SAT Report

PMN Number: P-12-0069

SAT Date: 12/9/2011

Print Date: 2/27/2015

Related cases: Yes

Health related cases: 

Ecotox related cases: Analogs: .

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2 2

 Persistence Bioaccum Toxicity Comments

1 1 1 Anion

1 1 1 Cation

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Dermal Inhalation 

Ecotox: All releases to water

Fate: ; Anion rapid; Cation rapid

Keywords:

 Keywords: LUNG; IRR/CORR-E,S,L,MM; NEURO; AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-12-0069-70

FATE: Estimations for the typical covalent ion pair MW 

Liquid with MP < 25 C (E)

log Kow = 8.77 (E) 

S = Disp. / <0.001 mg/L at 25 C (ICB/E)

VP < 1.0E-6 torr at 25 C (E)

BP > 400 C (E)

H < 1.00E-8 (E)

log Koc = 5.04 (E)

log Fish BCF = 1.85 (E)
log Fish BAF = 5.61 (E) 

POTW removal (%) = Anion 90 via sorption and biodeg; Cation 0-90; OECD 

 301B(Mod Sturm CO2 ev): 94.2%/28d.

Time for complete ultimate aerobic biodeg = Anion wk; Cation wk-mo

Sorption to soils/sediments = Anion low; Cation low

PBT Potential: Anion P1B1; Cation P1B1

*CEB FATE: Migration to ground water = Anion rapid; Cation rapid

 Health:

 Health Summary: Absorption is poor from the skin, moderate from the GI 

tract, and good from the lung (analog). Concern for surfactant effects on the lung; irritation to 

eye, skin (chronic), mucous membranes and lung based on surfactant properties of the 

compounds and test data on an analogue. Also concern for neurotoxicity for the small 

 Test Data: [Analog: ]: (-) Salmonella with 

and without activation; rat oral LD50 >500, <1000 mg/kg; rat dermal LD0 = 2000 mg/kg; 

Corrosive in an in vitro rat skin disc assay

 Ecotox:

Test Organism Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 50 62 Analog data

daphnid 48-h LC50 6.1 > 100 Analog data

green algal 96-h EC50 4.7 19 Analog data

fish _ chronic value 2.6

daphnid _ chronic 

value

0.52

algal _ chronic 

value

1.6 2.7 Analog data

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic 

Value

_

Ecotox Values Comments: Predictions are based on SARs for with 

molecular weight adjustment; SAR chemical class = ; ; liquid with mp 

unknown (P); S = dispersible in water at 25 C (P); pH7; effective concentrations based on 

100% active ingredients and mean measured concentrations; hardness <150.0 mg/L as CaCO3; 

and TOC <2.0 mg/L;

P-12-0069: . with 

 (CASRN: NONE)

Three acute ecotoxicity tests were conducted on an analog of PMN (P-12-0069) in 2005 by 

 with fish, daphnia, and algae. The compound tested was 
 and is considered an acceptable analog (by Gordon Cash) for 

P-12-0069. P-12-0069 is a liquid with an estimated boiling point is > 400 °C. The estimated 

vapor pressure is < 0.000001 mm Hg at 25 °C. The solubility of the P-12-0069 is dispersible. 

These studies complied with OCSPP and OECD guidelines for: 1) O2, pH, temperature, water 

hardness values and other water quality parameters; 2) species, age, number of organisms per 

replicate, and biomass loading rates; and, 3) replicate and overall variability. The test was 

performed in a and there was a quality assurance statement provided.

In a 96-hour fish test, (10/ two replicate/test concentration) were exposed 

to as water accommodation fraction (WAF) of 6.3, 13, 25, 50, and 100 

mg/L as nominal concentrations with static-renewal exposures. The test protocol was amended 

by aerating the test chambers throughout the 96-hour exposure period. Also, the test chambers 

were 25-L stainless steel aquaria containing 11.5 L of test solution rather than the 

 specified in the protocol. test solutions were mixed directly 

with dilution water on a weight volume basis. Each was stirred for approximately 24 

hours in a 13.2 L pyrex aspirator bottle using a lined magnetic stir bar to create a 

vortex depth of approximately 30% of the test solution height. After mixing, the were 

allowed to settle for approximately one hour. The test solutions were then drawn from spigots 

placed near the bottom of the mixing vessels and added to the appropriate test chamber. The fish 

were transferred to newly prepared test solutions at 48 hours, and at test termination and 

analyzed using was measured using a 

-5000 total . There was no mortality in the control or 6.3 – 25 mg/L 

treatment groups. Mortality in the 50 and 100 mg/L treatment groups was 20 and 100%, 

respectively. The 96-hour LL50 for is 62 mg/L. The 96-hour NOEL for 

 is 25 mg/L. The P test is valid.

In a 48-hour immobilization toxicity test, Daphnia magna (10 daphnia/two replicates/test 

concentration) were exposed to as WAF of 6.3, 13, 25, 50, and 100 mg/L 

with static-renewal exposures. test solutions were mixed directly with dilution water on a 

weight volume basis. Each 12-L was stirred for approximately 24 hours in a 13.2 L pyrex 

aspirator bottle using a lined magnetic stir bar to create a vortex depth of 

approximately 30% of the test solution height. After mixing, the s were allowed to settle 

for approximately one hour. The test solutions were then drawn from spigots placed near the 

bottom of the mixing vessels and added to the appropriate test chamber. 

was renewed at 24 hours, and at test termination and analyzed using was measured 

using a total . Observations of immobility 

were made at 3, 24, and 48 hours after test initiation. The 48-hour EL50 for 

is > 100 mg/L. The NOEL of is 6.3 mg/L. The D. magna test is valid.

In a 72-hour algal growth inhibition test, (1 x 104 cells/mL) 

were exposed to at concentrations of 1.8, 4.1, 10, 20, 45, and 100 

mg/L as nominal concentrations under static conditions. The pH ranged from 7.7 to 7.9. Three 

replicates were used for each of the test concentrations and 6 replicates for the control. Over the 

course of the algal study, the temperature remained at 23.0°C. The 72-hour ErL50 (growth rate) 

and EbL50 (biomass) of for P. subcapitata are 72 and 19 mg/L, 

respectively. The 72-hour NOEL for biomass was <1.8 mg/L. The 72-hour NOEL based on 
growth rate for is 1.8 mg/L. The 72-hour LOEL based on biomass for 

 is 1.8 mg/L. The 72-hour LOEL for growth rate for is 

4.1 mg/L. The calculated geometric mean of the LOEL and NOEL (the algal chronic value or 

algal ChV), based on growth rate for is 2.7 mg/L. The 

toxicity test is valid.

 All three submitted aquatic ecotoxicity studies are valid. Since is a suitable 

analog for P-12-0069, the aquatic toxicity endpoint results from can be used 

to assess the aquatic toxicity endpoints for P-12-0069. For comparative purposes, the ECOSAR 

(v. 1.1) predicted fish 96-hour LC50, Daphnia 48-hour EC50 and algal 72-hour EC50 are 50, 6.1, 

and 4.7 mg/L for P-12-0069, respectively. In addition, the ECOSAR predicted chronic value for 

fish, daphnid and algae is 2.6, 0.52, and 1.6 mg/L. The acute concentration of concern is derived 

by dividing the 72-hour algal EC50 (19 mg/L or 19,000 ppb), the most sensitive aquatic species 

of the three submitted, by an uncertainty factor of 4 (for algae) to yield 4,750 ppb. The chronic 

concentration of concern is derived by dividing the predicted Daphnid ChV (0.52 mg/L), more 

sensitive than the experimental algal ChV of , by an uncertainty factor of 

10, yielding 0.052 mg/L or 52 ppb.

Acute CoC = 4,750 ppb

Chronic CoC = 52 ppb

Ecotox Study Reviewer: Amuel Kennedy QA/QC: Jeff Gallagher 

14 December 2011

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

52

SARs with molecular 

weight adjustment

SAR Class

Ecotox Category 

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916