new Mark IX} Exposed substance Hrs/Day OayslYr (121 (11 (21 (31 (41 {51 (61 (71 (8) (9) (101 (ii) 

Mark (X) this box if the data continues on the next page. I I 

Enter Attachment filename for Part II, Section A on the bottom of page 9a. 0 

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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. 

(1) -­ Enter the number of each release point Identified in the process description, part II, section A, subsection 1 d(3l. 

(2) -­ Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kglbatch). 

(3) -­ Mark (X) this column if entries in columns (1) 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 (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential 

business information (CBI). 

Release Amount of New Medium of release Control technology and efficiency (you may wish to 

Number Substance Released CBI e.g. Stack air optionally attach efficiency data) CBI 

(4) 

Binding 

(1) (6) (2a) (2b) (3) (Sa) Mark (5b) 

(X) 

• 

Mark (X) this box if the data continues on the next page . D 

• (7) Mark (X) the destination(s of releases to water. NPDES# eBI 

D POTW-provide 

name(s) D

D Navigable waterway-

- provide name(s) D

D Other-Specify D 

Enter Attachment filename for Part II, Section A. I 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 


Page 14 

111111111111111111111111111111111111111111111111111111111111 SANITIZED SUBMISSION 

PMN2011P10 PMN Page 10 

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued 

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 

The Information on pages 10 and 10a refer to consolidated chemical number(s): 01 02 03 04 [J 5 l J6 

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 ofproceSSing, or use operation Involving the new chemical substance. If the same operation is perfonned at 

more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet. 

1(a). Operation Description ­ To claim infonnation in this section as confidential, bracket (e.g. {}) the specific infonnation 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 

palls, 55 gallon drums, raiJ cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. 

(2) -­ Either in the diagram or in the text field 1 (b) below, provide the identity, the approximate weight (by kg/day or kgibatch, 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 daiJy or per batch). 

(3) - Either in the diagram or In the text field 1 (b) below, identify by number the points of release, including small or intennittent 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): 

I Number of Sites I I Confidential 0 

1(b). (OptionaQ This space is for a text description to clarify the diagram above. Confidential 

XXX 

Enter Attachment filename for Part II, Section B on the bottom of page 10a. I o 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Fonn 7710-25 

Page 15 
11111111111111111111I 	 SANITIZED SUBMISSION 

PMN2011P10A 	 PMN Pa e 10a 

2. Worker ExposurelEnvironmental Release 

(1) -	 From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. 

(2) --	 Estimate the number ofworkers 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. 

(10) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment On 

kg/day or kglbatch). 

(12) - D esen 'b e me d' la 0 f re I ease I.e. s tack air, ' fu gl 'ti ve air . ( op ti ona -see I ns truct' Ions M anua I) • su rf ace wa er. on-sl 't e or 0 ff -Sl 't e an I d or InClnera rlon, 

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 bypro ducts 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 Duration of Protective Equlp./Englneerlng ControlslPhyslcal % new %In of Workers CSI CSI CSI 

Activity Exposed Exposure Form substance Formulation 

(1) (2) (3) (4a) (4b) (6) (6) (6) (7) (8) 

Release Amount ofNew Substance Released CBI Media of Release & Control Technology CBI Number 

(9) (10a) (10b) (11) (12) (13) 

Mark (X) this box if the data continues on the next page, D 

(14) Byproducts: I (15) CBI D 

Enter Attachment filename for Part II. Section B. D 

" 

EPA FORM 7710-25 (Rev. 6-09) 	 Replaces previous editions of EPA Form 7710-25 

Page 16 
PMN201 P11 

11111111111111 111111I1111111111111111 SANITIZED SUBMISSION 

PMN Page 11 

OPTIONAL POLLUTION PREVENTION INFORMATION 

To claim infonnation in the following section as confidential, bracket (e.g. mthe specific infonnation that you claim as confidential. 

In this section you may provide infoonation not reported elsewhere in this fonn 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 infonnation 

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 refonnulation, and/or raw materials substitution. 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. Quantitative or qualitative 

descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction in addition to compliance with existing 

regulatory requirements. The EPA is interested in the infonnation to assess overall net reductions in toxicity or environmental releases and 

exposures, not the shifting of risks to other media (e.g., air to water) or nonenvironmental areas (e.g., occupational or consumer exposure). To the 

extent known, infonnation about the technology being replaced will assist EPA in its relative risk detennination. In addition, infonnation on the 

relative cost or perfonnance characteristics of the PMN substance to potential alternatives may be provided. 

Describe the expected net benefits, such as 

(1) an overall reduction in risk to human health or the environment; 

(2) a reduction in the generation of waste materials through recycling, source reduction or other means; 

(3) a reduction in the use of hazardous starting materials. reagents, or feedstocks; 

(4) a reduction in potential toxicity, human exposure and/or environmental release; or 

(5) 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. 

Infonmation provided In this section will be taken Into consideration during the review of this substance. See PMN Instructions Manual 

and Pollution Prevention Guidance manual for Quldance and examples • 

••*******......******••*************** CONFIDENTIAL - CBI............ ........••• ....... ** **··..••...........·***...··*****.....**····· 

It is anticipated that the PMN substance will replace conventional telomer-based perfluorinated polymeric compounds currently used in paper 

treatments and coatings. These compounds consist of C-8, C-10, C-12, and higher chain length components. Concems have been raised 

regarding PFOA and its precursors because of their apparent toxicity, perSistence, and ability to bioaccumulate.ln contrast, the PMN substance 

dose not contain polymeric materials or impurities with chain lengths greater than six carbons and, as a result, presents a more favorable risk 

profile than conventionally marketed telomer-based products by eliminating any potential for environmental release of perlluorinated carboxylic 

acids of chain lengths> C-6. 

In addition, the low level of impurities in the PMN substance and the likelihood that the polymeric side chain will not degrade implicate a low 

potential for environmental release of the potential breakdown product. perlluorohexanoic acid (PFHA or C~ acid) . 

••*****.........................******. CONFIDENTIAL ­ CBI·**··...,...•••..••... ••• ... ·····*******··············...•••..···**** 

Enter Attachment filename for Pollution Prevention Page 11. o 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Fonn 7710-25 

Page 17 
SANITIZED SUBMISSION 

I-'MNZ0111-'1Z PMNPage 12 

Part III -- LIST OF ATTACHMENTS 

Attach continuation sheets for sections of the form, 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 any paper attachments. In the Number of Pages column 

below, enter the inclusive page numbers of each attachment for paper submissions or enter the total number of pages for each 

attachment for electronic submissions. Electronic attachments can be identified by filename. 

Mark (X) the "Confidential" box next to any attachment name or filename 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. 

Number Associated 

# Attachment Name Attachment Filename of Pages PMN Section eBI 

Number 

001 IES Report 1 Pt.l, Sec.B, 2c. 1$'" ",,<om 1 Pt.l, Sec.B, 2e. 

6 

1004 Manufacturing Process Description 1 

005 Determination of impurities 4 

006 Additiona! Data Relevant to the PMN 1 

Mark (Xl this box if the data continues on the next page. D 

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25 


Page 18 

I I 111111111111111111 
 11111111 SANITIZED SUBMISSION 

PMN2011P13 PMNPage 13 


PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET 

mation on this page refers to chemical number(s): 01 02 03 04 05 [ J6 

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and include it in the 

notice. Identify the property measured, the value of the property, the units in which the property is measured (as necessary), and whether or not the 

property is claimed as confidential. Give the attachment number (found on page 12) in column (b). The physical state of the neat substance should be 

provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or 

formulations should be so noted (% PMN SUbstance in _). You are not required to submit this worksheet; however, EPA strongly recommends that 

you do so, as it will simplify the review and ensure that confidential information is properly protected. You should submit this worksheet as a 

supplement to your submission of test data. This worksheet is not a substitute for submission of test data. 

Property Unit I Mark X if Attachment Value Measured eBI 

Number or Estimate Mark (X) (a) Provided (b) (c) CM orE) (d) 

0 (solid) I (liquid) (gas) 

Physical state of neat substance 0 0 0 

Vapor Pressure @ ·e Torr Temperature 

Density/relative density 0 g/cm3 

Solubility 

@ Temperature ·c 0 giL 

Solvent 

Solubility in Water @ ·c 0 giL Temperature 

Melting Temperature ·c 

Boiling / Sublimation Torr 0 ·c 

temperature @ 

Spectra 0 

DiSSOCiation constant I I 

Octanoll water partition coefficient 0 

Henry's Law constant 

Volatilization from water 0 

Volatilization from soil 0 

pH@ concentration 0 

Flammability 

ExpJodability 0 

Adsorption I Coefficient 

Particle Size Distribution 0 

! 

Other - Specify ! 

Page 19 

ATTACHMENT HEADER SHEET 


Attachment Number 001 

Attachment Name 


IES Report 


Associated PMN Section Number 

Ptl, Sec.B, 2c. 

Does not contain eBI 

Report Number 


AG-E11 0202924773944 

•• • •• • ••••••• 

··· . ern® 

• Inven,oryExpert"Se'rvide

. " AdMslon of the AmerIcan Chemleal Sodety Phone: 8QO.63f.188lf. 61+447-3870 

fale 614447.-37"'7­

E-maIl:lftswel'1@ca.t.~tg 

W.www.cu.<qf~/(llentl 

,. 

I 

INVENTORY EXPBRT,SERVICE REPOR~ 

It. tJd.1iII .ho]( b c~$ukad, CAS hais m&48 correc;Jt;!QJ:l.Ca) J1'IIU:MQ iu t'e4 to 

yoU%' DB odu. ,lA'.e make t.ha I_G CloZ'Z'ooeJ.on(s) to yoUlL' l'MN belon 

auhzd.ttlZlg it to tile &PA. 

" . 

P"Q. 80)( ]34] 
ATTACHMENT HEADER SHEET 


Attachment Number 002 

Attachment Name 


Structural Diagram 


Associated PMN Section Number 


Pt.I, Sec.B, 2e. 


Does not contain eBI 

Report Number 


AG-E110202924773944 


ATTACHMENT HEADER SHEET 


Attachment Number 003 

Attachment Name 

MSDS 

Associated PMN Section Number 

N/A 

Does not contain eBI 

Report Number 

AG-E110202924773944 

Inhaling fumes or mists may irritate the respiratory organs. (Cough, discomfort. labored breathing 

etc.) 

Additional hazards information for humans and environment 

Inhaling fumes or mists from overheating fluoropolymers may cause lung irritation and "polymer 

fume fever" a temporary flu-like illness. 

4. FIRST AID MEASURES 

• 	 Inhalation: Ifinhaled, remove the affected individual immediately to fresh air. 

Call a physician ifrespiratory irritation develops or if breathing becomes difficult. 

• 	 Skin contact: Wash affected areas with plenty of water and soap for several minutes. Call a 

physician if irritation develops. 

• 	 Eye contact: First rinse eyes with water. Remove any contact lenses, and continue washing 

with running water for at least 15 minutes. Call a physician if irritation develops. 

• 	 Ingestion: If swallowed seek medical immediately and show the doctor packing or label. 

Give 3-4 glasses of water, but do not induce vomiting. If vomiting continues, give water 

again. Do not give anything to an unconscious or convulsing person. 

5. FfRE..FIGHTING MEASURES 

• 	 Suitable extinguishing media: Use dry chemical, alcohol-resistant foam, water spray or 

carbon dioxide for surrounding fire. 

• 	 Unsuitable extinguish media/methods: none 

• 	 Hazardous combustion product or gases: This product is non-flammable. However, if 

involved in a fire or if overheated (>220deg.C(>428deg.F», there is a risk ofgeneration of 

toxic degradation products such as: hydrogen fluoride, carbonyl fluoride, carbon monoxide, 

and carbon dioxide. Between 425-450deg.C (797deg.F- 842deg.F), toxic particulate with a 

size of O.2-0.5um may be generated by heat degradation. Over 470deg.C (878deg.F), 

perfluoro isobutylene may be generated by heat degradation. 

• 	 Special protective equipment for fire fighters: Wear self-contained breathing apparatus in 

confined areas or when exposed to combustion products. 

• 	 Additional information: Move container from fire areas if it can be done without risk. 

Cool containers with water spray. Fire residues and contaminated firefighting water must be 

disposed of in accordance with the local regulations. 

6. ACCIDENTAL RELEASE MEASURES 

Personal precautions: 

Ensure adequate ventilation. 

Use personal protective clothing 

Environmental precautions: 

Collect contaminated water/firefighting water separately. 

Do not wash away into shower or waterway. 

Methods for cleaning up/taking up: 

Take up with absorbent material (e.g. sand, general-purpose binder) 

Additional information: 

Information for safe handling looks up chapter 7. 

Information for disposal looks up chapter 13. 

7. HANDLING AND STORAGE 
Handling 


Avoid contact with eyes. 


Avoid circumstances that release respirable particles. , 


For spray applications, use a coarse spray device such as trigger sprayer or pressurized dispenser 


with particle size production of greater than 15 microns. 


Adjust spray pressure to keep particle size greater than 15 microns. DO NOT aerosolize or atomize. 


Suitable ventilation must be used during application. 


Do not breathe spray. During fumigation/spraying wear suitable respiratory equipment 


Storage 


Keep container tightly closed. Keep away from heat, and sunlight. 


Avoid contact with heat (>40 0C) when in storage. 


Storage temperature range: 5-40deg.C (41 deg.F - 104deg.F). 


Ifmaterial freezes, gently thaw prior to use. Mild agitation may be required. 


8. EXPOSURE CONTROL I PERSONAL PROTECTION 

Ingredients with occupational exposure limits to be monitored 

N/A 

Exposure controls 

Occupational exposure controls 

Engineering Controls: 

Use suitable ventilation to remove spray mists and vapor or fume generated by applications where 

the fluoropolymers will be exposed to elevated temperatures. 

Personal protection: 

• 	 Respiratory protection: An air purifYing respirator with organic vapor cartridge or canister. 

Use NIOSH approved respirator where there is likelihood of 

inhalation ofthe product mist. 

Acetic acid has TWA, if its concentration is greater than the 

exposure limits, use protective equipment. 

• Skin protection: Protective gloves 

• Eye protection: Chemical goggles 

Additional recommendations: An eyewash and safety shower should be nearby and ready for use. 

Hands should be washed thoroughly after handling. . 

9. PHYSICAL AND CHEMICAL PROPERTIES 

• Appearance and Odor: Pale Yellow to Brown Liquid, acetic acid odor 

• pH value (25 deg.C): 2.1-2.4 

• Boiling Point: ca.100deg.C (212deg.F) 

• Melting Point: NID 

• Flash Point (method): >100deg.C (212deg.F) nonflammable 

• Auto Flammability: NID 

• Ignition Temperature: NID 

• Flammability: NID 

• Explosive Limits: (lower) N/A, (upper) N/A 

• Oxidizing Properties: Non-oxidizing 

• Vapor Pressure (20deg.C): NID 

• Specific gravity (25deg.c): 1.05-1.11 

• Solubility (20deg.C) in water: Dispersible 
10. STABILITY AND REACTIVITY 

Conditions to avoid: 

Avoid contact with heat. 

Avoid long storage periods in more than 40deg.C (l04deg.F) since the product degrades with age. 

Stability: Stable under normal temperature and pressure. 

Materials to avoid (lncompatibilities):Oxidizers, alkalis. 

Hazardous decomposition products: 

In a fIre situation, hydrogen fluoride, carbonyl fluoride, carbon monoxide and carbon dioxide may 

liberate. 

11. TOXICOLOGICAL INFORMATION 

Acute toxicity: 

NID 

Sensitization: Negative (LLNA) (as Fluoropolymer) 

Mutagenicity: 

• Ames Assay: negative OECD No.471 (as Fluoropolymer) 

• Chromosomal aberration test: negative (as Fluoropolymer) 

Repeated Dose Toxicity (28day.rat. Oral.) 

NOEL=IOOOmglkglday (as Fluoropolymer) 

Carcinogenicity 


All ingredients are not listed by NTP, IARC or OSHA as carcinogens. 


12. ECOLOGICAL INFORMATION 

Biodegradability: 


Not to be readily biodegradable (OECD301C) (as Fluoropolymer) 


Bioaccumulation: 


BCF 6.7-13 (as Fluoropolymer) 


Other information: 


Fish, Acute Toxicity Test: NOEC=>lOOmg/L, 96h (Medaka);OECD No.203 (as Fluoropolymer) 


Alga, Growth Inhibition Test: NOEC=>IOOmg/L, 72h ;OECD NO.201 (as Fluoropolymer) 


Daphnia sp., Acute Immobilis~tion Test: NOEC=> 1 OOmg/L, 48h ;OECD No.202 (as 


Fluoropolymer) 


13. DISPOSAL CONSIDERATIONS 

RCRA Waste Code: Not regulated under RCRA, 40 CFR261. 
Reuse when possible the residual product. Send waste product for thermal destruction, using 


high-temperature incinerators designed to bum fluorine compounds. 


Reuse containers when possible, after thorough washing. Dispose of waste containers to authorized 


landfill, in accordance with local laws and regulations. 


Comply with all federal, state and local regulations. 


Do not dump this product into sewers, on the ground or into any body ofwater. 


14. TRANSPORT INFORMATION 

US DEPARTMENT OF TRANSPORTATION (DOT) 

Hazardous Materials: NIA 

Hazardous Materials Description and Proper Shipping Name: NIA 

Hazardous Class or Division: Not classified 

Identification Number: Not regulated 

Packing Group: Not classified 

Label(s) Required: Not classified 

UN Number: N/A 

IMDG Status: Not restricted 

Marine Pollutant: No 

ICAOIIATA Status: Not restricted 

15. REGULATORY INFORMATION 

OSHA STATUS: This product is not hazardous under 29 CFR 1910.1200. 


TSCA STATUS: This Fluoropolymer malic acid salt is not listed on the TSCA inventory. 


CERCLAISUPERFUND (40 CFR 117,302) 


N/A 

SARA TITLE III 

SECTION 302(40 CFR 355): Not applicable 

SECTION 311/312(40 CFR 370): Not applicable 

SECTION 313(40 CFR 372): Not applicable. 

Ensure this material in compliance with federal requirements and ensure conformity to local 

regulations. 

16. OTHER INFORMATION 

• NIE: Not Established 

• NIA: Not Applicable 

• NID: No Data 

• ACGffi: American Conference ofGovemmental Industrial Hygienists 

• T.C.C.: Tag Closed Cup 

• C.O.C.: Cleveland Open Cup 

NFPACODES 

Iilammability I~azard I~nstability 

Revision Summary: 


The product is not designed for special applications such as pharmaceutical, medical use. 

The information given in this safety data sheet is for safety purposes only. It is given in good faith 

and based on the best knowledge and experience ofthe company at the date of issuing. 

The company is not responsible for any loss or damage caused by the use of the product in 

applications for which it was not intended or for conditions of use contrary to the recommendations 

in this safety data sheet. 
ATTACHMENT HEADER SHEET 


Attachment Number 004 

Attachment Name 


Manufacturing Process Description 


Associated PMN Section Number 

N/A 

Does not contain eBI 

Report Number 

AG-E110202924773944 

ATTACHMENT HEADER SHEET 


Attachment Number 005 

Attachment Name 


Determination of impurities 


Associated PMN Section Number 


N/A 


Does not contain eBI 

Report Number 

AG-E11 0202924773944 
September 21. 2010 

CERTIFICATE OF ANALYSIS 


Article name: P-3010 [25% aqueous emulsion ofPMN substance] 

Lot. No.: 50lO0451L007 

Analysis date: 03/AUG/2010 

Analytical method 

Sample 

P3010 

(pL) 

standard 

stock 

solution 

for 

addition 

(pL) 

2·Butanol 

(pI..) 

n-Hexane 

(pL) 

Added concentrations in 

R-3010 (llg/mI..) 

C6AL C6FMA 

0 1000 0 1000 4000 0 0 

1 1000 100 900 4000 160 

2 1000 200 800 4000 320 312 

3 1000 350 650 4000 560 546 

4 1000 800 200 4000 1248 

2-Butanol and n-Hexane were added into all (five) vials until total amount with 
fortification solution was 6 mL and mixed well and separated by centrifugation at 10000 

rpm for 10 minutes. The supernatant was injected into GC-MS conditioned as follows. 

C6AL and C6FMA were determined using standard addition method. 

<Instruments> 

(1) Apparatus: 	 GC-MS 

GC: Agilent Technologies, Model 6890 

MS: JEOL (Tokyo, Japan), BU-25 

(2) GC column: Agilent technologies DB-1301, 60 m length, 0.25 mm diameter, 1 micro 

m film thickness 

<GC-MS analytical conditions> 

(1) Injector temp.: 280°C 

(2) Oven temp.: 40°C (10 min) - 10 °C/min - 280°C (10 min) 

(3) Transfer line temp.: 280 °C 

(4) Column top pressure: 24 psi constant 

(5) Split flow or ratio: 1/50 

<Result> 

Mass chromatograms of GC-MS SIM analyses ofP-30lO are shown in Figure 1. 

The calibration curves for standard addition method were shown in Figure 2 (n = 1,2). 


ATTACHMENT HEADER SHEET 


Attachment Number 006 

Attachment Name 


Additional Data Relevant to the PMN 


Associated PMN Section Number 


N/A 


Does not contain CBI 

Report Number 

AG-E110202924773944 
Attachment 6 

Additional Data Relevant To The PMN 

The PMN submitter has previously provided EPA with health and safety data pertaining to the 

. These data were submitted to EPA in support of a PMN for 

. Because these previously-submitted data may be relevant to 

EPA's evaluation ofthe current PMN, we incorporate by reference herein the health and safety 

data that were submitted with . We would be happy to provide EPA with additional 

copies ofthe study reports submitted with , ifthe Agency requires additional copies of 

those reports.