p. 1 

International Flavors & Fragrances Inc. OpPI-- aV70S '~ rna.~333~~ ~ 

J/ 7`/ p 

February 23, 2011 

RECD MAR 11 2011 

RE CE: IVED 

or~' 

I I F'EB ? t, PIN 12 : 17 

Document Control Office (DCO) (7407M) 

Office of Pollution Prevention and Toxics (OPPT) 

Environmental Protection Agency, 

1200 Pennsylvania Ave., NW 

Washington, D.C. 20460-0001 

Attn: TSCA Section 4 

To Whom It May Concern: 

~m4 M0 ii1 u^im() upiq~upNpui1 in4 ui 

Ref: Federal Register : January 7, 2011 (Volume 76, Number 5), Page 1067-1093 . 

40 CFR Parts 9 and 799 . 

Testing of Certain High Production Volume Chemicals; Second Group of Chemicals 

International Flavors & Fragrances Inc. (IFF) imports into the United States a small 

quantity of Methanone, diphenyl-, CAS 119-61-9, for use in products that are subject to 

the provisions of the Toxic Substances Control Act (TSCA). Methanone, diphenyl- is 

one of the substances listed in the referenced Final Rule . As such, IFF is considered a 

Tier 1 person and is subject to the requirements of the Final Rule. 

As a relatively small volume importer, we believe that the required testing will be 

performed by another person. Therefore, we are applying for an exemption to this Final 

Rule for Methanone, diphenyl-, CAS 119-61-9. - 

The following information is provided to support this exemption application : 

(a) The identity of the test rule, the chemical identity, and the CAS No . of the test 

substance on which the application is based. 

a. Identity of the test rule: Federal Register, January 7, 2011 (Volume 76, 

Number 5) (Page 1067-1093). 40 CFR Parts 9 and 799. Testing of 

Certain High Production Volume Chemicals; Second Group of Chemicals . 

Final Rule . Docket ID number EPA-HQ-OPPT-2007-0531 . 

b. Chemical identity : Test substance CAS name: Methanone, diphenylc. Test substance CAS number : 119-61-9 

800 Rose Lane, Union Beach, NJ 07735 

T 732 264-4500 CONTAINS CON1-~P'~I~.~S 1V , ,O Cpf 0 
(b) The specific testing requirement(s) from which an exemption is sought and the 

basis for the exemption request. 

a. Required tests as indicated in Table 2 and 3 in the referenced Final Rule : 

i. B - Testing category: Environmental fate and pathway - ready 

biodegradation. For B, consult ISO 10634:1995(E) for guidance, 

and choose one of the methods listed in this column : 

1 . ASTM E1720-01 (Reapproved 2008) (sealed vessel C02 

prduction test) OR. 

2. ISO 14593 :1999(E) (C02 headspace test) OR. 

3 . ISO 7827 :1994 (E) (analysis of DOC) OR. 

4. ISO 9408 :1999(E) (determination of oxygen demand in a 

closed respirometer) OR. 

5 . ISO 9439:1999(E) (C02 evolution test) OR. 

6. ISO 10707:1994(E) (closed bottle test) OR. 

7. ISO 10708:1997(E) (two-phase closed bottle test). 

ii . C2 - Testing category: Aquatic toxicity . For C2, Test Group 1 or 

Test Group 2 listed in this column must be used to fulfill the 

testing requirements - See Special Conditions . . 

1 . Test Group 1 for C2: 

a. Acute Toxicity to Daphnia: ASTM E 729-96 

(Reapproved 2007). 

b. Toxicity to Plants (Algae) : ASTM E 1218-04\el\. 

2. Test Group 2 for C2 : 

a. Chronic Toxicity to Daphnia: ASTM E 1193-97 

(Reapproved 2004). 

b. Toxicity to Plants (Algae): ASTM E 1218-04\el\. 

b. Basis for the exemption request: We believe that the required testing will 

be performed by another person or consortium. 

(c) Name, address, and telephone number of applicant. 

a. Name: International Flavors & Fragrances Inc. 

b. Address: 521 West 57th Street, New York, NY 10019-2929 

c . Telephone number: 1-212-765-5500 

(d) Name, address, and telephone number of appropriate individual to contact for 

further information. 

a. Name : Mark Fukayama, Ph.D ., DABT 

b. Address: 800 Rose Lane, Union Beach, NJ 07735 

c. Telephone Number: 732-203-8139 

(e) If required in the test rule to establish equivalence - Not applicable. As indicated 

in the referenced Final Rule, EPA will not require the submission of equivalence 

data. 
I understand that if this application is granted before the reimbursement period described 

in section 4(c)(3)(B) of TSCA expires, I must pay fair and equitable reimbursement to the 

person or persons who incurred or shared in the costs of complying with the requirement 

to submit data and upon whose data the granting of my application was based. 

Thank you for your consideration of this exemption. 

Mark Fukayama, Ph.D., DABT 

Director of Toxicology 

Global Regulatory Affairs 

International Flavors & Fragrances Inc.