AEPA
United States Office of Chemical Safety and
Environmental Protection Agency Pollution Prevention
Final Risk Evaluation for
C.I. Pigment Violet 29
(Anthra[2,l,9-def:6,5,10-dVf ]diisoquinoline-
1,3,8,10(211,9II)-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
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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
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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
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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
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Jewett, Freeborn
From:
Sent:
To:
Subject:
Mott, Robert
Monday, September 25, 2017 11:41 AM
Muneer, Alie
RE: Exposure questions
Dear Ale,
In Chart 2-2, my understanding of the meaning of emissions applies to volatile materials. Since this pigment is not
volatile, I don't think the pathways are relevant
On the same chart, I don't believe oral contact is relevant, as eating is not allowed in the production and laboratory work
areas.
Dermal exposure is handled as a nuisance dust and employees in production and laboratory areas where long sleeves
and are provided gloves.
Inhalation testing has shown exposure was ~0.Srng/m3 over an 12 hour work shift.
On chart 2-4 POTW, underground injection, and Incinerators are not relevant release pathways for manufacturing. A
separate chart should be considered for processors,
Hope this helps,
Maybe we can discuss further r late this afternoon if needed.
Best regards,
Manager, Global Regulatory
Sun Chemical Corporation
http://www.suncliemicai.com/
From: Muneer, Alie I
Sent: Monday, September 25,. 2017 8:31AM
To: Mott, RobertP
Subject: RE: Exposure questions
Hello Robert: Do you plan to send the materials today? Sate travels. A he
WC Mumer
I'.S. Environments*! Pnupction Agwicj ; Office of Pollution Pipvenlinu A Toxics, Rixk VsspsMiient Division, AwpsshwH
Bi ;Hicli 2 | 1201 Constitution Ave.. NW.: Washinsttoii, DC 29004 |
| Office hours: M
From: Muneer, Alie
Sent: Friday, September 22, 2017 4:56 PM
To: 'Mott, Robert'
Cc: Todd, JasonHasan. Jafrul|
Subject: RE: Exposure questions
Page 6 of 96
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One last question:
Any algal shading for PV29?
I hanks A lie
AFPft
A iit1 Milium
l\S. Environmental Protection Agency [ Office of Pollution Prevention & Toxics, Risk As<>c^sinenr llivfcion. Awmwnt
Branch 2 j 12D1 Constitution Ave., \\\. WJC fcnst Blrta..PH|||||||H I Washington, DC 21)004
|j Office hoars: M ¥. 8sim to 4:30pm,
From: Muneer, Alie
Sent: Friday, September 22, 2017 4:52 PM
Robert'J|HHHh|HHHH||H|HH|||
Cc: Todd, Jason Hasan, Jafrul|
Subject: RE: Exposure questions
Pei oui phone convention. the following weMink contains the NPD1S pennit info.
h?'p c.'i ui. cj>a t::hfy oVt,:)' ^'Itn j t bV*: ~?nj ,
Thanks, Alie
oEW ..
Abe Muiwr
? .S f'ltt ir iFiiru'!if:il Offli c lij'PoMnlimi 1'rpu'Hliim A Tuvit-y Risk ssim-iit Dhisimi.
Branch 2 1 I2f>t C'on\ihtni
-------
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
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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
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Jewett, Freeborn
From: Molt, Robert
Sent Tuesday, December 5, 201
To: Muneer, Alie; Todd, Jason
Subject: RE: Exposure questions
Dear Alie,
Here is the modified calculation. I've rearranged the lines and added additional comments which hopefully improve the
transparency,
pigment processed per year 12,500,000
per day 34,247
average handling loss 1.5%
pigment handling losses per day 514
Violet 29 per year 500,000
average production Violet 29 per day 1,370
average loss of Violet 29 loss to WWTP per
day 21
Limit for Sludge to river from WWTP per day
WWTP sludge per day dry
% V29 in sludge per day
V29 per day to the river
Please let me know if there are further questions.
Best regard,
1,049
28,000
0.07%
0.77
Sun Chemical Corporation
http :i>#w^y,sjjncherTii.cal,com«'
From: Muneer, Alie I
Sent: Monday, December 4. 2017 1:26 PM
To: Mott, Robert]
Subject: RE: Exposure questions
i Todd,Jasoj
Sounds area!, thanks
v-,CPA,r
Alio Miii.evr
U.S. Knvironmctifnl Protection A}»«u*y ! Office of Piilhiciim Prevention Toxic.. Risk Aw»simnt Division, Assessment
Branch 2 | I 201 Constitution Ave.. \\Y, WJC East | Washington, DC 20004 |
OH ire lioiirs: M T, fin n; t«> 4:3»|>in
Page 10 of 96
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From: Mott, Robert!
Sent: Monday, December 04, 2017 1:22 Pr"
To: Muneer, Alie|mmj^mmTodd, Jason |
Subject: Re: Exposure questions
Dear Alie,
I'm running late getting to my Hotel. I'll cal your office when I'm settled into my room.
Best regards,
RCM
Sent from my iPlione
On Dec 1, 2017, at 4:16 PM, Mott, Robert I
/rote:
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 Rci, Bid
Goose Creek, SC 29445
Tel.
Cell 1
Fax-
http://www.synchem
From: Muneer, Alie I
Sent: Friday, Dece 1ber 1, 2017 4:12 PM
To: Todd, Jason j Mott, Robert|
Subject: RE: Exposure questions
Hello Robert Mott: Can you pis explain the 0.6 lbs/day PV29 calculation? Thanks, Alie
¦ Aiit* MiHifcr
I -S. I'm i (is ii men t ;i i ProU'Ctimt Au« n< \ Office iifl'oHiifiuii Pri-M-iiiiim T»\ics. Risk Asscssiin-iti Division.
AssossjiH'ni BnmdiZUii I ("unsHmuon Avo.. NW. W.ft' \\ ashiugtou
Dc 20004 ^ ^nnm onice hours: mf.
From: Todd, Jason
Sent: Friday, October 06, 2017 9:14 AM
To: Mott, Robert |
Cc: Hasan, Jafrul I
Subject: RE: Exposure questions
Muneer, Alie I
Dr. Mott,
Page 11 of 96
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I am in the office today. Feel free to call at your convenience, as III be at my desk most of the day, if
easier, I'm happy to set up a settime as weli. Thanks!
Best,
Jason
la son Todd, Ph.D|
Risk Assessment Div. / OPPT / OSEPA
1200 Pennsylvania Ave., NW/ Washington, DC 20460
From: Mott, Robert
Sent: Thursday, October 05, 2017 4:34 PM
To: Todd, JasonMuneer. Alie|
af ru
Subject: RE: Exposure questions
Importance: High
Dear Todd,
I just came across your message in the wrong folder,
Are you available tomorrow morning to discuss your questions?
Best regards,
noil
Sun Chemical Corporation
1506 Bushv Park Rd Blcfo, B11
httDi^wwv,1.sunchemical.com/
From: Todd, Jason I
Sent: Monday, September 25, 2017 2:02 PM
To: Mott, Robert |
Cc: Hasan, Jafrul I
Subject: RE: Exposure questions
Muneer, Alie
Dr. Mott, thank you very much for the information. This is helpful. I am just trying to follow your math in
how you get to that 0,6 lb/day value of PV29 and I can't seem to figure out how you're getting to that
number.
Your 1,049 Ib/d value equates with the reported max allowable load between 2011-2013 on the DMR
report of 382,885 Ibs/yr (=max allowable load/365) [see table below for data compiled from DMR], It
appears the facility's max allowable load has actually increased since 2014 to a little over 454,000 Ibs/yr
for 2014-2016 (or ~1246 Ibs/d for 2016 numbers). 1 also see how you're getting that slipping number of
4% (1,049 Ibs/d is ~4% of 28,000 Ibs/d).
Page 12 of 96
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If I'm understanding your written description and you look at the actual reported releases to the river
(e.g. 2016: 173,277 Ibs/yr or 475 Ibs/d) gets you to that 1-2% number (e.g. 475 Ibs/d is 1.7% of 28,000
Ibs/d) you reference I believe. But I don't see what you used to get to 0.6 Ibs/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 Ibs/d PV29 released to the river, then that'd equate to ~219
Ibs/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 Ibs/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 it continuously over the entire year (e.g. 365 days, low-end).
Again best estimates are useful, if unable to give a specific number of days.
And finally, if there are concerns about sharing of this type of information due to CBI concerns, there are
ways such information can be shared to shield that information from our end. Feel free to reach out via
phone or email. Thanks and look forward to hearing from you.
Best,
Jason
Reported releases of TSS from DMR:
Table 1. Sun Chemical Bushy Park facility (NPDES: SC0003441)
reported annual load release, maximum allowable load, and percent
of maximum allowable load released for total suspended solids
Percent of
Maximum
Reporting
Total Annual
Maximum
Allowable Load
Year
Load
Allowable Load
Released
Ibs/yr
kg/yr
Ibs/yr
kg/yr
%
2016
173,277
78,597
454,927
206,351
38.1
2015
111,137
50,411
454,589
206,198
24.4
2014
137,401
62,324
454,589
206,198
30.2
2013
102,256
46,383
382,885
173,674
26.7
2012
108,382
49,161
382,885
173,674
28.3
2011
68,385
31,019
382,885
173,674
17.9
2010
96,975
43,987
299,665
135,926
32.4
*The DMR lists annual loads in Ibs/yr, but use in EPA model requires kg/yr. Showing
both here to ease comparison
Page 13 of 96
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Jason Todd, Ph.D ,
Risk Assessment Div. / OPPT/ USEPA
1200 Pennsylvania Ave., NW/ Washington, DC 20460
From: Mott, Robert
Sent: Monday, September 25, 2017 11:08 AM
To: Muneer, Alie
Cc: Todd, Jason
Subject: RE: Exposure questions
Hasan, Jafrull
Dear Alie,
in my looking at this question I found the attached link which on first blush surprised me,
https://echo.epa.aoi'/effluent-chartst'S Zi)nP:.~-«i/C'Ur-30 . Upon reflection the l,049!b/day average for
TSS is actually readily understood.
1. Our WW TP generates ~28,0G0!bs of sludge per day (dry weight), so this is >4% "slipping"
through the filter. This is somewhat higher than we experience in the manufacturing of our
pigments, where the standard yield loss is 1-2% for the ~12 million pounds processed. 1 think
this is due to our being more careful operating filter presses that isolate pigments than those
which are basically capturing biomass The isolated bio mass is transported to a licensed lined
land fiil.
2. It seems that the TSS going to the river is 90-95+% bio solids. This leads to PV29 being
~0.6lb/day of a material with a very low aquatic solubility lOpg/L.
3. Our engineering controls capture "15% (15K pounds per year) of the lost material in our bag
houses. This material is then disposed of in a licensed lined line fill. It is estimated that the
capture efficiency of our baghouse is >99%. PV29 would be ~4% of this dust handled,
I hope this helps.
Best regards,
f! 1' !
Manager, Global Regulatory
Sun Chemical Corporation
http ://www.sunchemical.corn
From: Muneer, Alie I
Sent: Friday, September 22, 2017 4:26 PM
To: Mott, Robert
Cc: Todd, Jason
Subject: Exposure questions
Hello Robert Mott:
We have a few questions relating to exposure:
Page 14 of 96
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1. Do you have any information related to release of PV29 to Cooper River? In the absence
of this data and using TSS as a surrogate, what percent of PV29 is a part of TSS?
2. What are the days of release to surface water for PV29?
3. Do you have any additional information on PV29 air release for occupational exposure
and environmental exposure?
Jason Todd/Exposure Assessor may contact you to follow-up via email or may call you.
Thanks, Alie
Alie Muneer
U.S. Environmental Protection Agency | Office of Pollution Prevention & Toxics, Risk Assessment Division,
Assessment Brand^^llf^Constitutio^AWj^W, WJC East | Washington,
DC 20004 | Office hours: M-F, Sam 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.
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.
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.
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 15 of 96
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Part II Information received after publication of the Draft Risk Evaluation in response
to public comments and TSCA Scientific Advisory Committee on Chemicals (SACC)
recommendations
Page 16 of 96
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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
Page 17 of 96
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From:
To:
Cc:
Subject:
Date:
Attachments:
Importance:
Blaufuss. Hannah
David Wawer
Robert Mott: Earl Seibert: Passe. Loraine: Hasan. Jafrul: Jewett. Freeborn
EPA Information Request - PV29
Tuesday, October 15, 2019 3:52:03 PM
Mott 2017a full.pdf
High
Dear David Wawer,
As you are aware, EPA has received public and SACC peer reviewer comments on the draft C.I.
Pigment Violet 29 (PV29) Risk Evaluation. Our team is reviewing and addressing the comments we
have received. Some of the comments question the robustness of the point estimates of worker
exposure numbers that Dr. Robert Mott provided in an email to the agency on September 25, 2017
(see attached pdf) and surface water release data. In order to address the concerns of the public,
improve the utility of the information already provided by Sun Chemical, and strengthen the risk
conclusions of the final risk evaluation, we are reaching out to you to supplement the numbers with
the following information.
Individual workplace air monitoring and site environmental release sample measurements (from
email) including the following for each sample:
1. Sample results including what was measured (e.g., How were the measured values
calculated? do the measurements represent total dust or specific PV29? Is dust particle
size available?)
2. The duration of sampling (e.g., sample start and stop times)
3. Date(s), frequency, and number of samples taken during each sampling event
4. Identify if the sample is personal breathing zone or area measurement.
5. Physical location of measurement device if area monitoring (include a description of the
work area and the monitored location)
6. Worker activity performed during sampling if personal monitoring device is used
(include information on personal protective equipment)
7. Ambient conditions during sampling (temperature, humidity)
8. Information on any Industrial Hygiene program and/or Chemical Safety Plan
9. Information on the analytical method (e.g., method, detection limit, and equipment as
appropriate)
In addition, the following would be useful to refine and contextualize the estimates of occupational
and environmental exposure at the Bushy Park site presented in the draft Risk Evaluation:
1. Specifics on personal protective equipment used for each activity and quantified
effectiveness
2. Engineering controls used for each activity and quantified effectiveness
3. OSHA incident reports
4. Details about on-site wastewater treatment and any off-site PV29 related waste disposal.
Included in those details would be any quantitative estimates of off-site disposal and
measures of water releases of PV29 relative to the overall manufactured volume with
anticipated days of release. Any releases not subject to wastewater treatment should
also be included
5. Estimate of the number of workers handling PV29 at the Bushy Park site, the days/year
each worker performs a specified activity and the details about shift length at the site
Page 18 of 96
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6. Number of workers who are not involved in the manufacturing and use of PV29 but
could be exposed because they work in the vicinity of those workers working with the
chemical directly
The Agency is not asking for Sun Chemical to create the data, perform monitoring or submit workers
personally identifiable information. The Agency is only asking Sun Chemical to provide information
that is currently in its possession or control. Please respond with a confirmation of receipt within
three business days and provide an estimate of the amount of time Sun Chemical will need to fulfil
this request. We look forward to your response.
Thank you,
Hannah Blaufuss, MHS
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
A Please do not print this email unless absolutely necessary A
Page 19 of 96
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ENCLOSURE 1 - EPA request for additional information in response to SACC
peer reviewer and including public comments on the draft C.I. Pigment Violet 29
(PV29) Risk Evaluation
Individual workplace air monitoring and site environmental release sample
measurements (from email) including the following for each sample (questions 1-9):
Sample results including what was measured (e.g., How were the measured
values calculated? do the measurements represent total dust or specific
PV29? Is dust particle size available?)
The Industrial Hygiene survey included employee exposure to total dust
associated with routine production activities in order to evaluate compliance with
applicable OSHA Permissible Exposure Limits (PELs) found in 29 CFR Subpart
Z and including current ACGIH Threshold Limit Values (TLVs) for "particulates
not otherwise regulated". Total Dust Exposure was assessed for four employees
working in buildings (B11) and (C82) as product operators. All employees
assessed were found to have exposures below the current OSHA PEL
(15mg/m3) and ACGIH TLV (10mg/m3). These findings indicate that corrective
actions were not necessary for compliance with the OSHA PELs beyond
maintaining existing engineering controls and proper work practices. A summary
of the results can be found in Table 1 (below). Particle size distribution data is not
currently available.
Table 1: Dust Exposure
Employee/ Work Area
Sample
Number
Employee
Exposure
(mg/m3)
OSHA PEL
(15mg/m3)
oxcoodod
(YES/NO)
ACGIH TLV
(10mg/m3)
excoecod
(YES/NO)
Production Operator (B11)
14-0941902
1.2
NO
NO
Production Operator (B11)
14-0941898
0,40
NO
NO
Production Operator (611)
14-0941902*
14-0941898*
0.72*
NO
NO
Production Operator (C82)
14-0941899
0.67
NO
NO
Production Operator (B11)
14-0941900
0.57
NO
NO
Procuration Ope;rater (Cfi?)
14-0941904
0.22
NO
NO
'Calculated value from :wo separate samples collected over the shift
2. The duration of sampling (e.g., sample start and stop times)
Samples were taken over a 12-hour duration (on average) based on a normal
production shift.
Page 20 of 96
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3. Date(s), frequency, and number of samples taken during each sampling
event
The Industrial Hygiene survey was performed at the Sun Chemicals facility in
Goose Creek, South Carolina on June 18, 2014. The total number of individual
samples taken are listed below along with values recorded for each sampling
event.
Total Oust
Sample fD
Air Volume (liter)
Total (mg)
Cone. fmg/m3)
14-0941902
175.5
0.21
1.2
14-0941900
826.8
0.47
0.57
14-0941899
852.6
0.57
0.67
14-0941904
854.1
0.19
0.22
14 0941898
266.5
0.11
0.4
4. Identify if the sample is personal breathing zone or area measurement.
All personal samples were collected from the employee's personal breathing
zone (PBZ).
5. Physical location of measurement device, if area monitoring (include a
description of the work area and the monitored location)
Personal breathing zone (PBZ) samples for total dust from the elevation 70
blender product operator in building (C82), the miscellaneous pack-out product
operator in building (C82), the de-lumper product operator in building (B11), and
the BM3 charge product operator in building (B11) in areas where PV29 is
handled.
6. Worker activity performed during sampling if personal monitoring device is
used (include information on personal protective equipment)
Worker activity performed during personal sampling associated with building
(C82) included charging big bags to the blenders on level 70 and packing out on
level 14, while activity associated with building (B11) included charging big bags
to the blender and charging trayed material to the delumper.
7. Ambient conditions during sampling (temperature, humidity)
Sample were taken throughout the day on June 18, 2014 with the temperature
ranging from 70-84F and relative humidity ranging from 74-85%.
Page 21 of 96
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8. Information on any Industrial Hygiene program and/or Chemical Safety
Plan
The site Industrial Hygiene plan consists of a series of standard programs,
procedures, and/or administrative controls including PPE, respiratory protection,
hearing conservation, hazard communication, and various site safety processes.
9. Information on the analytical method (e.g., method, detection limit, and
equipment as appropriate)
Sample collection and analysis was performed in accordance with the National
Institute for Occupational Safety and Health (NIOSH) Manual of Analytical
Methods (NMAM) and OSHA Analytical Methods. Samples were submitted to an
AIHA accredited laboratory. Personal samples for total dust were collected
utilizing pre-weighed PVC cassettes. The samples were collected by utilizing a
battery powered personal pump calibrated before and after use with a TSI 4100
primary calibrator. The samples were analyzed utilizing the NIOSH 0500 method
having a working range between 1 to 20 mg/m3 for a 100-L air sample.
Page 22 of 96
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ENCLOSURE 2 - EPA request for additional information in response to SACC peer
reviewer and including public comments on the draft C.I. Pigment Violet 29 (PV29) Risk
Evaluation
In addition, the following would be useful to refine and contextualize the estimates of occupational
and environmental exposure at the Bushy Park site presented in the draft Risk Evaluation:
(questions 1-6):
1. Specifics on personal protective equipment used for each activity and
quantified effectiveness
Personal protective equipment (PPE) requirements in both buildings (C82) and
(B11) where pigment dust (including PV29) is present would be Safety Glasses,
Nitrile Gloves, Tyvek Coveralls, 3M 8511 Paper Dust Mask (95% efficiency) as
specified in the detailed work instructions. Minimum PPE requirements for site-
wide production areas include long-sleeve shirt, long-pants, steeled-toed safety
shoes, safety glasses, and hard hat.
2. Engineering controls used for each activity and quantified effectiveness
Wet Scrubbers and Dust collectors are the two main engineering control devices
covering the production of PV29 presscake and dry pigment in buildings (B11)
and (C82). Air pollution control devices include process area packed bed
scrubber systems with approximately 95% PM removal efficiency, tray drying
area wet scrubber systems with approximately 80% PM removal efficiency, and
various delumping, blending and packout dust collectors with over 99.9% PM
removal efficiency.
3 OSHA incident reports
None related to PV29 exposure.
4. Details about on-site wastewater treatment and any off-site PV29 related
waste disposal. Included in those details would be any quantitative
estimates of off-site disposal and measures of water releases of PV29
relative to the overall manufactured volume with anticipated days of
release. Any releases not subject to wastewater treatment should also be
included.
The Bushy Park facility manages industrial wastewater discharge compliance
through an NPDES permit to discharge into the Cooper River. Any other off-site
Page 23 of 96
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releases of PV29 would relate to industrial waste disposal. Worst-case estimates
for the total amount of PV29 released from the facility through both wastewater
and including off-site waste disposal would be a maximum of 7,500 lbs/day. It is
estimated that only 300 Ibs/yr are released resulting from wastewater discharge.
The balance of off-site releases would result from the disposal of industrial
wastewater sludge and including dust collector filter waste.
Estimate of the number of workers handling PV29 at the Bushy Park site,
the days/year each worker performs a specified activity and the details
about shift length at the site
Estimates of the number of workers handling PV29 at the Bushy Park site are
approximately 22 employees working four different 12-hour shifts, 24 hours per
day, 362 days per year. Facility-wide annual production of PV29 is estimated to
constitute 3% of the total finished-goods production at the facility.
Number of workers who are not involved in the manufacturing and use of
PV29 but could be exposed because they work in the vicinity of those
workers working with the chemical directly
There are approximately 56 additional employees who would have very limited
workplace exposure to PV 29 dust.
Page 24 of 96
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Information received from Sun Chemical Corporation in response to clarification about
environmental releases of C.I. Pigment Violet 2929
Page 25 of 96
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Tcj
^ Sifai_Eari; jcwgHgl' hhmm. teteiMA
'54sfej«*s RB W S ¥torW» m|«sw!^afety srfww*.«twK Sim £>®wiu^ ^u:% Pafi
Onus Ty«4j», -m-Hitr 5, MB IfBSiSS IW
Dear HannA,
Upon further research by Sun Chemical, the informal! on below should aiWress the question presented by EPA on November 4 2013
(tease feel free to contact me if there are any final questions.
DM
Bushy Park, worst-case estimate of Violet 29 wastewater fosses
Para metes
Est. value
Comments
A
Toti Violet 29 pounds handed per year
500.000 lbs
countingf of Violet 29 production to account
tor losses atong each step in *>e batch
WtJOSS.
B
Avwatje handing tosses of Violet 29
15%
Typical yte« loss estimate for pioducts
manufetitued at tfte taciHy (based on
operational experience 1 Overal yield loss
estimate 1.5* to WWTP.
C
Averaoe toss of Violet 29 to WWTP per war
?,500 lbs
tA-Byioo
0
Average loss of Violet 29 to WWTP per day
21 lbs
ccoaju*.)
E
Total mm sludge pa day
28,000 lbs
F
Average percent of Violet 29 in WW IT ski« rriravgc *nd it^y stiwtifflwto tmy owHa*n osoWmW rtomatoo to- tfc® essetosw f«of CPMA fevy pyotc^iax d:ssm®Kfea;\ AsUtbul^> & i»
•femwop toaiv<*i*efoi9a«»£B®oBC« per*» *uri« rot twenty employed by nCPMA member company e prohMed inlea* aultanzee by CPku iiyou liwerecawditB message «
e?mr( plemefrt% CPhiArrieslMd^ af^eteWe &rw messiKje sud »ny aaKtotsftafi^xjfs^teffl
From; Blaufuss, Hannah
Sent! Mundiy, November 4, 201912.28 CM
To: Davd
ft- ritimi : '*' ®5*rt- ^a,i|
Jafryl «Ha$8nJafrul(aepa gov>, Jewett, Freeborn , Robert Mott|
Subject: RE. PV 29 Wtorter exposure/safety information Sun Chemical, Bushy Park
Passe, Lorame
-------
Hello Dave,
Thank you again for the responses. It was nice to see you at the Sun Chemical site visit. Thank you for your part is setting up the learning opportunity for
myself and EPA colleagues.
We had one specific PV29 question as a follow-up to the environmental release and exposure information you sent us. Within 04 in Enclosure 2, the
following is stated:
"Worst-case estimates for the total amount of PV29 released from the facility through both wastewater and including off-site waste disposal would be a
maximum of 7,500 lbs/day yr. It is estimated that only 300 Ibs/yr are released resulting from wastewater discharge. The balance of off-site releases would
result from the disposal of industrial wastewater sludge and including dust collector filter waste."
EPA Comment: It'd be useful to clarify how 7,500 Ibs/yr and 300 Ibs/yr were derived. The assumptions, calculations, and processes used to arrive at these
number would help the Agency better understand the context and create transparency for this information. Please let me know if you have any questions
about our comment.
Thankyou,
Hannah Biaufuss, MHS
Enviionrnental Ptotection Specialist
U S EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
Please do not print this email unless absolutely necessary
From: David Wawerl
Sent: Friday, October 25, 2019 2:24 PM
To: Biaufuss, Hannah
Letcheva^^^^^^^^^^^^^^^^^^^; Seibert, Earl|
Subject: RE: PV 29 Worker exposure/safety information: Sun Chemical, Bushy Park
Dear Hannah,
One minor correction I was just made aware of. In the answer to question #4 (wastewater discharge), the paragraph should read 7500 lbs/year. The initial
information provided to me had a typo, stating 7500 lbs/day.
Dave
From: Biaufuss, Hannah
Sent: Friday, October 25, 2019 1:20 PM
Wawe
Letcheva^^^^^^^^^^^^^^^^^^J Seibert, Earl|
Subject: RE: PV 29 Worker exposure/safety information: Sun Chemical, Bushy Park
Hello Dave,
Thank you for the response. I will forward the information to our risk evaluation team. Always a pleasure working with you. Give my thanks to Sun
Chemical.
Thank you,
Hannah Biaufuss, MHS
Enviionrnental Ptotection Specialist
U S EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
Please do not print this email unless absolutely necessary
From: David Wawerl
Sent: Friday, October 25, 2019 12:51 PM
To: Biaufuss, Hannah
Page 27 of 96
-------
Subject: PV 29 Worker exposure/safety information: Sun Chemical, Bushy Park
Good afternoon Hannah,
Attached for your review and use is information about worker exposure/worker safety from the Sun Chemical manufacturing site in Charleston, SC. Plant
officials reviewed recent questions posed by you and your PV29 technical team to CPMA, as part of EPA's review of SACC comments and development of
the final risk evaluation document for PV 29, and identified relevant information in response to the specific questions. I believe the attached information
will further assist the Agency in its efforts to finalize the PV 29 risk evaluation process.
Glad to respond to any follow-up questions.
This message and any attachments may contain confidential information for the exclusive use of the recipient CPMA member. Any publication, dissemination, distribution or copying of this
information to any other organization or person that is not currently employed by a CPMA member company is prohibited unless authorized by CPMA. If you have received this message in
error, please notify CPMA immediately and delete this message and any attachments from your system.
Dave
David Wawer, Executive Director
Color Pigments Manufacturers Association, Inc.
Page 28 of 96
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C.I. Pigment Violet 29 particle size data received from Sun Chemical Corporation
and the Color Pigments Manufacturers Association
Page 29 of 96
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From: David Wawer
To: Blaufuss Hannah
Subject: Particle Size Question
Date: Thursday, November 7, 2019 4:24:10 PM
Attachments: imaaeOOl.pna
imaaeQQ2.pna
imaaeQQ3.ipa
TEM 229-4050 Std. TM12548.pdf
Dear Hannah,
Please see the information below, provided to CPMA by Sun Chemical. Hope this meets your needs.
Dave
PARTICLE SIZE DATA
PSD by sedimentation method, mean weight diameter Dw is 53nm. Median weight diameter D50 is 43nm
Sample ID
D„1
Di
D10
°30
°50
°70
°90
°95
°99
229-4050 Std. SB-40502
53
20
27
35
43
54
80
101
192
1 Data are obtained by DCP method and are based on weight/volume in the unit of nm
TEM attached (above)
David Wawer, Executive Director
Color Pigments Manufacturers Association, Inc.
This message and any attachments may contain confidential information for the exclusive use of the recipient CPMA member. Any publication, dissemination, distribution or copying of this
information to any other organization or person that is not currently employed by a CPMA member company is prohibited unless authorized by CPMA. If you have received this message in
error, please notify CPMA immediately and delete this message and any attachments from your system.
From: Blaufuss, Hannah
Sent: Tuesday, November 5, 2019 3:33 PM
Wawe
Letcheva^^^^^^^^^^^^^^^^^^J Seibert, Earl|
Jafrul ; Jewett, Freeborn ; Robert Mottl
Subject: RE: PV 29 Worker exposure/safety information: Sun Chemical, Bushy Park
; Passe, Loraine ; Hasan,
Thank you Dave,
The Agency appreciates your response and will include the provided information in the final C.I. Pigment Violet 29 risk evaluation. In regards to the
workplace air monitoring, do you have information on the particle size of the dust? If you had a particle size range and distribution for the dust collected
that would be ideal for characterizing the total dust. We are grateful for any information you can provide.
Thank you,
Hannah Blaufuss, MHS
Envifonmental Pfotection Specialist
U S EPA Office of Pollution Prevention and Toxics
Page 30 of 96
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j
SunChemical
Colors Group
Bushy ParK Technology
Sample Identification
Acceleration Voltage: 80 KV
Date: 5/2C/2010
Operator: J. SieliO
TM12548
229-4050
SB40502
1 minute Ultrasonic @ 300W
ID05075
Magnification
70000x
500 nm
I |
Analytical Technology
Performance Pigment
Page 31 of 96
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From: Blaufuss Hannah
To: Jewett Freeborn
Cc: Passe Inraine: Hasan lafrul
Subject: FW: Answer to previous question: Micron or nanometer
Date: Tuesday, November 19, 2019 8:28:08 AM
Attachments: imaaeOOl.pna
imaae002.pna
imaae003.iDQ
imageQQ6.png
imaae007.pna
Hello Garrett,
Below is a clarification of particle size for PV29 from CPMA. Please share with appropriate staff. Let me know if you have any questions.
Thankyou,
Hannah Blaufuss, MHS
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
Please da not print this email unless alisolitelf necessary
From: David Wawerl
Sent: Monday, November 18, 2019 3:26 PM
To: Blaufuss, Hannah
Subject: Answer to previous question: Micron or nanometer
Good afternoon Hannah,
I'm providing revised plant site information re: worker exposure testing data. This replaces the information sent in an earlier email and
clarifies the question you asked about particle size measurement. Please share with appropriate EPA technical colleagues.
Dave
This information is based on the actual particle size and is representative of the respirable dust observed in the workplace
monitoring use and exposure testing data previously provided to EPA.
The mean diameter of the agglomerates is 20.0 microns and he median is 10.4 microns. The air pressure for dispersing the
powder was 750 millibars.
Sample ID
' \ncan (m)
Dio (m)
D50 (m)
D90 (m)
D99 (m)
229-4050 AMML0075 750 mb
20.0
1.04
10.4
54.4
109
Sample
Surface Area (m2/g)
True Density (ft'itj
229-4050
75
163
Page 32 of 96
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Particle Size Distribution Curve of 229-4050 AMML0075
David Wawer, Executive Director
Color Pigments Manufacturers Association, Inc.
This message and any attachments may contain confidential information for the exclusive use of the recipient CPMA member. Any publication, dissemination, distribution
or copying of this information to any other organization or person that is not currently employed by a CPMA member company is prohibited unless authorized by CPMA. If
you have received this message in error, please notify CPMA immediately and delete this message and any attachments from your system.
Page 33 of 96
-------
From: Blaufuss, Hannah
To: David Wawer
Cc: Tatiana Letcheva: Seibert. Earl: Passe. Loraine: Hasan. Jafrul: Jewett. Freeborn: Robert Mott
Subject: RE: EPA Request for PV29 Solubility Tests
Date: Monday, December 9, 2019 3:33:00 PM
Hello Dave,
I would like to schedule a meeting/call with you this week about the particle size of PV29. Also how
is it going with the protocol development for the solubility studies? Please let me know your
availability this week. Look forward to talking with you.
Thank you,
Hannah Blaufuss, MHS
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
A Please do not print this email unless absolutely necessary A
Page 34 of 96
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Particle Size Measurements for CI Pigment Violet 29
Two sets of particle size measurement have been supplied through CPMA to the Agency. Both of these
samples were analyzed by Sun Chemical Corporation in the Particle Physics Laboratory located at 1506
Bushy Park Road.
The sample in the first set was identified as BP40502, this sample was analyzed by test methods
intended to measure the primary particles as would be observed by typical customers manufacturing
automotive paint.
1. Transmission Electron Microscopy- Instrument used Zeiss EM-109TTEM (Transmission Electron
Microscope). The sample was ultrasonically dispersed (Branson 1200 Ultrasonic Bath or
equivalent) in 80/20 Ethanol (Reagent Alcohol)/Water for one mixture and loaded onto 3mm
200 mesh carbon coated copper grids with Formvar resin (EMS Cat. # FCF200-CU-50) which was
then dried. The sample was measured using an impact energy of 80 KV at magnification level of
30,000X (magnification knob number 11) engaged for the image taking, which gives a 70000X
magnification on objects. The field of view is selected to show a well dispersed field of crystals.
The TEM picture shows the calibration bar.
2. Disc Centrifuge - Instrument used a Bookhaven DCP. The received pigment powder sample is
first thoroughly mixed with Nuosperse W-28 (Disperse Ayd W-28) in a ratio of 1 to 2 (0.5g
pigment sample based on dry color to l.Og Nuosperse W-28). The resulting paste was then
mulled on a Hoover Automatic Muller (Model M5) for 4x50 revolutions, the paste was manually
re-mixed and re-spread after each of the first three 50-revolution cycles. A pre-dispersion was
made by mixing 0.2g of the mulled paste in 20mL of deionized (Dl) water (< 0.2m) using a glass
rod with sonication in an ultrasonic bath (Branson 1200 Ultrasonic Bath or equivalent) for at
least two more minutes in the ultrasonic bath until completely dispersed. The resulting pre-
dispersion was sonicated at 300W for 2 minutes using a ultrasonic horn (a Branson Digital
Sonifier 450 or equivalent). After cooling down, the dispersion was mixed with 5mL of methanol
prior to injection to the DCP analyzer. The measurement was performed on a Brookhaven Bl-
DCP Particle Sizer using a Dl water/MeOH gradient spin fluid.
The second sample was identified as AMML0075, this sample was analyzed as received in the laboratory
without preparation. The method of analysis was selected to show the particles expected on the
manufacturing floor for respirable dust.
This test was done on Cilas 1190LD laser diffraction instrument using standard dry mode. The
sample as received (in dry powder state) was charged into the instrument directly.
Measurement conditions are indicated on the report (Averaged from three individual
measurement. Driving with a pressure of 750 mb compressed air and feeding with 52 Hz and
53% power level to maintain a proper signal level of 7%-8% Obscuration).
Dr. Robert C. Mott
Mott Consulting LLC
December 20, 2019
Page 35 of 96
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From: Blaufuss. Hannah
To: David Wawer
Cc: Tatiana Letcheva: Hasan. Jafrul: Passe. Loraine
Subject: RE: Background Information on particle size data submitted to EPA in 2019
Date: Tuesday, January 28, 2020 12:53:00 PM
Attachments: imaaeOOl.pna
imaae002.pna
Hello Dave,
Yes, we agree the study plan is a higher priority.
Thank you,
Hannah Blaufuss, MHS
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
A Please do not print this email unless absolutely necessary A
From: David Wawer|
Sent: Tuesday, January 28, 2020 12:50 PM
To: Blaufuss, Hannah
Letcheva
Loraine
Subject: RE: Background Information on particle size data submitted to EPA in 2019
I; Hasan, Jafrul ; Passe,
Good afternoon Hannah,
We're researching the questions, and will get back to you in a few days. First priority is submitting
revised test method protocol information, as requested in the 01/24/2020 email.
Dave
David Wawer, Executive Director
Color Pigments Manufacturers Association, Inc.
www.pigments.org
Page 36 of 96
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3
"CPMA
rPigments
Mormfcieiurers. Association
This message and any attachments may contain confidential information for the exclusive use of the recipient CPMA
member. Any publication, dissemination, distribution or copying of this information to any other organization or person that is
not currently employed by a CPMA member company is prohibited unless authorized by CPMA. If you have received this
message in error, please notify CPMA immediately and delete this message and any attachments from your system.
From: Blaufuss, Hannah
Sent: Tuesday, January 28, 2020 11:43 AM
Wa we r
Cc: Tatiana Letcheva Hasan, Jafrul : Passe,
Loraine
Subject: RE: Background Information on particle size data submitted to EPA in 2019
Hello Dave,
Our staff had three additional clarification questions for you and Sun Chemical regarding particle
size.
1. Are nanometer-sized PV29 particles produced and present at the Sun Chemical manufacturing
facility and if so, under what conditions of use and associated activities?
2. Do workers at Sun Chemical handle dry chemical containing PV29 with particle diameters in
the nanometer range? This was not adequately explained in the attached clarification.
3. Are the nanometer-sized particles expected to occur outside of a solvent or medium?
Thank you,
Hannah Blaufuss, MHS
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
A Please do not print this email unless absolutely necessary A
Page 37 of 96
-------
From: David Wawer|
Sent: Monday, January 6, 2020 2:57 PM
To: Blaufuss, Hannah : Hasan, Jafrul
Letcheva
Subject: Background Information on particle size data submitted to EPA in 2019
Dear Hannah,
Welcome to 2020. We're back in the office today to begin the new year. We look forward to final
conclusion to the PV 29 evaluation process in 2020.
Attached for your review is the explanation of the two distinct data sets submitted to EPA last year.
In addition, we're providing a document that describes technical information for respirators used by
Sun Chemical.
By January 6th: Sun Chemical will provide EPA with clarifications of the emails sent from
CPMA to EPA on November 7th and November 19th regarding particle size. Sun will also
provide EPA with PPE information used at the Sun Chemical Bushy Park site, i.e., type of
masks used during manufacturing, processing and handling PV29.
Dave
David Wawer, Executive Director
Color Pigments Manufacturers Association, Inc.
www.pjgments.org
Icpma
':¦¦¦¦¦ ' ¦ ¦ -mMit*
Monwfdftur*rsi Astee lotion
This message and any attachments may contain confidential information for the exclusive use of the recipient CPMA
member. Any publication, dissemination, distribution or copying of this information to any other organization or person that is
not currently employed by a CPMA member company is prohibited unless authorized by CPMA. If you have received this
message in error, please notify CPMA immediately and delete this message and any attachments from your system.
Page 38 of 96
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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
Page 39 of 96
-------
This memorandum presents draft sample questions based on information in the memorandum
and preliminary research conducted while supporting preparation of the PV29 Scope Document.
Note that the primary domestic manufacturing company (Sun Chemical) provided information in
the memorandum pertaining to some of the draft questions. However, other companies that
manufacture or import PV29 below the CDR reporting threshold did not provide information
pertaining to their facilities (e.g. BASF). The questions have been developed based on
information that may be needed from all importers and manufacturers. Questions that have been
answered by Sun Chemical in the memorandum are identified when appropriate.
We welcome the opportunity for additional questions as this project moves along.
General Questions pertaining to exposure
[BASF Corporation, including Colors & Effects, does not manufacture or process Pigment
Violet 29 (PV29) in the US and so has no information responsive to Questions 1-5.]
1. Please provide details of any industrial hygiene program at your facility.
2. Please provide available area and personal monitoring data of PV29 for workers directly
handling PV29 or active in the work area where PV29 is manufactured or handled (or
unloaded, transferred, or loaded into containers) including a description of the test
methodology.
3. Please provide available area and personal monitoring data for total particulates for workers
directly handling PV29 or active in the work area where PV29 is manufactured or handled
(or unloaded, transferred, or loaded into containers) including a description of the test
methodology.
4. Do workers wear any Personal Protective Equipment? If so, please describe it and indicate
which set/subset of workers are required to use it.
5. Please provide available monitoring data where PV29 containing mist maybe generated.
Include a description of the test methodology, the estimated number of workers possibly
exposed to the mist, the duration of exposure and description of worker activity.
General Questions pertaining to releases
[BASF Corporation, including Colors & Effects, does not manufacture or process Pigment
Violet 29 (PV29) in the US and so has no information responsive to Questions 6-14.]
Please describe the process for equipment cleaning, including (but not limited to):
a. What solvent is used (or is it aqueous cleaning)?
Page 40 of 96
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b. What is the frequency of cleaning (e.g., each batch (and how many batches per year),
each campaign (and what defines a campaign), once per month, once per year)?
How is the cleaning solution Please describe engineering controls (if applicable) to minimize
fugitive dust or mist containing PV29 from:
a. Process operations.
b. Unloading, transfer, and loading operations.
Sun Chemical provided a general summary of this information for all operations at their site:
"Dust handling systems are in place where the dried powder is added or dischargedfrom
equipment and the dust is captured in baghouses. The resulting dust and bags are handled as
contaminated industrial waste and sent to a licensed industrial waste handler for disposal"
6. How is collected fugitive dust disposed?
Sun Chemical provided a general summary of this information for all operations at their site
(see above).
7. Are there ventilation systems associated with indoor areas? If so, are there associated air
pollution control devices (please describe)?
Sun Chemical provided a general summary of this information for all operations at their site
(see above).
8. How are floor sweepings from process areas disposed?
9. Is any process wastewater generated? If so, please describe.
Sun Chemical provided this information for all operations at their site: " Wastewaters
associated with the manufacturing site are handled in a hard piped, state-of-the-art, above
ground biological wastewater treatment system. The resulting process wastewater is
discharged to the Cooper River under a NPDESpermit. The biological sludge is sent to a
licensed industrial waste handler
10. How is process wastewater disposed?
Sun Chemical provided a general summary of this information for all operations at their site
(see above).
11. Describe releases from processing/use not covered above:
a. sources of release
b. estimated amount
c. frequency of release
Page 41 of 96
-------
d. disposal media (surface water, landfill etc.)
12. Are there any PV29 monitoring data in landfills, sediment, surface water, effluent, biosolids,
leachate, soil, and/or air available for review?
13. Are there any known concentrations of PV29 in consumer products (e.g., watercolors, artistic
color, rubber and plastic)? List specific rubber and plastic products containing PV29.
Questions Related to Import of PV29
(These questions are primarily directed at the importer for volumes below the CDR
reporting threshold.)
14. Please provide the volume of PV29 imported on a yearly basis.
[The quantity of PV 29 imported to the US by BASF Corporation, including BASF C&E,
is <25,000 lbs/yr.J
15. Please indicate the concentration of PV29 in the imported material.
[The concentration of the imported industrial pigment product is 80% to 90% PV29.
The concentration of the imported tint paste is <25% PV29. The concentration of
paint/coating is <3% PV29. The primary function of this pigment is to tint the color of a
paint and would generally be formulated at levels <1 % but can be as high as 3%. J
16. Please indicate the physical state of the imported material.
[The industrial pigment is imported as a powder.
The tint paste/paint/coating products are imported as a liquid. ]
17. Please indicate the type of import container(s) PV29 is received in.
[Typical packaging for the industrial pigment product is two 15 kg multi-layered paper
bags packaged in a plastic bag lined carboard box.
Typical packaging for paint/coating products include steel IBC totes (ranging 200 to 528
gallons), steel drums (45 to 55 gallons), as well as, 1- and 5-gallon containers (metal and
plastic).]
18. Please describe how import containers are emptied and cleaned.
[Coatings containing PV29 are used on OEM Automotive Customer Paint Lines. For
coatings supplied in totes, once a tote is empty according to the Resource Conservation and
Recovery Act (RCRA), the RCRA-empty totes are sent to a tote cleaning facility in the US
to be cleaned and the tote is reused. The wash solution is handled according to RCRA
regulations as well.]
19. Please indicate how empty import containers are disposed.
[Imported paint/coatings products containing PV29 are used on OEM Automotive
Customer Paint Lines in the US. BASF Corporaton does not Manufacture or process
PV29 in the US]
Page 42 of 96
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20. Please describe the expected use(s) and quantity for each use at the import and/or customer
site (e.g., direct sale without repackaging, repackaging for direct resale, formulated on site
into another product/mixture for sale, consumed as a reactant for manufacture of another
pigment).
[Imported paint/coatings product are directly sold without repackaging in the US for use
on OEM Automotive Customer Paint Lines and some imported paint/coatings products are
stored in warehouses in the US and then exported. Imported tint pastes are stored in
warehouses in the US and then exported]
Questions Related to Domestic Manufacturing (and import) of PV29
[BASF Corporation, including Colors & Effects, does not manufacture or process Pigment
Violet 29 (PV29) in the US]
(These questions are directed at any manufacturing or importing company(ies);
recognizing Sun Chemical has provided some of this information for their site in the
CPMA letter, therefore Sun has already provided answers to some questions as noted
below.)
21. Please indicate the volume used on site and characterize the on-site use or uses, identifying
the volume for each on-site use (e.g., direct sale after manufacture without repackaging,
formulated on site into another product/mixture for sale, consumed as a site-limited
intermediate for manufacture of another pigment).
22. Please indicate the final concentration of PV29 in any product generated from on-site use that
is sent off site.
23. Please indicate the volume sent off site for domestic use vs. the volume exported.
24. Please describe unloading, transfer, and loading operations, as applicable:
a. from import containers, for on-site use(s) or for repackaging and sale/transfer off
site;
b. from manufacturing equipment (e.g. reactors) to temporary storage containers;
c. from manufacturing equipment or temporary storage containers to containers that
will be shipped off site; and,
d. associated with repackaging operations.
25. Please indicate the number of workers associated with manufacturing processes.
26. Please indicate the number of workers associated with unloading, transfer, and loading
operations as described above.
Page 43 of 96
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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
Page 44 of 96
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From: Seibert, Earl |
Sent: Wednesday, September 2, 2020 4 52 PM
To: Blaufuss, Hannah *ur>s. ria-tnc>M>ey?a.f.ov>
Cc. Lloyd, Tyler ^I'cy.'7>; Menasche, Claudia <;\ictcc i;
)avid Wawer
'Ji v >; Kendrick, Robert
Seibert, Earl
Subject; FW: PV29 Processors
Dear Ms Blaufuss,
Please find attached, the following information relating to the Pigment Violet 29 (PV29) risk assessment in response to
questions raised by EPA during our teleconference held yesterday September 1st, 2020,
Regarding the characteristics of containers leaving the facility, there are two primary packaging configurations employed
at the facility. The predominant packaging configuration includes the use of a 20kg Kraft paper bag, which is placed into
a corrugated cardboard box. A total of ten (10) boxes are then placed on a single pallet and shrink-wrapped in
preparation for shipment. The less frequent packaging configuration involves the use of a single 300kg bulk bag
(supersac) which is placed into a large corrugated box with lid (gayiord) and placed on a pallet. This gaybrd typically
does not require the use of shrink wrap.
With regards to the estimated 90% of PV29 used as an intermediate chemical at the Bushy Park facility, all "intermediate
use" would take place on site. That said, the production of PV29 is the starting point for the synthesis of all other
peryiene pigments at the facility, Other perylenes produced at the facility may contain an estimated 0-5% residual PV29
in the finished pigment. The remaining 10% of the finished Pigment Violet 29, which is not further processed or used as
an intermediate, is sold into the Plastics and Coatings (P&C) industries.
In response to your question relating to downstream customer use and exposure involving PV29, we have the following
comments for your consideration. Although we may have a general sense of customer use and exposure relating to
PV29 and the P&C industries, we currently do not have a detailed understanding that we would be comfortable sharing
with EPA. Additional time would be needed for Sun Chemical's Sales and Marketing team to identify customer contacts
in the P&C Industries who may be able to provide more detailed information. Due to the complexity of what is being
asked by EPA, Sun Chemical's management team would need to have further internal discussions before making any
decisions regarding the aforementioned. It is highly likely that customers in the P&C industry are not fully aware of the
intricate details of the PV 29 risk evaluation. In addition, there is concern over uncertainty as to the sensitive nature of
the request and where this information request may end up. The technical details (PPE used, paint manufacturing
processes), if answered without propping from Sun land CPMA), could raise major concerns with our customer base. The
P&C folks are already nervous about PCB's in their products {Washington State Safer Products Report), as well as the
lead paint legacy. It is our preference that Sun Chemical work directly with any paints/coatings customer to obtain the
information desired by EPA,
Regulatory Affairs Manager
Sun Chemical Performance Figments
working, for you.
Page 45 of 96
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From: Blaufuss, Hannah < L*a is f u s i, > i«, > nci h,'fi) vpa,ac>
Sent; Thursday, August_27, 2020 2:02 PM
To: Seibert,
€c'. Lloyd, Tyie-r < r' «i " '>, Menasche, Claudia <'...•¦• ..
David Wawer
Subject: {ExtemaljRE: PV29 Processors
•*¦ -'.QA-Z^y>.* Kendrick, Robert
Hello Earl,
We are looking to talk directly to Sun Chemical's customers on how they process the PV29 product. Are you available to
talk this afternoon or tomorrow morning?
Thank you,
Hannah Blaufuss
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone; 12021 564-5614
for information on COVID-19 visit the CDC
>a.gov>; Kendrick, Robert
Seibert, Earl
Subject: IE: PV29 Processors
Hello Hannah,
Thank you for thinking of Sun Chemical as a potential resource for questions related to paints & coatings manufacturing.
I'm not certain we can assist directly because we are talking about technical processes for a totally different
industry. Could we schedule a brief WebEx discussion with you and your colleagues in the next several days to help
clarify what you're seeking to achieve? I've copied Dave Wawer at CPMA because he may also be able to shed some
light on the topics raised in your email.
1 look forward to hearing from you soon.
Thank you,
Sun Chemical Performance Pigments
From: Seibert, Earf 1
Sent: Tuesday, August 25, 2020 7:03 PM
To: Blaufuss, Hannah ^efj^fej)n.gov>; Menasche, Claudia
-------
working for you*
From: Blaufuss, Hannah 'c.ufuss,Hgnrahig'ejm goo
Sent: Monday, August 24, 2020 12:59 PM
To: Seibert, Ear
Cc: Lloyd, Tyler
enasche, Claudi
Subject: [External]PV29 Processors
Hello Mr, Seibert,
We are getting closer to completing the risk evaluation and we are checking our assumptions. Could you put us in
contact with your paint and plastic/rubber customers for PV29? We would like to check with them on some assumptions
as we evaluate conditions of use downstream from manufacturing. The nature of our questions are regarding their
processing activities, PPE used and the physical state of PV29 that they handle. Please let us know if this would be
something that you could help us with,
Also I will be out of the office from September 7-11, so if you have any questions for the Agency during that time please
contact my colleagues Tyler Lloyd and Claudia Menasche (cc'd above).
Thank you,
Hannah Blaufuss
Environmental Protection Specialist
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 aay form or ta.te any action in reliance on it.
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 ta'ce any action in reliance on it.
Prevention and Toxics
For information on COV1D-19 visit the CDC
Page 47 of 96
-------
From:
To:
Cc:
Subject:
Date:
Attachments:
Parsons. Doug: Wolf. Joel
Blaufuss. Hannah: Menasche. Claudia: Kramek. Niva: I
RE: PV29 Processors
Wednesday, September 16, 2020 4:10:58 PM
PV29 Questions for Users and Processors -(Plastics Aggregate datal.pdf
Dear Mr. Parsons,
As agreed in our Sept 3, 2020 meeting with EPA , please find attached the risk evaluation
questionnaire provided by EPA, which includes aggregate information for Pigment Violet 29
(PV29) as it relates to downstream customer use and exposure for the Plastics industry.
We still working to aggregate the industry response for Coatings and will submit the
information as soon as possible.
Please let me know if you have any questions.
Earl Seibert
Regulatory Affairs Manager
Sun Chemical Performance Pigments
working for you.
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 48 of 96
-------
Questions on Downstream Uses of C.I. Pigment Violet 29 (PV29)
Purpose: As the agency continues working on the final risk evaluation for PV29, we are
interested in information from people that process PV29 for plastics and paint manufacturing to
better understand exposures. During conference calls over the last week, Sun Chemical
Corporation confirmed their intent to seek downstream processing information on PV29. Sun
Chemical Corporation requested the types of information that could inform the risk evaluation
and requested EPA provide some written questions. The questions are below. Compiling and
submitting this data is entirely voluntary. The specific questions are:
1. When the processor receives PV29, what physical state and what concentration?
a. 100% Dry pigment
2. What type of processing is done to PV29 as it is incorporated into plastics and paints after
the companies received PV29 from Sun Chemical Corporation? Or What type of
processing is done after receiving PV29 from Sun Chemical Corporation in order to
incorporate the pigment to plastics and paints?
a. Pigments including PV29 are weighed and dry blended with polymers and
other additives. This preparation is then extruded into pellets to make single
pigment dispersions and custom colors primarily for Fiber.
3. How is PV29 handled by those incorporating the pigment into plastics and paints? Is it a
manual operation requiring an intervention of a worker, or a more automatic operation?
a. Typically, PV29 bags are manually opened and added to a vessel for
weighing. This blend is then extruded via a continuous and closed process
involving encapsulation into pellets. Dust collection and PPE are required in
the weigh up area where a potential for exposure to dust exists. Typical PPE
includes Tyvek coverings, goggles, and dust masks.
4. Description of how exposures from PV29 are managed during processing/use, including
how bags are opened, how they are emptied, how any dust is controlled, what PPE,
ventilation, or engineering controls are common during processing activities at your site.
a. Controls are in place to manage dust via a dust collection system and
including PPE. Dust collection systems and PPE are required in the weigh
up area where a potential for exposure to dust exists. Pigment bags are
manually opened in the presence of a dust collection system and PPE is
required according to the SDS at minimum.
5. Are there any personal or area air monitoring data available that could be shared with
EPA to better estimate exposures to workers of the downstream processors and users?
a. Not currently
6. How long does it take to incorporate PV29 into the plastics and paints? Are workers
exposed to PV29 during the entire processes?
Page 49 of 96
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a. Workers are only exposed during the short weigh up and transfer process of
a couple minutes. Extruder time depends on batch size and equipment size,
but can take up to 30 minutes for the entire process.
7. Are inhalation exposures only possible at certain times, for example at the beginning of
the batching processing, or are there inhalation exposures to PV 29 in multiple phases of
the processing, or are workers continuously exposed to PV29?
a. Potential for a small amount of inhalation exposure exists mainly during the
weigh up, transfer and/or blending processes. The mixer and extrusion
process are closed systems and have fume collection.
8. What is the expected exposure time of workers to PV29, for example, is it one day a
month, several days a month, or only a few hours a month?
a. A few minutes/ per month up to one day/ per month
9. How much PV29 do you use/handle per day and how many days of the year?
a. A few tons may be used in one day, but only 6 to 12 days/ per year typically.
Small amounts of PV29 are used compared to other pigments and only in
select formulas.
10. Do processors test PV29 product they receive for particle size? Is this information
provided in the product description by Sun Chemical?
a. Pressure testing (FPV) is typically done on the concentrate after
encapsulation. Particle size data is typically not included in the testing as no
dry analyses is conducted.
11. Is PV29 milled additionally after receiving it from Sun Chemical?
a. No. PV29 is weighed blended and extruded.
12. What end products incorporate PV29? Describe the products containing PV29 leaving
your facility (physical state, concentration of PV29)?
Are any of these potentially marketed to children?
a. All PV29 used in nylon fiber at low pigment content ( < 0.5%) predominantly
in carpet fiber/ commercial flooring applications
b. Children are not targeted as the primary application is nylon fiber
13. Can you estimate the number of processors for each of those end products?
a. A total of 3-10 processors
Page 50 of 96
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Blaufuss, Hannah
From: Seibert, Earl <1
Sent: Tuesday, October 27, 2020 3:32 PM
To: Blaufuss, Hannah
Cc: Menasche, Claudia; Kramek, Niva; David Wawer; Parsons, Doug; Kendrick, Robert; Wolf, Joel; Seibert,
Earl
Subject: RE: PV29 Processors, Plastics & Coatings Industries (follow up response)
Attachments: PV29 Plastics Industry Follow up response 10 27 2020.pdf; PV29 Coatings Industry Follow up
response 10 27 2020.pdf
Follow Up Flag:
Flag Status:
Follow up
Flagged
Dear Ms. Blaufuss,
Please find attached , a follow up summary of the feedback received from both the Plastics and Coatings
industries in response to questions posed by EPA on October 5,2020.
Please me know if you have any additional questions.
working for you.
From: Blaufuss, Hannah
Sent: Monday^)ctobe^j>^02Cr^47^^^^^^^
Seibert,
Cc: Menasche, Claudia ; Kramek, Niva ; David Wawer
l>: Parsons, Doug ; Kendrick, Robert
|>; Wolf, Joel
Subject: [External]RE: PV29 Processors
Hello Mr. Seibert,
Thank you for submitting the responses from the coatings industry. The Agency had a couple follow-up questions
regarding the specific coating responses and some pertaining to the plastics sector as well.
• It was not clear if these responses were your general understanding about the coatings industry or if these
responses were directly from one of your downstream clients in the coatings industry. Could you confirm where
the responses came from?
• If there is any more robust information for how answers are known would be helpful, specifically questions 1, 6,
8 and 9.
1
Page 51 of 96
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• If there is any more information on the details in question 4 like type of respirator and engineer controls, that
would also be helpful.
• Question 4: (for both coating and plastics) Provide an estimate for the number of workers
• For coatings: Provide the number of workers handling bags and workers involved in mixing and milling operation
per site.
• For plastics: Provide an estimated number of workers handling bags containing PV29 and handling pellets
containing PV29 per site.
• Question 12: (for coatings only) Please estimate the PV29 concentration in the base coat used in the automotive
industry if possible.
• Question 13: (for both coating and plastics) Please clarify if the response to this question refers to Sun
Chemical's direct customers (processors) or the commercial/industrial end users.
• For coatings: Provide the number of direct customers (processors - coating manufacturers) and the associated
number of potential end users (automotive customers).
• For plastics: Provide the number of direct customers (processors -compounders producing pellets) and
associated number of carpet fiber / commercial flooring manufacturers.
Thank you,
Hannah Blaufuss
Environmental Protection Specialist
U.S. EPA Office of Pollution Prevention and Toxics
Chemical Control Division
Phone: (202) 564-5614
ft Please do not print this email unless absolutely necessary ft
For information on COVID-19 visit the CDC
Page 52 of 96
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Coatings industry Follow up response 10-27-2020
Please find attached , a follow up summary of the feedback received from the Coatings industry in
response to questions posed by EPA on October 5,2020.
Question 1: Can you explain why the concentration of pigment is only 80%? Is the pigment being sent
to an offsite processor to be "mixed" with another material/liquid? Could it be a typo? The pigment
powder, as received from the supplier, is a mixtM >i . >ut 80% PV29 and 20% bai iniii --nlfate.
Question 4: Is there any more information that can be provided on dust mask type or engineering
controls? PPE and engineering controls are consistent with industry standards for exposure and control
of workplace dust.
Question 4: Provide the number of workers handling PV29 bags versus workers involved in mixing and
milling operation per site. One worker handles bags, one worker is assigned and, one person is
assigned to mill.
Question 8: Can any more detailed information be provided regarding the expected exposure time to
the worker. In other words, how much time per day / per worker on average is there exposure to PV29
dust? Is the exposure time distributed somewhat evenly over the course of the month? Year? One
worker for 30 minutes, 30 days per year
Question 9: Similar to Question 8 clarification, is there any more detail on how much PV29 do you
use/handle per day and how many days of the year? 220-280 pounds per day, 30 days a year
Question 12: Are you able to provide a concentration range for the PV29 in the base coatings used in
the automotive industry which leave the facility. Less ti 1% to 6%
Question 13: Are you able to provide the number of potential end users (automotive customers). No
Page 53 of 96
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Plastics Industry Follow up response 10-27-2020
Please find attached , a follow up summary of the feedback received from the Plastics industry
in response to questions posed by EPA on October 5,2020.
Question 4 (Plastics): Is there any more information that can be provided on dust mask type or
engineering controls. Customers reported to have dust collection at the point of bag opening &
weigh up consistent with industry standards. Employees handling the product use PRE as
specified in the SIDS. In general, /Jill customers have stated that them I I II Engineering
controls are consistent with industry standards for exposure and control of woirkplla t.
(Plastics only): Provide an estimated number of workers handling PV29 bags versus those
handling pellets containing PV29 per site. Please define what is meant by "pellet".
This varied slightly, but would be sim n one location to the next. One or two employees
weigh up the dry blend while one or two employees mama- > n - xtruder or sev- i J > -traders
used to make pellets . Pellets consist xtruded concentrate of pigment, additives, and
resin, which lerently non-dusting.
Question 6 (Plastics): What percentage of the dry pigment used in the plastics industry is
supplied in PE bags where there is no real exposure to PV29 dust.
The majority of PV 29 is supplied in non-inclusion paper bags.
Question 8 (Plastics): Can any more detailed information be provided regarding the expected
exposure time to the worker. In other words, how much time per day / per worker on average
is there exposure to PV29 dust? Is the exposure time distributed somewhat evenly over the
course of the month? Year? All customers reported a few to several minutes of exposure time
on the days they were making PV 29 blends. This would only include one worker or two, at the
most. Use is not evenly distributed over the year but demand driven. The tir " exposure to
PV29 is minimal as compared to other pigment types.
Question 9 (Plastics): : Similar to Question 8 clarification, is there any more detail on how much
PV29 do you use/handle per day and how many days of the year? The estimated worst case
2 of usage spread across the total customer base is estimated to be between 10-780
lbs/day typically not exceeding 6-12 days per year.
Question 13: (Plastics only): Are you able to provide the associated number of carpet fiber /
commercial flooring manufacturers. Based on customers surveyed, a tot e of 3-10
processors are involved per individual customer. Each customer predominantly supplies into
the carpet fiber/ commercial flooring markets.
Page 54 of 96
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From:
¦
< u
Subjor lost by any error in
transmission. If yc u ale not the intended recipient"-; f tnis messacre you are
hereby notified that y;>u mist n~>t use, disseminata, ccpy it in any form or
take any action in reliance .-n it.
Page 55 of 96
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Questions on Downstream Uses of C.I. Pigment Violet 29 (PV29)
Coatings Industry Responses (in bold text)
9-21-2020
Purpose: As the agency continues working on the final risk evaluation for PV29, we are
interested in information from people that process PV29 for plastics and paint manufacturing to
better understand exposures. During conference calls over the last week, Sun Chemical
Corporation confirmed their intent to seek downstream processing information on PV29. Sun
Chemical Corporation requested the types of information that could inform the risk evaluation
and requested EPA provide some written questions. The questions are below. Compiling and
submitting this data is entirely voluntary. The specific questions are:
1. When the processor receives PV29, what physical state and what concentration? Dry
pigment powder with concentration of approximately 80%.
2. What type of processing is done to PV29 as it is incorporated into plastics and paints after the
companies received PV29 from Sun Chemical Corporation? Or What type of processing is done
after receiving PV29 from Sun Chemical Corporation in order to incorporate the pigment to
plastics and paints? Mixing and milling into tint paste.
3. How is PV29 handled by those incorporating the pigment into plastics and paints? Manual
additions of product bags. Is it a manual operation requiring an intervention of a worker, or a
more automatic operation? Yes.
4. Description of how exposures from PV29 are managed during processing/use, including how
bags are opened, how they are emptied, how any dust is controlled, what PPE, ventilation, or
engineering controls are common during processing activities at your site. The bags are
opened and lifted manually and material is dumped into the mixer. Local exhaust
ventilation is used. There are mechanical exhaust fans with low level vents, a dust
collection unit, and a supply air unit. PPE worn during batch additions are typically
protective clothing, respirator, and chemical resistant gloves.
5. Are there any personal or area air monitoring data available that could be shared with EPA to
better estimate exposures to workers of the downstream processors and users? Not at this
time, although total particulate results historically have been less than the action level
for facilities with the greatest use of powder-like materials.
6. How long does it take to incorporate PV29 into the plastics and paints? Less than 30
minutes. Are workers exposed to PV29 during the entire processes? Exposure is limited to
the 30 minute task.
Page 56 of 96
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7. Are inhalation exposures only possible at certain times, for example at the beginning of the
batching processing, or are there inhalation exposures to PV 29 in multiple phases of the
processing, or are workers continuously exposed to PV29? Only the beginning of the
process, opening of bags, addition, and bag disposal.
8. What is the expected exposure time of workers to PV29, for example, is it one day a month,
several days a month, or only a few hours a month? A few hours a month
9. How much PV29 do you use/handle per day and how many days of the year? On average,
an average of about 7-8 [44 pound] bags are added per batch. Less than 200 [44 pound]
bags are processed per year.
10. Do processors test PV29 product they receive for particle size? No. Is this information
provided in the product description by Sun Chemical? No
11. Is PV29 milled additionally after receiving it from Sun Chemical? Yes, into tint paste
12. What end products incorporate PV29? Describe the products containing PV29 leaving your
facility? (physical state, concentration of PV29) PV29 containing intermediates are added to
a wide variety of liquid colored basecoats for the automotive industry.
a. Are any of these potentially marketed to children? No
13. Can you estimate the number of processors for each of those end products? 1 processor
Page 57 of 96
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Part III. SDSs for C.I. Pigment Violet 29
Page 58 of 96
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SDS for C.I. Pigment Violet 29- BASF (importer) (BASF SDS 4081884)
Page 59 of 96
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PALIOGEN® REDVIOLET K 5011
General Properties
Chemical Structure
Colour Index Part I
Colour Index Part II
CAS Number
Physical Form
Colour Shade
Perylene Red
P.V. 29
71129
81-33-4
Powder
Red Violet
Preparations
Luprofil™ Violet 50-1105 C 4
Palamid™ Violet 50-1105
(Other) preparations can be made on special request.
Colouristical Properties Org.
Hue Grade in PVC 1/3 SD 334
Chroma in PVC 1/3 SD 35
Red. Ratio in PVC 1/3 SD 17.1
Hue Grade in PVC 1/9 SD 330
Chroma in PVC 1/9 SD 29
Red. Ratio in PVC 1/9 SD 45.7
Hue Grade in PE-LD 1/3 SD 327
Chroma in PE-LD 1/3 SD 25.6
Red. Ratio PE-LD 1/3 SD 6.2
Hue Grade in PE-LD 1/9 SD 325
Chroma in PE-LD 1/9 SD 22.9
Red. Ratio in PE-LD 1/9 SD 18.6
Ease of Dispersion
20
Physical Properties
Density
Bulk Density
Index of pH
Conductivity
Specific Surface
Fastness properties
Heat stability
Light fastness
Weather fastness
Migration fastness
Infl. on warping of PE-HD
1.6
0.23
4-5
215
78
300
8
5
Distinct
g/cm3
g/cm3
|jS/cm
m2/g
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct.1998) - Printed: 8/24/99
Page: 1
Page 60 of 96
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PALIOGEN® REDVIOLET K 5011
Fastness to chemicals:
HCI conc.
>6
Months
HCI 10%
>6
Months
H2S04 conc.
>6
Months
H2S04 10%
>6
Months
HN03 conc.
Instable
HN0310%
>6
Months
NaOH conc.
>6
Months
Na2C03 sat.
>6
Months
Criteria for the fastness to chemicals was a possible colour change
of the coloured plastic material during the storage in the test medium.
Recommendations for applications
PVC-p
PVC-u
PUR
LD-PE
HD-PE
PP
PS
SB
SAN
ABS/ASA
PMMA
PC
PA
PETP
CA/CAB
UP
Suitable
Suitable
Suitable
Suitable
Suitable
Suitable
Suitable
Suitable
Suitable
UCC
Suitable
UCC
UCC
UCC
Suitable
Suitable
UCC: Under certain conditions
Recommendations for food applications
BgW
FDA
France
Suitable
UnderApp.
Not suitable
UCC: Under certain conditions
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct. 1998) - Printed: 8/24/99
Page 61 of 96
Page: 2
-------
LUCOLOR 2.0
8/24S9
Product Specification - PALIOGEN® RED VIOLET K 5011
PROPERTIES
Pigment type:
Colour Index:
Application:
Physical form:
Storage:
Food packaging:
SPECIFICATION
Colour tolerances:
Strength equivalence:
Test method:
Perylene red
Pigment Violet 29
Colourant for plastics
Powder
practically unlimited shelf life
approved according to "Empfehlung IX des BgW".
dH*±0.7;dC* ±0.7; dL* ± 0.7; dE* <=1.0;
da* ±0.7; db* ± 0.7
100 ± 5 %
BASF test method 11.3.1
Please note:
The above data will be warranted by us. These data, however, as well as
the properties of any product samples do not imply any legally binding
assurance of certain properties or of suitability for a specific purpose so that any
liability for damages cannot be derived therefrom.
Page 62 of 96
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LUCOLOR 2.0
8/24/99
Microscopy - PALIOGEN® REDVIOLET K 5011
-------
Reflection Curve
PALIOGEN® REDVIOLET K 5011
100 T
80-
60-
40
20
0
400
0.2%
1:10
1:100
Test medium:
PVC-p
450
500
550
Wavelength nm
600
650
700
Note: The program stores curve points (see table). The diagram shows approximations.
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct.1998) - Printed: 8/24/99
Page 64 of 96
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Particle Size Distribution
PALIOGEN® REDVIOLET K 5011
100
CD
N
if)
a)
>
O
Susp. Fluid: H20
Disp. Agent: Tetronic
Mixer Time: 60 s
Median Size: 0.608 u
CI LAS
Diameter |j
Note: The program stores curve points (see table). The diagram shows approximations.
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct.1998) - Printed: 8/24/99
Page 65 of 96
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Heat Stability
PALIOGEN® REDVIOLET K 5011
5 T
3
*
LD
"O
1 -
1:50
1:10
Test medium:
PE-HD (Lupolen 6031M)
According to
DIN 53772
0
200
220
240 260
Temperature °C
280
300
320
Note: The program stores curve points (see table). The diagram shows approximations.
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct.1998) - Printed: 8/24/99
Page 66 of 96
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Weather fastness
PALIOGEN® REDVIOLET K 5011
3000
1:50
1:10
0.2%
0.05%
Test medium:
PE-HD (Lupolen 6031M)
According to
DIN 53387, 54001
0 12 3
Steps grey scale
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct.1998) - Printed: 8/24/99
Page 67 of 96
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Light fastness
PALIOGEN® REDVIOLET K 5011
All data is subject to the producer's disclaimer
LUCOLOR 2.0 - BASF Colourants for Plastics (Oct.1998) - Printed: 8/24/99
Page 68 of 96
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Product Safety Datasheet BASF
Name of product
PALIOGEN® Red K 3580
C.I. No. / Name
CAS No. / EINECS No.
71 137 / C.I. Pigment Red 149, Perylene Red
4948-15-6/225-590-9
Name of product
C.I. No. / Name
CAS No. / EINECS No.
PALIOGEN® Red K 3911 HD
71 155 / C.I. Pigment Red 178, Perylene Red
3049-71-6/221-264-5
Name of product
C.I. No. / Name
CAS No. / EINECS No.
PALIOGEN® Red K 4180
71 130 / C.I. Pigment Red 179, Perylene Red
5521-31-3/226-866-1
Name of product
C.I. No. / Name
CAS No. / EINECS No.
PALIOGEN® Red Violet K 5011
71 129 / C.I. Pigment Violet 29, Perylene Red
81-33-4/201-344-6
Chemical nature
Toxicology
The listed PALIOGEN® types, also known as perylene pigments, are
derivatives of perylenetetracarboxylic anhydride. Originally used as vat dyes,
it is only since 1950 that they have found application as pigments for
colouring plastics and high-grade industrial paints.
Perylene pigments do not exhibit acute oral toxicity in animal trials, nor do
they irritate the skin and mucous membranes. A 28-day (subacute) feeding
trial carried out with a perylene pigment did not show any adverse
toxicological results.
Ecology
Labelling
Because of their poor solubility in water, perylene pigments are nontoxic to
aquatic organisms and are not an environmental hazard. An 8-week
bioaccumulation study with a perylene pigment on fish showed that the
pigment does not accumulate in the organism.
The above listed products are not dangerous substances in the sense of the
German Ordinance on Dangerous Substances or of corresponding EU
regulations.
Classification as dangerous goods
The products are not classified as hazardous under transport regulations.
Heavy metal content
PALIOGEN® pigments do not contain any lead, cadmium, chromium(VI)
and mercury compounds in their formulations. The sum of the total contents
of these elements, according to tests on standard samples, is less than 100
mg/kg. It is thus below the limit in the EU packaging directives and the
American CONEG model.
Antimony
Arsenic
< 20 mg/kg
< 20 mg/kg
Chromium
Selenium
< 50 mg/kg
< 20 mg/kg
Page 69 of 96
-------
Halogen content
Food legislation
are
are
migration".
Toys
Registration status
Lead
Cadmium
< 20 mg/kg
< 30 mg/kg
Mercury
Zinc
Prim, aromatic amines
< 20 mg/kg
< 20 mg/kg
<100 mg/kg
The metal levels quoted are based on the detection limit of the analytical
determination method used (X-ray fluorescence spectroscopy). The actual
levels may lie well below these values.
PALIOGEN® pigments do not contain organically combined halogens.
According to tests on standard samples (Type 8081) the listed PALIOGEN®
pigments conform to the demands on purity in the following food legislation
(see also "Heavy metal content"):
Europe: Resolution AP (89)
Germany: BgVV Empfehlung IX., 190. Mitteilung vom 1.6.1994
France: Brochure No. 1227. Red K4180 and Redviolet K5011
not listed in the French Positive List.
Italy: Decreto Ministeriale dated 21.3.1973
Spain: Resolution del 4.11.82 de la Subsecretaria de Sanidad
USA: C.I. Pigment Red 179 ist listed in the FDA-Positive List
(21.CFR, § 178.3297). The other PALIOGEN® pigments
in approval. Current use only on evidence of "non
According to tests on standard samples (Type 8082), the listed PALIOGEN®
pigments conform to the demands on purity in the European standard on
toys, i.e. EN 71, Part 3.
The components of the products are listed in the chemical inventories of the
following countries: EU (EINECS), USA (TSCA), Canada (DSL), Japan
(MITI), Australia (AICS), Korea (ECL), Philippines (PICCS, Final Version
1995), and Switzerland (BAGT No. 612200, Class free).
Other legislation on chemicals
The products do not fall under the provisions of the agreement on chemical
weapons and do not contain any substances that are mentioned in the
German Ordinance on the Prohibition of Certain Chemicals
(ChemVerbotsV). They are produced without using substances that destroy
ozone (Montreal Agreement - Ozone Depleting Substances).
TA Luft
MAK value
Para 3.1.3 - Total dust (Germany)
The general threshold value for dust, i.e. 6 mg/m3, must be observed.
(Proposal of the MAK commission for the alveolar passing dust fraction, i.e.
1.5 mg/m3, is not yet valid) (Germany)
Water hazard class
WGK 1 (slightly water hazardous according to German legislation
group classification organic colours)
KBwS ¦
Further information can be found in our Material Safety Data Sheets and Technical Information Bulletins.
The Product Safety Department in our Organic Pigments Division will gladly reply to your queries and can
be reached under the following address:
Page 70 of 96
-------
BASF AG
Fax:!
Dr Oberlinner
Mrs Paymal
Mr Schwanse
The information submitted in this publication is based on our current knowledge and experience. It is the responsibility of those to
whom we supply our products to ensure that any proprietary rights and existing laws and legislation are observed.
Page 71 of 96
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SDS for C.I. Pigment Violet 29 Commercial Product - Sun Chemical Corporation
Page 72 of 96
-------
SiiiiChemiea]
a member of the D1C group
Color * Comfort
SAFETY DATA SHEET
Section 1. Identification
Product code
GHS product identifier
Trade name
2294050
PERRINDO® VIOLET 29
PERRINDO® VIOLET 29
Relevant identified uses of the substance or mixture and uses advised against
Identified uses
Colorant; Printing ink related material; Printing ink.
Manufacturer / Distributor
Sun Chemical Corporation
5020 Spring Grove Avenue
Cincinnati, OH 45232-1999
Phone: +1 (513)681-5950
Emergency telephone : +1
number (with hours of +1
operation)
Other information : +1
(800) 424-9300 (U.S.) (24 hours)
(703) 527-3887 (International) (24 hours)
708 236 3798
Section 2. Hazards identification
OSHA/HCS status
Classification of the
substance or mixture
While this material is not considered hazardous by the OSHA Hazard Communication
Standard (29 CFR 1910.1200), this SDS contains valuable information critical to the
safe handling and proper use of the product. This SDS should be retained and available
for employees and other users of this product.
Not classified.
GHS label elements
Signal word
Hazard statements
Precautionary statements
Prevention
Response
Storage
Disposal
Hazards not otherwise
classified
No signal word.
No known significant effects or critical hazards.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Fine dust clouds may form explosive mixtures with air. Handling and/or processing of
this material may generate a dust which can cause mechanical irritation of the eyes,
skin, nose and throat.
Section 3. Composition/information on ingredients
Substance/mixture : Mixture
CAS number/other identifiers
Ingredient name
CAS number
%
Barium Resinate
68188-14-7
5-10
Any concentration shown as a range is to protect confidentiality or is due to batch variation.
27- October- 2017 en - US Page: 1/9
rage 73 of 96
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2294050
Section 3. Composition/information on ingredients
There are no additional ingredients present which, within the current knowledge of the supplier and in the
concentrations applicable, are classified as hazardous to health or the environment and hence require reporting
in this section.
Occupational exposure limits, if available, are listed in Section 8.
Section 4. First aid measures
Description of necessary first a id measures
Eye contact
Inhalation
Skin contact
Ingestion
immediately flush eyes with plenty of water, occasionally lifting the upper and lower
eyelids. Check for and remove any contact lenses. Get medical attention if irritation
occurs..
Remove victim to fresh air and keep at rest in a position comfortable for breathing. Get
medical attention if symptoms occur. In case of inhalation of decomposition products in
a fire, symptoms may be delayed. The exposed person may need to be kept under
medical surveillance for 48 hours.
Flush contaminated skin with plenty of water. Remove contaminated clothing and
shoes. Get medical attention if symptoms occur.
Wash out mouth with water. Remove victim to fresh air and keep at rest in a position
comfortable for breathing. If material has been swallowed and the exposed person is
conscious, give small quantities of water to drink. Do not induce vomiting unless
directed to do so by medical personnel. Get medical attention if symptoms occur.
Most important symptoms/effects, acute and delayed
Potential acute health effects
Eye contact
Inhalation
Skin contact
Ingestion
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the eyes.
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the nose, throat and lungs.
No known significant effects or critical hazards.
No known sianificant effects or critical hazards.
Indication-of immediate medicaLattention-and special.treatment needed..if necessary
Notes to physician : In case of inhalation of decomposition products in a fire, symptoms may be delayed.
The exposed person may need to be kept under medical surveillance for 48 hours.
Specific treatments : No specific treatment.
Protection of first-aiders : No action shall be taken involving any personal risk or without suitable training.
See toxicological information (Section 11}
Section 5. Fire-fighting measures
Extinguishing media
Suitable extinguishing
media
Unsuitable extinguishing
media
Use dry chemical, CO?, water spray (fog) or foam.
Do not use water jet.
Specific hazards arising
from the chemical
Hazardous thermal
decomposition products
No specific fire or explosion hazard.
Decomposition products may include the following materials:
carbon dioxide
carbon monoxide
nitrogen oxides
sulfur oxides
metal oxide/oxides
27- October- 2017
en - US
Page 74 of %
Page: 2/9
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2294050
Section 5. Fire-fighting measures
Special protective actions
for fire-fighters
Special protective
equipment for fire-fighters
Promptly isolate the scene by removing all persons from the vicinity of the incident if
there is a fire. No action shall be taken involving any personal risk or without suitable
training.
Fire-fighters should wear appropriate protective equipment and self-contained breathing
apparatus (SCBA) with a full face-piece operated in positive pressure mode.
Section 6. Accidental release measures
For non-emergency
personnel
For emergency responders
No action shall be taken involving any personal risk or without suitable training.
Evacuate surrounding areas. Keep unnecessary and unprotected personnel from
entering. Do not touch or walk through spilled material. Avoid breathing dust. Put on
appropriate personal protective equipment.
If specialized clothing is required to deal with the spillage, take note of any information in
Section 8 on suitable and unsuitable materials. See also the information in "For non-
emergency personnel".
Environmental precautions : Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains
and sewers. Inform the relevant authorities if the product has caused environmental
pollution {sewers, waterways, soil or air).
Methods andmaleiiatslpr.containment and cleaning tip
Small spill : Move containers from spill area. Vacuum or sweep up material and place in a
designated, labeled waste container. Dispose of via a licensed waste disposal
contractor.
Large spill : Move containers from spill area. Approach release from upwind Prevent entry into
sewers, water courses, basements or confined areas. Vacuum or sweep up material
and place in a designated, labeled waste container. Avoid creating dusty conditions and
prevent wind dispersal. Dispose of via a licensed waste disposal contractor. Note: see
Section 1 for emergency contact information and Section 13 for waste disposal.
Section 7. Handling and storage
Precautions for safe handling
Protective measures : Put on appropriate personal protective equipment (see Section 8). Avoid breathing dust.
Advice on general : Eating, drinking and smoking should be prohibited in areas where this material is
occupational hygiene handled, stored and processed. Workers should wash hands and face before eating,
drinking and smoking. Remove contaminated clothing and protective equipment before
entering eating areas. See also Section 8 for additional information on hygiene
measures.
Conditions for safe storage,
including any
incompatibilities
Store in accordance with local regulations. Store in original container protected from
direct sunlight in a dry, cool and well-ventilated area, away from incompatible materials
(see Section 10) and food and drink. Keep container tightly closed and sealed until
ready for use. Containers that have been opened must be carefully resealed and kept
upright to prevent leakage. Do not store in unlabeled containers. Use appropriate
containment to avoid environmental contamination.
Section 8. Exposure controls/personal protection
C?ntr9i parameters
Occupational exposure limits
None.
Appropriate engineering : Use only with adequate ventilation. If user operations generate dust, fumes, gas, vapor
controls or mist, use process enclosures, local exhaust ventilation or other engineering controls
to keep worker exposure to airborne contaminants below any recommended or statutory
limits.
27- October- 2017 en - US Page: 3/9
rage 75 of %
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2294050
Section 8. Exposure controls/personal protection
Environmental exposure : Emissions from ventilation or work process equipment should be checked to ensure
controls they comply with the requirements of environmental protection legislation. In some
cases, fume scrubbers, filters or engineering modifications to the process equipment
will be necessary to reduce emissions to acceptable levels.
Individual protection measures
Hygiene measures :
Eye/face protection
Skin protection
Hand protection
Body protection
Other skin protection
Respiratory protection
Wash hands, forearms and face thoroughly after handling chemical products, before
eating, smoking and using the lavatory and at the end of the working period.
Appropriate techniques should be used to remove potentially contaminated clothing.
Wash contaminated clothing before reusing. Ensure that eyewash stations and safety
showers are close to the workstation location.
Safety eyewear complying with an approved standard should be used when a risk
assessment indicates this is necessary to avoid exposure to liquid splashes, mists,
gases or dusts. If contact is possible, the following protection should be worn, unless
the assessment indicates a higher degree of protection: safety glasses with side-
shields. If operating conditions cause high dust concentrations to be produced, use
dust goggles.
Chemical-resistant, impervious gloves complying with an approved standard should be
worn at all times when handling chemical products if a risk assessment indicates this is
necessary.
Personal protective equipment for the body should be selected based on the task being
performed and the risks involved and should be approved by a specialist before
handling this product.
Appropriate footwear and any additional skin protection measures should be selected
based on the task being performed and the risks involved and should be approved by a
specialist before handling this product.
In case of inadequate ventilation wear respiratory protection. Respirator selection must
be based on known or anticipated exposure levels, the hazards of the product and the
safe working limits of the selected respirator. Use a properly fitted, particulate filter
respirator complying with an approved standard if a risk assessment indicates this is
necessary
Section 9. Physical and chemical properties
Physical state
Color
Odor
Odor threshold
pH
Melting point
Boiling point
Flash point
VOC % (w/w)
Evaporation rate
Flammability (solid, gas)
Lower and upper explosive
(flammable) limits
Vapor pressure
Vapor density
Relative density
Solubility
Partition coefficient; n-
octanoi/water
Solid. [Powder.]
Violet.
Odorless.
Not applicable.
Not tested
Not available.
Not available.
Not applicable.
0
Not tested
Not available.
Not tested
Not available.
Not tested
1.76
Insoluble in the following materials: cold water and hot water.
Not applicable.
27- October- 2017 en - US Page: 4/9
rage 76 oF %
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2294050
Section 9. Physical and chemical properties
Auto-ignition temperature
Decomposition temperature
Viscosity
Not applicable.
Not applicable.
Not tested
Section 10. Stability and reactivity
Reactivity
Chemical stability
Possibility of hazardous
reactions
Conditions to avoid
Incompatible materials
: No specific test data related to reactivity available for this product or its ingredients.
: The product is stable.
: Under normal conditions of storage and use, hazardous reactions will not occur.
: No specific data.
: No specific data.
Hazardous decomposition : Under normal conditions of storage and use, hazardous decomposition products should
products not be produced.
Section 11. Toxicological information
Acute toxicitv
Conclusion/Summary
: No known significant
effects
or
critical
hazards
Irritation/Corrosion
Conclusion/Summarv
Skin
: No known significant
effects
or
critical
hazards
Eyes
: No known significant
effects
or
critical
hazards
Respiratory
: No known significant
effects
or
critical
hazards
Sensitization
Conclusion/Summarv
Skin
: No known significant
effects
or
critical
hazards
Respiratory
: No known significant
effects
or
critical
hazards
Mutagenicity
Conclusion/Summary
: No known significant
effects
or
critical
hazards
Carcinoqenicitv
Conclusion/Summary
: No known significant
effects
or
critical
hazards
Reproductive toxicitv
Conclusion/Summary
: No known significant
effects
or
critical
hazards
Teratogenicity
Conclusion/Summary
: No known significant
effects
or
critical
hazards
Specific target organ toxicitv (single exposure)
Not available.
Specific target organ toxicity (repeated exposure)
Not available.
Aspiration hazard
Not available.
27-October-2017
en - US
Page 77 of 96
Page: 5/9
-------
2294050
Section 11. Toxicological information
Information on the likely
routes of exposure
Potential acute health effects
Eye contact
Inhalation
Skin contact
Ingestion
Not available.
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the eyes.
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the nose, throat and lungs.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
Symptoms related to the physical, chemical and toxicological characteristics
Eye contact : Adverse symptoms may include the following:
irritation
redness
Inhalation : Adverse symptoms may include the following:
respiratory tract irritation
coughing
Skin contact : No specific data.
Ingestion : No specific data.
Delayed and immediate effects and also chronic effects from short and long term exposure
Short term exposure
Potential immediate : Not available,
effects
Potential delayed effects : Not available.
Long term exposure
Potential immediate : Not available,
effects
Potential delayed effects : Not available.
Potential chronic health effects
General : Repeated or prolonged inhalation of dust may lead to chronic respiratory irritation.
Carcinogenicity : No known significant effects or critical hazards.
Mutagenicity : No known significant effects or critical hazards.
Teratogenicity : No known significant effects or critical hazards.
Developmental effects : No known significant effects or critical hazards.
Fertility effects : No known significant effects or critical hazards.
Numerical measures of toxicity
Acute toxicity estimates
Route
ATE value
Oral
Inhalation (dusts and mists)
7142.9 mg/kg
21.43 mg/l
27- October- 2017 en - US Page: 6/9
rage 78 of 96
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2294050
Section 12. Ecological information
Toxicity
Not available.
Persistence and dearadabilitv
Not available.
Bioaccumulative potential
Not available.
Mobility in soil
Soil/water partition : Not available.
coefficient (Koc)
Other adverse effects : No known significant effects or critical hazards.
Section 13. Disposal considerations
Disposal methods : The generation of waste should be avoided or minimized wherever possible. Disposal
of this product, solutions and any by-products should at all times comply with the
requirements of environmental protection and waste disposal legislation and any
regional local authority requirements. Dispose of surplus and non-recyclable products
via a licensed waste disposal contractor. Waste should not be disposed of untreated to
the sewer unless fully compliant with the requirements of all authorities with jurisdiction.
Waste packaging should be recycled. Incineration or landfill should only be considered
when recycling is not feasible. This material and its container must be disposed of in a
safe way. Empty containers or liners may retain some product residues. Avoid
dispersal of spilled material and runoff and contact with soil, waterways, drains and
sewers.
Section 14. Transport information
DOT
Classification
TDG
Classification
Mexico
Classification
IMDG
I ATA
UN number
Not regulated.
Not regulated.
Not regulated.
Not regulated.
Not regulated.
UN proper
shipping name
-
-
-
-
-
Transport
hazard class(es)
Packing group
-
-
-
-
-
Environmental
hazards
No.
No.
No.
No.
No.
Additional
information
-
-
-
-
-
Special precautions for user : Transport within user's premises: always transport in closed containers that are
upright and secure. Ensure that persons transporting the product know what to do in the
event of an accident or spillage.
27- October- 2017 en - US Page: 7/9
rage 79 of 96
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2294G5G
Section 15. Regulatory information
TSCA 8(b) inventory ; Listed
U.S. Federal regulations
SARA 313
Product name
CAS number
%
Supplier notification
barium Compounds
68188-14-7
7
SARA 313 notifications must not be detached from the SDS and any copying and redistribution of the SDS shall include
copying and redistribution of the notice attached to copies of the SDS subsequently redistributed.
Toxics in Packaging : In compliance
(CONE6)
Canada inventory : All components are listed or exempted.
International regulations
International lists : Australia inventory (AICS): All components are listed or exempted.
China inventory (IECSC): All components are listed or exempted.
Japan inventory (ENCS): All components are listed or exempted.
Korea inventory: All components are listed or exempted.
Malaysia Inventory (EHS Register): Not determined.
New Zealand Inventory of Chemicals (NZIoC): All components are listed or exempted.
Philippines inventory (PICCS): All components are listed or exempted.
Taiwan Chemical Substances Inventory (TCSI): All components are listed or
exempted.
Turkey inventory: Not determined.
Europe Inventory: Please contact your supplier to get the information.
Section 16. Other information
Health < 1
V
Rammability
/ Instability/Reactivity
Special
Reprinted with permission from NFPA 704-2001, Identification of the Hazards of Materials for Emergency
Response Copyright ©1997, National Fire Protection Association, Quincy, MA 02269. This reprinted material Is
not the complete and official position of the National Fire Protection Association, on the referenced subject
which is represented only by the standard in its entirety.
Copyright ©2001, National Fire Protection Association, Quincy, MA 02269. This warning system is intended to
be interpreted and applied only by properly trained individuals to identify fire, health and reactivity hazards of
chemicals. The user is referred to certain limited number of chemicals with recommended classifications in
NFPA 49 and NFPA 325, which would be used as a guideline only. Whether the chemicals are classified by NFPA
or not, anyone using the 704 systems to classify chemicals does so at their own risk.
UMqix
Date of issue/Date of
revision
Date of previous issue
Version
Key to abbreviations
1/13/2017
12/3/2016
6
ATE = Acute Toxicity Estimate
BCF = Bioconcentration Factor
GHS = Globally Harmonized System of Classification and Labelling of Chemicals
IATA = International Air Transport Association
IBC = Intermediate Bulk Container
IMDG = International Maritime Dangerous Goods
Log Row = logarithm of the octa nol/water partition coefficient
MARPOL = International Convention for the Prevention of Pollution From Ships, 1973
as modified by the Protocol of 1978. ("MarpoT = marine pollution)
UN = United Nations
27.October-2017 en-US Page: 8/9
Page 80 oF')(,
-------
?»405O
Section 16. Other information
References : Not available.
Indicates information that has changed from previously issued version.
ftl-Qtice-tajeader
To the best of our knowledge, the information contained herein is accurate. However, neither the above-named
supplier, nor any of its subsidiaries, assumes any liability whatsoever for the accuracy or completeness of the
information contained herein.
Final determination of suitability of any material is the sole responsibility of the user. All materials may present
unknown hazards and should be used with caution. Although certain hazards are described herein, we cannot
guarantee that these are the only hazards that exist.
2294050
27- October- 2017 en - US Page: 9/9
Page 81 oF %
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SDS for C.I. Pigment Violet 29 Non-Commercial Product (dry) - Sun Chemical
Corporation
Page 82 of 96
-------
SiiiiChemiea]
a member of the D1C group
Color * Comfort
SAFETY DATA SHEET
Section 1. Identification
Product code : VIOLET 29
GHS product identifier : C. I. Pigment Violet 29
Relevant identified uses of the substance or mixture and uses advised against
Identified uses
Colorant
Manufacturer / Distributor
Sun Chemical Corporation
5020 Spring Grove Avenue
Cincinnati, OH 45232-1999
Phone: +1 (513)681-5950
Emergency telephone : +1
number (with hours of +1
operation)
Other information : +1
(800) 424-9300 (U.S.) (24 hours)
(703) 527-3887 (International) (24 hours)
708 236 3798
Section 2. Hazards identification
OSHA/HCS status
Classification of the
substance or mixture
While this material is not considered hazardous by the OSHA Hazard Communication
Standard (29 CFR 1910.1200), this MSDS contains valuable information critical to the
safe handling and proper use of the product. This MSDS should be retained and
available for employees and other users of this product.
Not classified.
GHS label elements
Signal word
Hazard statements
Precautionary statements
General
Prevention
Response
Storage
Disposal
Hazards not otherwise
classified
No signal word.
No known significant effects or critical hazards.
Read label before use. Keep out of reach of children. If medical advice is needed,
have product container or label at hand.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Fine dust clouds may form explosive mixtures with air. Handling and/or processing of
this material may generate a dust which can cause mechanical irritation of the eyes,
skin, nose and throat.
Section 3. Composition/information on ingredients
Substance/mixture : Substance
CAS number/other identifiers
Ingredient name
CAS number
%
anthra[2,1,9-def:6,5,10-d'e'f]diisoquinoline-1,3,8,10(2h,9h)-tetrone
81-33-4
100
27- October- 2017 en - US Page: 1/8
rage 83 of 96
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VIOLET 29
Section 3. Composition/information on ingredients
Any concentration shown as a range is to protect confidentiality or is due to batch variation.
There are no additional ingredients present which, within the current knowledge of the supplier and in the
concentrations applicable, are classified as hazardous to health or the environment and hence require reporting
in this section.
Occupational exposure limits, if available, are listed in Section 8.
Section 4. First aid measures
Description of necessary first aid measures
Eye contact
Inhalation
Skin contact
Ingestion
Immediately flush eyes with plenty of water, occasionally lifting the upper and lower
eyelids. Check for and remove any contact lenses. Get medical attention if irritation
occurs.
Remove victim to fresh air and keep at rest in a position comfortable for breathing. Get
medical attention if symptoms occur. In case of inhalation of decomposition products in
a fire, symptoms may be delayed. The exposed person may need to be kept under
medical surveillance for 48 hours.
Flush contaminated skin with plenty of water. Remove contaminated clothing and
shoes. Get medical attention if symptoms occur.
Wash out mouth with water. Remove victim to fresh air and keep at rest in a position
comfortable for breathing. If material has been swallowed and the exposed person is
conscious, give small quantities of water to drink. Do not induce vomiting unless
directed to do so by medical personnel. Get medical attention if symptoms occur.
Most important symptoms/effects, acute and delayed
Potential acute health effects
Eye contact
Inhalation
Skin contact
Ingestion
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the eyes.
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the nose, throat and lungs. Exposure to decomposition products
may cause a health hazard. Serious effects may be delayed following exposure.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
Indication of immediate medical attention and special treatment needed, if necessary
Notes to physician : In case of inhalation of decomposition products in a fire, symptoms may be delayed.
The exposed person may need to be kept under medical surveillance for 48 hours.
Specific treatments : No specific treatment.
Protection of first-aiders : No action shall be taken involving any personal risk or without suitable training.
See toxicological information (Section 11)
Section 5. Fire-fighting measures
Extinguishing media
Suitable extinguishing : Use an extinguishing agent suitable for the surrounding fire,
media
Unsuitable extinguishing : None known,
media
Specific hazards arising
from the chemical
Hazardous thermal
decomposition products
No specific fire or explosion hazard.
Decomposition products may include the following materials:
carbon dioxide
carbon monoxide
nitrogen oxides
27-October-2017
en - US
Page 84 of 96
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VIOLET 29
Section 5. Fire-fighting measures
Special protective actions
for fire-fighters
Special protective
equipment for fire-fighters
Promptly isolate the scene by removing all persons from the vicinity of the incident if
there is a fire. No action shall be taken involving any personal risk or without suitable
training.
Fire-fighters should wear appropriate protective equipment and self-contained breathing
apparatus (SCBA) with a full face-piece operated in positive pressure mode.
Section 6. Accidental release measures
Personal precautions, protective equipment and emergency procedures
For non-emergency
personnel
For emergency responders
No action shall be taken involving any personal risk or without suitable training.
Evacuate surrounding areas. Keep unnecessary and unprotected personnel from
entering. Do not touch or walk through spilled material. Avoid breathing dust. Put on
appropriate personal protective equipment.
If specialized clothing is required to deal with the spillage, take note of any information in
Section 8 on suitable and unsuitable materials. See also the information in "For non-
emergency personnel".
Environmental precautions
Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains
and sewers. Inform the relevant authorities if the product has caused environmental
pollution (sewers, waterways, soil or air).
Methods and materials for containment and cleaning up
Small spill
Large spill
Move containers from spill area. Vacuum or sweep up material and place in a
designated, labeled waste container. Dispose of via a licensed waste disposal
contractor.
Move containers from spill area. Approach release from upwind. Prevent entry into
sewers, water courses, basements or confined areas. Vacuum or sweep up material
and place in a designated, labeled waste container. Avoid creating dusty conditions and
prevent wind dispersal. Dispose of via a licensed waste disposal contractor. Note: see
Section 1 for emergency contact information and Section 13 for waste disposal.
Section 7. Handling and storage
Precautions for safe handling
Protective measures
Advice on general
occupational hygiene
Put on appropriate personal protective equipment (see Section 8). Avoid breathing dust.
Eating, drinking and smoking should be prohibited in areas where this material is
handled, stored and processed. Workers should wash hands and face before eating,
drinking and smoking. Remove contaminated clothing and protective equipment before
entering eating areas. See also Section 8 for additional information on hygiene
measures.
Conditions for safe storage,
including any
incompatibilities
Store in accordance with local regulations. Store in original container protected from
direct sunlight in a dry, cool and well-ventilated area, away from incompatible materials
(see Section 10) and food and drink. Keep container tightly closed and sealed until
ready for use. Containers that have been opened must be carefully resealed and kept
upright to prevent leakage. Do not store in unlabeled containers. Use appropriate
containment to avoid environmental contamination.
Section 8. Exposure controls/personal protection
Control parameters
Occupational exposure limits
None.
Appropriate engineering
controls
Use only with adequate ventilation. If user operations generate dust, fumes, gas, vapor
or mist, use process enclosures, local exhaust ventilation or other engineering controls
to keep worker exposure to airborne contaminants below any recommended or statutory
limits.
27-October-2017
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VIOLET 29
Section 8. Exposure controls/personal protection
Environmental exposure
controls
Emissions from ventilation or work process equipment should be checked to ensure
they comply with the requirements of environmental protection legislation. In some
cases, fume scrubbers, filters or engineering modifications to the process equipment
will be necessary to reduce emissions to acceptable levels.
Individual protection measures
Hygiene measures
Eye/face protection
Skin protection
Hand protection
Body protection
Other skin protection
Respiratory protection
Wash hands, forearms and face thoroughly after handling chemical products, before
eating, smoking and using the lavatory and at the end of the working period.
Appropriate techniques should be used to remove potentially contaminated clothing.
Wash contaminated clothing before reusing. Ensure that eyewash stations and safety
showers are close to the workstation location.
Safety eyewear complying with an approved standard should be used when a risk
assessment indicates this is necessary to avoid exposure to liquid splashes, mists,
gases or dusts. If contact is possible, the following protection should be worn, unless
the assessment indicates a higher degree of protection: safety glasses with side-
shields. If operating conditions cause high dust concentrations to be produced, use
dust goggles.
Chemical-resistant, impervious gloves complying with an approved standard should be
worn at all times when handling chemical products if a risk assessment indicates this is
necessary.
Personal protective equipment for the body should be selected based on the task being
performed and the risks involved and should be approved by a specialist before
handling this product.
Appropriate footwear and any additional skin protection measures should be selected
based on the task being performed and the risks involved and should be approved by a
specialist before handling this product.
In case of inadequate ventilation wear respiratory protection. Respirator selection must
be based on known or anticipated exposure levels, the hazards of the product and the
safe working limits of the selected respirator. Use a properly fitted, particulate filter
respirator complying with an approved standard if a risk assessment indicates this is
necessary.
Section 9. Physical and chemical properties
Physical state
Solid.
Color
Violet.
Odor
Characteristic.
Odor threshold
Not applicable
PH
Not tested
Melting point
Not available.
Boiling point
Not available.
Flash point
Not applicable
VOC % (w/w)
0%
Evaporation rate
Not tested
Flammability (solid, gas)
Not available.
Lower and upper explosive
Not tested
(flammable) limits
Vapor pressure
Not available.
Vapor density
Not tested
Density
Not tested
Solubility
Not tested
Partition coefficient: n-
Not applicable
octanol/water
Auto-ignition temperature
Not applicable
27-October-2017
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VIOLET 29
Section 9. Physical and chemical properties
Decomposition temperature
Viscosity
Not applicable.
Not tested
Section 10. Stability and reactivity
Reactivity
: No specific test data related to reactivity available for this product or its ingredients.
Chemical stability
: The product is stable.
Possibility of hazardous
reactions
: Under normal conditions of storage and use, hazardous reactions will not occur.
Conditions to avoid
: No specific data.
Incompatible materials
: No specific data.
Hazardous decomposition : Under normal conditions of storage and use, hazardous decomposition products should
products not be produced.
Section 11. Toxicological information
Information on toxicoloaical effects
Acute toxicity
Conclusion/Summary
Irritation/Corrosion
Conclusion/Summary
Skin
Eyes
Respiratory
Sensitization
Conclusion/Summary
Skin
Respiratory
Mutagenicity
Conclusion/Summary
Carcinogenicity
Conclusion/Summary
Reproductive toxicity
Conclusion/Summary
Teratogenicity
Conclusion/Summary
No known significant effects or critical hazards.
No known significant effects
No known significant effects
No known significant effects
No known significant effects
No known significant effects
or critical hazards,
or critical hazards,
or critical hazards.
or critical hazards,
or critical hazards.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
Specific target organ toxicity (single exposure)
Not available.
Specific target organ toxicity (repeated exposure)
Not available.
Aspiration hazard
Not available.
Information on the likely
routes of exposure
Not available.
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VIOLET 29
Section 11. Toxicological information
Potential acute health effects
Eye contact
Inhalation
Skin contact
Ingestion
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the eyes.
Exposure to airborne concentrations above statutory or recommended exposure limits
may cause irritation of the nose, throat and lungs. Exposure to decomposition products
may cause a health hazard. Serious effects may be delayed following exposure.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
Symptoms related to the physical, chemical and toxicological characteristics
Eye contact
Inhalation
Skin contact
Ingestion
Adverse symptoms may include the following:
irritation
redness
Adverse symptoms may include the following:
respiratory tract irritation
coughing
No specific data.
No specific data.
Delayed and immediate effects and also chronic effects from short and long term exposure
Short term exposure
Potential immediate : Not available,
effects
Potential delayed effects
Long term exposure
Potential immediate
effects
Potential delayed effects
Potential chronic health effects
General
Carcinogenicity
Mutagenicity
Teratogenicity
Developmental effects
Fertility effects
Not available.
Not available.
Not available.
Repeated or prolonged inhalation of dust may lead to chronic respiratory irritation.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
No known significant effects or critical hazards.
Numerical measures of toxicity
Acute toxicity estimates
Not available.
Section 12. Ecological information
Toxicity
Not available.
Persistence and degradabilitv
Bioaccumulative potential
Not available.
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VIOLET 29
Section 12. Ecological information
Mobility in soil
Soil/water partition : Not available,
coefficient (Koc)
Other adverse effects : No known significant effects or critical hazards.
Section 13. Disposal considerations
Disposal methods : The generation of waste should be avoided or minimized wherever possible. Disposal
of this product, solutions and any by-products should at all times comply with the
requirements of environmental protection and waste disposal legislation and any
regional local authority requirements. Dispose of surplus and non-recyclable products
via a licensed waste disposal contractor. Waste should not be disposed of untreated to
the sewer unless fully compliant with the requirements of all authorities with jurisdiction.
Waste packaging should be recycled. Incineration or landfill should only be considered
when recycling is not feasible. This material and its container must be disposed of in a
safe way. Empty containers or liners may retain some product residues. Avoid
dispersal of spilled material and runoff and contact with soil, waterways, drains and
sewers.
Section 14. Transport information
DOT
Classification
TDG
Classification
Mexico
Classification
IMDG
I ATA
UN number
UN proper
shipping name
Transport
hazard class(es)
Not regulated.
Not regulated.
Not regulated.
Not regulated.
Not regulated.
Packing group
-
-
-
-
-
Environmental
hazards
No.
No.
No.
No.
No.
Additional
information
-
-
-
-
-
Special precautions for user : Transport within user's premises: always transport in closed containers that are
upright and secure. Ensure that persons transporting the product know what to do in the
event of an accident or spillage.
Section 15. Regulatory information
TSCA 8(b) inventory : Listed
U.S. Federal regulations
SARA 313
Product name
CAS number
0/
/O
Supplier notification
None identified.
Toxics in Packaging : In compliance.
(CONEG)
Canada inventory : All components are listed or exempted.
International regulations
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wouerm
Section 15. Regulatory information
Internationa! lists Australia inventory (AICS): All components are listed or exempted.
China inventory (IECSC): All components are listed or exempted.
Japan inventory: Ail components are listed or exempted.
Korea inventory: All components are listed or exempted.
Malaysia Inventory (EHS Register): Not determined.
New Zealand Inventory of Chemicals (NZIoC): All components are listed or exempted.
Philippines inventory (PICCS): All components are listed or exempted.
Taiwan Chemical Substances Inventory (TCSI): All components are listed or
exempted.
Europe Inventory: Please contact your supplier to get the information.
Section 16. Other information
tifltiwifll Fir? Protection Association
Flammability
Health ' / Instability/Reactivity
Sr w"
/ Special
Reprinted with permission from NFPA 704-2001, Identification of the Hazards of Materials for Emergency
Response Copyright ©1997, National Fire Protection Association, Quincy, MA 02269. This reprinted material is
not the complete and official position of the National Fire Protection Association, on the referenced subject
which is represented only by the standard in its entirety.
Copyright ©2001, National Fire Protection Association, Quincy, MA 02269. This warning system is intended to
be interpreted and applied only by properly trained individuals to identify fire, health and reactivity hazards of
chemicals. The user is referred to certain limited number of chemicals with recommended classifications in
NFPA 49 and NFPA 325, which would be used as a guideline only. Whether the chemicals are classified by NFPA
or not, anyone using the 704 systems to classify chemicals does so at their own risk.
History
Date of issue/Date of 5/28/2015
revision
Date of previous issue 5/28/2015
Version * 1.01
Key to abbreviations * ATE = Acute Toxicity Estimate
BCF = Bioconcentraion Factor
GHS = Globally Harmonized System of Classification and Labeling of Chemicals
IATA = International Air Transport Association
IBC = Intermediate Bulk Container
IMDG = International Maritime Dangerous Goods
LogPow = logarithm of the octanol/water partition coefficient
MARPOL = International Convention for the Prevention of Pollution From Ships, 1973
as mocffied by the Protocol of 1978. ("Marpol" = marine pollution)
UN = United Nations
References : Not available.
Indicates information that has changed from previously issued version.
Notice to reader.
To the best of our knowledge, the information contained herein is accurate. However, neither the above-named
supplier, nor any of its subsidiaries, assumes any liability whatsoever for the accuracy or completeness of the
information contained herein.
Final determination of suitability of any material is the sole responsibility of the user. All materials may present
unknown hazards and should be used with caution. Although certain hazards are described herein, we cannot
guarantee that these are the only hazards that exist.
voourr»
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SDS for C.I. Pigment Violet 29- TCI America (importer)
Page 85 of 90
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TCI AMERICA
SAFETY DATA SHEET
Page 1 of 5
Revision number: 4
Revision date: 02/18/2017
If. IDENTIFICATION
Product name:
Product code:
3,4,9,10-Perylenetetracarboxylic Diimide
P0984
Product use:
Restrictions on use:
Company:
TCI America
9211 N. Harborgate Street
Portland, OR 97203 U.S.A.
Telephone:
+1 -800-423-8616 / +1 -503-283-1681
Fax:
+1 -888-520-1075 / +1 -503-283-1987
e-mail:
sales-US@TCIchemicals.com
www.TCIchemicals.com
For laboratory research purposes.
Not for drug or household use.
Emergency telephone number:
Chemical Emergencies:
TCI America (8:00am - 5:00pm) PST
+ 1-503-286-7624
Transportation Emergencies:
Chemtrec 24-Hour
+ 1-800-424-9300 (U.S.A.)
+1-703-527-3887 (International)
Responsible department:
TCI America
Environmental Health Safety and Security
+ 1-503-286-7624
\2. HAZARD(S) IDENTIFICATION
OSHA Haz Com: CFR 1910.1200: Not classifiable
Signal word: None
Hazard Statement(s): None
Pictogram(s) or Symbol(s): None
Precautionary Statement(s): None
Supplementary Information:
While this material is not classified as hazardous under OSHA, this SDS contains valuable information
critical to safe handling and proper use of the product. This SDS should be retained and available for
employees and other users of this product.
13. COMPOSITION/INFORMATION ON INGREDIENTS'
Substance/Mixture:
Components:
Percent:
CAS Number:
Molecular Weight:
Chemical Formula:
Substance
3,4,9,10-Perylenetetracarboxylic Diimide
>95.0%(N)
81-33-4
390.35
C24H10N2O4
|4. FIRST-AID MEASURES'
Inhalation:
Skin contact:
Move victim to fresh air. Call emergency medical service. Give artificial respiration if victim is not breathing.
Administer oxygen if breathing is difficult. Keep victim warm and quiet. Treat symptomatically and
supportively. Ensure that medical personnel are aware of the material(s) involved and take precautions to
protect themselves.
Remove and isolate contaminated clothing and shoes. In case of contact with substance, immediately
flush skin with running water for at least 20 minutes. Treat symptomatically and supportively. Ensure that
medical personnel are aware of the material(s) involved and take precautions to protect themselves.
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TCI AMERICA
Page 2 of 5
|4. FIRST-AID MEASURES'
Eye contact:
Ingestion:
Move victim to fresh air. Check for and remove any contact lenses. In case of contact with substance,
immediately flush eyes with running water for at least 20 minutes. Keep victim warm and quiet. Treat
symptomatically and supportively. Effects of exposure to substance may be delayed. Ensure that medical
personnel are aware of the material(s) involved and take precautions to protect themselves.
If a person vomits place them in the recovery position so that vomit will not reenter the mouth and throat.
Rinse mouth. Keep victim warm and quiet. Loosen tight clothing such as a collar, tie, belt or waistband. If
swallowed, seek medical advice immediately and show the container or label. Treat symptomatically and
supportively. Ensure that medical personnel are aware of the material(s) involved and take precautions to
protect themselves. Effects of exposure (ingestion) to substance may be delayed.
Symptoms/effects:
Acute: No data available
Delayed: No data available
Immediate medical attention: If breathing has stopped, perform artificial respiration. Use first aid treatment according to the nature of the
injury. Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
|5. FIRE-FIGHTING MEASURES I
Suitable extinguishing media: Dry chemical, CO2, water spray, or alcohol-resistant foam. Consult with local fire authorities before
attempting large scale fire fighting operations.
Specific hazards arising from the chemical
Hazardous combustion products: These products include: Carbon oxides Nitrogen oxides
Other specific hazards: Closed containers may explode from heat of a fire.
Special precautions for fire-fighters:
Not available
Special protective equipment for fire-fighters:
Structural fire fighters' protective clothing provides limited protection in fire situations ONLY; it may not be effective in spill situations.
6. ACCIDENTAL RELEASE MEASURES
Personal precautions: Do not touch damaged containers or spilled material unless wearing appropriate protective clothing
(Section 8).
Personal protective equipment: Wear protective clothing, gloves and eye protection.
Emergency procedures: In case of a spill and/or a leak, always shut off any sources of ignition, ventilate the area, and excercise
caution.
Methods and materials for containment and cleaning up:
Dike far ahead of liquid spill for later disposal.
Environmental precautions:
Prevent entry into sewers, basements or confined areas.
7. HANDLING AND STORAGE
Precautions for safe handling: Provide appropriate exhaust ventilation at places where dust is formed. Normal measures for preventive
fire protection. Follow safe industrial hygiene practices and always wear proper protective equipment when
handling this compound.
Conditions for safe storage: Keep container tightly closed in a dry and well-ventilated place.
Storage incompatibilities: Store away from oxidizing agents
|8. EXPOSURE CONTROLS / PERSONAL PROTECTION
Exposure limits: No data available
Appropriate engineering controls:
Good general ventilation should be sufficient to control airborne levels. Eyewash fountains should be provided in areas where there is any possibility that
workers could be exposed to the substance. Follow safe industrial engineering/laboratory practices when handling any chemical.
Personal protective equipment
Respiratory protection:
Hand protection:
Eye protection:
Skin and body protection:
Dust respirator. Be sure to use a
Wear protective gloves.
Safety glasses.
Lab coat.
approved respirator or equivalent.
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TCI AMERICA
Page 3 of 5
9. PHYSICAL AND CHEMICAL PROPERTIES
Physical state (20°C):
Form:
Color:
Odor:
Odor threshold:
Solid
Crystal - Powder
Deep yellow red - Black
No data available
No data available
Melting point/freezing point:
Boiling point/range:
Decomposition temperature:
Relative density:
Kinematic Viscosity:
Partition coefficient:
n-octanol/water (log P ow)
Flash point:
Flammability (solid, gas):
Solubility(ies):
Water: Insoluble
No
data
available
pH:
No
data
available
No
data
available
Vapor pressure:
No
data
available
No
data
available
Vapor density:
No
data
available
No
data
available
Dynamic Viscosity:
No
data
available
No
data
available
No
data
available
Evaporation rate:
No
data
available
(Butyl Acetate = 1)
No
data
available
Autoignition temperature:
No
data
available
No
data
available
Flammability or explosive limits:
Lower:
Upper:
No data available
No data available
\10. STABILITY AND REACTIVITY
Reactivity:
Chemical Stability:
Possibility of Hazardous Reactions:
Conditions to avoid:
Incompatible materials:
Hazardous Decomposition Products:
Not Available.
Stable under recommended storage conditions. (See Section 7)
No hazardous reactivity has been reported.
Avoid excessive heat and light.
Oxidizing agents
No data available
Iff. TOXICOLOGICAL INFORMATION
Acute Toxicity:
No data available
Skin corrosion/irritation:
No data available
Serious eye damage/irritation:
No data available
Respiratory or skin sensitization:
No data available
Germ cell mutagenicity:
No data available
Carcinogenicity:
No data available
I ARC:
No data available
NTP:
No data available
OSHA:
No data available
Reproductive toxicity:
No data available
Routes of Exposure: Inhalation, Eye contact, Ingestion.
Symptoms related to exposure:
No specific information is available in our data base regarding the toxic effects of this material for humans. However, exposure to any chemical should
be kept to a minimum. Always follow safe industrial hygiene practices and wear proper protective equipment when handling this compound.
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3,4,9,10-Perylenetetracarboxylic Diimide
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Page 4 of 5
Potential Health Effects:
No specific information available; skin and eye contact may result in irriatation. May be harmful if inhaled or ingested.
Target organ(s): No data available
112. ECOLOGICAL INFORMATION
Ecotoxicity
Fish:
No
data
available
Crustacea:
No
data
available
Algae:
No
data
available
Persistence and degradability:
No
data
available
Bioaccumulative potential (BCF):
No
data
available
Mobillity in soil:
No
data
available
Partition coefficient:
No
data
available
n-octanol/water (log Pow)
Soil adsorption (Koc):
No
data
available
Henry's Law:
No
data
available
constant (PaM3/mol)
113. DISPOSAL CONSIDERATIONS
Disposal of product:
Disposal of container:
Other considerations:
Recycle to process if possible. It is the generator's responsibility to comply with Federal, State and Local
rules and regulations. You may be able to dissolve or mix material with a combust ble solvent and burn in a
chemical incinerator equipped with an afterburner and scrubber system. This section is intended to provide
assistance but does not replace these laws, nor does compliance in accordance with this section ensure
regulatory compliance according to the law. US EPA guidelines for Identification and Listing of Hazardous
Waste are listed in 40 CFR Parts 261.
Dispose of as unused product.
Observe all federal, state and local regulations when disposing of the substance.
114. TRANSPORT INFORMATION
DOT (US)
I ATA
IMDG
Non-hazardous for transportation.
Non-hazardous for transportation.
Non-hazardous for transportation.
\15. REGULATORY INFORMATION
Toxic Substance Control Act (TSCA 8b.):
This product is ON the EPA Toxic Substances Control Act (TSCA) inventory.
US Federal Regulations
CERCLA Hazardous substance and Reportable Quantity:
SARA 313:
SARA 302:
Not Listed
Not Listed
State Regulations
State Right-to-Know
Massachusetts
New Jersey
Pennsylvania
California Proposition 65:
Not Listed
Not Listed
Not Listed
Not Listed
Other Information
NFPA Rating:
Health: 0
Flammability: 0
Instability: 0
HMIS Classification:
Health: 0
Flammability: 0
Physical: 0
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TCI AMERICA
Page 5 of 5
\15. REGULATORY INFORMATION
International Inventories
WHMIS hazard class:
Canada: DSL
EC-No:
No data available.
On DSL
201 -344-6
If 6. OTHER INFORMATION
Revision date: 02/18/2017
Revision number: 4
TCI chemicals are for research purposes only and are NOT intended for use as drugs, food additives, households, or pesticides. The information herein
is believed to be correct, but does not claim to be all inclusive and should be used only as a guide. Neither the above named supplier nor any of its
affiliates or subsidiaries assumes any liability whatsoever for the accuracy or completeness of the information contained herein. Final determination of
suitability of any material is the sole responsibility of the user. All chemical reagents must be handled with the recognition that their chemical,
physiological, toxicological, and hazardous properties have not been fully investigated or determined. All chemical reagents should be handled only by
individuals who are familiar with their potential hazards and who have been fully trained in proper safety, laboratory, and chemical handling procedures.
Although certain hazards are described herein, we can not guarantee that these are the only hazards which exist. Our SDS are based only on data
available at the time of shipping and are subject to change without notice as new information is obtained. Avoid long storage periods since the product is
subject to degradation with age and may become more dangerous or hazardous. It is the responsibility of the user to request updated SDS for products
that are stored for extended periods. Disposal of unused product must be undertaken by qualified personnel who are knowledgeable in all applicable
regulations and follow all pertinent safety precautions including the use of appropriate protective equipment (e.g. protective goggles, protective clothing,
breathing equipment, face mask, fume hood). For proper handling and disposal, always comply with federal, state and local regulations.
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