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## - ntUNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C., 20460

VIA FACSIMILE: 201-437-4801 April 19,2012 Attention: Glenn Merritt (201-437-4000) OFFICE OF PREVENTION, PESTICIDESAND TOXIC SUBSTANCES

Subject: Follow-upto fax transmission of4/13/12 (ePMAremoval ofCBI claimsregarding identified studies) 

### DearMr. Merritt: This is sentto you pursuantourconversation ofseveral minutes ago. In Larry Robinson's fax of April 13th while there is a waiver ofconfidential business information (CBI) claims in the identified studiesthere is a an assertion ofcopyrightprotections and some additional text that provides in part ... "Reproduction, reference, summarization, retransmission orotheruse ofthis copyrighted document...including electronic transmission, using the internet oremail....is strictlyprohibited...." While we understand the basisforthe copyrightprotections, we have a concernthat the language in the fax mightbe interpreted to meanthat ePMA is asserting that the studies submitted perthe TSCA activity are not tobemade available in an Agencye-docket (electronic docket) orbe included in EPA websites amongthe collection ofTSCAhealth and safety studies. We are thinking that the identified limitations noted in the fax are not intended to apply to EPA's normal procedures for the handling ofnon-CBI materials submitted by entities subjectto TSCA regulations (includingtheposting ofsuch materials ongovernment websites) and submittedby such entities in orderto complywith a TSCA requirement, but are rather intended to limit entities outside the government from the unauthorized use or appropriation ofthe studies. Canyou please confirm CPMA's intent? Manythanks. Scott M. Sherlock,Attorney Advisor Environmental Assistance Division Office ofPollution Prevention and Toxics

### CONFIDENTIAL HRC #7512-266

ACUTE DERMAL TOXICITY OF ALKALI BLUE FLUSHINGS FL-14-637 IN RABBITS

RECEIVF JAN 2 0

Ms. Alicia Whatley Huntingdon Research Center The Sherwin-Williams Company 216 Congers Road Chemical Division New City, New York 10956 11541 South Champlain Avenue Chicago, Illinois 60628

### S UMM4ARY Alkali Blue Flushings FL-14-637 was evaluated for its dermal toxicit' in the rabbit according to The Federal Hazardous Substances Act. The paste was applied at 2 gm/kg of body'weight to the intact and abraded skin. 1% Rabbit #338 died on Day 10 which isbelieved not compound related. No dermal reactions were noted. Body weight gain and general appearance of the rabbits remained good throughout the 14-day observation period. Alkali Blue Flushings FL-14-637 would be considered dermally nontoxic.



### Kenneth E.McElroy 

# U Supervisor, Toxicology

SN 

### Paul J. Upman Managecr, Toxicology January 16, 1976

j cp HUNTINGDON RESEARCH CENTER 216 CONGERS ROAD NEWA CITY, NEW YORK 10956

### I NTRODUCT ION Alkali Blue Flushings FL-14-637 was evaluated for Acute Dermal toxicity in rabbits according to the guidelineq of The Federal Hazardous Substances Act. MATERIAL Alkali Blue Flushings FL-14-637 was received as a blue paste assumed to be 100% active. METHODS Ten mature albino rabbits of the New Zealand variety were selected from the stock colony for this study. The Alkali Blue Flushings FL-14-637 was applied at 2 gm/kg to the clipped skin of five intact and five abraded rabbits. The rabbits were wrapped with a dam. After 24 hours, the wrapping was removed and the residue gently washed off. The test site was examined for erythema and edema and scores were recorded daily for 14 days. Bodyweights were recorded on Days 0, 3, 7, 10 and 14. A gross examination of the viscera was conducted on all rabbits sacrificed at 14 days. RESULTS Daily Observations (Table 1, 3) No erythema or edema were noted during the 14-day observation * period. The general appearance of the rabbits remained good throughout.

Bodyweight Gain (Table 2) Bodyweight gain was acceptable for all rabbits during the 14-day study. Mortality Day 10 rabbit #338 died. Due to advanced autolysis, reason for death was not determined. No gross pathology was noted in the rabbits sacrificed at 14 days. HUNTINGDON RESEARCH CENTER 216 CONGERS ROAD NEW CITY, NEW YORK 10956

### RESULTS (cont'd) Necropsy (Table 3)- Gross examination of the viscera revealed'no compound related observations. Yellow foci noted inthe liver o'f four rabbits is believed to be a parasitic condition not uncommon in the rabbit. CONCLUS ION Alkali Blue Flushings FL-13-637 at 2 gm/kg of bodyweight would be considered non-toxic dermally.

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### TABLE 3 INDIVIDUAL OBSERVATIONS'
Rabbit No. Daily At Necropsy 324 Appears normal No gross path noted 326 Appears normal No gross path noted 335 Appears normal No gross path noted 337 Appears normal Mo gross path noted 338 Appears normal Died - 

### Day 10 

### 333 Appears normal Yellow foci in liver 322 Appears normal Yellow foci in liver 323 Appears normal No gross path noted 325 Appears normal Yellow foci in liver 339 Appears normal Yellow foci in liver

### APPENDIX 1
Evaluation of Skin Reaction Value Erythema and eschar formation: No erythema0 Very slight erythema (barely perceptible) 1 Well1-defined erythema 2 Moderate to severe erythema 3 Severe erythema (beet redness) to slight eschar formation (injuries in depth) 4

Edema formation: No edema0 Very slight edema (barely perceptible) 1 Slight edema (edges of area well defined by definite raising) 2 Moderate edema (raised approximately Imillimeter) 3 Severe edema (raised more than 1 millimeter and extending beyond the area of exposure) 4

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