United States Office of Chemical Safety and &EPA Environmental Protection Agency Pollution Prevention Final Risk Evaluation for C.I. Pigment Violet 29 (Anthra[2,1,9-def:6,5,10-d'e'r]diisoquinoline- 1,3,8,10(2H,9H)-tetrone) Supplemental File: Information Received from Manufacturing Stakeholders CASRN: 81-33-4 January 2021 This supplemental file is a compilation of information received by EPA from the domestic manufacturing (including importing) and industry stakeholders for C.I. Pigment Violet 29 (CASRN 81- 33-4). Any information provided and incorporated in the C.I. Pigment Violet 29’s risk evaluation by these stakeholders can be found in this supplemental file. Types of information include email correspondences, SDS sheets, and questionnaires about practices. There is no information claimed as Confidential Business Information. The only redactions are the contact information for the stakeholders. The communications received include: • Occupational exposure and engineering information received from sole U.S. manufacturer, Sun Chemical Corporation, for C.I. Pigment Violet 29 and incorporated into the Problem Formulation and Draft Risk Evaluation • Environmental release information received from the sole U.S. manufacturer Sun Chemical for C.I. Pigment Violet 29 and incorporated into Problem Formulation and Draft Risk Evaluation • Information received after publication of the Draft Risk Evaluation in response to public comments and TSCA Scientific Advisory Committee on Chemicals (SACC) including: • Initial information received from Sun Chemical in response to EPA's request for additional data characterizing the environmental releases, occupational exposure and engineering processes for C.I. Pigment Violet 29 • Information received from Sun Chemical Corporation in response to clarification about environmental releases of C.I. Pigment Violet 29 • C.I. Pigment Violet 29 particle size data received from Sun Chemical Corporation and the Color Pigments Manufacturers Association • Information received from BASF in response to EPA's request for additional data characterizing the environmental releases, occupational exposure and engineering processes for C.I. Pigment Violet 29 • Information received from Sun Chemical in response to EPA's request for additional data characterizing the manufacturing processes and downstream processes for C.I. Pigment Violet 29 • SDS for C.I. Pigment Violet 29– BASF (importer) (BASF SDS 4081884) • SDS for C.I. Pigment Violet 29 Commercial Product – Sun Chemical Corporation • SDS for C.I. Pigment Violet 29 Non-Commercial Product (dry) – Sun Chemical Corporation • SDS for C.I. Pigment Violet 29– TCI America (importer) Page 2 of 96 Table of Contents Part 1: Information received from Sun Chemical Corporation for C.I. Pigment Violet 29 and incorporated into Draft Risk Evaluation....................................................................................................4 Occupational exposure, and engineering information received from sole U.S. manufacturer Sun Chemical Corporation for C.I. Pigment Violet 29 and incorporated into Problem Formulation and Draft Risk Evaluation ............................................................................................................................................ 2 Environmental release information received from sole U.S. manufacturer Sun Chemical for C.I. Pigment Violet 29 and incorporated into Problem Formulation and Draft Risk Evaluation ....................... 6 Part II: Information received after publication of Draft Risk Evaluation in response to public comment and TSCA Scientific Advisory Committee on Chemicals recommendations ......................................... 13 Initial information received from Sun Chemical in response to EPA's request for additional data characterizing the environmental releases, occupational exposure and engineering processes for C.I. Pigment Violet 29. ...................................................................................................................................... 14 Information received from Sun Chemical Corporation in response to clarification about environmental releases of C.I. Pigment Violet 29 ............................................................................................................. 20 C.I. Pigment Violet 29 particle size data received from Sun Chemical Corporation and the Color Pigments Manufacturers Association ....................................................................................................... 24 Information received from BASF in response to EPA's request for additional data characterizing the environmental releases, occupational exposure and engineering processes for C.I. Pigment Violet 29 ................................................................................................................................................................... 30 Information received from Sun Chemical in response to EPA's request for additional data characterizing the manufacturing processes and downstream processes for C.I. Pigment Violet 29 ............................... 35 Part III: SDSs for C.I. Pigment Violet 29 ...................................................................................................46 SDS for C.I. Pigment Violet 29– BASF (importer) (BASF SDS 4081884) ...............................................48 SDS for C.I. Pigment Violet 29 Commercial Product – Sun Chemical Corporation .................................64 SDS for C.I. Pigment Violet 29 Non-Commercial Product (dry) – Sun Chemical Corporation.................74 SDS for C.I. Pigment Violet 29– TCI America (importer) .........................................................................83 Page 3 of 96 Part 1 Information received from Sun Chemical Corporation for C.I. Pigment Violet 29 and incorporated into the Draft Risk Evaluation Page 4 of 96 Occupational exposure and engineering information received from sole U.S. manufacturer, Sun Chemical Corporation, for C.I. Pigment Violet 29 and incorporated into the Problem Formulation and Draft Risk Evaluation Page 5 of 96 Page 6 of 96 Page 7 of 96 U.S. Environmental Protection Agency | Office of Pollution Prevention & Toxics, Risk Assessment Division, Assessment Branch 2 | 1201 Constitution Ave., NW, | Washington, DC 20004 | | | Office hours: M-F, 8am to 4:30pm ET This message may contain confidential, proprietary or legally privileged information and is intended only for the use of the addressee named above. No confidentiality or privilege is waived or lost by any error in transmission. If you are not the intended recipient of this message you are hereby notified that you must not use, disseminate, copy it in any form or take any action in reliance on it. Page 8 of 96 Environmental release information received from the sole U.S. manufacturer Sun Chemical for C.I.Pigment Violet 29 and incorporated into Problem Formulation and Draft Risk Evaluation Page 9 of 96 Page 10 of 96 From: Mott, Robert Sent: Monday, Dec m r To: Muneer, Alie Todd, Jason Subject: Re: Exposure questions Dear Alie, I'm rnnning late getting to my Hotel. I'll cal yow- office when I'm settled into my room. Best regards, RCM Sent frommy iPhone On Dec 1, 2017, at 4:16 PM, Mott, Robe1i wrote: Dear Alie, I'm sorry, I thought we had already resolved that. I'm not with my notes right now, could I send a note this evening and then we could discuss it Monday around 1:30PM if needed? Best regards, Dr. Robert C. Mott Manager, Global Regulatory Sun Chemical Corporation 1506 Bushy Park Rd., Bldg. B11-3 Goose Creek, SC 29445 Tel. Cell Fax: From: Muneer, Alie Sent: Friday, Dece To: Todd, Jason Subject: RE: Exposure questions Hello Robe1i Mott: Can you pls explain the 0.6 lbs/day PV29 calculation? Thanks, Alie From: Todd, Jason Sent: Friday, October 06, 2017 9:14 AM To: Mott, Robert Muneer, Alie Cc: Hasan, Jafrul Subject: RE: Exposure questions Dr. Mott, Page 11 of 96 Page 12 of 96 If I’m understanding your written description and you look at the actual reported releases to the river (e.g. 2016: 173,277 lbs/yr or 475 lbs/d) gets you to that 1‐2% number (e.g. 475 lbs/d is 1.7% of 28,000 lbs/d) you reference I believe. But I don’t see what you used to get to 0.6 lbs/d of PV29. Can you explain how you got to that number? It’s probably obvious, but I’m just not seeing the numbers used to arrive at that result. And if we use your given 0.6 lbs/d PV29 released to the river, then that’d equate to ~219 lbs/yr or 0.13% of all TSS releases in 2016 (219 lbs/ 173,277 lbs). Does that seem in line with expectations or logical? Maybe, since you’ve now had a chance to look at actual numbers, it would be helpful to state things more equivocally: 1. What I am interested in is what percentage of that reported release of 173,277 lbs/yr of TSS in 2016 is likely composed of PV29? It appears on your previous email and from what I show above that it’s a low amount (e.g. <1%), but I’d want verification and clarification from you. Even ballpark percentage numbers would be useful (e.g. <10%?, <5%?, <1%?). 2. The monitoring data is based on a monthly sampling so the facility is obviously producing TSS throughout the year, but do you have a feel for the number of days you’re releasing PV29 to the river or producing PV29 over the course of the year? For instance, is PV29 made and released throughout the year or is it made and released over a finite number of days. At the most extreme ends of the spectrum, a company could release all of a chemical to the environment in a single day (high‐end) or release