Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-222 

EPA Docket EPA-HQ-OPPT-2011-0577 
Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-222 

A-002 Initial Review Engineering Report for 

PMN P-10-222 

A-003 Initial Review Exposure Report for 

PMN P-10-222 
A-001 

Structure Activity Team (SAT) Report

for PMN P-10-222 
 

 
 

 

 

 
 

 
 
 

A-002 

Initial Review Engineering Report

for PMN P-10-222 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0222 

Focus Ready Draft 3/8/2010 Revised 4/26/2010 & 5/20/2010

ENGINEER: Arnold \ DGR 

PV (kg/yr): 

SUBMITTER: 

USE: 

OTHER USES: 

 

MSDS: Yes Label: No 

Gen Eqpt: protective gloves/ protective, impervious 

clothing/ chemical goggles/ adequate ventilation 

Respirator: If engineering controls do not maintain 

airborne concentrations below recommended exposure limits 

(where applicable) or to an acceptable level (in 

countries where exposure limits have not been 

established), an approved respirator must be worn. 

Health Effects: Causes eye irritation/ may cause 

irritation to the respiratory system/ may be harmful if 

absorbed through skin/ may be harmful if swallowed 

TLV/PEL: 

None established for PMN chemical 

CRSS : 

Chemical Name: 

S-H20: 1.1 g/L @ 25.00 

VP: 

MW: 

Physical State and Misc CRSS Info: 

Neat: Liquid 

 

 

 

 

Consumer Use: No 
SAT (concerns) (03/02/2010): 

Migration to groundwater: Moderate 

PBT rating: P2B1T2 

 Drinking Water, Inhalation, 

o water with a CC = 22 ppb), 

OCCUPATIONAL EXPOSURE RATING: 2A 

NOTES & KEY ASSUMPTIONS: 

Generated by the 06/07/2005 version of ChemSTEER. 

 

 

 

 

 

 

 

 

 

 

 

 

POLLUTION PREVENTION CONSIDERATIONS: 

None. 

EXPOSURE-BASED REVIEW: 

 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0222 

Manufacturing: Batch 

Number of Sites/ Location: 

 

 

Days/yr: 

Basis: 

 

 

 

Process Description: 

 

 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

IRER Note: The daily releases listed for any source below 

may coincide with daily releases from the other sources 

to the same medium. 

 

 

 

Conservative: 

t

from: 

basis: 

 

 

 

 

 

Typical: 

Worst Cas

to: 

from: 

basis: 
Output 2: 

to: 

from: 

basis: 

RELEASE TOTAL 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers exposed via assessed routes: 

Basis: 

Inhalation: 

Exposure 

Typical: 

Worst Cas

Number of wo tes) with inhalation exposure: 

Basis: 

INHALATION MONITORING DATA REVIEW 

1) Uncertainty (estimate based on model, regulatory limit 

 or data not specific to industry): Yes 

2)a) Exposure level > 1 mg/day? Yes 

 OR 

 b) Hazard Rating for health of 2 or greater? 2 Yes 

Inhalation Monitoring Data Desired? Yes (both criteria 

met) 

Exposure 

Typical: 

Worst Case

Number of wo tes) with inhalation exposure: 

Basis: 

INHALATION MONITORING DATA REVIEW 

1) Uncertainty (estimate based on model, regulatory limit 

 or data not specific to industry): Yes 

2)a) Exposure level > 1 mg/day? No 

 OR 

 b) Hazard Rating for health of 2 or greater? 2 Yes 

Inhalation Monitoring Data Desired? Yes (both criteria 

met) 

Dermal: 
Exposure t

High End: 

Number of sites) with dermal exposure: 

Basis: 

Exposure t

High End: 

Number of w sites) with dermal exposure: 

Basis: 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0222 

Use: 

Number of Sites/ Location: 

 

 

Days/yr: 

Basis: 

 

 

 

Process Description: 

 

 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

IRER Note: 

 

 

 

Output 2: 

to: 

from: 

basis: 

RELEASE TOTAL 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers exposed via assessed routes: 

Basis: 

Inhalation: 

Exposure 

Typical: 

Worst Cas

Number o on

Basis: 
INHALATION MONITORING DATA REVIEW 

1) Uncertainty (estimate based on model, regulatory limit 

 or data not specific to industry): Yes 

2)a) Exposure level > 1 mg/day? No 

 OR 

 b) Hazard Rating for health of 2 or greater? 2 Yes 

Inhalation Monitoring Data Desired? Yes (both criteria 

met) 

Dermal: 

Exposure t

High End: 

Number of sites) with dermal exposure: 

Basis: 
CALL BY: Dan Roper 

Organization: ERG, for EPA/OPPT/CEB 

CALL TO: 

Organization: 

Date: 03/03/2010 

Time: 11:32 am 

Phone: 

PMN: 10-0222 
A-003 

Initial Review Exposure Report

for PMN P-10-222