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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 

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In compliance with the final rule, "Testing of Certain High Production Volume Chemicals; Second Group of 

Chemicals", 76FR1067, January 17, 2011, Lonza Inc. submits this Letter of Intent to test for "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 

two companies, 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. 

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The repeated dose/reproduction/developmental test is based on the Agency's requirement for information 

the developmental/reproductive endpoint under the HPV program . The data requirements of the HPV 

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program are modeled after the Organization for Economic and Community Development (OECD) Screening 

Information Dataset (SIDS) . OECD considers the developmental/reproductive endpoint to be fulfilled with 

either the screening study listed in EPA's test rule or a 90 day repeated dose study coupled with results from a 

prenatal developmental study. Multiple mammalian repeated dose studies ranging in length from 28 days 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. A rat prenatal developmental is considered the preferred testing to fulfill the 

reproductive/developmental endpoint. The proposed study would be performed according to OPPTS 

870.3700/OECD 414. A copy 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 

NYb4 II0 IIIIIII,II0 YN0 Y0 III0 II0 IIIIIIIIII CONTAIN 
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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 for this 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 

The Albemarle contact named below will be the primary contact for this testing. 

Kim Boudreaux 

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-- 

Rob ert J . S an 

Senior Manager, Regulatory Compliance - Americas