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: No

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 (NOMO5)

BP = 351 °C (NOMO5) 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 (pchem), 

 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 NAD unacceptable since 

nominal conc. reported 

and stock solution 

prepared above the WS; 

<15.8

daphnid 48-h LC50 0.953 NAD unacceptable since 

nominal conc. reported 

and stock solution 

prepared above the 

WS;<16.8

green algal 96-h EC50 0.195 NAD unacceptable since 

nominal conc. reported 

and stock solution 

prepared 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 at 
20 C (M); 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;

*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 

present 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 

predictions were used to calculate COCs. SAR predictions for P-15-0120 were based on SARs 
for 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 ppb and the chronic 

COC is 1 ppb for subject PMN substance. 

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb) 

Acute 

Concentration of Concern 

(ppb) Chronic

1

SARs

SAR Class

TSCA New Chemcial 

Category 

Ecotox Factors Comments: 

 SAT Chair: 

 Fate assessor: Ecotox assessor: Health assessor: