### SAT Report PMN Number: P-15-0120 SAT Date: 12/12/2014 Print Date: 5/29/2015

Related cases : Yes Health related cases: Ecotox related cases:

Concern levels : Type of Concern: Health Eco Comments Level of Concern: 1-2 3

Persistence Bioaccum Toxicity Comments 1 11

Exposure Based Review : Health: Ecotox: N o
Routes of exposure : Health: Dermal Inhalation Ecotox: All releases to water Fate: ; Keywords : Keywords: MUTA; ONCO; DEVEL; IRR-S,E; LIVER; KIDNEY; SENS; AQUATOX
Summary of Assessment :

Fate : Fate Summary: P-15-0120 FATE: Liquid with MP < 10 °C (M) log Kow = 3.54 (M) S = 83.8 mg/L at 25 °C (E) VP = 3.4E-5 torr at 25 °C ( N OMO5) BP = 351 °C ( N OMO5) based on 120-128 °C @ 0.1 mm Hg (M) H = 4.77E-8 (E) log Koc = 3.89 (E) log Fish BCF = 2.00 (E)log Fish BAF = 1.92 (E) POTW removal (%) = 90 via biodeg Time for complete ultimate aerobic biodeg = wk Sorption to soils/sediments = moderate - strong PBT Potential: P1B1 *CEB FATE: Migration to ground water = slow - moderate

Health : Health Summary: Expect moderate absorption via all routes ( p che m ), Concern for mutagenicity, oncogenicity, developmental, liver, and kidney toxicity, sensitization, and irritation from the

Ecotox :

Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 0.935 N AD unacceptable since nominal conc. reported and stock solution p repared above the WS; <15.8 daphnid 48-h LC50 0.953 N AD unacceptable since nominal conc. reported and stock solution p repared above the WS;<16.8 green algal 96-h EC50 0.195 N AD unacceptable since nominal conc. reported and stock solution p repared above the WS; <31.7 (growth rate),11.6 (yield) fish

_ chronic value 0.001

daphnid

_ chronic value 0.03

algal

_ chronic value 0.07

Sewage Sludge 3-h EC50

_ Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for SAR chemical class = liquid with mp <10 C (M); log Kow = 4.2 (P), 3.5 (M); S = 84 mg/L at20 C (M); p H7; effective concentrations based on 100% active ingredients and mean measured concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;
*Experimental data are available that are being reviewed. Preliminary concerns with the data include testing above the solubility limit without analytical confirmation of test concentrations.
Acute ecotoxicity tests were conducted with fish, daphnia, and algae on August 2014 for P-15-0120 by , Inc. The PMN material is a pale, yellow, transparent liquid with an estimated vapor pressure of 3.4 × 10-5 torr at 25 °C. The estimated water solubility of the PMN material is 0.084 g/L at 25 °C. The measured log Kow was 3.54 and predicted log Kow was 4.20. The sorption to soils and sediments is between strong to moderate and the time to complete ultimate aerobic biodegradation was estimated to be weeks. The sponsor stated that OECD No.23 test method was used since the PMN substance was a The PMN substance is water-soluble as supported by the measured log Kow of 3.54 and estimated water solubility of 0.084 g/L. The PMN substance does not degrade quickly in soils and sediments. Due to the physical-chemical properties, the PMN substance is not likely to p resent technical difficulties for testing that would warrant OECD No.23 test methods.
The results of the submitted aquatic toxicity tests for P-15-0120 were not acceptable and were not used to calculate the acute and chronic concentrations of concern (COC). Specific reasons are the use of a filter in all tests thereby not knowing the resulting exposure concentrations, misclassifying the PMN substance as when the supporting data and information shows the PMN substance is water-soluble and does not degrade quickly, using serial dilutions, not knowing the identification of the remaining 26% of the PMN substance, use of loading rates, using water-accommodated fractions (WAF), nominal concentrations instead of measured concentrations, and testing above the solubility limit since the sponsor used a stock solution of 100 mg/L when the predicted water solubility was 84 mg/L and there was no analytical confirmation of the test concentrations.
Although the sponsor states that the PMN substance was poorly water-soluble in breeding water and this warranted OECD No. 23 test methods, it was likely that the insoluble portion of the PMN substance were components (see Table 1 in attached document entitled EcoTox Summary) as supported by the log Kow. In addition, the estimated water solubility was 0.084 g/L and the log Kow for the major component of the PMN substance (73.49% area) was 3.54 meaning that a major portion of the PMN substance is water-soluble.
The sponsor should consult OCSPP testing guidelines for the acute fish aquatic test, acute daphnid aquatic test, and algae aquatic test. The specific methods for preparation of the test substance, the methods used for exposure, the methods used for the flow-through conditions, and the methods for the test item concentrations should follow the OSCPP testing guidelines. The sponsor should advise the chemical structures for the rest of the components in Table 1, namely , to find out if these chemical components pose toxicity.
The results of the submitted aquatic toxicity tests for P-15-0120 were not acceptable and were not used to calculate the acute and chronic concentrations of concern (COC). Instead, SAR p redictions were used to calculate COCs. SAR predictions for P-15-0120 were based on SARsfor acrylates and were classified as having high toxicity hazard.
Based on the predicted aquatic toxicity values, the acute value for algae and the chronic value for fish were deemed the most sensitive species. As such, the acute COC is 49 p pb and the chronic COC is 1 p pb for subject PMN substance.

Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) Acute Concentration of Concern ( p pb) Chronic 1

SARs SAR Class TSCA New Chemcial Category

Ecotox Factors Comments:

SAT Chair: Fate assessor: Ecotox assessor: Health assessor: