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P2 Awards, 1996 - Engelhard Corporation

Mr. Barry Perry
Chief Executive Officer
Engelhard Corporation
101 Wood Avenue
Iselin, New Jersey 08830-0770

Re: Recognition of Achievement in Pollution Prevention--PMN 95-1528

Dear Mr. Perry:

I am very pleased to inform you that EPA's Office of Pollution Prevention and Toxics (OPPT) is hereby recognizing Engelhard Corporation for an important achievement in pollution prevention (P2) via innovative chemical design. This achievement involves the new chemical substance described in premanufacture notice (PMN) 95-1528 submitted to EPA pursuant to Section 5 of the Toxic Substances Control Act (TSCA).

The manufacture of your new chemical, generically named a metalized azo yellow pigment, represents a significant innovation in the chemistry for manufacturing yellow dyes, one with important pollution prevention benefits. As part of the New Chemicals Program's P2 Recognition Program, I congratulate you for this technological innovation and for your environmental stewardship.

EPA considers your new chemical worthy of recognition because it is expected to replace heavy metal yellow and diaryl yellow pigments. Thus, the PMN substance should reduce human and environmental exposure to heavy metals such as lead and chromium and to diaryl compounds and byproducts such as dichlorobenzidine and other polychloro-biphenyls. This replacement is expected to reduce the risk to society of cancer and other adverse health effects, and to benefit the environment by reducing the use of heavy metals, diarylides and other deleterious compounds. Although the Agency continues to have concerns for the potential human health effects associated with exposure to aromatic amines, the safety advantages of this new chemical make it an outstanding example of innovative chemistry that benefits human health and the environment.

EPA is also aware of two other new chemicals for which Engelhard Corporation submitted premanufacture notices, PMN 95-1742 and 97-480, also described generically as metalized azo yellow pigments. These PMNs would also reduce human and environmental exposure to heavy metals such as lead and chromium and to diaryl compounds and byproducts. Unfortunately, the Agency has not received a notice of commencement of commercial manufacture (per 40 CFR 720.102) for these new chemicals. EPA acknowledges the potential P2 and safety advantages of the chemistry described in P95-1742 and P97-480 and would proceed to formally recognize their prevention benefits once manufacture commences and these benefits begin to accrue. Please notify us if the manufacturing status of these substances changes.

OPPT has instituted the P2 Recognition Program as a means to encourage innovation and further pollution prevention. In addition to formal notice by letter, EPA is considering publicly listing P2 Recognition recipients on the Internet and perhaps in other media as well. The Agency may also publish articles describing the pollution prevention benefits of specific chemicals which are the subject of a PMN. As always, confidential business information claims will limit our ability to communicate about these new chemicals and to announce, describe and promote these P2 innovations. The Agency welcomes your ideas and comments on how best to recognize and spread the word about your and other noteworthy P2 accomplishments. In this particular case, it would be helpful if you would drop the CBI claims concerning chemical identity.

Please realize that New Chemicals Program reviewers often rely heavily on information manufacturers supply on the P2 page of the Premanufacture Notice to identify recognition candidates. EPA urges all submitters to provide sufficient detail in a notice so that the Agency can perform a thorough analysis of P2 claims. In essence, pollution prevention means reducing or eliminating a potential pollutant before it is created. Ideally, P2 should be accomplished through innovative chemical design or redesign. EPA advocates P2 because it makes sense -- for the environment and the economy. By not creating a pollutant, one avoids the hazards and costs associated with controlling exposures to and releases of that pollutant. In process recycling may provide benefits similar to P2. (For more information on P2, see EPA's Pollution Prevention homepage: http://www.epa.gov, select "Search" then type "p2home.")

Since EPA has only limited information on your P2 Recognition chemical, I ask that you keep the Agency informed of this substance's commercial success over time, any toxicity data that becomes available, and the uses you make of this P2 recognition (e.g., in product literature or advertising). Please note that under Section 5 of the Federal Trade Commission Act any marketing claims based on this letter must be accurate and not misleading. (For additional information, see "Guides for the Use of Environmental Marketing Claims" issued by the Federal Trade Commission on July 28, 1992 at 57 FR 36363, codified at 16 CFR Part 260, and reissued in October 1996. Copies of the Guide are available by calling the FTC at (202) 326-2222 or on the Internet at http://www.ftc.gov under the heading "Consumer Protection Rules and Guides" and the subheading "Environmental Marketing Guides.")

When you have new information or if you have any questions regarding the P2 Recognition Program, please contact Roy Seidenstein (202-260-2252) or Kenneth Moss (202-260-3395). You can reach Mr. Seidenstein or Mr. Moss by fax at 202-260-0118; by mail at USEPA, Office of Pollution Prevention and Toxics, MC 7405, 401 M Street, SW, Washington, DC 20460; or via e-mail at seidenstein.roy@epamail.epa.gov or moss.kenneth@epamail.epa.gov. Also, my office runs the President's Green Chemistry Challenge Awards program; your P2 Recognition PMN may be a good candidate for this award. (For information on how to apply, contact Tracy Williamson at 202-260-3960, or williamson.tracy@epamail.epa.gov.)

Again, congratulations on your pollution prevention achievement. The Agency wishes you continued success with future innovations.

William H. Sanders III, Dr. P.H., P.E.
Director, Office of Pollution Prevention and Toxics

cc: Mr. Steven Camenisch, Engelhard
      Dr. Byron Hays, Engelhard


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