SAT Report

PMN Number: P-13-0674

SAT Date: 7/16/2013

Print Date: 5/5/2014

Related cases:

Health related cases: 

Ecotox related cases: No suitable analogs were found.

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 2

 Persistence Bioaccum Toxicity Comments

1 1 2 PMN

1 1 Hyd Pdt

Exposure Based Review:

Health: No Exposure based testing (health): XB testing through developmental toxicity 

testing submitted with PMN

Ecotox: No

Routes of exposure: Health: Drinking Water Inhalation 

Ecotox: All releases to water

Fate: ; Hyd Pdt moderate

P2Rec Comments:

Comment: P2REC: SAT: Do Not Forward. This substance showed developmental 

toxicity and was judged by SAT to have a potential to cause cancer

Keywords:

 Keywords: DEVEL; SYSTEMIC; ONCO (UNCERT); AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-13-0674

FATE: Estimations for hydrolysis product 

log Kow = 0.35 (E)

log Koc = 2.21 (E)

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log Fish BCF = 0.50 (E)

log Fish BAF = 0.04 (E)

PMN Substance: Solid with MP = Dec. 156.9 C (M)

log Kow = -3.05 at pH 5 (M) 

S = 424 g/L at pH 4 and 25 °C (M)

S = Reacts at pH 7 and 9 (M)

Hydrolysis Half-life = min-hr at pH 7 or 9, >mo at pH 4

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

BP > 400 C (E)

H < 1.00E-8 (E)

POTW removal (%) = PMN 90-99 via hydrolysis; then Hyd Pdt 90 via sorption and biodeg; 

OECD 302C(MITI): 100%/27d; OECD NS(Closed Btl): 63.7-64.1%/28d; OECD 301F(Mano 

Resp): 100%/28d; OECD 111(Hydrolysis): t1/2(pH4,7,9):276d, 3.5hr, 10min.

Time for complete ultimate aerobic biodeg = Hyd Pdt wk

Sorption to soils/sediments = Hyd Pdt moderate

PBT Potential: PMN P1B1; Hyd Pdt P1B1

*CEB FATE: Migration to ground water = Hyd Pdt moderate

 Health:

 Health Summary: Not absorbed through the skin, moderate absorption from 

the GI tract and good absorption from the lung (pchem). Concern for developmental toxicity and 

general systemic toxicity based on submitted test data. Uncertain concern for oncogenicity based 

on the possible mechanism of action for the indicated use.

 Test Data: (-) Salmonella with and without activation; (-) for 

chromosome aberrations in V79 cells with and without activation; (-) for gene mutations in V79 

cells with and without activation; (-) ip mouse micronucleus assay; rat oral LD0 = 2000 mg/kg; 

rat dermal LD0 = 2000 mg/kg; rat inhalation LC0 = 5.75 mg/L (5750 mg/m3); no skin irritation 

in rabbits; not corrosive to human skin in vitro at 85 and 32% ai; not irritating to human skin in 

vitro at 85 and 32% ai; no eye irritation in rabbits; no serious eye damage in vitro Bovine 

Corneal Opacity and Permeability Test; (-) for skin sensitization in a mouse local lymph node 

assay up to 50% ai; rat oral developmental toxicity NOEL = 250 mg/kg; rat 28-day oral NOEL = 

1000 mg/kg (highest dose tested); rat 90-day oral NOEL = 300 mg/kg, lower mean body weight 

and elevated bile acids in blood at 1000 mg/kg

 Ecotox:

Test Organism Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 >100 60.0

daphnid 48-h LC50 >100 24.7

green algal 96-h EC50 >100 12.9 48-hour test results; 

yield

fish _ chronic value >10

daphnid _ chronic 

value

>10

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algal _ chronic 

value

>10 0.106 48-hour test results; 

yield

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic 

Value

_

Ecotox Values Comments: Predictions are based on SARs for anionic surfactants: SAR 

chemical class = surfactant-anionic ; MW 376; solid with mp = 150 C (dec., M); S = 

424 g/L at 20 C (M); pH7; effective concentrations based on 100% active ingredients and 

nominal concentrations; hardness < 150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Ecotoxicity Test Data Results for P-13-0674: 

Acute fish, daphnia, and algae toxicity studies were completed for PMN P-13-0674 in 2009 by 

 A second 

acute fish study was completed for PMN P-13-0674 by 

 but was submitted as a robust summary without 

full study details. The PMN material is described as a solid in the neat form, as a solid mixture 

 The molecular weight is 376.32 g/mol. Based on an 

experimental water solubility of 424 g/L, an estimated Log Kow of 0.35 and an estimated 

Henry’s Law Constant of < 1.00 x 10-8 atm-m3/mole this PMN is expected to nonvolatile and 

highly soluble in water. The PMN material also reacts at pH 7 and 9 based on experimental 

results and has experimental hydrolysis half lives at 25 °C and pH 4, pH 7 and pH 9 of 276 days, 

3.5 hours and 10 minutes, respectively. The PMN material is 

 The pH is controlled at > 8 – 9 during processing. The PMN material is used as 

 Studies followed the respective guidelines of OECD 203 (Acute Toxicity for 

Fish), Council Regulation (EC) No 440/2008, Method C.1 'Acute toxicity for Fish' (2008), 

OECD 202 (Daphnia sp., Acute Immobilization Test), Council Regulation (EC) No 440/2008, 

Method C.2 ‘Acute toxicity for Daphnia’ (2008), OECD 201 (Freshwater Alga Growth 

Inhibition Test) and Commission Regulation (EC) No 761/2009 amending Regulation No 

440/2008, Method C.3 ‘Freshwater Algae and Cyanobacteria, Growth inhibition test’ (2009) and 

were GLP compliant. Study methods concurred with methods specified in the respective 

guidelines except where specified below.

Fish Ecotoxicity Test:

(1) conducted a 96-hour acute toxicity test in zebra fish 

(Brachydanio rerio) with P-13-0674 under semi-static conditions with 24-hour renewal. The 

substance tested was a solution containing 65% water and 35% solid. The solid is the “drying 

residue” and contains 31.95% of the PMN substance and is considered to be the active 

ingredient. Following a range-finding test, single replicates of seven B. rerio were exposed to a 

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dilution water control (reconstituted water) or the test substance at nominal test concentrations of 

9.4, 20.7, 45.5 and 100 mg/L. Effective concentrations ranged from 97.9 – 111.4% of nominal 

values in the freshly prepared media and from 44.1 – 82.8% of nominal values in the media after 

24 hours of exposure. Concentrations were only measured for the 20.7 and 100 mg/L nominal 

test concentrations. The test item concentrations for the 9.4 and 45.5 mg/L test concentrations 

were calculated based on the mean recovery rate measured at the next highest concentration, 

respectively. Thus, the recovery rate for the 20.7 mg/L nominal test concentration was used to 

calculate the concentration of the 9.4 mg/L nominal test concentration. Measured concentrations 

were determined by HPLC analysis and MS detection with a limit of quantification (LOQ) of 

0.021 mg/L. The analytical values refer to the drying residue of the test substance with a content 

of 35.05%. Stock solutions were prepared to give the desired series of test concentrations based 

on a drying residue of 35.05% (according to data of the sponsor). To prepare a stock solution, a 

certain amount of test substance was added daily to 1 L of Millipore water and shortly treated on 

a magnetic stirrer. Appropriate amounts of the stock solution were then diluted with water 

according ISO 7346 and adjusted to a pH of 6 to obviate rapid hydrolysis. Test vessels were 

covered with glass plates. Over the course of testing, temperature ranged from 19.9 – 21.5 °C, 

pH ranged from 6.0 – 6.7 and dissolved oxygen ranged from 7.6 – 9.0 mg/L. Dilution water 

hardness was 264 mg CaCO3/L which exceeds both the OECD 203 guideline water hardness 

value of 250 mg CaCO3/L and the OPPTS 1075 water hardness value of 180 mg CaCO3/L. A 

loading rate of 0.54 g fish/L was reported. Observations were made on the numbers of dead fish 

and the incidence of sub-lethal effects after 2, 24, 48, 72 and 96 hours of exposure. No 

mortalities occurred at nominal concentrations ≤ 45.5 mg/L. However, there was abnormal 

swimming behavior documented after 2 hours at the nominal concentrations of 45.5 mg/L and 

100 mg/L. Cumulative mortality in the 100 mg/L group was 86%. Based on geometric mean 

measured concentrations, the 96-hour LC50 is 65.86 mg/L for the drying residue and 60.01 mg/L 

for the active ingredient. Although the water hardness exceeded the test guideline values, this 

test was considered to be adequate.

96-hour LC50 = 65.86 mg/L (drying residue)

96-hour LC50 = 60.01 mg/L (active ingredient)

(2) 

conducted a 96-hour acute toxicity test in zebra fish (Brachydanio rerio) with P-13-0674 (98.2 ± 

1.2% purity) under semi-static conditions with 24-hour renewal. The test temperature was 23 ± 

1°C. Only a study summary is available; no additional study details were provided. The 96-hour 

LC50 is 67.2 mg/L (it is not specified whether this value is based on nominal or measured 

concentrations). This test is not considered to be adequate due to the lack of information on the 

test conditions and results.

96-hour LC50 = 67.2 mg/L 

Invertebrate Ecotoxicity Test:

 conducted a 48-hour acute toxicity test in water fleas (Daphnia 

magna) with P-13-0674 under semi-static conditions with 24-hour renewal. The substance tested 

was a solution containing 65% water and 35% solid. The solid is the “drying residue” and 

contains 31.95% of the PMN substance and is considered to be the active ingredient. Following 

a range-finding study, two replicates of 10 D. magna were exposed to a dilution water control or 

the test substance at nominal concentrations of 1.9, 4.3, 9.4, 20.7, 45.5 and 100 mg/L 

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corresponding to geometric mean concentrations of 0.922, 1.61, 4.49, 10.9, 27.1 and 63.3 mg/L, 

respectively. Recovery rates ranged from 83.0 – 98.7% of nominal values in freshly prepared 

media, and from 14.8 – 56.5% of nominal values in media after 24 hours of exposure, 

respectively. Measured concentrations were determined by HPLC analysis and MSD-detection 

with a limit of quantification (LOQ) of 0.021 mg/L. The analytical values refer to the drying 

residue of the test substance with a content of 35.05%. Stock solutions were prepared to give the 

desired series of test concentrations based on a drying residue of 35.05% (according to data of 

the sponsor). To prepare a stock solution, a certain amount of test substance was added to 1 L of 

distilled (Millipore) water. Appropriate amounts of the stock solution were then diluted with M4 

Medium which was adjusted to a pH of 6 to obviate rapid hydrolysis of the test item. Test 

vessels were covered with glass plates. Over the course of testing, temperature ranged from 19.5 

– 21.9 °C, pH ranged from 6.0 – 7.0 and dissolved oxygen ranged from 8.0 – 8.9 mg/L. Dilution 

water hardness was 266 mg CaCO3/L which exceeds both the OECD 203 guideline water 

hardness value of 250 mg CaCO3/L and the OPPTS 1010 water hardness value of 180 mg 

CaCO3/L. A loading rate of 500 daphnia/L was calculated exceeding the loading rate of 40 

daphnids/L in the OPPTS guideline, potentially causing overcrowding. No immobilization 

occurred at concentrations ≤ 10.9 mg/L. Percent immobilization at 27.1 and 63.3 mg/L was 50% 

and 100%, respectively. Additionally, abnormal swimming behavior was observed at 63.3 mg/L. 

Based on geometric mean measured concentrations, the 48-hour EC50 is 27.1 mg/L for the 

drying residue and 24.7 mg/L for the active ingredient. Although the water hardness exceeded 

the test guideline values and the daphnid loading exceeded the OPPTS guideline, this test was 

considered to be adequate.

48-hour EC50 = 27.1 mg/L (drying residue)

48-hour EC50 = 24.7 mg/L (active ingredient)

Algal Ecotoxicity Test:

conducted a 72-hour toxicity test in green algae 

(Desmodesmus subspicatus) with P-13-0674 under static conditions. The substance tested was a 

solution containing 65% water and 35% solid. The solid is the “drying residue” and contains 

31.95% of the PMN substance and is considered to be the active ingredient. While the study was 

conducted for 72 hours, the data were analyzed on a 48 hour basis since the algal cell numbers 

increased well above 16-fold over 48 hours and all other validity criteria were met. This option 

is cited to be covered by OECD 201. The OPPTS guideline requires a 96-hour algal test. The 

substance tested in this study was not fully characterized and its identity was not provided. The 

active ingredient was described and confirmed to be the PMN substance. Following a 

range-finding test, three replicates of D. subspicatus (5000 cells/mL) were exposed to a dilution 

water control or the test substance at nominal concentrations of 0.32, 1.0, 3.2, 10 and 32 mg/L. 

Corresponding geometric mean measured concentrations of 0.071, 0.189, 0.467, 1.755 and 8.413 

mg/L were determined via HPLC analysis and MSD-detection with a limit of quantification 

(LOQ) of 0.021 mg/L. The analytical values refer to the drying residue of the test substance 

with a content of 35.05%. Effective concentrations ranged from 76.0 – 103.4% of nominal 

values at 0 hours, from 16.2 – 35.1% of nominal values at 24 hours, and from 2.5 – 9.6% of 

nominal values at 48 hours, respectively. Stock solutions were prepared to give the desired 

series of test concentrations based on a drying residue of 35.05% (according to data of the 

sponsor). To prepare a stock solution, 356.8 mg of test substance was added to 1 L of dilution 

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water and adjusted to a pH of 6 to obviate rapid hydrolysis of the test item. To produce the 

different test concentrations, the prepared stock solution was diluted with dilution water to a 

volume of 80 mL. This was followed by the addition of 10 mL of nutrient medium and 10 mL of 

algal inoculum with a cell density of 5000 cells/mL to achieve the final nominal concentrations. 

Algal cultures were illuminated at a light intensity of 4000 – 8000 lux with constant shaking. 

Over the course of testing, temperature ranged from 20.0 – 21.5 °C and pH ranged from 6.1 –

7.2. Dilution water hardness was 22.5 mg CaCO3/L. Mean cell density in control cultures 

increased by a factor of 108.7 within 72 hours. The test was carried out for 72 hours, but only 

48-hour results are reported. Based on geometric mean measured concentrations, the 48-hour 

EC50 values for growth rate and yield are > 100 and 12.9 mg/L, respectively, for the active 

ingredient. The NOEC and LOEC values for the active ingredient are 0.065 and 0.172 mg/L, 

respectively. The ChV for the active ingredient is 0.106 mg/L. Because concentrations of the 

test item markedly decreased over time, the study data were analyzed on a 48-hour basis which 

reflects exposure better than the 72-hour values based on comments from the testing facility. 

Minimally, the results for the 72-hour test duration should have been reported, but the 48-hour 

results are considered to be adequate since algae is the most sensitive species using the 48-hour 

results.

Drying Residue (35.05%):

48-hour ErC50 (growth rate) > 100 mg/L

48-hour EyC50 (yield) = 14.1 mg/L

48-hour NOEC (growth rate and yield) = 0.071 mg/L

48-hour LOEC (growth rate and yield) = 0.189 mg/L

Active Ingredient (31.94%):

48-hour ErC50 (growth rate) > 100 mg/L

48-hour EyC50 (yield) = 12.9 mg/L

48-hour NOEC (growth rate and yield) = 0.065 mg/L

48-hour LOEC (growth rate and yield) = 0.172 mg/L 

The 96-hour fish (LC50 = 60.01 mg/L), 48-hour daphnid (EC50 = 24.7 mg/L) and 48-hour algal 

(EyC50 = 12.9 mg/L; NOEC = 0.065 mg/L and LOEC = 0.172 mg/L) toxicity tests were 

considered to be adequate for P-13-0674 (the active ingredient). For comparative purposes, the 

96-hour fish LC50, the 48-hour daphnid LC50, and the 96-hour algae EC50 of >100 mg/L, and 

the fish, daphnid, and algae chronic values (ChV) of > 10 mg/L, respectively were predicted 

using the SAR for anionic surfactants. Available experimental data indicate algae to be the most 

sensitive species for calculating the acute and chronic concentrations of concern (CoC). The 

48-hour algae results are being used to calculate the acute and chronic CoCs, however, if risk is 

confirmed from environmental releases based on the CoC values below, EPA recommends the 

submittal of the results for the full 72-hour test or for the algae test to be conducted again for the 

full 96-hours with the PMN compound and hydrolysis product measured over the duration of the 

test. Based on the experimental 48-hour algae EyC50 of 12.9 mg/L (12,900 ppb), and the 

application of an assessment factor of 4, the acute CoC for P-13-0674 is 3225 ppb. The ChV for 

P-13-0674 is calculated by determining the geometric mean of the NOEC and LOEC to yield a 

ChV of 0.106 mg/L (106 ppb). The chronic CoC for P-13-0674 is then derived by dividing the 

ChV of 0.106 mg/L (106 ppb) by a factor of 10 (uncertainty factor) yielding a chronic CoC of 

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10.6 ppb.

Acute CoC = 3225 ppb

Chronic CoC = 11 ppb

Ecotox Study Reviewer: K. Eisenreich July 24, 2013

Factors Values Comments

Assessment Factor

10

Concentration of Concern 

(ppb)

11

SARs anionic surfactants

SAR Class surfactant-anionic

Ecotox Category Anionic Surfactants

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

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