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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

10 ( o ~-- 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU : 

reaction 

TO : 

Request for Review on the Physical Chemical endpoints of Test Plan for HPV 

Test Rule Chemical Orphan, Urea, products with formaldehyde (CAS 

No. 68611-64-3) 

Industrial Chemistry Branch (7406M) 

Kathryn E. Schechter, Chemist 

Chemistry (744M) 

c- J 

Tracy Williamson, Chief C G'`,1 

Industrial Branch 

Greg Schweer, Chief 

Chemical Information and Testing Branch (7405M) 

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This memo is in response to your request to evaluate the adequacy of the submitted prope g 

information by The Fertilizer Institute (TFI) to meet the endpoints in the HPV-1 test rule for 

t; rea, reaction products with formaldehyde (CAS No . 68611-64-3) using Urea, N,N"- ~` 

methylenebis- (MDU) as a representative chemical for the reaction mixture. 

e 

Urea, reaction products with formaldehyde is a complex mixture of products. TFI cn 

identified MDU as a representative chemical for this set of products. MDU is expected to the 

major component of the reaction between formaldehyde and urea; MDU is also expected to be 

the product with the lowest weight. Therefore, MDU as the representative chemical is justified. 

The following comments are made with regards to the physical-chemical properties of 

MDU: 

Boiling Point. 

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guidance') . 

Melting Point. The submitted value is 212-214 deg C. Similar melting point values were 

found in Beilstein (218 and 207 deg C); therefore, the submitted value is reasonable . 

The submitted value says "not applicable" . The estimated boiling point is 

337 deg C which is greater than 300 deg C; therefore, this assessment is reasonable . 

Vapor Pressure . The submitted value says "not applicable" . The estimated vapor 

pressure is 2.8e-6 torr which is higher than the cut off value of 7.Se-8 torr in EPA's 

guidance for estimating vapor pressure values (EPA's guidance is based on O CD 

As this representative chemical is expected to be only a component of the 

reaction mixture and the most volatile, this estimate can be used as an upper limit for the 

reaction product mixture, and it is not necessary to test for the vapor pressure . 

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" Water Solubility. The submitted value is 25 g/L. A similar water solubility value was 

found in Beilstein (29.41 g/L at 28 deg C); therefore, the submitted value is reasonable . 

" Log P. The submitted value is -3 .01 (estimate by EPI). The HPV program accepts 

estimated values for log P. 

I agree with the sponsor's reasoning for no further testing for the physical-chemical 

endpoints of this chemical. Data for the representative chemical MDU adequately fulfills this 

requirement. 

1 . Appendix 1 in the OECD Guideline for the Testing of Chemicals, Guideline 104 : Vapour 

Pressure