# Op-,~007 vs3/ Lonza p.7

CERTIFIED MAIL - RETURN RECEIPT REQUESTED Lonzalnc. M " `V33V#7/3 90 Boroline Road Allendale, NJ 07401, USA Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave., N.W . Washington, DC 20460-0001

Attn: TSCA Section 4 40 CFR Part 799.5087 0 (Z) ~u 0 i'Tf ;

In compliance with the final rule, "Testing of Certain High Production Volume Chemicals; Second Groupof Chemicals", 76FR1067, January 17, 2011, Lonza Inc. submits this Letter of Intent to testfor "Benzenecjiamine, ar,ar-diethyl-ar-methyl=", CAS number 68479-98-1 . Lonza Inc. intends to conduct the required testing in conjunction with Albemarle Corporation. Albemarle will be submitting a separate letter of intent to test. The twocompanies, together, plan to conduct and/or submit testing to meet all the required endpoints as ou in the final rule and detailed below . The companies plan to conduct the testing for the following endpoints. A3 - Vapor Pressure A5 -Water Solubility C1 -Test Group 1

Acute Toxicity to Fish Acute Toxicity to Daphnia The companies plan to request modification to the testing requirements for the following endpoint . F1 - Mammalian toxicity - repeated dose/reproduction/developmental . ~C'3 est ® d

The repeated dose/reproduction/developmental test is based on the Agency's requirement for information the developmental/reproductive endpoint under the HPVprogram . The data requirements of the HPV on programare modeled after the Organization for Economic and Community Development (OECD) Screening Information Dataset (SIDS) . OECDconsiders the developmental/reproductive endpoint to be fulfilled with either the screening study listed in EPA's test rule or a 90day repeated dose study coupled with results froma prenatal developmental study. Multiple mammalian repeated dose studies ranging in length from28days to two years with histopathological examination of the male and female reproductive tracts have been performed on this chemical . The reproductive tract was not a target organ. Additional repeated dose testing would be redundant. Arat prenatal developmental is considered the preferred testing to fulfill the reproductive/developmental endpoint. The proposed study would be performed according to OPPTS 870 .3700/OECD414

. Acopy of the 90-day repeated dose study will be submitted along with the protocol for the rat prenatal test in the request for modification of the testing requirements. Robert J. Sloan Senior Manager Regulatory Compliance - Americas Phone: (201) 316-9365 Fax:(201)696-3569 bob .sloan@lonza.com t March 7, 2011



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The companies believe that sufficient data exists to meet the following endpoints. The existing test data consists of data submitted to ECHA in compliance with REACH by the consortia forthis chemical in Europe. Albemarle will submit the existing data and the rational for why it meets the endpoints in a separate letter. A1 - Melting point A4 - n-Octanol/Water Partition Coefficient C1 -Test Group 1

Toxicity to Plants (algae) E1 - Mammalian toxicity - Genotoxicity (Bacterial Reverse Mutation Test) E2 - Mammalian toxicity - Genotoxicity (Chromosomal Damage) The contact information for the corporation and contact person filing this letter of intent to test is provided below . Robert Sloan Lonza Inc

. 90 Boroline Road Allendale, NJ 07401 USA Telephone 201-316-9365 Fax 201-696-3569 , Email : bob.sloan(U-)lonza .com TheAlbemarle contact named below will be the primary contact for this testing. KimBoudreaux Albemarle Corporation 451 Florida Street Baton Rouge, LA 70801-1765 Telephone 225-388-7776 Fax 225-388-7046 Email : Kim

. Boudreaux(a)_albemarle.com If you have any questions, please contact me and at the number provided above. Sincerely, Lonzaj-rle--

Robert J . S an Senior Manager, Regulatory Compliance - Americas