Product Description and Composi tion. Kathon w * Biocides. magnesium nitrate % 21-23% 2 reaction by-product 3 stabilizer

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ROHM AND HAAS COMPANY'S COMMENTS ON S. 2426 - a bill to provide for the temporary suspension of the duty on mixtures of 5-chloro-2-methyl-4-isothiazolin-3- one, 2-methyl-4-isothiazolin-3-one, magnesium chloride and magnesium nitrate. Product Description and Composi tion Kathon w * Biocides Kathon 886F Kathon CG 5-chloro-2-methyl-4-isothiazolin-3-one 1 10-11% 1.05-1.25% 2-methyl-4-isothiazolin-3-one 2 3-4% 0.25-0.45% magnesium chloride 2 8-9% 0. 5-1.0% magnesium nitrate 3 15-17% 21-23% water 60-62% 74-77% 1 active ingredient 2 reaction by-product 3 stabilizer * Kathon is a registered trademark of Rohm and Haas Company,

Typical End Uses Kathon 886F preservative for metal-working fluids, waterbased paints and other latex polymers; slimicide for paper and pulp mills; prevention of growth in oil and gas-field injection water and in industrial recirculatingwater cooling towers and air washers Kathon CG preservative for cosmetics, toiletries, floor polishes, fabric softeners, dishwashing liquids Product History First sale outside the United States First sale in the United States 1974 1976 Location for Production Facilities Jarrow, U.K. - at Rohm and Haas U.K., a wholly-owned subsidiary of Rohm and Haas Company (USA) Dedicated new world scale plant at Jarrow started up in the 3rd Quarter of 1983.

Production in semi-works at Rohm and Haas Company 1 s Philadelphia, PA plant to be discontinued in the 1st Quarter of 1984. Demand outran capacity, necessitating construction of new facilities. Semi-works continues in service for scale-up projects and production of limited volume chemicals. Other Manufacturers None - domestic OP foreign. Patent coverage in the United States and in major western countries extends into the 1990 f s (Exhibit A). Raw Material Sources Share of U.S. Capacity* Used When Production of Kathon Products was Based Source in the United States methyl 3 mercaptopropionate U.K. & U.S. <" 2% monomethyl amine *\ < 0.2% chlorine V Non-U.S. < 0.1% magnesium oxide, magnesium nitrate <" 0.1% 1% * Based on world market for Kathon products in 1983. U.S. market for Kathon products is less than 50% of world market.

Customer Need Kathon biocides are in demand because they are slow reacting, long lasting and effective at extremely low use levels compared to competitive biocides. These benefits result in: significant cost/performance advantages over competitive biocides less potential for hazard to people due to contact with fnished product formulations incorporating Kathon less potential for environmental hazard less potential for disturbing the esthetics (color and/or odor) of finished product formulations, as in cosmetics Competitive Products There is a wide variety of biocides in use today. None offer the customer the advantages of Kathon, as outlined above. Effectiveness at low use levels is a particularly important factor in the customer's choice of biocide. A comparison of recommended use levels for Kathon and competitive biocides in several major applications is shown in Exhibit B.

Present Tariff Classification Item 432.25 TSUS - Mixtures not specially provided for Other: Other: Duty Rate 7.9% ad valorem - the highest rate applicable to any component in Kathon - from item 425.52 TSUS; Nitrogenous compounds: Other: Other: Revenue Impact of Proposed Suspension of Duty Duties first payable when imports of Kathon began (September 1983) would be foregone. There would be no revenue impact of the proposed suspension of duty compared to the situation prevailing when Kathon products were manufactured exclusively in the United States (1974 through August 1983). Kathon products and the active ingredients in Kathon products were manufactured and sold in the United States from 1974 through August 1983 without payment of duty. Kathon was first imported into the United States in September 1983.

EXHIBIT A ROHM AND HAAS COMPANY PRINCIPAL UNITED STATES PATENTS COVERING 5-CHLORO-2-METHYL-4-ISOTHIAZOLIN-3-ONE AND ITS SELECTED END USES Patent Number 3,761,488 4,105,431 4,234,403 4,279,762 4,252,694 4,265,899 Expiration Date 9/25/90 8/08/95 1/06/98 7/21/98 2/24/98 5/05/98 Subject 3-isothiazolone compounds Biocidal compositions and uses Coatings containing 3-isothiazolones Cutting oils containing 3-isothiazolones Cleaning compositions containing 3-isothiazolones Cosmetic formulation containing 3-isothiazolones as biocides