Document a4RbwzvGbXkaQ7Gk4XGbzkr0a

Katherine E. Reed, Ph.D. Staff Vice President Certified Mail 3M Environmental Technology and Safety Services Mfi-6 - H A . 900 Bush Avenue Building 42-2E-26 PO Box 33331 St Paul, M N 55133-3331 651 778 4331 oro3_ 03 73 May 20, 2003 <&> - 3 ? 3 , 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 *t GBi RE: TSCA 8(E) SUBSTANTIAL RISK NOTICE ON: Phosphonium, triphenyl(phenylmethyl)-, sait with 1,1,2,2,3,3,4,4,4-nonafluoro-N-methyl-lbutanesulfonamide (1:1) (CAS 332350-93-3) Dear Sir: 3M has received data for an acute eye irritation study in rabbits conducted with phosphonium, triphenyl(phenylmethyl)-, salt with 1,1,2,2,3,3,4,4,4-nonafluoro-Nmethyl-l-butanesulfonamide (1:1) (CAS 332350-93-3) (TPBP C4 amide) indicating ocular corrosion of the eyelids and nictating membrane. The study was conducted by NOTOX Safety and Environmental Research. Single samples of approximately 51 mg (a volume of approximately 0.1 ml) TPBP C4 amide were instilled into one eye each of three rabbits. Observations were made at 1, 24, 48, and 72 hours after instillation. Necrosis of the nictating membrane was observed in one animal on days 3 and 4 and in two animals on days 2, 3, and 4. In addition, necrosis of the eyelids was seen in one animal on days 3 and 4. Based on presence of necrosis of the eyelids and/or nictating membrane, it was concluded that ocular corrosion had occurred. During the observation period, other ocular effects were also noted. Specifically, corneal injury was seen as opacity (maximum grade 2) and epithelial damage (maximum 65% of the corneal area); iridial irritation (grade 1) was observed; and irritation of the conjunctivae was seen as redness, chemosis, and discharge. A copy of the final report is enclosed. Please contact Andrew Seacat (651-575-3161) if you have any questions or if we can provide additional information. jgr EPA-OTS 000811856T oooanasbT *i :6 hv -NOCMOZ 1 Document Processing Center Page No. 2 May 20, 2003 Once a docket number has been assigned for this submittal, please send the docket number postal card to Cheri Kedrowski, 3M Center Bldg. 220-2E-02, St. Paul, MN 55144. Sincerely, lerine E. Reed Staff Vice President Environmental Technology and Safety Services Enclosure