Document MGqmnbB2N1KDvrkkZxDnBKRQ7

3M General Offices 3M Center p. 1 St. Paul, MN 55144-1000 651 7331110 Certified Mail November 20, 2007 ,too ` 2~f :: IBIIIINIIVIIIIIII!I'IIIIYIIIIIIINIIIIiilllll I"Jr.=-M3 '4 Document Processing Center EPA East - Room 6428 Attn: Section 8(e) Office of Pollution Prevention and Toxics, US EPA 1200 Pennsylvania Avenue NW Washington DC 20460-0001 ~,rt9~p Pany Sanitized RE: TSCA 8(e) Substantial Risk Notice : Docket No. 8EHQ-07-16721 To Whom It May Concern : In October of 2007, 3M notified the EPA that draft data from a mouse local lymph node assay (LLNA) performed on an experimental chemical, [fluorinated surfactant salt], had been received . The design ofthis study included immunophenotyping via flow cytometry to determine %B cells, %T cells, and B:T cell ratio to ascertain whether the observed response was a result of irritation or sensitization . Topical application of the test material resulted in a stimulation index greater than 3, as well as a greater than 25% increase in %B cells and in B:T ratio compared to both vehicle and na'ive controls . These data suggest the test article is a dermal sensitizer. The final report for this study is enclosed. For reference, 3M has submitted data from an oral (gavage) developmental toxicity screening study in rats, a five day repeat oral study in rats, a 28 day repeat dose toxicity study in rats, and a standard mouse local lymph node assay conducted on the same chemical . These submissions have also been assigned the docket number listed above. Please contact me at 651-737-1374 or diluebkerna-,mmm .com ifyou have any questions or if we can provide additional information . Sincerely, Deanna J. Luebker, PhD 3M Toxicologist and TSCA 8(e) Coordinator Enclosure pmuuui~p~!p~u~iniqiiuli~ ~~~iuuu