UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF 

PREVENTION, PESTICIDES

AND

TOXIC SUBSTANCES

MEMORANDUM

SUBJECT: Risk Assessment and Science Support Branch: Final Draft of Dietary ExposureFood(Residue Chemistry) Science Chapter For 1,4-Bis(bromoacetoxy)-2-butene. PC

Code 03605, Case 3030, Barcode D251933.

FROM: Robert Quick, Chemist

Risk Assessment and Science Support Branch

Antimicrobials Division(7510C)

TO: Norm Cook, Chief

Risk Assessment and Science Support Branch

Antimicrobials Division(7510C)

Attached please find the following documents for the final draft dietary exposure-food(residue chemistry)

science chapter for 1,4 Bis(bromoacetoxy)-2-butene:

1. Draft bibliography chapter (Norm Cook, Allen Vaughan, Najm Shamim)

2. Draft science chapter (Norm Cook, Allen Vaughan, Najm Shamim)

This is the final draft of these documents and concurrence and sign-off is required.
HUMAN HEALTH SCIENCE CHAPTER OF

BIS (BROMOACETOXY)-2-BUTENE

EXECUTIVE SUMMARY

The major use of bis (bromoacetoxy)-2-butene is as a slimicide in the manufacture of paper. The registrant has a

use on the label for the preservation of water-based coatings. However, the registrant does not presently market

the chemical for this use. It is the Agency understanding that the registrant intends to keep this use on the label. 

Bis (bromoacetoxy)-2-butene(BBAB) is used as a slimicide in the manufacture of paper and paperboard products

that contact food. This use results in a potential dietary exposure of this chemical to humans. The registrant

submitted a migration study for this chemical to the Food & Drug Administration in the 1960's. This migration

study does not reflect the use of simulating solvents that are recommended in the present FDA Guidelines.

Consequently, the EPA has used a worst case calculation for estimating the level of BBAB that may migrate from

BBAB-treated paper into food through contact with the treated paper. 
 HUMAN HEALTH ASSESSMENT OF THE CHEMICAL

 BIS (BROMOACETOXY)-2-BUTENE

 Human Health Assessment

1. Exposure and Risk Assessment

a. Dietary Exposure and Risk Assessment

Bis (bromoacetoxy)-2-butene has a food use from its use in the manufacture of paper and paperboard that

contact food. FDA has approved this use and the Regulation is codified 21 CFR 176.300 Slimacides. The

Regulation states that the quantity added is not to exceed the amount necessary to accomplish the intended

effect. The registered Slimacide V-10 label permits the application rate of 0.15-0.30 lb. of product(0.24 lb.

active) per ton of paper produced. If all of the bis (bromoacetoxy)-2-butene were to be concentrated in the

paper, the paper would contain 120 ppm of bis (bromoacetoxy)-2-butene.

 

 Bis (bromoacetoxy)-2-butene also has a use for the preservation of water based coatings on the Busan

1210/Slimacide V-10 labels. The use of BBAB in paint is a treated article use as defined under 40 CFR

152.25(a) and is exempt from registration under FIFRA. The EPA considers that there is no dietary

exposure from this use.

 

 i. Incidental Residues in Food From Treated Paper.

Worst Case Calculation for Residues in Food.

The worst case calculation for migration of BBAB residues from treated paper to food assumes that 100% of

the BBAB paper additive migrates to food. The FDA guidelines entitled, "RECOMMENDATIONS FOR

CHEMISTRY DATA FOR INDIRECT FOOD ADDITIVE PETITIONS " were used as guidance for this

calculation. EPA has decided to use the FDA GUIDELINES for this calculation because the submitted data

are over 30 years old and do not follow present FDA guidance, thus making the data unreliable.

 

The assumption was made that the basis weight of a treated paper is 50 pounds/3000 square feet 

or 50 milligrams/square inch. This is the example used in the FDA guidance document. (Note: Papers with

various weight bases will be treated with the BBAB additive.)
Using this assumption, the maximum weight of BBAB per unit area of paper is:

Given: The label allows 0.30 lbs. of 80% product per ton of paper(or 0.24 lbs. of active). 

This is equivalent to 120 ppm BBAB in the paper. Then:

120 x 10!6g(120) ppm/g of paper x 50 mg/in2 = 0.006 mg BBAB/in2. 

 

If all of the BBAB additive in the paper migrates into food and 10 g of food is in contact with 1 square inch of 

paper (FDA usual assumption), then the maximum concentration of BBAB residue would be 0.600 ppm or

600 ppb. 

0.00600 mg BBAB/10 g food = 0.600 ppm.

The estimated daily intake of BBAB for an individual would be as follows:

The FDA guidance “RECOMMENDATIONS FOR CHEMISTRY DATA FOR INDIRECT FOOD

ADDITIVE PETITIONS”, Appendix IV, Table I lists the consumption factor for uncoated paper as 0.1.

Then:

3 Kg food/person/day(FDA assumption) x 0.600ppm x .1 = 0.18 mg BBAB 

intake/person/day. 

 

 Estimate of Residue in Food Based on Submitted Data.

The data submitted to the FDA to support the BBAB use in the manufacture of paper and paperboard that

contacts food is a study that was conducted in 1960 entitled,"Migration of Vineland V-10 Germicide Into

Food Simulating Solvent". In that study, various types of paper were manufactured using different dosage rates

of BBAB in the manufacturing process. The paper types included wax bakery tissue, freezewrap, steak

interleaving paper, bubble gum box and specialty food board. The study was modeled after FDA data

requirements at the time the study was conducted. The study design and food simulating solvents are not the

same as those recommended in the present FDA recommendations.

The present FDA recommendations assume 10 g of food contact each square inch of surface area. The

present FDA guidance document also recommends that a migration study be conducted using either a

particular type of packaging or with the use of a migration cell. For this study, the petitioner did not use 10 ml

of simulating food solvent for extraction purposes. Instead, 2 ml of food solvent contacted each square inch of

paper in this study. Adjusting for volume, 10 ml of food solvent would contain 20% of the BBAB migrant

concentration that 2 ml of food simulating solvent would contain. Furthermore, the BBAB application rate in

the paper manufacture in this study was lower than that now registered for use. Hence, the residue levels

extracted into the food simulating solvents have been adjusted for application rate in the EPA calculations.

 
Therefore, the concentration of BBAB additive in the food simulating solvents was adjusted for the application

rates now registered for use in the paper manufacture and further adjusted for the 2 ml/square inch food

solvent used in the study.

The analytical method used to generate the residue data in this 1960 study was a colorimetric method. In this

method, the BBAB is hydrolyzed with sodium hydroxide to yield bromide. The bromide ion is then converted

to bromate with hypochlorite solution. The bromate is quantitatively reacted with sodium bromide to yield

bromine which is then reacted with rosaniline to produce a red color. The intensity of the color is proportional

to the amount of bromate. The absorbance is measured at 570 millimicrons with a photometer.

 

The concentration of BBAB in the food contacting the steak interleaving paper is 0.32 ppm. This paper had

the highest residue in the 1960 study submitted to the FDA. The concentration of BBAB in the daily diet from

the use of BBAB in paper manufacture is 0.032 ppm.

The estimated daily intake of BBAB, assuming no other dietary sources of BBAB is 0.1 mg. This assumes a

daily intake of 3 kg of food/person/day.

 

Note: Treated paperboard was also used in this study. For a paperboard product, the basis weight of the

paperboard would be much higher, e.g. 300 mg/in2. This would result in a much higher concentration of

BBAB/square inch in the paperboard manufacture. However, the experimental data from this study showed

no extraction of BBAB from the paperboard product. Therefore, the treated steak interleaving paper data

were used for this RED because it provided a worst case situation.

 

Because the study does not follow the FDA recommendations for conducting this type of study and

because of the calculation adjustments made to the data from this 1960 study, it is recommended

that the worst case calculation be used for dietary risk assessment rather than the 1960 study. The

paper and paperboard manufacturing use for BBAB appear to be the only use for BBAB with a

dietary impact.

The worst case calculation for estimated daily intake of BBAB/person is 0.18 mg.

 
 REFERENCE

1. MIGRATION OF VINELAND V-10 GERMICIDE INTO FOOD SIMULATING SOLVENTS.

Microbiological And Biochemical Center Syracuse University Research Corporation.March 3,1960. Revised

April 1963.