Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-11-637 

EPA Docket EPA-HQ-OPPT-2011-0942 

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Index 

A-001 Structure Activity Team (SAT) Report for 

PMN P-11-637 

A-002 Initial Review Engineering Report for 

 PMN P-11-637 

A-003 Initial Review Exposure Report for 

 PMN P-11-637 

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A-001 

Structure Activity Team (SAT) Report 

 for PMN P-11-637 

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SAT Report

PMN Number: P-11-0637

SAT Date: 9/23/2011

Print Date: 11/1/2011

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2 1

 Persistence Bioaccum Toxicity Comments

1 11

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Dermal Inhalation 

Ecotox: No releases to water

Fate: ;

Keywords:

 Keywords: SENS-S; BLOOD; LIVER; MUTA (UNCERT)

Summary of Assessment:

 Fate:

Fate Summary: P-11-0637

FATE: 

Solid

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

BP > 400 C (E)

H < 1.00E-8 (E)

POTW removal (%) = 90 via sorption and biodeg; OECD 301B(Mod Sturm CO2 ev): 26% 

(avg.)/28d.

Time for complete ultimate aerobic biodeg = wk - mo

Sorption to soils/sediments = v.strong

PBT Potential: P1B1

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*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Not absorbed from the skin as the neat material (pchem); 

poor through the skin if in solution (testing); poor absorption from the lung and GI tract (pchem). 

Concern for dermal sensitization, and blood and liver toxicity based on submitted test data. 

Uncertain concern for mutagenicity based on submitted test data and organo tin analogues.

 Test Data: (-) Salmonella with and without activation; (-) E. coli 

with and without activation; (-) for chromosome aberrations in human lymphocytes, (+) for 

polyploidy in a second trial; rat oral LD0 = 2000 mg/kg; rat dermal LD0 = 2000 mg/kg; no eye 

irritation in rabbits; mild skin irritation in rabbits, cleared by day 7; (+) skin sensitization in 

guinea pigs using the Magnusson-Kligman assay, 100% pos response at 20% ai; rat 28-day oral 

NOAEL = 330 mg/kg, changes in liver enzymes and increased white blood cell counts at 1000 

mg/kg

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 * *

daphnid 48-h LC50 * *

green algal 96-h EC50 * *

fish _ chronic value *

daphnid _ chronic value *

algal _ chronic value *

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for organotin compounds; ecotox 

chemical class: organotin; MW 698; S < 0.001 mg/L at 20 C; pH 7; hardness <180.0 mg/L as 

CaCO3; 100% active ingredients; mean measured concentrations; and TOC <2.0 mg/L;

Ecotoxicity Test Data Results for P-11-0637: Tin, C16-18 and C18-unsatd. fatty acids castor-oil 

fatty acids complexes; CASRN: 1315588-63-6

Three acute ecotoxicity studies were conducted on PMN (P-11-0637) in 2000 by NOTOX B.V. 

(The Netherlands) for Evonik Goldschmidt Corporation (submitter) with fish, daphnia, and 

algae. The PMN consisted of a yellow liquid at room temperature with a tin content of 16.4%, a 

reported water solubility of < 0.060 mg/L, and a vapor pressure of 1E-6 mmHg at 25°C. The 

purity of the entire PMN was not reported, but was treated as 100% by the testing laboratory. 

The sorption to sediments and soils from P-11-0637 is estimated to be very strong. For the 

submitted water accommodated fraction (WAF) toxicity studies, the testing laboratories 

measured the PMN in the test medium and the tin content (using ICP-MS), but reported their 

endpoints (for example, EC50) based on the nominal WAF loading rates since the analytical 

values were difficult to interpret (per the testing laboratory). The analytical results indicated that 

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many of the higher test solutions were above the water solubility limit. The ecotoxicity studies 

complied with OECD guidelines (OECD 201, 202, 203) for: 1) O2, water hardness values and 

other water quality parameters; 2) species, age, number of organisms per replicate, and biomass 

loading rates; and, 3) replicate and overall variability.

Carp (Cyprinus carpio) were exposed to P-11-0637 in a combined range finding/limit test under 

96-hour static conditions. The testing laboratory used a solvent (acetone) to get their PMN into 

the WAF solutions, so a solvent control was included with the dilution water control. The WAF 

prepared nominal concentrations consisted of 0.1, 1.0, 10, and 100 mg/L. The number of C. 

carpio in the controls and 100 mg/L WAF solution was seven/treatment. The number of C. 

carpio in the 0.1, 1.0, 10 mg/L concentrations was three/treatment. Only ten percent mortality 

was reported in the nominal 100 mg/L WAF treatment. Over the course of the study, water 

temperature ranged from 20 - 22°C, pH ranged from 7.2 - 8.0, and the O2 concentrations ranged 

4.7 - 9.0 mg/L. Since no significant observed adverse effects were observed below or at the 

water solubility limit, EPA will treat P-11-0637 (for fish) as no effects at saturation. This is a 

valid test.

In a 48-hour immobilization test, water fleas (Daphnia magna) (10 daphnia/replicate x 2 

replicates) were exposed to P-11-0637 under static conditions with a combined range 

finding/limit test similar to the one described above. In the nominal 100 mg/L WAF treatment, 

all organisms became immobilized, while no immobilization occurred in the lower nominal test 

concentrations. The testing laboratory conducted two further WAF tests with either nominal 

concentrations of 10, 18, 32, 56, and 100 mg/L or nominal concentrations of 1.8, 3.2, 5.6, 10, 18, 

and 32 mg/L. In all three tests, a solvent control and a dilution water control was included. 

Immobility was only observed at concentrations with un-dissolved test material. The initial tin 

concentrations in these solutions indicated that the PMN was well above the water solubility 

limit. Over the course of the two studies, water temperature ranged from 20.1 - 21.5°C, pH 

ranged from 7.7 - 8.1, and O2 concentrations ranged from 8.0 - 9.2 mg/L. Since no significant 

observed adverse effects were observed below or at the water solubility limit, EPA will treat 

P-11-0637 (for aquatic invertebrates) as no effects at saturation. This is a valid test.

In a 72-hour algal toxicity test for growth rate and biomass, an initial cell concentration of 1E+4 

cells/ml (6 replicates/control and 3 replicates/test concentration) of green algae 

(Pseudokirchneriella subcapitata) was exposed to P-11-0637 under static conditions with two 

range finding tests and one definitive test. For the first range finding test, the WAF prepared 

nominal concentrations consisted of 0.1, 1.0, 10, and 100 mg/L (plus a solvent control). For the 

second range finding test, the WAF prepared nominal concentrations consisted of 0.001, 0.01, 

and 0.1 mg/L (plus a solvent control and a dilution water control). For the definitive WAF, the 

nominal concentrations were 0.065, 0.14, 0.3, 0.65, 1.4, 3, 6.5, 14, and 30 mg/L (plus a solvent 

control). In the first range finding test, 90% algal inhibition was observed in the nominal 100 

mg/L test solution. In the second test, algal growth was not adversely affected by nominal test 

concentrations of 0.001 and 0.01 mg/L. In the definitive test, adverse effects were only observed 

at nominal concentrations that had been analytically measured above the water solubility limit. 

Adverse effects to algae were not observed at concentrations at and below the water solubility 

limit of P-11-0637 (<0.06 mg/L). The test occurred with continuous light (60 to 135 ìE/m2/s) 

and continuous agitation. The temperature ranged from 23 - 24°C. The pH ranged from 6.7 –

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9.4. The hardness of the dilution water was 24 mg CaCO3/L. Cell growth was measured by 

direct microscopic cell enumeration. Since no significant observed adverse effects were 

observed below or at the water solubility limit, EPA will treat P-11-0637 (for algae) as no effects 

at saturation. This is a valid test.

The three submitted aquatic ecotoxicity studies are considered valid. For comparative purposes, 

the chronic and acute concern concentrations for P-11-0637, based on ECOSAR (v. 1.00a) 

predictions, are no effects at saturation. Based on the submitted toxicity test results, the chronic 

and acute concern concentrations for P-11-0637 are no effects at saturation.

Ecotox Study Reviewer: J. Gallagher 28 September 2011

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

*

SARs organotin compounds

SAR Class organotin-insoluble

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

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A-002 

Initial Review Engineering Report 

for PMN P-11-637 

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INITIAL REVIEW ENGINEERING REPORT

P-11-0637

Focus Ready Draft 09/22/2011

ENGINEER: Austin \ BCS

PV (kg/yr): 30000 Import only 

Revision Notes/Assessment Overview:

SUBMITTER: Evonik Goldschmidt Corporation (submitter)

USE: Catalyst for polyurethane foam. Analog P-05-0510 has this same use.

OTHER USES: Analog P-99-1251 is used as a catalyst for electrostatic powder coating spray systems.

MSDS: Yes LABEL: No

Gen Eqpt: PVC gloves, chemical resistant goggles or safety glasses with side shields.

Respirator: in case of formation of aerosols or vapors, an organic vapor cartridge respirator may be used if 

ventilation is not adequate.

Health Effects: Eyes, Inhalation, Ingestion: no harmful effects have been reported. // Skin: causes irritation, may be 

harmful upon contact with skin. //

TLV/PEL: - none established

CRSS: (9/22/2011):

Chemical Name: Tin, C16-18 and C18-unsatd. fatty acids castor-oil fatty acids complexes

S-H2O: 0.000001 g/L @ 

VP: 1.0E-6 torr @ 

MW: 698 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: Solid (est.) Mfg: NK - Imported

Proc/Form: Solution, 90% PMN material diluted to 0.5% PMN material in formulation End Use: Solid, PMN 

material entrained in polymer matrix or destroyed. The structure drawn is representative. The MW and MF above 

are for C18 unsatd. fatty acid and ricinoleic acid. Castor oil fatty acid typically consists of 86-92% ricinoleic acid, 

2-6% linoleic acid, 3-6% palmitic acid, 1-2% stearic acid, and 0-8.5% oleic acid (Organic Coating Technology Vol. 

I, page 48; H.F. Payne/John Wiley & Sons, Inc.). Submitted data: the submitted MSDS is for 70-90% PMN 

material. Estimated data: negligible vapor pressure (salt) and negligible water solubility (tin salt). The structure as 

drawn is 17% tin.

Consumer Use: No

SAT (concerns): (9/23/2011):

Related Cases and Misc SAT Info:

Ecotox Analogs: P-05-510, P-99-1251.

Migration to groundwater: Negligible

PBT rating: P1 B1 T1

Health: 2, Dermal, Inhalation

Eco: 1, No releases to Water

OCCUPATIONAL EXPOSURE RATING: 1D

NOTES & KEY ASSUMPTIONS:

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Generated by the 06/07/2005 version of ChemSTEER. This PMN is imported directly to the end user. Therefore, 

mfg and proc are not assessed. // The PMN contains an element of concern, tin // Note SAT concern for dermal and 

inhalation with not releases to water required and migration to gw = negl. Therefore, this IRER only assesses 

incineration releases. Inhalation exposure is not assesses (VP < 0.001 torr; PMN not handled as a solid). Dermal 

exposures are assessed. // For USE: This IRER assesses equipment and container cleaning to uncertain media and 

additional releases to incineration based on submitter estimates. Dermal exposure is assessed during unloading and 

pouring of liquid foam. // Same submitter, same-use past cases P05-0510 and same submitter similar use past case 

P11-0140 were referenced for consistency. // Both past cases are non-volatile solids (consistent with this IRER). 

P05-0510 is imported in solution and assesses dermal exposure but not inhalation exposure (consistent with this 

IRER). P11-0140 is imported as a solid and both dermal and inhalation exposure are assessed. // Both past cases 

assess equipment and container cleaning to uncertain media (consistent with this IRER). This IRER also assesses 

additional releases based on submitter information.

POLLUTION PREVENTION CONSIDERATIONS:

No Pollution Prevention information provided by the submitter.

P2 REC:

EXPOSURE-BASED REVIEW: No (0 criteria met)

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P-11-0637

USE: Polyurethane Foam Catalyst

Number of Sites/Location: 1 submitter site(s) 

unknown sites 

Basis: Per submission, 10 customers sites, 250 days/yr, PMN imported in 25 kg pails, 220 kg drums, or 1000 kg totes and used 

as a liquid at 90% and formulated to 0.5%. CS calculates a use rate of 12 kg/site-day. CEB assumes drums for the import 

container.

Process Description: PMN (90%, liquid) is imported in either 25 kg pails, 220 kg drums, or 1000 kg totes ---> transferred to 

mixing head with other raw materials ----> pour into open ventilated container (PMN 0.5% liquid) to form polyurethane foam 

solid ---> PMN entrained in solid (submission, CRSS)

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. Note SAT concerns for dermal and inhalation with no releases to water required and migration 

to gw = negl. Therefore, this IRER only assesses releases to incineration.

Incineration

Output 2: 1.6E-1 kg/site-day over 16 day/yr from 10 sites or 2.6E+1 kg/yr

to: off-site incineration (submission)

from: Unloading Liquid Raw Material from Drums

basis: User-Defined Loss Rate Model. The submission estimates 0.16 kg/day are released to off-site incineration 

from leakage during unloading.

Water or Incineration or Landfill

High End: 5.6E+0 kg/site-day over 16 day/yr from 10 sites or 9.0E+2 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission does not address container 

cleaning residuals. CEB assesses these releases to uncertain media using the standard model loss fraction.

Water or Incineration or Landfill

Conservative: 1.2E-1 kg/site-day over 250 day/yr from 10 sites or 3.0E+2 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from a Mixing Tank

basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. The submission does not address 

equipment cleaning residuals. CEB assesses these releases to uncertain media using the standard model loss 

fraction.

Incineration

Output 2: 3.0E-2 kg/site-day over 1 day/yr from 10 sites or 3.0E-1 kg/yr

to: off-site incineration (submission)

from: Losses from Meter Calibration

basis: User-Defined Loss Rate Model. The submission estimates 0.03 kg/day of PMN released to off-site 

incineration from losses during meter calibration. The submission estimates that this release will occur 1 day/yr.

RELEASE TOTAL

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1200 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 600

Basis: The submission estimates a total of 60 workers/site. As conservative, CEB assess a workers to PMN as a 

liquid at 90% (unloading) and 0.5% (pouring foam).

Dermal:

Exposure to Liquid 

High End: 1.6E+3 mg/day over 250 days/yr

Number of workers (all sites) with Dermal exposure: 600

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Liquid 

High End: 4.3E+1 mg/day over 250 days/yr

Number of workers (all sites) with Dermal exposure: 600

Basis: Pouring Liquid Polyurethane Foam; EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.

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A-003 

Initial Review Exposure Report 

for PMN P-11-637 

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Exposure Report

PMN Number: P-11-0637 

11/1/2011 9:21:23 AM

Assessor: Kwon/BC

Ratings

Non-Occupational: Environmental:

Drop Criteria: EAB Drop

Criteria Reasoning: No water releases assessed. Other 

releases below the threshold. 

Exposure Based Assessment:

Exposure-Based (Non-Occupational): 

Exposure-Based (Environmental): 

Exposure Parameter Exposure-Based Persistent/Bioaccum Exposure Value

Surface DW:

 Fish Ingestion:

Ground DW:

Inhalation:

Water Releases:

Total Releases:

Consumer Exposure:

Recommended Fate Tests:

Consumer Use expected? N

Consumer Use remarks: 

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Scenario Comment Sites Location

1. Scenario -- Medium: (Engineering) ; USE: Polyurethane Foam Cata 10 , 

 2. Release -- Medium: Water or Incineration or Landfill (EnginUSE: Polyurethane Foam Cata 10 

 3. Release -- Medium: Water or Incineration or Landfill (EnginUSE: Polyurethane Foam Cata 10 

 4. Release -- Medium: Incineration (Engineering) ; USE: Polyurethane Foam Cata 10 

 5. Release -- Medium: Incineration (Engineering) ; USE: Polyurethane Foam Cata 10 

**Environmental Release Information for Those Releases Which Went to the Model (Release Identifier 

Number)

1

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