Furniture Flame Retardancy Partnership: 

Environmental Profiles of Chemical Flame-Retardant 

Alternatives for Low-Density Polyurethane Foam 

Volume 2 

Chemical Hazard Reviews 

September 2005
1

2

3

4

5

TABLE OF CONTENTS

Page

Introduction .................................................................. i

Flame Retardant Alternatives: Proprietary I: Organic phosphate ester . . . . . . . . . . . . . . . . . 1 -1

Flame Retardant Alternatives: Proprietary J: Aryl phosphate . . . . . . . . . . . . . . . . . . . . . . . . 1 -1

Flame Retardant Alternatives: Proprietary K: Aryl phosphate . . . . . . . . . . . . . . . . . . . . . . . . 1 -1

Flame Retardant Alternatives: Proprietary L: Aryl phosphate . . . . . . . . . . . . . . . . . . . . . . . . 1 -1

Flame Retardant Alternatives: Triphenyl Phosphate ................................ 1-1

Flame Retardant Alternatives: Tribromoneopentyl Alcohol .......................... 2-1

Flame Retardant Alternatives: Tris(1,3-dichloro-2-propyl) Phosphate .................. 3-1

Flame Retardant Alternatives: Proprietary A: Chloroalkyl phosphate (1) ................ 4-1

Flame Retardant Alternatives: Proprietary B: Aryl phosphate ......................... 5-1

Flame Retardant Alternatives: Proprietary C: Chloroalkyl phosphate (2) ................ 6-1

Flame Retardant Alternatives: Proprietary D: Reactive brominated flame retardant ........ 7-1

Flame Retardant Alternatives: Proprietary E: Tetrabromophthalate diol diester ........... 8-1

Flame Retardant Alternatives: Proprietary F: Halogenated aryl ester ................... 9-1

Flame Retardant Alternatives: Proprietary G: Triaryl phosphate, isopropylated .......... 10-1

Flame Retardant Alternatives: Proprietary H: Halogenated aryl ester .................. 1-1

i 
LIST OF TABLES 

Page 

1-1 Summary of available acute fish toxicity studies for triphenyl phosphate 

(115-86-6) .......................................................... 1-27

1-2 Summary of available acute invertebrate toxicity studies on triphenyl phosphate

(115-86-6) .......................................................... 1-36

1-3 Summary of available algal toxicity studies for triphenyl phosphate ............. 1-41

1-4 Summary of available chronic fish toxicity studies for triphenyl phosphate

(115-86-6) .......................................................... 1-46

3-1 Summary of available acute fish toxicity studies for tris(1,3-dichloro-2-propyl)

phosphate [TDCPP] (CASRN: 13674-87-8) ................................ 3-30

3-2 Summary of available acute invertebrate toxicity studies for tris(1,3-dichloro-2-

propyl)phosphate [TDCPP] (CASRN: 13674-87-8) .......................... 3-35

3-3 Summary of available algal toxicity studies for tris(1,3-dichloro-2-propyl)

phosphate [TDCPP] (CASRN: 13674-87-8) ................................ 3-38

4-1 Summary of available acute fish toxicity studies for Proprietary A .............. 4-30

4-2 Summary of available acute invertebrate toxicity studies for Proprietary A ........ 4-35

4-3 Summary of available algal toxicity studies for Proprietary A .................. 4-38

13-1 Composition data (%) for selected t-butylated aryl phosphate products ........... 13-4

ii 
Introduction 

This volume contains detailed hazard reviews of available information for each of the chemicals 

in the 14 flame-retardant formulations evaluated through the Furniture Flame Retardancy 

Partnership. 

These detailed hazard reviews are the basis for the summary assessments in section 4 of volume 

I. The summary assessments were in turn used as the basis for summary table 4.1, which 

provides top-level information on all of the alternatives. 

The goal of the Furniture Flame Retardancy Partnership is to enable informed decision making 

in the process of selecting alternatives to pentaBDE. Production of pentaBDE ceased at the end 

of 2004. The industry is now adopting alternative flame retardants to meet performance 

requirements. Given the large quantities of flame retardants used in foam and furniture 

manufacture, the potential for adverse effects to health and the environment should be addressed. 

EPA developed this flame-retardant alternatives evaluation through stakeholder participation. 

The information in this volume represents the first phase of data collection. The data were 

collected in a manner consistent with the HPV Chemical Challenge Program guidance on 

searching for existing chemical information and data 

(http://www.epa.gov/chemrtk/srchguid.htm). This information was collected and data were 

evaluated for adequacy following HPV data adequacy guidelines 

(http://www.epa.gov/chemrtk/datadfin.htm). The evaluation protocol differed from the HPV 

program in that EPA reviewed the experimental studies and developed the summaries. In the 

HPV Program, EPA and the public participate in the review of the robust summaries developed 

by HPV Challenge Program sponsors. The purpose of data collection in this Partnership was to 

identify data gaps, not determine data needs. 

EPA used EPA’s New Chemicals Program criteria to interpret the data contained in the detailed 

hazard reviews and identify potential hazard concerns in volume 1 for the purposes of informing 

decision making. When measured data were not available, estimates for chemicals were 

determined when possible to identify areas with a potentially high hazard concern. EPA also 

identified potentially low and moderate hazard concerns. 

The information presented in this volume will provide an appropriate starting point for 

longer-term efforts to fully characterize hazard, exposure and risk issues associated with 

flame-retardant alternatives. 

iii 
Flame Retardant Alternatives

Triphenyl Phosphate

Hazard Review

1-1
Triphenyl Phosphate: 

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal T

Inhalation * 

Eye irritation T

Dermal irritation T

Skin sensitization T

Subchronic Toxicity 

28-Day oral * 

90-Day oral * 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal * 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

* 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects 

Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental T

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

T

Neurotoxicity 

screening battery 

(adult) 

T

Developmental 

neurotoxicity 

Additional Y

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity T

Genotoxicity 

Gene mutation in vitro T

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other T

1-2
Triphenyl Phosphate: 

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

T

Oxidation/reduction 

Melting point T

Boiling point T

Vapor pressure T

Odor T

Oxidation/reduction 

chemical 

incompatibility 

Flammability T

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption T

Viscosity 

Density/relative 

density/bulk density 

T

Dissociation constant in 

water 

Y

Henry’s Law constant T

Environmental Fate 

Bioconcentration 

Fish T

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish * 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water T

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis * 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

T

Soil biodegradation w/ 

product identification 

T

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

T

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 T

Daphnia acute EC50 T

Mysid shrimp acute * 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

T

Fish chronic NOAEL, T

LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Sediment organisms * 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

1-3
Chemical Identity 

Triphenyl phosphate 

CAS 115-86-6 

MF C18H15O4P 

MW 326.29 

SMILES c1ccccc1OP(=O)(Oc2ccccc2)Oc3ccccc3 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401). 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Several acute oral lethality studies were available in a variety of species: rats, mice, rabbits, 

guinea pigs, and hens. These studies were from the older (pre 1980) literature, and do not fully 

conform to OPPTS or OECD guidelines, but together may be adequate to support the evaluation 

of acute oral toxicity. The toxic potency of TPP tended to be somewhat lower when it was 

administered in aqueous vehicle (usually as a suspension) than when administered in oil. Deaths 

generally did not occur following administration in aqueous vehicle ([LD50 >5,000-20,000 

mg/kg), and were seen at relatively high doses (LD50 = 10,800 mg/kg) from administration in 

oil. Two of the better studies in the preferred species (rat), one using an aqueous vehicle and the 

other using an oil vehicle, and one each in mice and rabbits using an aqueous vehicle, are 

summarized below as the critical studies. 

Critical Studies: 

Type: Acute oral limit test 

Species, strain, sex, number: Rat, Wistar, 5 male and 5 female 

Dose: 20,000 mg/kg 

Purity: Not reported, Monsanto commercial TPP 

Vehicle: Water: 25% aqueous “solution” 

Method: Similar to limit test, but higher dose; 24-hour fasting period prior to dosing; 14-day 

post-dosing observation period; observations limited to mortality and necropsy 

Results: No deaths, therefore LD50 >20,000 mg/kg. Necropsy revealed sporadic visceral 

hemorrhages. 

Reference: Food and Drug Research Labs, 1976 

1-4
Type: Acute oral LD50 

Species, strain, sex, number: Rat, Sprague-Dawley, male and female, number not specified 

Dose: Up to 15,800 mg/kg 

Purity: GC-verified, but not specifically reported 

Vehicle: Corn oil 

Observation period: 14 days post dosing 

Method: LD50 calculated according to DeBeer (1945); not specified whether fed or fasted at 

time of dosing; 14-day post-exposure observation period; mortality only 

Results: LD50 = 10,800 mg/kg; actual mortality data not reported 

Reference: Johannsen et al., 1977 

Type: Acute oral limit test 

Species, strain, sex, number: Mouse, strain not specified, male and female, 5 total/dose 

Doses: 2,500 and 5,000 mg/kg 

Purity: Not specified 

Vehicle: Emulsion in aqueous gum acacia 

Method: Similar to limit test; not specified whether fed or fasted at time of dosing; 8-day 

observation period; observations limited to mortality and overt signs 

Results: No deaths at either dose; therefore, LD50 >5,000 mg/kg; slight stupor 

Reference: Ciba-Geigy Ltd., 1954 

Type: Acute oral limit test 

Species, strain, sex, number: Rabbit, strain and sex not specified, 1/dose 

Purity: Technical grade TPP 

Doses: 3,000 and 5,000 mg/kg 

Vehicle: Suspended in aqueous gum acacia 

Method: Preliminary limit test, observation was for “several days”, observations limited to 

clinical signs and mortality 

Results: Neither rabbit died, indicating LD >5,000 mg/kg; both had diarrhea 

Reference: Dow Biochemical Research, 1934 

Additional Studies and Information: 

Other studies that were of lesser quality or were reported in less detail are generally consistent 

with the above studies (Houghton EF & Company, no date; Kettering Lab, 1945; Smith et al., 

1932; Sutton et al., 1960). 

Specific organ toxicity was generally not observed in the studies that include gross pathological 

examinations. Some signs possibly indicative of neurotoxicity (lassitude incoordination, 

tremors, or weakness) were observed in a few studies (Ciba-Geigy Ltd. 1954; Kettering Lab, 

1945; Smith et al., 1932). It has been suggested that at the very high doses employed in these 

acute toxicity studies, even small amounts of impurities could be responsible for the apparent 

neurotoxicity, which has not been seen with purified TPP (see section on neurological effects), 

or that the signs may have been secondary to other effects. 

1-5
Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available studies predate the preferred study guidelines, and lack details including purity and 

discussion of necropsy results, but together indicate a low order of toxicity (LD50>7,900-10,000 

mg/kg), consistent with the acute oral studies. 

Type: Acute dermal toxicity 

Species, strain, sex, number: Rabbit, albino, sex not specified, 10 

Dose: 10,000 mg/kg 

Purity: No data, commercial product provided by Monsanto, white flakes 

Vehicle: Not reported, but the concurrent acute oral study used water 

Method: U.S. Federal Hazardous Substances Act Regulations study guideline16 CFR 1500.40; 5 

rabbits tested with intact skin and 5 with abraded skin; 14-day observation period 

Results: Mortality after 14 days 0/5 intact, 0/5 abraded. Therefore, LD50 >10,000 mg/kg. 

Reference: Food and Drug Research Labs, 1976 

Type: Acute dermal toxicity 

Species, strain, sex, number: Rabbit, New Zealand albino, sex and number not specified 

Dose: Highest dose = 7,900 mg/kg 

Purity: No data, prepared from pure phenol 

Vehicle: None (“undiluted”) 

Method: Intact skin, occlusive dressing, test material washed off after 24 hours, 14-day 

observation period. Necropsy. 

Results: No deaths; therefore, LD50 >7,900 mg/kg; necropsy results not discussed. 

Reference: Johanssen et al., 1977 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint, unless 

data regarding particle size in the TPP powder study are provided. 

Basis for Conclusion: 

The available studies on TPP predate the preferred guidelines, but the study using TPP powder 

(Food and Drug Research Labs, 1976) was reported to be conducted according to a guideline that 

was relevant at the time. The duration was shorter than currently recommended and the 

1-6
concentration was much higher, but no signs of toxicity and no deaths were observed. Analysis 

of particle size, however, was not mentioned, so it is not known whether the size was respirable. 

Necropsies apparently were not performed. The other available study, on TPP vapor (Sutton et 

al., 1960), was conducted at an exposure level lower than recommended for a limit test, the 

observation period was inadequate, and it appears that the chamber was a closed chamber, which 

is not according to guideline. 

Type: Acute inhalation toxicity 

Species, strain, sex, number: Rat, Wistar, 5 males and 5 females 

Doses: 200 mg/L (nominal); administered as a powder; particle size not reported 

Purity: No data, commercial product provided by Monsanto, white flakes 

Vehicle: None 

Duration: 1 hour 

Method: 16 CFR 1500.3; 300 mL chamber with air flow of 5 L/minute. Observation period = 

14 days. Observed daily for signs of toxicity and for mortality. 

Results: Mortality after 14 days 0/5 males, 0/5 females; no overt signs of toxicity 

Reference: Food and Drug Research Labs, 1976 

Type: Acute inhalation toxicity 

Species, strain, sex, number: Mouse, Carworth Farms CF 1, male 

Doses, duration, number: 363 mg/m3

 (6 hours exposure, 5 mice) and 757 mg/m3 (2 and 4 hours 

exposure, 7 mice/duration) 

Purity: Practical Grade Eastman 

Vehicle: None 

Method: The mice were exposed to TPP vapor in a battery jar following generation of the vapor 

by flowing preheated air through molten TPP at 175-180°C. Observation period = 24 hours. 

The mice were observed for signs of cholinergic toxicity and blood cholinesterase was measured 

at termination. 

Results: No overt signs of toxicity; cholinesterase determinations not considered valid because 

controls did not appear to have been sham exposed. 

Reference: Sutton et al., 1960 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Two reasonably adequate studies report similar results in rabbits: mild reversible irritation 

primarily of the conjunctiva. The studies are summarized below. 

Type: Acute eye irritation 

1-7
Species, strain, sex, number: Rabbit, albino, sex not specified; 9 

Doses: 100 mg 

Purity: No data, commercial product provided by Monsanto, white flakes 

Vehicle: Not reported 

Method: Patterned after U.S. Federal Hazardous Substances Act Regulations study guideline 

16 CFR 1500.42, except 6 rabbits–eyes not washed after instillation of TPP, 3 rabbits–eyes 

washed 4 seconds following instillation of TPP; eyes examined at 24, 48, and 72 hours, and 7 

days after instillation of TPP. 

Results: Mild conjunctival effects (slight redness 6/6, slight discharge 4/6) at 24 hours in the 

eyes that were not washed out, which cleared by 72 hours; no effects in eyes that had been 

washed out (incidence 0/3). 

Reference: Food and Drug Research Labs, 1976 

Type: Acute eye irritation 

Species, strain, sex, number: Rabbit, New Zealand, 3 males and 3 females 

Doses: 100 mg 

Purity: No data, commercial product provided by Monsanto, white flakes 

Vehicle: None 

Method: Patterned after U.S. Federal Hazardous Substances Labeling Act Section 191.12 

(February 1965). Eyes of 3 (of the 6) rabbits were washed out 30 seconds following instillation 

of TPP; eyes examined at 1, 24, 48, and 72 hours and 6 days after TPP instillation. 

Results: Mild conjunctival effects (slight redness 6/6) at 24 hours in all exposed eyes, which 

cleared in all but 1 (unwashed) eye by 72 hours; and in that eye by 6 days. Slight corneal 

opacity was seen in one unwashed eye at 24 hours, which cleared by 48 hours. 

Reference: Ciba-Geigy Pharmaceuticals Division, 1983a 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Two reasonably adequate studies, patterned after guidelines in effect at the time, provide similar 

results, indicating that TPP was not a skin irritant in rabbits. Additional studies provide support. 

The studies are summarized below. 

Critical Studies: 

Type: Acute dermal irritation 

Species, strain, sex, number: Rabbit, albino, sex not specified, 6 

Doses: 500 mg 

Purity: No data, commercial product provided by Monsanto, white flakes 

1-8
Vehicle: Not reported, but acute oral study used water 

Method: Patterned after U.S. Federal Hazardous Substances Act Regulations study guideline 

16 CFR 1500.41; shaved back, each rabbit tested on intact and abraded skin, semiocclusive 

dressing removed after 24 hours, observations at 24 and 72 hours. 

Results: No erythema or edema on intact or abraded skin in any of the 6 rabbits. 

Reference: Food and Drug Research Labs, 1976 

Type: Acute dermal irritation 

Species, strain, sex, number: Rabbit, New Zealand, 3 males and 3 females 

Doses: 1.0 mL of suspension of 10,000 mg/20 mL = 500 mg 

Purity: No data, white flakes 

Vehicle: 50% aqueous solution of polyethylene glycol 

Method: U.S. Federal Hazardous Substances Labeling Act Section 191.12 (February 1965); 

shaved back, each rabbit tested on intact and abraded skin, occlusive dressing removed after 

24 hours, observations at 24 and 72 hours. 

Results: No erythema or edema on intact or abraded skin in any of the 6 rabbits. 

Reference: Ciba-Geigy Pharmaceuticals Division, 1983b 

Additional Studies: 

Other studies, reported in less detail, also reported no effects in rabbits from dermal exposure on 

intact skin to the dry powdered TPP, and only slight dryness during repeated application as a 

saturated solution in ethanol (13 times in 16 days) (Dow Biochemical Research, 1933). 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential skin sensitization study with negative results in guinea pigs was submitted. These 

data allow this endpoint to be adequately characterized. 

No experimental studies of skin sensitization in animals were located in the published literature. 

A few human cases of TPP allergic dermatitis have been reported. An example is a case of 

allergy to TPP from cellulose acetate eyeglass frames that contained TPP as an additive (Carlsen 

et al., 1986). Patch testing of dermatological patients, however, has not generally implicated this 

chemical as a sensitizer. For example, of 343 patients tested because of suspected sensitivity to 

plastics and glues components, none reacted to TPP (Tarvainen, 1995). In a study of 23,192 

patents with eczema who were patch tested with cellulose acetate film containing 7-10% TPP 

and 4-5 % phthalic acid, positive reactions were observed in only 15 (0.065%) (Hjorth 1964). 

1-9
SUBCHRONIC TOXICITY 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

Conclusion: 

The available subchronic oral toxicity data were judged inadequate to meet the endpoint, but an 

existing unpublished Food and Drug Administration (FDA) study, if provided, could address this 

data gap. 

Basis for Conclusion: 

A single 35-day study in rats (Sutton et al., 1960) provides limited relevant information. The 

study was not adequate to characterize this endpoint because of the small number of rats in each 

dose group, testing of only one sex, lack of clinical chemistry and histopathology data, and lack 

of detailed reporting. A set of concurrent approximately 120-day studies performed by FDA 

investigated general toxicity, reproductive and developmental toxicity, neurotoxicity, and 

immunotoxicity (Hinton et al., 1987, 1996; Sobotka et al., 1986; Welsh et al., 1987). The 

general toxicity study, however, was not published, and the associated studies do not report 

adequate information on the general toxicity of this chemical. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

The only relevant available study is a 35-day repeated oral study that does not satisfy the 

guideline. A summary of the study is as follows: 

Type: 35-Day repeated oral 

Species, strain, sex, number: Rat, Holtzman, male, 5/dose 

Doses: 0, 0.1, and 0.5% in the diet (the 0.1% group received 5% for the first 3 days, but refused 

to eat, and therefore was switched to a lower dietary concentration) 

Purity: Practical Grade Eastman Organic, purity not specified 

Vehicle: None; added to diet 

Exposure period, frequency: 35 days, daily 

Post Exposure Period: 2 weeks 

Method: Two rats/group killed at end of 35 days; 3 rats/group observed for 2 week recovery 

period; body weight, hematology (hemoglobin, cell volume, red and white cell count, and 

differential), necropsy with organ weights. 

Results: Slight depression in body weight gain in high dose group at day 35, but not after 2­

week recovery period. Slight but statistically significant increase (Student’s t test) in mean 

relative liver weight in high dose group–not specified whether all 5 rats/group were included in 

organ weight determinations. No gross abnormalities seen at necropsy. No statistically 

significant differences in hematological values. 

Reference: Sutton et al., 1960 

1-10
• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

The only $90 day subchronic studies of TPP toxicity were specialized studies of reproductive, 

developmental, neurological, and immunological endpoints in the rat conducted by the FDA 

(Hinton et al., 1987; Sobotka et al., 1986; Welsh et al., 1987). These studies provide only 

limited information on other systemic toxicities, and therefore do not satisfy the guideline. 

• In the reproductive and developmental toxicity study in the rat, males and females were 

fed TPP at dietary levels up to 1% for 91 days prior to mating, continuing through 

mating, and the females were continued on the diet until day 20 of gestation. This study 

reported no differences in behavior or gross pathology of the treated dams, a slight but 

significant decrease on day 0 of gestation in the body weight of the dams fed the 1% diets 

(690 mg/kg/day), a slight but significant increase in food consumption primarily at 0.5 

and 0.75% in the diet(not dose-related), and a non-significant decrease in body weight 

gain (minus the gravid uterus) at day 20 of gestation in dams fed $0.5% (341 mg/kg/day) 

(Welsh et al., 1987). 

• The neurological study, in which male rats were fed up to 1% TPP in the diet for 4 

months, provided no evidence of neurobehavioral effects, but also noted a decrease in 

body weight gain. The NOAEL and LOAEL for this effect were 0.25% in the diet (161 

mg/kg/day) and 0.50% in the diet (345 mg/kg/day) (Sobotka et al., 1986). 

• In the immunotoxicity study, in which male and female rats were fed up to 1% TPP in the 

diet for 4 months, the only effects seen were a decrease in body weight gain at 1.0% 

(approximately 700 mg/kg/day) in the diet, and non-dose related increases in the relative 

percentages of "-globulins in treated females and $-globulins in treated males, which 

were interpreted as a possible sign of liver activity of uncertain toxicological significance 

(Hinton et al., 1987). Because of the lack of dose-response, these findings may not be 

indicative of a chemical effect. The NOAEL and LOAEL for decreased body weight 

gain were 0.75% in the diet (517 mg/kg/day) and 1.0% in the diet (700 mg/kg/day). 

Details of these studies are provided in the appropriate sections. These studies are not adequate 

to fulfill the requirements of the 90-day subchronic oral toxicity guideline. 

An associated, concurrent FDA subchronic toxicity study, mentioned in the other FDA reports 

(Hinton et al., 1987, 1996; Sobotka et al., 1986; Welsh et al., 1987), has not been published. The 

study has been requested for review. 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No studies of this type were located. 

1-11
Subchronic Dermal Toxicity (21/28-day or 90-day) 

Conclusion: 

The available subchronic dermal toxicity data were judged inadequate to meet the endpoint, 

unless further information is provided for the available 21-day study. 

Basis for Conclusion: 

The only study available for this endpoint, a 21-day dermal toxicity study, has a design similar to 

that of the OPPTS guideline, but the reporting of the study is deficient. Only the text portion of 

the results was available, but the tables summarizing the data were omitted, as were data 

regarding the outcome of tests of purity of the TPP. Because it is the only relevant study, more 

detailed reporting of information from this study is needed if it is to be used to satisfy the 

endpoint. The study is summarized below. 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD 

Guideline 410) 

Type: 21-Day dermal toxicity 

Species, strain, sex, number: Rabbit, New Zealand white, 10 males and 10 females/dose 

Doses: 0 (vehicle control), 100, and 1,000 mg/kg body weight 

Purity: Determined at start and end of test but results not reported 

Vehicle: Absolute ethanol 

Exposure period, frequency: 21-23 days, 5 days/week 

Post Exposure Period: none 

Method: Similar to 870.3200 but functional observational battery omitted, number of 

tissues/organs examined histopathologically was not as extensive, and histopathological 

examinations were performed on all control and high dose rabbits and “as required” on low dose 

rabbits. The skin of 5 males and 5 females in each dose group was abraded twice a week; the 

skin of the other 5 males and 5 females in each group was not. No dressing was used after 

application of the vehicle or test substance, but collars were used to prevent contact with the 

material, and the excess was removed after 6 hours. 

Results: No treatment-related changes were seen in clinical signs, mortality, body weight, 

hematology, gross or histopathology, or routine clinical chemistry. Low-dose females had 

decreased mean thyroid/body weight ratio and increased mean kidney weight. Dose-related 

depressions in serum, erythrocyte, and brain cholinesterase were observed. The tables 

summarizing the actual data were omitted from the report. 

Reference: Bio/Dynamics, Inc., 1970 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

No studies of this type were located. 

1-12
Subchronic Inhalation Toxicity: 90-Day Inhalation Toxicity (OPPTS Harmonized 

Guideline 870.3465; OECD Guideline 413) 

Conclusion: 

No available subchronic inhalation toxicity data. 

Basis for Conclusion: 

No repeated-exposure inhalation toxicity studies were located. 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A study of reproduction and development in rats exposed for 91 days prior to mating, and 

continuing through mating until day 20 of gestation (Welsh et al., 1987) partially characterizes 

this endpoint, but is not fully adequate. No other data relevant to this endpoint were located. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

A study of reproduction and development in rats exposed for 91 days prior to mating, and 

continuing through mating until day 20 of gestation (Welsh et al., 1987) partially satisfies the 

reproductive screening component of this guideline, but is not fully adequate, primarily because 

it lacks histopathology of male and female reproductive organs. The study is summarized below 

under Developmental Toxicity. Findings relevant to reproduction were that there were no 

significant differences in number of corpora lutea, implants, implantation efficiency, viable 

fetuses, and number of early or late deaths at dietary levels as high as 1.0% TPP (690 

mg/kg/day). Because both sexes were treated, and there were no effects on litter size (as 

measured by number of viable fetuses), the study provides some evidence that fertility is not 

affected by TPP in the rat. 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No studies with this specific design were available. 

1-13
• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

No studies with this specific design (two-generation reproduction) were available. 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A study of reproduction and development in rats exposed for 91 days prior to mating, and 

continuing through mating until day 20 of gestation (Welsh et al., 1987) appears to fulfill the 

requirements of the Prenatal Developmental Toxicity Study guideline, and is adequate to 

characterize developmental toxicity. Details of this study are as follows: 

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

Type: Reproductive screen, prenatal developmental toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 40 males and 40 females/dose 

Purity: Commercial grade, Aldrich, 98% pure 

Doses: 0, 0.25, 0.50, 0.75, or 1.00% in the diet (0, 166, 341, 516, and 690 mg/kg/day based on 

food consumption and body weight of pregnant females) 

Exposure duration, frequency: Starting at 4 weeks post weaning, males and females exposed 

for 91 days prior to mating, continuing through mating and, for the dams, through gestation day 

20; daily 

Method: Body weight, food consumption, clinical signs, and necropsy of dams; uterine contents 

at day 20 of gestation; fetal weight, crown-rump length, external, visceral, and skeletal 

abnormalities; extensive statistical analyses. 

Results: The body weights of the females fed the 1.0 % diets were slightly but significantly 

lower than those of controls on day 0 of gestation. During gestation, the dams that consumed 

TPP in the diet generally consumed slightly more food than controls; but their body weight gains 

during gestation and the adjusted body weight gain (excluding gravid uterus) at day 20 were not 

significantly different from controls. No differences in behavior or gross pathology were 

reported. Fertility (pregnancy rate) was higher in the treated females than in controls, but control 

fertility was relatively low. No significant differences between treated and control groups were 

seen for numbers of corpora lutea, implants, implantation efficiency, viable fetuses, or 

resorptions (total or early or late deaths). Male and female fetuses from the treated groups 

tended to weigh more than control fetuses, but the differences were minimal (<10% increase in 

fetal weight), not dose-related, and significant (p<0.05) only for the males in the 0.50 and 1.00% 

groups (but not the 0.75% group). Significant, slight increases in visceral variations (moderate 

1-14
hydroureter, enlarged ureter proximal to kidney) were seen in litters of all treated groups, but the 

increases were not dose-related, and the controls had a relatively high incidence of moderate 

hydroureter. Given the lack of dose response and uncertain biological significance of the slight 

fetal changes in this study, the highest dose level (1.0% TPP in the diet, 690 mg/kg/day) may be 

a NOAEL for fetotoxicity. TPP did not produce teratogenic effects in this study. This study 

suggests a minimal LOAEL for decreased body weight gain of 1.0% TPP in the diet (690 

mg/kg/day) for the dams. Although the highest dose in the study (1.0% in the diet, 690 

mg/kg/day) is not as high as a limit dose of 1,000 mg/kg/day, it did produce slight body weight 

depression in the dams, and in the two associated studies (on neurotoxicity and immunotoxicity), 

produced more striking depressions in body weight gain in male and female rats at the same 

dietary level, particularly in the first few weeks on test, and in the absence of a depression in 

food consumption. A higher dietary level (5%) was tested in a 35-day study in rats and resulted 

in food refusal (Sutton et al., 1960). Thus testing with dietary levels substantially higher than 

1.0% TPP may not be advisable. 

Reference: Welsh et al., 1987 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No studies with this specific design were available. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

A study of reproduction and developmental toxicity is available (Welsh et al., 1987); the 

developmental toxicity portion of the study is consistent with a full prenatal developmental 

toxicity study, and was discussed previously under that category. 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

Basis for Conclusion: 

No relevant studies were located. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

No studies of this type were located. 

1-15
• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 

870.4300; OECD Guideline 453) 

No studies of this type were located. 

CARCINOGENICITY 

Conclusion: 

The available carcinogenicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available study, a strain A mouse pulmonary adenoma study, is not a suitable type of study 

to characterize the potential carcinogenicity of chemicals for chronic oral exposure. The study is 

summarized below. 

Type: Strain A mouse pulmonary adenoma 

Species, strain, sex, number: Mouse, strain A/St, 20 males/dose 

Identity: Uncertain—reported as triphenyl phosphate, and also as phosphorous acid, triphenyl 

ester (which is triphenyl phosphite, a different chemical) 

Purity: Not reported, Aldrich, reagent grade 

Doses: 0 (vehicle control), 20, 40, and 80 mg/kg 

Vehicle: Tricaprylin 

Route: Intraperitoneal injection 

Exposure duration, frequency: 3 injections/week; for 20 mg/kg–18 injections (6 weeks), for 

40 mg/kg–3 injections (1 week), for 80 mg/kg–1 injection (the experimental design was to give 

24 injections, but fewer injections were given for the “more toxic chemicals”. 

Method: 24 weeks after the first injection, the mice were killed and the lungs were examined for 

surface nodules; a few of the nodules were examined histologically to confirm that they were 

adenomas; positive controls received urethan; Student t test. 

Results: Survival at 24 weeks was 46/50 for controls, 18/20 at 20 mg/kg (18 injections), 3/20 at 

40 mg/kg (3 injections), and 12/20 at 80 mg/kg (1 injection). No increase in the number of 

pulmonary adenomas/mouse was seen. 

Reference: Theiss et al., 1977 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

No studies of this type were located. 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 

870.4300; OECD Guideline 453) 

No studies of this type were located. 

1-16
NEUROTOXICITY 

Conclusion: 

The available neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Some components of this endpoint—delayed neurotoxicity and neurotoxicity screening (in adult 

animals)—are satisfied by the existing data, but no study of developmental neurotoxicity has 

been conducted. This endpoint could be addressed in combination with the reproductive toxicity 

endpoint. TPP gave negative results in several acute oral delayed neurotoxicity studies in the 

hen as well as a subcutaneous study in the cat, and also in a subchronic oral neurotoxicity 

screening study in the rat. Further information is provided in the following subsections. 

Delayed Neurotoxicity 

Conclusion: 

The available delayed neurotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available acute delayed neurotoxicity studies in the hen and in the cat (another sensitive 

species), summarized below, give no evidence of acute cholinergic toxicity or of delayed 

neurotoxicity. These studies, performed prior to the existence of the guidelines, do not entirely 

conform to the guidelines, and lack detail including, in the hen studies, purity of the TPP sample. 

Nevertheless, together they indicate a lack of delayed neurotoxicity for TPP. Neurotoxic 

esterase (NTE) assays were not conducted in these studies. In a separate unpublished study, 

summarized in a review of structure-activity studies, an NTE assay in brain homogenate 

following a single oral dose of 700 mg/kg TPP (>99% purity) to the hen (Johnson, 1975) gave 

negative results. This dose is lower than those used in the critical studies of delayed 

neurotoxicity in hens but given the lack of signs and histopathological evidence for delayed 

neurotoxicity, additional NTE assays do not appear necessary. 

Because of the lack of signs or histopathology indicating delayed neurotoxicity in the acute 

studies, 28-day studies are not required. In addition, structure-activity studies indicate that TPP 

would not be expected to cause delayed neurotoxicity (Johnson, 1975). 

1-17
• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS

Harmonized Guideline 870.6100; OECD Guideline 418, 419)

1-18
Critical Studies 

Type: Delayed neurotoxicity 

Species, strain, sex, number: Hen, White Leghorn, 9 for TPP 

Purity: Not reported, prepared from pure phenol 

Doses: 5,000 mg/kg twice daily; thus, 10,000 mg/kg/day 

Vehicle: Corn oil 

Route: Gavage 

Exposure duration, frequency: Twice a day on days 1-3 and 21-23 of the study (6 days of 

dosing); interval between doses not reported. 

Method: Dosing twice daily for 6 days was needed because of the low toxicity of TPP (no 

lethality at 5 mg/kg, the largest feasible dose). Hens were fasted for 16 hours before dosing 

(further explanation not provided). Daily observations for deaths and signs of neurotoxicity 

were conducted from day 1 through day 42, at which time hens were necropsied. Brain, sciatic 

nerve, and spinal cord were examined histopathologically. Tricresyl phosphate (mixed o-, m-, 

p-) was tested concurrently. 

Results: For TPP, no overt signs of neurotoxicity and no histopathological effects in the nervous 

tissues were observed (0/9). Although the hens were weighed at 0, 21, and 42 days, no body 

weight results were presented. Tricresyl phosphate, a known delayed neurotoxicant, resulted in 

overt signs and histopathological evidence of delayed neurotoxicity in 6/6. Details of the 

histopathological data were not provided. 

Reference: Johannsen et al., 1977 

Type: Delayed neurotoxicity 

Species, strain, sex, number: Hen, Rhode Island Red x Light Sussex, 2/dose 

Purity: Not reported, white flakes 

Doses: 2,000, 3,000, 5,000, 8,000, or 12,500 mg/kg 

Vehicle: Arachis oil 

Route: Gavage 

Exposure duration, frequency: Single dose 

Method: Hens were not fasted. Post-dosing observation period was 21 days. Daily observations 

for deaths and signs of neurotoxicity. Necropsy but not histopathology. 

Results: No overt signs of neurotoxicity. Necropsy results not mentioned. 

Reference: Ciba-Geigy Pharmaceuticals Division, 1980 

Type: Delayed neurotoxicity 

Species, strain, sex, number: Hen, Rhode Island Red x Light Sussex, 2 

Purity: Not reported, white flakes 

Doses: 12,000 mg/kg 

Vehicle: Arachis oil 

Route: Gavage 

Exposure duration, frequency: Single dose 

Method: Hens were not fasted. Post-dosing observation period was 21 days. Daily observations 

for deaths and signs of neurotoxicity. Necropsy but not histopathology. 

1-19
Results: No overt signs of neurotoxicity, and no abnormalities at necropsy. 

Reference: Ciba-Geigy Pharmaceuticals Division, 1981a 

Type: Delayed neurotoxicity 

Species, strain, sex, number: Cat, not further specified, 5 

Purity: Zone-refined triphenyl phosphate, purity 99.99% 

Doses, number: 400 mg/kg in propylene glycol (2 cats), 700 mg/kg in corn oil (2 cats), and 

1,000 mg/kg in corn oil (1 cat) 

Vehicle: Propylene glycol (1 cat), corn oil (2 cats) 

Route: Subcutaneous injection 

Exposure duration, frequency: Single dose 

Method: Post-dosing observation period was 4 months. Daily observations for deaths, general 

behavior, eating, and drinking. Weighed at intervals. Whole blood, plasma, and erythrocyte 

cholinesterase determined for cats given 700 mg/kg of TPP and their controls. Complete 

necropsies on cats given 700 mg/kg. Brain stem and spinal cord examined histopathologically in 

all cats. 

Results: All except one on the lowest dose lost weight (due to cessation of eating); the other on 

the lowest dose lost weight initially and then regained it. These cats had no overt signs of 

toxicity and were not necropsied or examined further. At 700 mg/kg, the cats stopped eating 

during the first week after injection, became moribund, and were euthanized. Cholinesterase 

activities in these cats were similar to those in the controls. No evidence of axonal degeneration, 

demyelination, or other adverse change was seen in sections from 11 levels of the nervous 

system extending from cerebral cortex to peripheral nerve in the 700 mg/kg group. The cat that 

received 1,000 mg/kg became anorexic 1 week after injection and was necropsied at 3 weeks 

after injection. Sections of this cat’s brain stem and spinal cord did not reveal any abnormalities. 

Actual data were not presented. 

Reference: Wills et al., 1979 

Additional studies 

Additional oral studies at lower doses in the chicken [one at 500 mg/kg in the hen (Aldridge and 

Barnes, 1961), and another at 1,000 mg/kg in the cockerel (young rooster) (Hine et al., 1956)] 

also reported no signs of delayed neurotoxicity. Two delayed neurotoxicity studies that reported 

some axonal lesions in the spinal cord of hens following 5,000 mg/kg/day of TPP (unknown 

purity) for 5 days are considered invalid because the doses were so high that most of the hens 

died or were killed in extremis during the study, severe weight loss occurred in the hens, and the 

same mild axonal lesions were seen in both controls and treated hens (Ciba-Geigy 

Pharmaceuticals Division, 1982), or because no controls were used (Ciba-Geigy Pharmaceuticals 

Division, 1981a). 

1-20
Neurotoxicity (Adult) 

Conclusion: 

The available adult neurotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available study of neurobehavioral effects following subchronic feeding of TPP to rats 

(Sobotka et al., 1986) predates the guidelines, but fulfills some of the criteria for a Neurotoxicity 

Screening Battery. It includes some of the observations from the functional observational 

battery, and a few additional measures (rearing activity, rotorod, negative geotaxis). It does not 

include neurohistopathological examinations, and testing was conducted in only one sex rather 

than both sexes as recommended. In other reasonably well-conducted studies of this chemical, 

however, there is no evidence that one sex is significantly more sensitive than the other or that 

the chemical is neurotoxic. Structure-activity studies do not indicate neurotoxic potential for 

TPP (Johnson, 1975). Therefore, the existing study, in context with the other information 

regarding TPP toxicity, may be adequate to satisfy the adult neurotoxicity component of the 

neurotoxicity endpoint. The study description follows: 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Type: Neurotoxicity screening, oral 

Species, strain, sex, number: Rat, Sprague-Dawley, 10 males/dose 

Doses: 0, 0.25, 0.50, 0.75, or 1.0% in the diet; 0, 161, 345, 517, or 711 mg/kg/day 

Vehicle: None 

Purity: 98% (commercial grade, Aldrich); homogeneity and stability of TPP diets confirmed by 

gas chromatography 

Exposure duration, frequency: 4 months, daily 

Method: Observations included food consumption, body weight, in-cage observation for overt 

signs, open-field exploratory behavior (motor activity and rearing), rotorod, forelimb grip 

strength, and negative geotaxis. Extensive statistical analysis. 

Results: Overt signs and test results for neurobehavioral endpoints were not statistically 

significantly different in treated versus control rats. Body weight gain, but not food 

consumption, was statistically and toxicologically significantly lower (>10% decrease) in the 

0.5, 0.75, and 1.0% dietary groups than in controls, and there was a negative dose-related linear 

trend for weight gain. Thus, no LOAEL for neurotoxicity was demonstrated. The NOAEL and 

LOAEL for effects on body weight gain were 0.25% in the diet (161 mg/kg/day) and 0.50% in 

the diet (345 mg/kg/day). 

Reference: Sobotka et al., 1986 

Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS Harmonized 

Guideline 870.6300) 

1-21
Conclusion: 

No available developmental neurotoxicity data. 

Basis for Conclusion: 

No studies of this type were located. 

Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) 

• OPPTS Harmonized Guideline 870.6500 

• Peripheral Nerve Function (rodent) 

• OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred) 

• OPPTS Harmonized Guideline 870.6855 

These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, 

or because of structural similarity of the substance to neurotoxicants that affect these endpoints. 

These studies may be combined with other toxicity studies. 

Conclusion: These endpoints do not appear to be applicable to TPP. 

Basis for Conclusion: Although there are no studies addressing these endpoints, there are no 

reliable data for TPP, and no structure-activity considerations, that indicate a need for these 

follow-up studies. 

IMMUNOTOXICITY 

Conclusion: 

The available immunotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The potential immunotoxicity of TPP was examined in a subchronic dietary study in rats (Hinton 

et al., 1987, reprinted as Hinton et al., 1996) which predates the guideline for immunotoxicity. 

This study appears to satisfy most of the requirements of the guideline, although no positive 

control was included, and the anti-sheep red blood cell assay is not the currently recommended 

assay. The study, which was negative for immunotoxicity, is summarized below. 

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

Type: Immunotoxicity, oral subchronic 

1-22
Species, strain, sex, number: Rat, Sprague-Dawley, 10 males and 10 females/dose 

Doses: 0. 0.25, 0.50, 0.75, or 1.00% TPP in the diet; approximately equivalent (based on 

measured dosages in the related studies by Sobotka et al., 1986 and Welsh et al., 1987) to 0, 163, 

343, 517, and 700 mg/kg/day. No positive control. 

Purity: Aldich, 98% pure, confirmed by gas chromatography, stable under the experimental 

conditions of this study 

Exposure duration, frequency: 120 days, daily 

Method: Observations included body weight, food consumption, midterm and terminal sacrifice, 

necropsy, spleen and thymus weights, histopathology of spleen, thymus, and mesenteric lymph 

nodes, immunohistochemical evaluation of B- and T-lymphocyte regions in these tissues, total 

serum protein and electrophoretic analysis of serum proteins, humoral response to sheep red 

blood cells (relative antibody titers by hemolytic assay). Extensive statistical analysis. 

Results: The only statistically significant effects were a decreased growth rate (>10% difference 

in body weight) during the first 4 weeks in males and females of the 1.00% dietary group, and 

non-dose related increases in the relative percentages of "-globulins in treated females and $­

globulins in treated males, which were interpreted by the study authors as a possible sign of liver 

activity but of uncertain toxicological significance. Because of the lack of dose-response, these 

findings may not be indicative of a chemical effect. This study did not demonstrate a LOAEL 

for immunotoxicity. The NOAEL and LOAEL for decreased body weight gain were 0.75% in 

the diet (517 mg/kg/day) and 1.0% in the diet (700 mg/kg/day). 

Reference: Hinton et al., 1987 

GENOTOXICITY 

Conclusion: The available genotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Three studies of gene mutation in vitro report negative results. These studies, two in bacteria 

and one in mammalian cells, predate the relevant guidelines, but were conducted in a manner 

similar to them, and together, characterize the gene mutation in vitro endpoint. Studies of 

chromosomal aberrations were not available, however, and are needed for adequate 

characterization of the genotoxicity endpoint. 

Gene Mutation in Vitro: 

• Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; 

OECD Guideline 471) 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA98, TA100, TA1535, TA1537 

Metabolic activation: Tested with and without Aroclor 1254-induced liver S9 from male Syrian 

hamsters (10% in S9 mix for all strains and also 50% for TA1535 and TA1537), and male 

Sprague-Dawley rats (10% for all strains) 

1-23
Concentrations: 0, 100, 333, 1,000, 3,333, and 10,000 :g/plate. Solvent was 95% ethanol. A 

precipitate was present in the plates at $3,333 ug/plate; tested in triplicate; plus replicate 

Purity: 98% + 

Method: Preincubation (20 minutes) and plate incorporation (48 hours) at 37°C. Positive 

controls were 2-aminoanthracene for all strains with S9, and sodium azide (TA1535 and TA100), 

9-aminoacridine (TA1537), and 4-nitro-o-phenylenediamine (TA98) in the absence of S9. 

Results: No increase over negative control at any concentration; no apparent cytotoxicity; the 

two highest concentrations tested may have exceeded solubility limits. 

Reference: Zeiger et al., 1987 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA98, TA100, TA1535, TA1537, TA1538 

Metabolic activation: Tested with and without Aroclor 1254-induced liver S9 from male 

Sprague-Dawley rats 

Concentrations: 0, 10, 100, 500, and 1,000 :g/plate. Solvent was DMSO; tested in triplicate; 

plus replicate 

Purity: No data, white crystals 

Method: Plate incorporation, 48 hour incubation at 37°C; apparently only one plate for each 

concentration. Negative and positive controls. 

Results: No increase in revertants over negative control at any concentration; highest 

concentration reportedly produced some evidence of physiological effect. Saccharomyces 

cerivisiae D4 also tested. 

Reference: Litton Bionetics, Inc., 1978a 

• In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

Type: Mammalian Cell Gene Mutation Test: Forward Mutation 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: Tested with and without Aroclor 1254-induced liver S9 from male 

Sprague-Dawley rats 

Concentrations: 0, 3.13 (only without S9), 6.26, 12.5, 25, 50, and 75 (only with S9) :g/plate. 

Solvent was DMSO; tested in triplicate; plus replicate 

Purity: No data, white crystals 

Method: Plate incorporation, 48 hour incubation at 37°C. Negative and positive controls 

(ethylmethanesulfonate without S9; dimethylnitrosamine with S9). 

Results: No increase over negative control at any concentration; highest concentration selected 

during prescreening as a level that reduced growth potential. 

Reference: Litton Bionetics, Inc., 1978b 

Other 

• Mitotic Gene Conversion in Saccharomyces cerevisiae (OPPTS Harmonized 

Guideline 870.5575) 

1-24
Type: Mitotic Gene Conversion 

Species, strain: Saccharomyces cerevisiae D4 

Metabolic activation: Tested with and without Aroclor 1254-induced liver S9 from male 

Sprague-Dawley rats 

Concentrations: 0, 10, 100, 500, and 1,000 :g/plate. Solvent was DMSO 

Purity: No data, white crystals 

Method: Plate incorporation, 3- to 5-day incubation at 30°C (without S9) or 37°C (with S9). 

Negative and positive controls 

Results: No increase over negative control at any concentration; highest concentration 

reportedly produced some evidence of physiological effect. 

Reference: Litton Bionetics, Inc. 1978a 

No studies were available on the genotoxicity of triphenyl phosphate in the following types of 

types of tests: 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

1-25
Ecotoxicity 

Acute Toxicity to Fish (OPPTS Harmonized Guideline 850.1075; OECD Guideline 203) 

Conclusion: 

The available acute fish toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available acute fish toxicity studies are summarized in Table 1-1. Acute 96-hour toxicity 

studies in freshwater fish species including rainbow trout, fathead minnows, goldfish, bluegill 

sunfish, medaka, channel catfish, and carp and in saltwater species including silverside and 

sheepshead minnow were located. Most of the 96-hour LC50 values reported in the available 

literature are consistent with each other and ranged from 300 to 1,200 :g/L. One study (Dawson 

et al., 1977), however, reported substantially higher LC50 values for TPP (95,000 :g/L in 

silverside and 290,000 :g/L in bluegill). A reason for this discrepancy is not clear. However, 

the data reported by Dawson et al. (1977) were considered unreliable because the reported LC50 

values are approximately 50 to 150 times greater than the solubility limit of TPP (approximately 

2,000 :g/L). Also, the results reported by Dawson et al. (1977) are inconsistent with results 

from multiple other studies. 

Overall, the available acute fish toxicity endpoint appears to be satisfied by the currently existing 

database for the following reasons: 

• Studies are available in both cold- and warm-water freshwater species and in marine 

species; 

• Numerous studies are available that reported similar LC50 values; and 

• Although most of the available studies used static conditions, the results from the only 

study located that used flow-through conditions and analytically confirmed the test 

concentrations are consistent with results from static studies conducted in the same 

species. These data indicate that use of static exposure conditions produces similar 

results as flow-through studies. 

It should be noted, however, that sufficient detail was not included in many of the study reports 

to allow for a comprehensive and independent evaluation of data adequacy, most studies used 

static conditions and did not analytically confirm the test concentrations, and many studies were 

conducted prior to publication of GLP guidelines. 

A summary of the available acute toxicity studies in fish that were located as well as selected 

deficiencies in the studies is presented in Table 1-1. Studies that were either published in a 

foreign language or that were not readily available AND that were not critical to the hazard 

assessment were not retrieved. 

1-26
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Ahrens et al., 1978 

Carp <1,000 

:g/L 

Static Not reported 10 No pH: NR 

Temp: “room” temp. DO: NR Hardness: NR 

Acetone (0.6 mL/L) 

ThGeReprevLCrepLC10

acLC5,0ac

Ciba-Geigy, 1981a 

Rainbow trout 49 mm; 0.94 g 

850 :g/L Static 5 concentrations; 

0.18 to 1,800 

:g/L 

10 No pH: 7.7-8.2 

Temp: 14.5­15.6°C DO: 5-9 mg/L Hardness: 172 

mg/L 

Mixture of octanol (>0.004 mL/L), tween (>0.07 mL/L), and ethylene glycol monomethyl ether (>0.02 mL/L) 

ThOEpuwarepnoincbeeqco

1-27
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Dawson et al., 1977 

Bluegill sunfish 

290,000 :g/L 

Water solubility is approx. 2,000 

:g/L 

Static 5 concentrations, 

125,000 to 560,000 :g/L 

Not reported 

No Dilution water 

was reported to have a pH of 7.6-7.9 and a hardness of 55 mg/L. Target temp. was 23°C for bluegill and 20°C for silverside 

Either distilled water or solvent with (reportedly) relatively low toxicity was used. Concentration of solvent, if used, was not reported. 

Thfrosuwa(aptheun

Silverside 95,000 

:g/L 

Water solubility is approx. 2,000 

:g/L 

Static 5 concentrations, 

75,000 to 560,000 :g/L 

Food and Drug Research Labs, 1979 

Rainbow trout 

760 :g/L Static 5 concentrations, 

180 to 1,800 

:g/L 

10 No pH: 7.2-7.5 

Temp: 12°C±1°C DO: 7.8-10 mg/L Hardness: 42 

mg/L 

Unidentified solvent 

StU.Sowe0.

1-28
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Fathead minnow 

3,800 :g/L 

Water solubility is approx. 2,000 

:g/L 

Static 5 concentrations, 

1,000 to 10,000 :g/L 

10 No pH: 6.8-7.5 

Temp: 20.6±0.6°C DO: 1.3-9.0 mg/L Hardness: 43 mg/L 

Unidentified solvent 

Dicothe low dewaso

Geiger et al., 1986 

Fathead minnow (17 mm; 0.071 g) 

870 :g/L Flowthrough 

(14.4x per day) 

5 concentrations; 180 to 1,150 

:g/L (mean 

measured) 

20 Yes (GLC; 

99.8% recovery) 

pH: 7.8 Temp: 24.5°C DO: 6.4 mg/L Hardness: 45.6 

mg/L Values are averages over the study duration; ranges were not reported 

None used; 1.2 mg/L stock solution in glass wool column 

Fistuwa981924remthe pedewavaoxcovaso

1-29
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Huckins et al., 1991 

Bluegill sunfish (0.5-1 g) 

780 :g/L Static 5 concentrations, 

500 to 10,000 :g/L with 

and without addition of 1 g/L soil and clay 

10 No pH: NR 

Temp: 22°C DO: NR Hardness: NR 

Acetone, unspecified concentration 

TPSedecopH the stu

Industrial Bio Test Labs, Inc., 1972 

Rainbow trout 

Between 100 and 1,000 

:g/L 

Static 4 concentrations; 

100 to 100,000 :g/L 

Not reported 

No pH: 7.3-7.9 

Temp: 12.2°C DO: 2.9-7.9 mg/L Hardness: NR 

Acetone Ve

the weunfrodeindda

Bluegill sunfish 

Between 1000 and 10,000 :g/L 

Water solubility is approx. 2,000 

:g/L 

Static 4 concentrations; 

100 to 100,000 :g/L 

Not reported 

No pH: 7.6-8.2 

Temp: 18.6°C DO: 6.9-7.5 mg/L Hardness: NR 

Acetone 

1-30
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Mayer et al., 1981 EG&G Bionomics, 1978a, b 

Rainbow trout 

400 :g/L Static Not reported 10 No pH: 7.2 

Temp: 12±1°C DO: NR Hardness: 272 

mg/L 

Not reported Da

MunTSanwe

Fathead minnow 

660 :g/L Static 3 concentrations; 

280 to 2200 :g/L 

10 No pH: 6.3-7.5 

Temp: 22±1°C DO: 2.5-8.7 mg/L Hardness: 28­44 mg/L 

Triethylene glycol (up to 7.5 mL) 

DaMunTSanwe

Sheepshead minnow 

Between 320 and 560 :g/L 

Static 5 concentrations; 

56 to 560 :g/L 

10 No pH: 7.9-8.1 

Temp: 20±1°C DO: 3.8-6.3 mg/L Hardness: NR Salinity: 17 parts per thousand 

Acetone Da

MunTSanwe

Mayer and Ellersieck, 1986 

Rainbow trout 

370 :g/L Static Not reported Not 

reported 

Yes pH: 7.4 

Temp: 12°C DO: NR Hardness: 40 mg/L 

Not reported Re

moGerepthasp

1-31
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Channel catfish 

420 :g/L Static Not reported Not 

reported 

Yes pH: 7.5 

Temp: 22°C DO: NR Hardness: 38 mg/L 

Not reported Re

moGerepthasp

Fathead minnow 

1,000 

:g/L 

Static Not reported Not 

reported 

Yes pH: 7.3 

Temp: 22°C DO: NR Hardness: 44 mg/L 

Not reported Re

moGerepthasp

Palawski et al., 1983 

Rainbow trout (0.11 g; 24 mm) 

360 :g/L Static 3 concentrations; 

210, 240, and 290 :g/L 

10 No pH: NR 

Temp: NR DO: NR Hardness: NR 

Not reported TP

stu(1daweon los

:g

fro

1-32
Table 1-1. Summary of available acute fish toxicity studies for triphenyl phosphate (115-86-6)a 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parameters 

Co

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistryb Solvent 

Sasaki et al., 1981 

Goldfish (0.8­2.8 g) Killifish (0.1­0.2 g) 

700 :g/L 

1200 

:g/L 

Static Static 

Not reported Not reported 

7 to 9 7 to 9 

No* *In a parallel study, .70% of TPP was present in water that contained goldfish after 96 hours. 

pH: NR Temp: 25BC 

DO: NR Hardness: NR 

Not reported Ne

are tesReprevSedechhaidecovedisSpat 

Sitthichaikasem., 1978 

Rainbow trout sacfry (0.081 g) Rainbow trout fingerling s (0.75 g) 

389 :g/L 

299 :g/L 

Static Static 

Control and 180­1000 :g/L Control and 180­1000 :g/L 

10 10 

No No 

pH: 7.0-7.2 Temp: 12BC 

DO: 7.3-8.5 ppm Hardness: 40­48 

Acetone Acetone 

Fiexde48

aStudies that were either published in a foreign language or that were not readily AND that were not critical to the hazard assessment were not retriebHardness reported as mg/L CaCO3 

1-33
Acute Toxicity to Freshwater and Marine/Estuary Invertebrates (OPPTS Harmonized 

Guidelines 850.1010 and 850.1035; OECD Guideline 202) 

Conclusion: 

• The available acute freshwater invertebrate toxicity data were judged adequate to meet 

the endpoint. 

• The available acute marine/estuary invertebrate toxicity data were judged inadequate to 

meet the endpoint. 

• Based on the environmental fate of TPP, additional data may be needed on sediment 

dwelling organisms. Currently available studies, although inadequate to meet the 

endpoint in this review, indicate that TPP may be toxic to sediment-dwelling organisms. 

Basis for Conclusion: 

Freshwater Organisms 

The available data are summarized in Table 1-2. Four studies in daphnids were located. All 

studies used static conditions, and none of the available studies analytically confirmed the test 

concentrations. The reported EC50 values were consistent with each other and ranged from 

1,000 to 1,350 :g/L. Sufficient detail was available from three of the four studies located to 

allow for an independent evaluation of data adequacy. Reporting deficiencies were noted in 

those three studies that included lack of identity of concentrations tested, TPP purity, 

concentration of solvent in the test solutions, and water hardness. In the remaining study 

(Ziegenfuss et al., 1986), even basic study design parameters were not reported. Due to these 

reporting deficiencies and on study design deficiencies (lack of analytical confirmation of the 

test concentrations), none of the currently available studies are independently sufficient to be 

used as the basis to satisfy the acute freshwater invertebrate toxicity endpoint. Collectively, 

however, the data appear adequate because the four studies that were located reported a narrow 

range of EC50 values, thus providing confidence in the reported effect levels. 

Studies were also located on the toxicity of sediment-dwelling organisms. Two studies using the 

midge and one study using the scud were located. These studies indicate that sediment-dwelling 

organisms could be particularly sensitive to the toxicity of TPP. EC50 values ranged from 250 

to 1,600 :g/L. All of the studies in sediment-dwelling organisms used static conditions, and 

none of the studies analytically confirmed the test concentrations. Based on the inconsistencies 

in the reported toxicity values and the lack of a study that analytically confirmed the test 

substance concentrations, these data were not judged to be adequate to satisfy the acute toxicity 

endpoint for sediment-dwelling organisms. Based on the environmental fate of TPP, additional 

testing on sediment-dwelling organisms may be needed. 

In addition, a confidential study for acute toxicity to freshwater aquatic invertebrates was 

submitted for which study results were consistent (daphnid 48-hour LC50 = 1.2 mg/L) with 

1-34
those reported in the publicly available literature. The available data were judged adequate to 

meet this endpoint. 

Marine/Estuarine Organisms 

One acute toxicity study in mysid shrimp was located (Table 1-2). The study was a 96-hour 

static study that did not analytically confirm the test concentrations. The dissolved oxygen 

concentration in this study was <60% of saturation after the 96-hour exposure period. The LC50 

from this study was between 180 and 320 :g/L; a discrete LC50 was not calculated. The 

available data in mysid shrimp do not appear to be adequate to satisfy the marine/estuarine 

invertebrate toxicity endpoint because only one publically available study was located, and it 

used static conditions, did not analytically confirm the test concentrations, and dissolved oxygen 

concentration in this study was below values recommended by standard guidelines. Because 

only one study was available, and it of questionable reliability, the marine/estuarine invertebrate 

toxicity endpoint does not appear to be satisfied by existing data. 

1-35
Table 1-2. Summary of available acute invertebrate toxicity studies on triphenyl phosphate (115-86-6) 

Study Reference 

Species Tested 

EC50 or LC50 (:g/L) 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

No. of Organisms/ Conc 

Analytical Monitoring 

Water Chemistry Solvent 

Ciba-Geigy Ltd., 1981b 

Daphnid 48­

hour: 1,350 

Static 800-3,700 :g/L 20 No pH: 8.6 

DO: 7.0-7.2 mg/L Temp: 20±1°C Hardness: NR 

DMF 

Food and Drug Research Labs, 1979 

Daphnid 48­

hour: 1,280 

Static 180-3,200 :g/L 20 No pH: 8.4-8.5 

DO: 7.8-9.4 mg/L Temp: 20±0.5°C Hardness: 232 mg/L 

Acetone 

1-36
Table 1-2. Summary of available acute invertebrate toxicity studies on triphenyl phosphate (115-86-6) 

Study Reference 

Species Tested 

EC50 or LC50 (:g/L) 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

No. of Organisms/ Conc 

Analytical Monitoring 

Water Chemistry Solvent 

Mayer et al., 1981 Analytical Bio Chemistry Labs, 1978 

Daphnid 48­

hour: 1,000 

Static Not reported 10 No pH: 7.7-8.0 

DO: 7.2-8.7 Temp: 19°C Hardness: <250 mg/L 

Ethanol 

Ziegenfuss et al., 1986 

Daphnid 48­

hour: 1,000 

Static Not reported Not reported No pH: NR 

DO: NR Temp: NR Hardness: NR 

Not reported 

Huckins et al., 1991 

Midge 48­

hour: 360 

Static 60-1,000 :g/L 10 No pH: NR 

DO: NR Temp: 22°C Hardness: NR 

Acetone 

Ziegenfuss et al., 1986 Monsanto Env. Science Section, 1982 

Midge 48­

hour: 1,600 

Static 125-2,000 :g/L 10 No pH: 7.6-8.1 

DO: 8.6-9.3 Temp: 21-23°C Hardness: 268­284 mg/L 

Unspecified solvent 

1-37
Table 1-2. Summary of available acute invertebrate toxicity studies on triphenyl phosphate (115-86-6) 

Study Reference 

Species Tested 

EC50 or LC50 (:g/L) 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

No. of Organisms/ Conc 

Analytical Monitoring 

Water Chemistry Solvent 

Huckins et al., 1991 

Scud 96­

hour: 250 

Static 10-560 :g/L Not reported No pH: NR 

DO: NR Temp: 17°C Hardness: NR 

Acetone 

Mayer et al., 1981 EG&G Bionomics. 1978c 

Mysid shrimp 

96­hour: >180 and <320 

Static 56-560 :g/L 10 No pH: 7.8-7.9 

DO: 43%-56% of saturated Temp: 20±1°C Hardness: NR 

Acetone (1 mL) 

Lo and Hsieh, 2000 

Golden apple snail 

72­hour: 38,200 

Static 10-250 :g/L 30 Yes pH: 7.5 

DO: NR Temp: 26°C Hardness: NR 

Not reported 

1-38
Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Conclusion: 

The available algal toxicity data were judged tentatively adequate to meet the endpoint, pending 

the availability of additional information from the studies that were not included in the published 

articles. 

Basis for Conclusion: 

Seventy-two-hour static studies in Selenastrum capricornutum, Scenedesmus subspicatus, 

Chlorella vulgaris (Millington et al., 1988), a 96-hour static study in Selenastrum capricornutum 

(Mayer et al., 1981), and a 22-day study in Ankistrodesmus falcatus were located. These data are 

summarized in Table 1-3. Taken together, these data may be adequate; however, additional 

information is needed from the studies before they can be used as the basis for satisfying the 

algal toxicity endpoint. 

Millington et al. (1988) conducted a series of 72-hour static studies that were designed to 

evaluate the influence of various standard test media (OECD, U.S. EPA, and Bold’s basal) on the 

toxicity of triphenyl phosphate to three algal species, Selenastrum capricornutum, Scenedesmus 

subspicatus, and Chlorella vulgaris. These static studies followed OECD Guideline 201. Five 

concentrations ranging from 0.05 to 5 mg/L were tested in triplicate cultures. The test 

concentrations were not analytically confirmed. The resulting 72-hour NOAEC values ranged 

from 0.1 to 1 mg/L depending on the algal species tested and the test media used. EC50 values 

were not derived, and raw data were not available to allow for an independent calculation of 

EC50 values. Overall, the studies appear to have been adequately conducted. Deficiencies in 

the data included reporting deficiencies (e.g., raw data, water quality values determined during 

the study, and growth of control replicates), lack of analytical confirmation of the test 

concentrations, and lack of EC50 determinations. Provided that the missing study details can be 

obtained and that an EC50 value can be determined, these data appear adequate to satisfy the 

algal toxicity endpoint. 

Mayer et al. (1981) conducted a 96-hour static test in Selenastrum capricornutum. Many details 

from this study were obtained from the unpublished report submitted to EPA (EG&G 

Bionomics, 1978d). Five concentrations that ranged from 0.6 to 10 mg/L were tested. Test 

concentrations were not analytically confirmed. An EC50 of 2 mg/L (95% confidence interval 

of 0.6-4 mg/L) was derived from this study. A clear NOAEC was not established because a 4% 

decrease in cell number and a 15% decrease in chlorophyll-" concentration was observed at the 

lowest concentration of 0.6 mg/L. Although the study appears to have been adequately 

conducted, initial and final cell concentrations of controls or treated cultures were not reported. 

Provided that these study details can be obtained, the 96-hour EC50 reported in this study 

appears to be adequate to satisfy the short-term algal toxicity endpoint. It should be noted that 

the EC50 determined from this study is at the approximate water solubility limit of TPP (2 

mg/L). The lack of a clear NOAEC precludes the use of this study as the sole basis to satisfy the 

1-39
chronic algal toxicity endpoint. However, the low magnitude of the effect observed at 0.6 mg/L 

in this study appears to be consistent with the NOAEC and LOAEC values reported in the other 

algal toxicity studies (Mayer et al., 1981; Wong and Chau, 1984). 

Wong and Chau (1984) reported a 22-day NOAEC of 0.1 mg/L and a LOAEC of 0.5 mg/L based 

on algal growth in Ankistrodesmus falcatus. Sufficient detail was not reported in this study to 

allow for an independent evaluation of data adequacy. Virtually no details on the methods or 

results were reported. The study also reported 4-hour IC50 values based on incorporation of 

radiolabeled CO3 as an indication of primary productivity. These IC50 values ranged from 0.2 to 

0.5 mg/L in Ankistrodesmus falcatus, Scenedesmus quadricauda, and Lake Ontario 

phytoplankton. The 4-hour IC50 values derived from this study were not considered adequate 

for this hazard assessment because TPP concentrations that caused reductions in primary 

productivity after 4 hours of exposure did not affect reproduction or growth during a separate 22­

day study conducted by the same laboratory. The NOAEC and LOAEC values derived from the 

22-day study were considered inadequate to satisfy the chronic algal toxicity endpoint because 

sufficient detail was not available on the study design or results to allow for an independent 

evaluation of study adequacy. However, if data are available to demonstrate that the study was 

adequately conducted, then the data may be sufficient to satisfy the chronic algal toxicity 

endpoint. Further, if concentration-response data are available to allow for a calculation of a 96­

hour EC50, then the data may also be used to support the short-term algal toxicity endpoint. 

Taken together, it appears that sufficient data are available to satisfy the algal toxicity endpoint; 

however, additional information is needed before the currently available data can be considered 

adequate. 

1-40
Table 1-3. Summary of available algal toxicity studies for triphenyl phosphate 

Study Reference 

Species Tested 

EC50, NOAEC, and LOAEC 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

Analytical Monitoring 

Water Chemistry Solvent 

Millington et al., 1988 

Selenastrum capricornutum 

EC50: NR 72-hour NOAEC: 0.1-1 mg/L* 72-hour LOAEC: 0.5-5 mg/L* *A range of NOAEC and LOAEC values is reported because tests were performed using three different test media, and the toxicity of TPP was influenced by the test media used. 

Static 0.05-5 mg/L No pH: NR 

Temp: 22°C DO: NR Hardness: NR 

Acetone (<100 uL/L) 

1-41
Table 1-3. Summary of available algal toxicity studies for triphenyl phosphate 

Study Reference 

Species Tested 

EC50, NOAEC, and LOAEC 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

Analytical Monitoring 

Water Chemistry Solvent 

Millington et al., 1988 

Scenedesmus subspicatus 

72-hour NOAEC: 0.1-1 mg/L* 72-hour LOAEC: 0.5-5 

mg/L. *A range of NOAEC and LOAEC values is reported because tests were performed using three different test media, and the toxicity of TPP was influenced by the test media used. 

Static 0.05-5 mg/L No pH: NR 

Temp: 22°C DO: NR Hardness: NR 

Acetone (<100 uL/L) 

Millington et al., 1988 

Chlorella vulgaris 

72-hour NOAEC: 1 mg/L 72-hour LOAEC: 5 mg/L 

The toxicity of TPP to Chlorella vulgaris was not affected by test medium. 

Static 0.05-5 mg/L No pH: NR 

Temp: 22°C DO: NR Hardness: NR 

Acetone (<100 uL/L) 

1-42
Table 1-3. Summary of available algal toxicity studies for triphenyl phosphate 

Study Reference 

Species Tested 

EC50, NOAEC, and LOAEC 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

Analytical Monitoring 

Water Chemistry Solvent 

Mayer et al., 1981 EG&G Bionomics, 1978d 

Selenastrum capricornutum 

96-hour: 2 mg/L 95% CI: 0.6-4 96-hour LOAEC: 0.6 mg/L 96-hour NOAEC: Not observed 

Static 0.6-10 mg/L No pH: 7.0-8.2 

Temp: 24±1°C DO: NR Hardness: NR 

Acetone: 0.05 

1-43
Table 1-3. Summary of available algal toxicity studies for triphenyl phosphate 

Study Reference 

Species Tested 

EC50, NOAEC, and LOAEC 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

Analytical Monitoring 

Water Chemistry Solvent 

Wong and Chau, 1984 

Ankistrodesmus falcatus 

22-day NOAEC: 0.1 mg/L 22-day LOAEC: 0.5 mg/L 

Static 0.05-5 mg/L No pH: NR 

Temp: NR DO: NR Hardness: NR 

5 :L 

1-44
Chronic Toxicity to Fish (OPPT Harmonized Guideline 850.1400; OECD Guideline 210) 

Conclusion: 

C The currently available data were judged adequate to meet the chronic toxicity endpoint 

for freshwater fish. 

C The currently available data were judged inadequate to meet the chronic toxicity endpoint 

for saltwater fish. 

Basis for Conclusion: 

Freshwater Fish 

A confidential study for chronic toxicity to freshwater fish was submitted. The study results 

indicated a Fish ChV of 0.140 mg/L. These data were judged adequate to meet this endpoint. 

Publicly available data are summarized in Table 1-4. Two chronic studies in fish were located. 

Both studies were published in Mayer et al. (1981). The study in fathead minnows reported a 

NOAEC of 87 :g/L and a LOAEC of 230 :g/L. The study used flow-through conditions and 

analytically confirmed the test concentrations; however, the study is considered invalid due to 

the large variation in measured concentrations (55-170 :g/L at the NOAEC and 140-390 :g/L at 

the LOAEC). The study in rainbow trout is considered to be inadequate because the highest 

concentration tested was 1.4 :g/L, a concentration that did not elicit any effects. Also, the 

measured concentrations were not given. Therefore, validity of the test could not be 

independently evaluated. 

Saltwater Fish 

No chronic toxicity studies in saltwater fish species were located. 

1-45
Table 1-4. Summary of available chronic fish toxicity studies for triphenyl phosphate (115-86-6) 

Study Reference 

Species Tested 

NOAEC/ LOAEC 

Selected Study Design Parameters 

Study Type 

Concentration Range Tested 

No. of Fish/ Conc 

Analytical Monitoring 

Water Chemistry Solvent 

Mayer et al., 1981 

Rainbow trout 

90-day LOAEC: >1.4 :g/L 

Flowthrough (20 L/hour) 

Nominal: 0.22, 0.38, 0.44, 0.64, 0.91, 1.2, and 1.4 :g/L 

Measured concentrations not reported 

NR, but at least 10 based on the number of fish subjected to vertebrae pathology exams. 

Yes (mean measured concentrations were within 62% of nominal) 

pH: 7.2 Temp: 12±1°C DO: NR Hardness: 272 mg/L 

Unidentified solvent at <0.05 mL/L 

Mayer et al., 1981 EG&G Bionomics, 1979 

Fathead minnow 

30-day NOAEC: 87 :g/L 

LOAEC: 230 :g/L 

Flowthrough (20 L/hour) 

Mean measured: 0, 2.8, 12, 36, 87, and 230 :g/L 

60 eggs 40 fry 

Yes pH: 6.8-7.6 

Temp: 25±1°C DO: >75% saturation Hardness: 38-44 mg/L 

TEG, unspecified concentration 

1-46
Chronic Toxicity to Aquatic Invertebrates (OPPTS Harmonized Guidelines 850.1300 and 

850.1350; OECD Guideline 211) 

Conclusion: 

No available chronic toxicity data for freshwater or saltwater invertebrates. 

Basis for Conclusion: 

Freshwater and Saltwater Species

No chronic toxicity studies in freshwater or saltwater invertebrate species were located.

Acute Oral, Acute Dietary, and Reproductive Toxicity in Birds (OPPTS Harmonized 

Guidelines 850.2100, 850.2200, and 850.2300; OECD Guidelines 205 and 206) 

Conclusion: 

No available acute oral, acute dietary, and reproduction toxicity data. 

Basis for Conclusion: 

No toxicity studies in relevant bird species were located. 

Earthworm Toxicity (OPPTS Harmonized Guideline 850.6200) 

Conclusion: 

No available earthworm toxicity data. 

Basis for Conclusion: 

No toxicity studies in earthworms were located. 

1-47
Physical/Chemical Properties 

Triphenyl phosphate 

CAS 115-86-6 

MF C18H15O4P 

MW 326.29 

SMILES c1ccccc1OP(=O)(Oc2ccccc2)Oc3ccccc3 

Physical/Chemical Properties 

Water Solubility (mg/L): 

Conclusion: The available water solubility data are adequate.

Basis for Conclusion: The two best-documented studies, including one that followed an OECDguideline test, report solubilities of 1.9-2.1 ppm. 

Solubility (mg/L) Reference 

Insoluble Budavari, 2001 (The Merck Index); Lewis, 2000 (Sax’s Dangerous Properties of 

Industrial Materials); Lide and Milne, 1995 (CRC Handbook of Data on Common 

Organic Compounds); Lewis, 1997 (Hawley’s Condensed Chemical Dictionary) 

1.90 Saeger et al., 1979 (shake-flask method using Milli-Q purified water); Huckins et al., 

1991; SRC, 2004 (PHYSPROP database) 

2.1±0.1 Ofstad and Sletten, 1985 (OECD Guideline 105 (column-elution) from a mixture at 

25°C) 

1.4-1.6 Howard and Deo, 1979 (in buffered distilled water, pH 4.4-9.5 at 21°C) 

0.2-0.3 Howard and Deo, 1979 (in filtered lake or river water, pH 7.8-8.2 at 21°C) 

0.73 Hollifield, 1979 

0.714 Kuhne et al., 1995 

Log Kow: 

Conclusion: The available log Kow data are adequate.

Basis for Conclusion: A variety of reputable studies report log Kow values in the range of 4.5­

4.7. 

Log Kow Reference 

4.59 SRC, 2004 (PHYSPROP database); Hansch et al., 1995 

3.9 Unpublished data cited in Bengtsson et al., 1986 

4.61 Mayer et al., 1981; Huckins et al., 1991 

1-48
Log Kow Reference 

4.63 Saeger, 1979 (shake-flask method) 

4.67 FMC Industrial Chemical Division, 1979 (shake-flask method) 

4.58 Ciba-Geigy, Ltd., 1982 

4.62 Monsanto Chemical Co., 1982a 

Monsanto Chemical Co., 1982b 

Melting Point: 

Conclusion: The available melting point data are adequate.

Basis for Conclusion: Melting point values within the range of 49-52°C are reported in a variety

of reputable secondary sources. 

Melting Point (°C) Reference 

50 Lewis, 1997 (Hawley’s Condensed Chemical Dictionary); SRC, 2004 (PHYSPROP 

database) 

49-50 Budavari, 2001 (The Merck Index); Lewis, 2000 (Sax’s Dangerous Properties of 

Industrial Materials) 

50.5 Lide and Milne, 1995 (CRC Handbook of Data on Common Organic Compounds) 

50.4 Ciba-Geigy, Ltd., 1982 

50-52 Sigma-Aldrich, 2003-2004 

49.5-50 Dorby and Keller, 1957 

Boiling Point: 

Conclusion: The available boiling point data are adequate. 

Basis for Conclusion: Most sources report reduced-pressure boiling points of 244-245°C at 10 

or 11 torr for triphenyl phosphate. Perry and Green (1984) report a boiling point of 413.5°C at 

760 torr, which is consistent with the boiling point extrapolated using the Clausius-Clapeyron 

Equation and the parameters measured by Dorby and Keller (1957). It has also been reported 

that triphenyl phosphate decomposes at or near its boiling point (Dorby and Keller, 1957). 

Boiling Point (°C/torr) Reference 

245/11 Lewis, 1997 (Hawley’s Condensed Chemical Dictionary); SRC, 2004 

(PHYSPROP database); Budavari, 2001 (The Merck Index); Lewis, 2000 

(Sax’s Dangerous Properties of Industrial Materials); Lide and Milne, 1995 

(CRC Handbook of Data on Common Organic Compounds) 

244/10 Sigma-Aldrich, 2003-2004 

1-49
Boiling Point (°C/torr) Reference 

413.5/760 Perry and Green, 1984 

414/760 

dec. >410 

Dorby and Keller, 1957 (Extrapolated according to the Clausius-Clapeyron 

Equation using experimentally-derived parameters: Log P(torr) = -A/T + C, 

where T is in Kelvin, A= 4253, C=9.07) 

The decomposition temperature was reported in this same paper. 

Vapor Pressure (torr): 

Conclusion: The available vapor pressure data are adequate.

Basis for Conclusion: Results from the Clausius-Clapeyron equation as measured by Dorby and

Keller (1957) are consistent with the vapor pressure data provided in Perry and Green (1984). 

Vapor Pressure (torr/°C) Reference 

6.28x10-6/25 

0.90/193.5 

8.6/249.8 

84.7/322.5 

354/379.2 

SRC, 2004 (PHYSPROP database, extrapolated); Dorby and Keller, 1957 

(Extrapolated according to the Clausius-Clapeyron Equation using 

experimentally-derived parameters Log P (torr) = -A/T + C, where T is in 

Kelvin, A= 4253, C=9.07) 

1/193.5 Lewis, 2000 (Sax’s Dangerous Properties of Industrial Materials) 

1/193.5 

5/230.4 

10/249.8 

20/269.7 

40/290.3 

60/305.2 

100/322.5 

200/349.8 

400/379.2 

760/413.5 

Perry and Green, 1984 

Odor: 

Conclusion: The odor of this compound has been adequately characterized. 

Odor Reference 

Odorless Lewis, 2000 (Sax’s Dangerous Properties of Industrial Materials) 

Slight aromatic odor resembling 

phenol 

Phenol-like odor 

HSDB, 2004 

1-50
Oxidation/Reduction: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: 

Conclusion: The flammability (as the flash point) has been adequately characterized. 

Basis for Conclusion: Similar values are reported in several reputable secondary sources. 

Flash Point Reference 

435°F (223°C) Sigma-Aldrich, 2003-2004 

428°F (220°C) Lewis, 1997 (Hawley’s Condensed Chemical Dictionary) 

428°F (cc) Lewis, 2000 (Sax’s Dangerous Properties of Industrial Materials) 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: 

Conclusion: The UV/VIS absorption of this compound has been adequately characterized. 

Basis for Conclusion: Absorption maxima and coefficients are available for this compound in 

three solvent systems, and are reported in reputable sources. 

Wavelength 

Absorption 

Coefficient Solvent Reference 

268 nm 912 Hexane Lide and Milne, 1995 (CRC Handbook of Data on Common 

Organic Compounds) 

262 nm 1175 Hexane Lide and Milne, 1995 (CRC Handbook of Data on Common 

Organic Compounds) 

256 nm 955 Hexane Lide and Milne, 1995 (CRC Handbook of Data on Common 

Organic Compounds) 

288 nm 7.03x103 

l/mol-cm 

MeOH, 

KOH 

Sadtler Standard Spectra, no date 

No absorption above 320 nm 

237 nm 2.62x104 

l/mol-cm 

MeOH, 

KOH 

Sadtler Standard Spectra, no date 

No absorption above 320 nm 

268.5 nm 2.36x103 

l/mol-cm 

MeOH Sadtler Standard Spectra, no date 

No absorption above 290 nm 

1-51
Wavelength 

Absorption 

Coefficient Solvent Reference 

273.5 nm 2.36x103 

l/mol-cm 

MeOH, 

HCl 

Sadtler Standard Spectra, no date 

No absorption above 290 nm 

218 nm 1.78x104 

l/mol-cm 

MeOH, 

HCl 

Sadtler Standard Spectra, no date 

No absorption above 290 nm 

Viscosity: No data 

Density/Relative Density/Bulk Density: 

Conclusion: The density of this compound has been adequately characterized. 

Basis for Conclusion: Similar values for density and relative density are available for this

material at different temperatures. Bulk density is also reported in a reputable source. 

Density Reference 

1.268 g/cc (60°C) Lewis, 1997 (Hawley’s Condensed Chemical Dictionary) 

Bulk: 10.5 lb/gal Lewis, 1997 (Hawley’s Condensed Chemical Dictionary) 

1.2055 g/cc (50°C) Lide and Milne, 1995 (CRC Handbook of Data on Common Organic 

Compounds) 

Specific gravity, 25°C: 1.2 Cited from Midwest Research Institute, 1979 in Huckins et al., 1991 

Dissociation Constant in Water: 

Conclusion: This endpoint is adequately characterized 

Basis for Conclusion: TPP is not expected to dissociate under environmentally important 

conditions. 

Henry’s Law Constant: 

Conclusion: The Henry’s Law Constant has been adequately characterized for this compound. 

Basis for Conclusion: One measured and one estimated value are reported in the literature, and 

are in reasonable agreement with one another. The estimated value is based on measured vapor 

pressure and water solubility data. 

Henry’s Law Constant Reference 

1.2x10-5 atm-m3/mole Cited from Mayer et al., 1981 in Huckins et al., 1991 

3.31x10-6 atm-m3

/mole SRC, 2004 (PHYSPROP database, estimated from vapor pressure and water 

solubility) 

1-52
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: The bioconcentration of TPP has been adequately measured in rainbow trout, 

goldfish, and killifish. 

Basis for Conclusion: Similar BCFs are reported for rainbow trout in two key 90-day studies 

(Monsanto Chemical Company, 1982c; Mayer, 1981). Other studies (Muir, 1984; Muir et al., 

1980) are available, but exhibit significant scatter in the data for rainbow trout. The data 

reported by this author are based on uptake times of 24 hours or less, and may not represent 

equilibrium conditions. The highest kinetic BCF value reported by this author, 18,960, may be 

irrelevant because it was calculated based on a “slow” rate of elimination of residual 

radioactivity by the fish. According to this study, the fish eliminated 98-99% of the initial load 

of radioactivity (from the uptake of 14C-labeled TPP) in 9 days. The remaining 1-2% was 

eliminated more slowly. Because only the total amount of radioactivity was measured without 

identifying specific radioactive compounds present, it is not certain that the residual radioactivity 

was due to unchanged TPP and not to metabolites. 

Adequate studies are available for goldfish and killifish (Sasaki et al., 1981, 1982). In these two 

studies, the authors measured BCFs under both static and flow-through conditions, with varying 

TPP concentrations, and over differing lengths of time. The authors found that the measured 

BCFs for killifish were largely independent of these parameters. 

Key Design Parameters 

Exp. Range Study T 

Reference Species BCF Type (ppb) Length (°C) Comments 

Monsanto 

Chemical Co, 

1982c 

Rainbow 

Trout 

271 90 days 

Mayer, 1981 Rainbow 132­ Flow­ 0.22, 90 days Elimination half life 

Trout 364 through 1.4 0.54 days 

Muir, 1984 Rainbow 573 Static 3.1­ 1-24 

Trout 931 50.4 hours 

1368 

1-53
Reference Species BCF 

Key Design Parameters 

Comments 

Exp. 

Type 

Range 

(ppb) 

Study 

Length 

T 

(°C) 

Muir et al., 

1980 

Rainbow 

trout 

2,590 

(fast) 

18,960 

(slow) 

Static 50 6 hours 10 River water mixed with 

dechlorinated tap water, 

pH 8.12-8.36. Fish were 

exposed to TPP+water 

for 6 hours then 

transferred to clean 

water. BCF expressed 

as 

k(uptake)/k(elimination). 

k(uptake) = 46.36/hour. 

Elimination rate slows 

down at about 9 days 

with 98-99% eliminated. 

k(fast)=0.0179/hour; 

k(slow)=0.00245/hour. 

Muir, 1984 Fathead 218 Static 0.8­ 1-24 

minnow 561 34.9 hours 

1,743 

Sasaki et al., 

1981 

Killifish 250­

500 

Static 250 

initial 

2-3 days 25 

Sasaki et al., 

1981 

Goldfish 110­

150 

Static 250 

initial 

2-3 days 25 

Sasaki et al., 

1982 

Killifish 189±90 

193±79 

84±32 

Flowthrough 

(all) 

30 

20 

10 

35 days 

32 days 

18 days 

25 BCF is independent of 

concentration, 

continuous (flowthrough) results correlate 

to static results (Sasaki, 

1981). BCF of 

phosphate esters tested 

correlate with Log Kow. 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

1-54
Fish Metabolism: 

Conclusion: The metabolism rate in fish has not been adequately characterized, and the 

metabolites have not been adequately identified. 

Basis for Conclusion: None of the studies summarized here identifies any metabolites. All of 

the studies were designed to monitor the levels of TPP (as either the natural isotope or 14C 

labeled) in fish to document the rates of uptake and elimination. Although these studies provide 

information about the rate of elimination of TPP and/or its carbon-containing metabolites from 

fish, none of these studies adequately describe how TPP is metabolized and what products are 

formed. 

Species Rate Comment References 

Rainbow trout 98-99% eliminated in 9 days 

Rate constant = 0.0179/hour 

Slower elimination after 9 days 

Rate constant = 0.00245/hour 

Muir et al., 1980 

Rainbow trout Elimination half-life is 0.54 days Mayer et al, 1981 

Killifish Elimination half-life 1-2 hours Sasaki et al., 1982 

Killifish Apparent metabolism is much 

faster in killifish than in goldfish. 

Concentration of TPP in 

water decreased in the 

presence of fish. 0% 

applied TPP remains in 

the water after ~72 hours. 

Control (no fish) has no 

change in TPP 

concentration. 

Sasaki et al., 1981 

Goldfish Apparent metabolism is much 

slower than in killifish. 

60-65% applied TPP 

remains in the water after 

100 hours in presence of 

goldfish. 

Sasaki et al., 1981 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in water: 

Conclusion: The available studies do not adequately describe the photolysis behavior of TPP in 

water under normal environmental conditions. However, this endpoint appears to be adequately 

characterized. 

Basis for Conclusion: Since triphenyl phosphate does not absorb light at wavelengths above 290 

nm, direct photolysis in sunlight is not expected. Three published photolysis studies were 

located. Similar rate constants and half-lives are reported. For two of these studies, the light 

1-55
from the lamps was not filtered to block wavelengths <290 nm in either experiment (Hg lamps 

emit at 254 nm), and the results are not environmentally relevant. For the third, the rate constant 

for photolysis was found to be 34 times greater than phenol with a quantum yield of 0.290 at 254 

nm (Wan et al., 1994). 

Photolysis of Aqueous Triphenyl Phosphate Irradiated with Low-Pressure Hg Lamps 

Initial concentration: 0.1 ppm 

pH: 3 and 10 

Pseudo 1st-order rate constant was >40/hour (t1/2

<1.04 minutes) at both pH levels. Some 

hydrolysis may occur at pH 10 

Ishikawa et al., 1992 

Initial concentration: 3.0x10-4 M 

pH: 3.4 

Time: 6 hours 

TPP removed: 100% 

PO4 

3- detected: 60% of theoretical max. 

Phenol detected: 0% 

Ishikawa et al., 1992 

Initial concentration: 3.0x10-4 M 

pH: 12 

Time: 6 hours 

TPP removed: 100% 

PO4 

3- detected: 60% of theoretical max. 

Phenol detected: 9% of theoretical max. 

Ishikawa et al., 1992 

Initial concentration: 1.0 ppm Rate constant: 1.9x10-2/second 

Half-life: 0.6 minutes 

Hicke and Thiemann, 

1987 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: The biodegradation of TPP under aerobic conditions has been adequately 

characterized. 

Basis for Conclusion: The key study was performed according to OECD guidelines. Additional 

studies are available, in which TPP is degraded under a variety of conditions. TPP was also 

found to be ready biodegradable in experimental studies. 

Study Type/ 

Method Innoculum Acclim. Degradation Time Comments Reference 

OECD 303A Activated 

sludge 

14 days 93.8% as DOC 

removal 

20 

days 

Initial 

concentration 

5 ppm, emulsified 

with octanol 

Ciba-Geigy, 

Ltd., 1983 

SCAS Activated >95% 24 Monsanto 

sludge hours Chemical Co., 

1980 

River dieaway 50% 2-4 

days 

Monsanto 

Chemical Co., 

1980 

1-56
Study Type/ 

Method Innoculum Acclim. Degradation Time Comments Reference 

CO2 

evolution 

Activated 

sludge 

14 days 82% 27 

days 

Initial 

concentration 

22 ppm 

Mayer et al., 

1981 

CO2 

evolution 

Activated 

sludge 

14 days 61.9% 

81.8% 

7 days 

28 

days 

Initial 

concentration 

18.3 ppm 

Saeger et al., 

1979 

Simulated 

biological 

treatment/ 

SCAS 

Activated 

sludge w/ 

domestic 

sewage feed 

95% 24 

hours 

Mayer et al., 

1981 

Simulated 

biological 

treatment/ 

SCAS 

Activated 

sludge w/ 

domestic 

sewage feed 

93-96% 24 

hours 

12-week test 

duration, 

acclimation time 

not reported 

Saeger et al., 

1979 

River dieaway River/lake 

water 

20-day 

lag time 

100% 

as TPP removal 

by GC analysis 

7-8 

days 

Seneca River water 

pH 8.2, Lake 

Onondaga water 

pH 7.8, Lake 

Ontario water pH 

8.2, all NY 

sources; hydrolysis 

may interfere with 

measurement at 

higher pH 

Howard and 

Deo, 1979 

River dieaway Mississippi 

River water 

50% primary 

biodegradation 

2-4 

days 

Initial 

concentration 

0.05 ppm 

Mayer et al, 

1981 

River dieaway Mississippi 

River water 

100% 1.75 

days 

Initial 

concentration 

1.0 ppm 

Saeger et al., 

1979 

MITI II Sewage 

sludge 

83-94% 28 

days 

Chemicals 

Inspection & 

Testing 

Institute, 1992 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: 

Conclusion: The pyrolysis products of triphenyl phosphate have not been adequately described. 

1-57
Basis for Conclusion: No formal pyrolysis studies have been located in the literature. 

Pyrolysis Products Reference 

Products include phosphorous oxide Lewis, 2000 (Sax’s Dangerous Properties of Industrial 

Materials) 

Hydrolysis as a Function of pH: 

Conclusion: The hydrolysis data are adequate. 

Basis for Conclusion: Triphenyl phosphate is rapidly hydrolyzed at high pHs, more slowly 

hydrolyzed at neutral pH, and only very slowly hydrolyzed at acidic pHs. The rates measured 

under alkaline conditions (pH ~9) are in good agreement with one another, and the rates 

measured under acidic conditions (pH ~5 or lower) are in reasonable agreement with one 

another. The results for hydrolysis at pH 7 have been reported to be 19 days, 1.3 years, and 406 

days. There is no apparent reason for this discrepancy in values. It appears that the half-life of 

19 days was measured once (Mayer et al., 1981) and has then been repeated in other sources. 

The longer half-life (ca. 1.3 years) has been reported (within acceptable experimental error) in 

two independent studies (Mabey and Mill, 1978), and is consistent with the observation in 

Howard and Deo (1979) that the half-life at pH 6.7 was too slow for accurate measurement over 

the course of the study (14 days). 

T1/2 pH Temp. Comment Reference 

19 days 

3 days 

7 

9 

25°C Mayer et al., 1981 

7.5 days 

1.3 days 

8.2 

9.5 

21°C Half-life was too slow for accurate 

measurement at pH 4.5 and 6.7. 

Diphenyl phosphate was the only 

hydrolysis product identified 

Howard and Deo, 1979 

1.3 years 7 25°C Rate constant = 1.7x10-9/sec at pH 7 Mabey and Mill, 1978 

>28 days 

19 days 

3 days 

5 

7 

9 

Monsanto Chemical Co., 1980 

366 days 

406 days 

<5 days 

3 

7 

9 

20°C Ciba-Geigy, Ltd., 1984 

630 days 

1,125 days 

<10 days 

3 

7 

9 

10°C Ciba-Geigy, Ltd., 1984 

28 days 

19 days 

3 days 

5 

7 

9 

25°C Mayer et al., 1981, cited in 

Anderson et al., 1993 

1-58
Sediment/Water Biodegradation: 

Conclusion: The biodegradation of triphenyl phosphate in the presence of pond and/or river

sediment under various conditions has been adequately characterized. 

Basis for Conclusion: Biodegradation of TPP has been studied under a variety of conditions and

temperatures in the presence of both river and pond sediment. 

Sediment Temp. T1/2 Comments Reference 

Pond soil 25 50-60 days Aerobic conditions. 

Sediment is described to be hydrosoil from a 

small pond. 

Initial concentration, 0.05 ppm 

Major product is diphenyl phosphate. 

Muir et al., 1989 

Pond sediment 25 

10 

2 

2.8 days 

2.8 days 

11.9 days 

Static conditions (air/oxygen neither 

excluded nor added during the test). 

Sediment was collected from a eutrophic 

farm pond near Winnipeg, Manitoba. 

Initial TPP concentration 0.10 :g/mL. 

Sediment:water ratio 1:10. 

Muir et al., 1989 

River 

sediment 

25 7.0 days Static conditions (air/oxygen neither 

excluded nor added during the test). 

Sediment was collected from the Red River 

near Winnipeg, Manitoba. 

Initial TPP concentration 0.10 :g/mL. 

Sediment:water ratio 1:10. 

Muir et al., 1989 

Pond sediment 25 56.7%, 

3 days* 

13.1%, 

40 days* 

Aerobic conditions (respirometer, aerated). 

Initial TPP concentration 0.05 :g/mL 

Sediment:water ratio 1:20 

*Half-life not reported. Values are % TPP 

remaining over time. 

Muir et al., 1989 

River 

sediment 

25 68.9%, 

3 days* 

10.3%, 

40 days* 

Anaerobic conditions (respirometer, under 

N2). 

Initial TPP concentration 0.05 :g/mL 

Sediment:water ratio 1:20 

*Half-life not reported. Values are % TPP 

remaining over time. 

Muir et al., 1989 

Soil Biodegradation with Product Identification: 

Conclusion: The biodegradation rate of triphenyl phosphate in soil has been adequately 

characterized under aerobic and anaerobic conditions. The biodegradation products have been 

adequately characterized. 

1-59
Biodegradation of Triphenyl Phosphate in a Loamy Sand Soil at 20°C 

Conditions 

Percent TPP Remaining Over Time, HPLC 

13 Days 32 Days 60 Days 101 Days Metabolites Identified

Aerobic 69.3 46.6 30.4 20.2 Diphenyl phosphate, CO2 

Anaerobic 50.2 35.4 31.4 Diphenyl phosphate, CO2, phenol 

Reference: Anderson et al., 1993 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: 

Conclusion: The Koc has been adequately characterized in a variety of soil types. 

Koc Soil Type Reference 

2514 silty clay Anderson et al., 1993 

All measurements were made at 20°C. 3561 loamy sand 

2756 silt loam 

1-60
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1-66
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1-68
Flame Retardant Alternatives

Tribromoneopentyl Alcohol

Hazard Review

2-1
Tribromoneopentyl alcohol: 

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal 

Inhalation * 

Eye irritation T

Dermal irritation T

Skin sensitization * 

Subchronic Toxicity 

28-Day oral T

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Y

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro T

Gene mutation in vivo 

Chromosomal T

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other T

2-2
Tribromoneopentyl alcohol: 

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

T

Oxidation/reduction 

Melting point T

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity T

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 T

Daphnia acute T

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, T

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

2-3
Chemical Identity 

1-Propanol, 2,2-dimethyl-, tribromo derivative 

Synonym 

CAS 

MF 

MW

SMILES 

Tribromoneopentyl alcohol 

36483-57-5 

C5H9Br3O 

324.84 

BrC(C(CO)(C)C)(Br)Br 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401). 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Several acute oral lethality studies were available in rats. One study summarized below as a 

critical study (Ameribrom, Inc., 1982a) conformed to OPPTS and OECD guidelines, but did not 

report the purity of the test substance. The other study summarized below (Norris et al., 1972a) 

was performed on a test substance containing a high purity of tribromoneopentyl alcohol 

(98.6%), but did not report all study details necessary for a full individual evaluation according 

to OPPTS and OECD guidelines. A confidential study using the acute toxic class method (OECD 

Guideline 423) provided lethality results for tribromoneopentyl alcohol (97% purity) that were 

consistent with the published studies. Thus, all available acute oral toxicity data report similar 

results for testing of tribromoneopentyl alcohol, and the quality of these studies, taken together, 

is adequate to support the evaluation of acute oral toxicity. 

Critical Studies: 

Type: Acute oral toxicity 

Species, strain, sex, number: Charles River CD rats, 5 animals/sex/dose 

Dose: 2,575, 3,204, 3,289, 3,501, 3,769, and 4,117 mg/kg 

Purity: Not reported, off-white crystals 

Vehicle: Corn oil 

Observation Period: 14 days 

Method: Designed to conform to U.S. EPA, Pesticide Programs, Proposed Guidelines for 

Registering Pesticides in the U.S., Hazard Evaluation: Humans and Domestic Animals, 163.81-1, 

dated 22 August, 1978; preliminary test followed by main study 

2-4
Results: Male mortality was 2/5 at 2,575 and 3,204 mg/kg, 4/5 at 3,289, 3,501, 3,769, and 4,117 

mg/kg. Female mortality was 2/5 at 2,575 and 3,501 mg/kg, 3/5 at 3,769 mg/kg, 4/5 at 3,204 and 

3,289 mg/kg, and 5/5 at 4,117 mg/kg. LD50 (male) = 2,847 mg/kg (95% CI = 2,050-3,644). 

LD50 (female) = 2,685 mg/kg (95% CI = 1,415-3,955). LD50 (combined) = 2,823 mg/kg (95% 

CI = 2,217-3,429). Clinical signs noted included decreased motor activity, proneness, ataxia, 

brady-pnoea, ptosis, irritability, hunching, reddening, urogenital wetting and bleeding, 

lachrymation, salivation, haematuria, coat staining, piloerection, and ungroomed appearance. 

Necropsy findings consisted of gastric mucosa congestion, ulceration, erosion, or hemorrhage, 

associated with abnormal oily and yellow contents. The small intestine was usually distended 

with hemorrhagic, pale, or yellow contents. One female at 3,769 mg/kg and one male at 4,117 

mg/kg had congestion of the urinary bladder; the bladder contents were blood-stained in the male 

with bladder congestion. 

Reference: Ameribrom, Inc., 1982a 

Type: Acute oral toxicity 

Species, strain, sex, number: Sprague Dawley albino rat, 5 males/dose 

Dose: 1,260, 1,580, 2,000, and 2,520 mg/kg 

Purity: 98.6% tribromoneopentyl alcohol 

Vehicle: Corn oil 

Observation period: 13 days 

Method: Test material administered as a 20% solution in corn oil to fasted rats by single dose 

gavage. Animals were weighed before dosing, the day following dosing, and at weekly intervals 

for 2 weeks thereafter. Clinical observations made “periodically” for signs of toxicity. 

Results: LD50 = 1,630 mg/kg (95% CI = 1,370-1,950). Mortality was 0/5 at 1,260 mg/kg, 4/5 at 

1,580 mg/kg, 3/5 at 2,000 mg/kg, and 4/5 at 2,520 mg/kg. Animals at all dose levels were noted 

as having bloody urine. Necropsy revealed hemorrhagic appearance of the mucosa of the urinary 

bladder at the highest dose level. 

Reference: Norris et al., 1972a 

Additional Studies and Information: 

Other studies that were of lesser quality (such as a low percentage of tribromoneopentyl alcohol 

in test substance) or that were reported in less detail are generally consistent with the above 

studies (Biochemical Research Laboratory, no date; Norris et al., 1972b; Toxicology Research 

Laboratory, 1976). 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

No available acute dermal toxicity data. 

2-5
Basis for Conclusion: 

No studies of this type were located. 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The only available study of tribromoneopentyl alcohol (Norris et al., 1972a), summarized below, 

did not fully conform to OPPTS and OECD guidelines. Study details to allow for a full 

evaluation of study adequacy were missing, and the test atmosphere was not characterized. In 

addition, only one concentration was tested, which did not produce mortality or toxicity, and was 

lower than the currently recommended limit dose for single dose testing. An additional study, 

conducted and reported in the same manner, was performed on a mixture containing only 11.3% 

tribromoneopentyl alcohol (Norris et al., 1972b). 

Type: Acute inhalation toxicity 

Species, strain, sex, number: Sprague Dawley rats, 5 males 

Doses: 0.714 mg/liter of air (nominal) 

Purity: 98.6% 

Vehicle: None 

Duration: 7-hour exposure 

Observation Period: 2 weeks 

Method: The test substance (a solid at room temperature) was maintained at 100°C. Air was 

metered through the test substance and into the 19 L glass exposure chamber at the rate of 1 

liter/minute; according to the investigators, this procedure produced a vapor. Whether the 

substance in the test chamber was exclusively a vapor, or whether aerosol or particulate was 

formed, is uncertain. The exposure period was 7 hours. Clinical observations were made during 

the exposure period and up to 2 weeks thereafter (no specification of frequency). Body weight 

was measured before and after exposure and “periodically” for 2 weeks thereafter. Necropsy 

was performed on 1 rat 1 day after exposure and on the remaining 4r rats at the end of the 

observation period. 

Results: No mortality, signs of toxicity, respiratory or nasal irritation, or abnormal body weight 

changes were observed during the exposure or observation period. No abnormalities were noted 

at necropsy. 

Reference: Norris et al., 1972a 

2-6
Additional Study: 

An acute inhalation toxicity study of a mixture containing only 11.3% tribromoneopentyl alcohol 

(plus 81.1% dibromoneopentyl glycol and 7.6% monobromoneopentyl triol) (Norris et al., 

1972b) was performed in a similar manner as the above study. The nominal exposure 

concentration of this mixture was 2.49 mg/L. The nominal exposure concentration of 

tribromoneopentyl alcohol would have been 0.28 mg/L, a lower concentration than in the above 

study of relatively pure tribromoneopentyl alcohol. There were no deaths, but labored breathing 

and slight signs of nasal irritation were observed in the rats during exposure. The rats appeared 

normal during the 2-week observation period and no pathological changes were observed during 

necropsy. The apparent irritant effects in this study cannot be attributed solely to 

tribromoneopentyl alcohol, which accounted for only a small percentage of the mixture, and 

which caused no signs of irritation when tested alone at a higher concentration. 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available acute eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The study summarized below as a critical study (Ameribrom, Inc., 1982b) conformed to OPPTS 

and OECD guidelines, and observed mild eye irritation, but did not report the purity of the test 

substance. A subsequent confidential (OPPTS and OECD guideline) study of tribromoneopentyl 

alcohol (97% purity) in the rabbit reported moderate eye irritation. Other available data, though 

inadequate for individual evaluation, reported similar results to these two studies and provide 

support for the acute eye irritation evaluation. 

Critical Studies: 

Type: Acute eye irritation 

Species, strain, sex, number: New Zealand White albino rabbits, 9/sex 

Doses: 100 mg 

Purity: Not reported; off-white crystals 

Vehicle: None 

Method: The study was designed to conform to the U.S. EPA, Pesticides Program, Proposed 

Guidelines for Registering Pesticides in the U.S.; Hazard Evaluation: Human and Domestic 

Animals 163.81-4, dated 22 August, 1978. Six rabbits were tested without any washing of test 

substance from the eye. Three rabbits were tested with irrigation of the eye after 30 seconds of 

exposure. Eyes were assessed at 24, 48, and 72 hours and 4, 7, 10, and 13 days after test 

administration. 

Results: Almost all animals of both groups (unwashed exposure and washed exposure) exhibited 

diffuse opacity (Grade 1 on a scale of 1-4) on the cornea at 24 hours after exposure. One rabbit 

2-7
from the unwashed group exhibited Grade 2 opacity. Irridial congestion was also noted in most 

animals in the unwashed exposure group. Conjunctival irritation, such as redness and discharge, 

was observed in both the unwashed and washed exposure groups at varying degrees. All ocular 

effects were fully reversible by the end of the observation period with many being fully resolved 

a few days after exposure. 

Reference: Ameribrom, Inc., 1982b 

Additional Studies and Information: 

Other studies that were of lesser quality (such as a low purity of tribromoneopentyl alcohol in 

test substance) or were reported in less detail are generally consistent with the above study 

(Keeler et al., 1974; Biochemical Research Laboratory, no date). 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available acute dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The study summarized below (Ameribrom, Inc., 1982c) generally conformed to OPPTS and 

OECD guidelines with only slight derivations and detail omissions, except for the lack of 

reporting of test substance purity. Although a summary table was also available for another 

acute dermal irritation study (Biochemical Research Laboratory, no date) that reported similar 

results to the above mentioned study, few study details were reported in the table. 

Type: Acute dermal irritation 

Species, strain, sex, number: New Zealand White albino rabbits, 3/sex 

Doses: 0.5 g 

Purity: Not reported, off-white crystals 

Vehicle: Saline, enough to moisten test material 

Method: The study was designed to conform with the U.S. EPA, Pesticides Programs, Proposed 

Guidelines for Registering Pesticides in the U.S.; Hazard Evaluation: Humans and Domestic 

Animals 163,82-5, dated 22 August 1978. Single application of slightly saline-moistened test 

material to shaved skin under an occlusive wrap. The skin of one side of each animal was mildly 

abraded and the skin of the other side was left intact. The test material was applied to both sides. 

The dressings were removed 24 hours after dosing and residual test material was removed by 

wiping with towels. Animals were regularly checked for clinical signs of toxicity during 

exposure and were checked daily from day 2 of the study until study termination. Skin irritation 

assessments were made 1 hour after removal of the wrap, as well as 72 hours and 4 and 5 days 

after application of the test material. 

Results: At 25 hours after application, very slight to well-defined erythema was displayed in 

most animals and moderate-to-severe erythema was displayed in two animals. At 72 hours after 

2-8
application, four rabbits displayed very slight erythema and two rabbits displayed well-defined 

erythema. One rabbit displayed a very slight edema. At 4 days after application, one rabbit 

displayed very slight erythema. All skin responses were completely resolved by the final 

assessment 5 days after application. Exfoliation was observed in three female rabbits from 72 

hours after application until study termination. Incidence or severity of dermal irritation was not 

affected by abrasion of skin before treatment. The authors concluded that the test substance was 

a mild irritant to the skin. 

Reference: Ameribrom, Inc., 1982c 

Additional Studies: 

Another study, reported with few details (Biochemical Research Laboratory, no date), was 

generally consistent with the results of the above study. In this other study, undiluted 

tribromoneopentyl alcohol was applied to the belly of rabbits for 10 applications (intact skin, no 

irritation occurred) or 3 applications (abraded akin, slight hyperemia on abrasions after each of 

the first two applications). Slight hyperemia and slight exfoliation occurred after similar 

applications to intact and abraded belly skin of a 10% solution of tribromoneopentyl alcohol in 

Dowanol DPM. There was no indication of absorption of acutely toxic amounts (not further 

explained). 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available skin sensitization study was performed on a test substance mixture containing only 

13.6 % tribromoneopentyl alcohol (plus 81% dibromoneopentyl glycol and 5.4% 

monobromoneopentyl triol) (Keeler et al., 1974). Toxicological effects of the individual 

component chemical, tribromoneopentyl alcohol, may differ from effects produced by the 

combination of the chemicals in the mixture. The study also did not conform fully to OPPTS 

and OECD guidelines. Results were negative for dermal sensitization in this study in guinea 

pigs. 

SUBCHRONIC TOXICITY

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental)

Conclusion:

The available subchronic oral toxicity data were judged adequate to meet the endpoint.

2-9
Basis for Conclusion: 

The only available study for subchronic oral toxicity is a 30-day study in rats (Humiston et al, 

1973), which was reasonably comprehensive, and conducted in a manner similar to the guideline 

specifications. Differences from the guidelines are as follows: the frequency of clinical 

observations was not reported; not all of the stipulated observations with regard to hematology, 

clinical chemistry, organ weights, and histopathology were made; and a limited neurobehavioral 

assessment was not performed. In these hazard reviews on the flame retardant alternatives, 

however, the adequacy of neurotoxicity data is considered separately, so this data gap will be 

noted under that topic. The 30-day study included urinalysis, which is not a guideline 

requirement, but provides valuable information. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

The only relevant available study is a 30-day repeated oral dose study, summarized below, which 

was conducted in a manner similar to the guidelines for a 28-day oral toxicity study in rodents. 

Type: Repeated-dose 30-day oral toxicity 

Species, strain, sex, number: Sprague-Dawley rats, 5/sex/dose 

Doses: 0, 10, 30, 100, and 300 mg/kg/day 

Purity: 98.0% 

Vehicle: None 

Exposure period, frequency: 30 days, administered daily in diet (food constantly available) 

Post Exposure Period: None 

Method: The test substance was administered in the diet. The rats were weighed initially then 

weekly throughout the study, and were observed for clinical signs, but frequency of this 

observation was not reported. Food consumption was measured weekly, and dietary 

concentrations were adjusted to maintain the target dosages. Hematologic evaluations (packed 

cell volume, hemoglobin, total erythrocyte count, total and differential leukocyte counts) and 

urinalysis (specific gravity, pH, sugar, proteins, occult blood, bilirubin) were performed on study 

day 24 in the control and high dose groups. Clinical chemistry analyses [BUN, alkaline 

phosphatase, SGPT (ALT)] were performed on blood samples collected from all the rats at the 

termination of the study. A complete necropsy was performed, and heart, liver, kidney, testes, 

and brain were weighed. A reasonably comprehensive selection of tissues was examined 

histologically in high dose and control animals. Liver, kidney, and bladder were examined 

histologically in the low- and mid-dose animals. Statistical analyses were performed on the 

continuous variables. 

Results: A statistically significant increase in BUN in male rats was noted at 300 mg/kg/day. 

No significant changes were seen in the urinalysis results. Dose-related histopathologic changes 

in kidney (degeneration and regeneration of renal cortical tubular epithelial cells) and urinary 

bladder tissue (generalized hyperplasia of the transitional epithelium) were noted only in male 

rats at $100 mg/kg/day. Incidences of each of these effects were 0/5 in controls and in each of 

the two lower dose groups, 2/5 in the 100 mg/kg/day group, and 5/5 in the 300 mg/kg/day group. 

2-10
Bladder effects were seen in some of the acute oral toxicity studies as well. Because the tissue 

staining procedures may not have been optimal for visualizing hyaline droplets in renal tissue, 

the possibility that the renal effects may have been related to alpha2u-globulin associated renal 

toxicity cannot be ruled out. The OPPTS and OECD guidelines, however, do not address the 

issue of staining techniques. No changes in any of the endpoints were noted in the female rats, 

and no changes in endpoints other than those noted above were seen in the males. Although 

alpha2u-globulin associated nephropathy is not considered relevant to humans (U.S. EPA, 1991), 

not all chemically-induced male rat nephropathy is of this type. Therefore, in the absence of 

additional information, the renal lesions are considered relevant. The NOAEL for bladder and 

renal effects was 30 mg/kg/day and the LOAEL was 100 mg/kg/day. 

Reference: Humiston et al., 1973 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

No studies of this type were located. 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No studies of this type were located. 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

Conclusion: 

No available subchronic dermal toxicity data. 

Basis for Conclusion: 

No pertinent subchronic dermal toxicity studies were located that addressed the endpoints in the 

guidelines listed below. 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD 

Guideline 410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

2-11
Subchronic Inhalation Toxicity: 90-Day Inhalation Toxicity (OPPTS Harmonized 

Guideline 870.3465; OECD Guideline 413) 

Conclusion: 

No available subchronic inhalation toxicity data. 

Basis for Conclusion: 

No studies of this type were located. 

REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the 

guidelines listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the developmental toxicity endpoints in the 

guidelines listed below. 

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

2-12
• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

Basis for Conclusion: 

No pertinent were located that addressed the chronic toxicity studies endpoints in the guidelines 

listed below. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 

870.4300; OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 

870.4300; OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

2-13
Basis for Conclusion: 

No pertinent neurotoxicity studies were located that addressed the endpoints in the guidelines 

listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Note this guideline is not relevant for tribromoneopentyl alcohol, which is not an 

organophosphorus substance. 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS Harmonized 

Guideline 870.6300) 

Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) 

• OPPTS Harmonized Guideline 870.6500 

• Peripheral Nerve Function (rodent) 

• OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred) 

• OPPTS Harmonized Guideline 870.6855 

These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, 

or because of structural similarity of the substance to neurotoxicants that affect these endpoints. 

These studies may be combined with other toxicity studies. 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data. 

Basis for Conclusion: 

No pertinent immunotoxicity studies were located that addressed the endpoints in the guideline 

listed below. 

2-14
C

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Adequate data were submitted for mutagenicity and chromosomal aberrations in vitro. Four 

studies of reverse mutation in bacteria in vitro reported negative results without activation or 

with activation using liver S9 from rat, rabbit, or monkey. These studies did not conform fully to 

OPPTS and OECD guidelines or were missing vital study details, but reported similar results. 

One study reported that activation with hamster S9 resulted in reverse mutation in bacteria. An 

additional, confidential, OECD guideline study of reverse mutation in bacteria in vitro also 

reported negative results without activation or with rat liver S9, and positive results with hamster 

liver S9. Other confidential studies reported positive results, with metabolic activation, for 

mutagenicity in cultured mouse lymphoma cells and chromosomal aberrations in cultured human 

peripheral lymphocytes. 

Gene Mutation in Vitro: 

Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA-1535, TA-100, TA-1538, TA-98, and TA-1537 

Metabolic activation: Absence and presence of an activating system derived from rat liver (S-9 

mix) 

Concentrations: 50, 250, 1,250, 2,500, and 5,000 :g/plate 

Purity: Not reported 

Solvent: DMSO 

Method: Procedures stated as complying with OECD Guideline 471 (1983); preliminary toxicity 

test in strain TA-98. The assay utilized a plate incorporation method. The main study was 

conducted in duplicate with a negative solvent control, positive controls, and plates devoid of 

organisms to verify the sterility of the S-9 mix. Incubation at 37°C for 48 hours. 

Results: No significant increases in revertant colony numbers over control counts were obtained 

for trineopentyl alcohol with any of the tester strains, either in the presence or absence of 

metabolic activation. 

Reference: Ameribrom, Inc., 1990 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA-1535, TA-100, TA-1538, TA-98, and TA-1537 

2-15
Metabolic activation: With and without S-9 mix 

Concentrations: 0, 50, 100, 500, and 1,000 :g/plate 

Purity: Not reported 

Solvent: DMSO 

Method: The test was reported as having been performed in accordance with the methods 

described in detail in the “Principles of the Ames Mutagenicity Test” by M. Green and E. Riklis 

of 1979. Each compound was tested at least twice and in duplicates. Negative controls. 

Positive controls, such as methylcholantrene, benzopyrene, and N-methyl-N-nitrosoguanidine 

(MNNG). 

Results: The compound was not mutagenic. 

Reference: Ameribrom, Inc., 1982d 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA-1535, TA-1537, and TA-1538 

Metabolic activation: With and without mammalian (rabbit, rat, and monkey) metabolic 

activation 

Concentrations: 0.05% (plate tests); 0.025%, 0.050%, and 0.100% (suspension tests) 

Purity: >99%, “pure” tribromoneopentyl alcohol 

Solvent: DMSO or saline 

Method: Cytotoxicity testing performed. Positive and negative controls used. Plate incubation 

at 37°C for 4 days, with each compound done in duplicate. Suspension tests were conducted 

with metabolic activation at 37°C for 1 hour in an oxygen atmosphere, or without metabolic 

activation at 37°C for 1 hour, with all flasks shaken during treatment. Suspension tests were 

scored after plating and incubation for 48 hours at 37°C. 

Results: The test substance did not exhibit genetic activity under any of the testing conditions 

(plate tests, with and without activation; suspension tests, with and without activation) employed 

in this study. 

Reference: Litton Bionetics, Inc., 1975a 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA-1535, TA-1537, and TA-1538 

Metabolic activation: With and without mammalian (rabbit, rat, and monkey) metabolic 

activation 

Concentrations: 0.150% (plate tests); 0.075%, 0.150%, and 0.300% (suspension tests) 

Purity: Not reported, “plant” tribromoneopentyl alcohol 

Solvent: DMSO or saline 

Method: Cytotoxicity testing performed. Positive and negative controls used. Plate incubation 

at 37°C for 4 days, with each compound done in duplicate. Suspension tests were conducted 

with metabolic activation at 37°C for 1 hour in an oxygen atmosphere, or without metabolic 

activation at 37°C for 1 hour, with all flasks shaken during treatment. Suspension tests were 

scored after plating and incubation for 48 hours at 37°C. 

Results: The test substance did not exhibit genetic activity when all test data were considered. 

The negative assessment was based on combined test results for both rat and rabbit activation 

assays and non-activation assays, as two sets of original test data with TA-1535 (one with rat 

2-16
tissue, one with rabbit tissue) suggested mutagenic activity, but repeat tests with this strain did 

not indicate mutagenic activity. 

Reference: Litton Bionetics, Inc., 1975b 

Additional Information 

Results of a 1983 preincubation assay in Salmonella typhimurium, listed on the NTP (2004) 

online database, confirm the negative results of other studies in TA100, TA98, TA1535, and 

TA1537 without activation or with activation by rat liver S9. Activation using S9 from hamster 

liver resulted in positive results in TA100 and TA1535, but negative results in the two other 

strains. A more recent confidential study of 98% pure tribromoneopentyl alcohol, conducted 

according to OECD guideline 471 (May 1983 version) in S. typhimurium (TA98, TA100, 

TA1535, TA1537), also reported negative results without an activating system or with rat liver 

S9 in all four strains, and positive results with hamster liver S9 in TA100 and TA1535 only. 

C In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

A confidential study reported dose-related mutagenicity in cultured L5178Y mouse lymphoma 

cells treated with tribromoneopentyl alcohol with, but not without metabolic activation. 

Chromosomal Aberrations in vitro: 

C In Vitro Mammalian Chromosome Aberration Test (OPPTS Harmonized Guideline 

870.5375; OECD Guideline 473) 

A confidential study reported that, with, but not without metabolic activation, tribromoneopentyl 

alcohol increased the frequency of chromosomal aberrations in human peripheral lymphocytes in 

vitro. 

Other 

C Mitotic Gene Conversion in Saccharomyces cerevisiae (OPPTS Harmonized 

Guideline 870.5575) 

The two available studies, conducted by the same laboratory at about the same time, appear 

marginally adequate. 

Type: Mitotic gene conversion 

Species, strain: Saccharomyces cerevisiae D4 

Metabolic activation: With and without mammalian (rabbit, rat, and monkey) metabolic 

activation 

Concentrations: 0.5%, 1.0%, and 2.0% 

2-17
Purity: >99%, “pure” tribromoneopentyl alcohol 

Solvent: DMSO or saline 

Method: Cytotoxicity testing performed. Suspension tests were conducted with metabolic 

activation at 37°C in an oxygen atmosphere for 4 hours, and without metabolic activation at 

30°C for 4 hours, with all flasks shaken during treatment. Scoring was done after plating and 

incubation for 3-5 days at 30°C. Concurrent negative controls, positive controls run 

concurrently with the non-activation assay. Study authors state (without reporting the data) that 

the positive controls for activation assay were run on a different day, but cell culture was the 

same. The authors may be referring to the positive control data reported in the appendix of the 

following report on “plant” tribromoneopentyl alcohol. 

Results: The test substance did not exhibit genetic activity either with or without metabolic 

activation. 

Reference: Litton Bionetics, Inc., 1975a 

Type: Mitotic gene conversion 

Species, strain: Saccharomyces cerevisiae D4 

Metabolic activation: With and without mammalian (rabbit, rat, and monkey) metabolic 

activation 

Concentrations: 0.375%, 0.750%, and 1.500% 

Purity: Not reported, “plant” tribromoneopentyl alcohol 

Solvent: DMSO or saline 

Method: Cytotoxicity testing performed. Suspension tests were conducted with metabolic 

activation at 37°C in an oxygen atmosphere for 4 hours, and without metabolic activation at 

30°C for 4 hours, with all flasks shaken during treatment. Scoring was done after plating and 

incubation for 3-5 days at 30°C. Concurrent negative controls. Concurrent positive controls for 

the activation assays. Positive control data for the non-activation assay were not reported, but 

may have been those in the above mitotic gene conversion study with pure tribromoneopentyl 

alcohol. 

Results: The test substance did not exhibit significant genetic activity either with or without 

metabolic activation. 

Reference: Litton Bionetics, Inc., 1975b 

No studies were available on the genotoxicity of tribromoneopentyl alcohol in the following 

types of types of tests: 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

2-18
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

The available acute toxicity data for fish, aquatic invertebrates, and algae were judged adequate 

to meet the endpoints. The acute marine/estuary toxicity endpoints for fish, aquatic invertebrates 

were judged inadequate to meet the endpoints. 

Basis for Conclusion: 

C Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

A confidential study in Cyprinus carpio (carp), with a 96-hour LC50 of 32 mg/L, conducted 

under static test conditions, was submitted. The LC0 was 18 mg/L. A 14-day study in Cyprinus 

carpio (carp), conducted under semi-static test conditions, was also submitted. The 14-day LC50 

was >32 mg/L. The NOEC and LOEC for sublethal effects were 5.6 and 10 mg/L, respectively. 

The available data were judged adequate to meet this endpoint. 

C Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1010; OECD Guideline 202) 

A confidential study in Daphnia magna was submitted. The 48-hour EC50 for immobility was 

64 mg/L under static test conditions. The NOEC was 32 mg/L. The available data were judged 

adequate to meet this endpoint. 

C Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

A confidential study in Selenastrum capricornutum was submitted. The 72-hour EC50 values for 

cell growth inhibition (biomass) and growth rate reduction were 28 and >100 mg/L, respectively, 

under static test conditions. The 72-hour NOEC was 2.2 mg/L. The available data were judged 

adequate to meet this endpoint. 

No additional acute toxicity studies with freshwater or saltwater fish, aquatic invertebrates, or 

algae were located that followed or were similar to the guideline protocol listed below. 

C Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

2-19
Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that 

addressed the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized 

Guideline 850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no 

subchronic toxicity studies with earthworms were located that addressed the endpoints in the 

guidelines listed below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

2-20
Physical/Chemical Properties 

1-Propanol, 2,2-dimethyl-, tribromo derivative 

Synonym Tribromoneopentyl alcohol 

CAS 36483-57-5 

MF C5H9Br3O 

MW 324.84 

SMILES BrC(C(CO)(C)C)(Br)Br 

Water Solubility (mg/L): 

Conclusion: 

The available water solubility data are adequate. 

Basis for Conclusion: 

A confidential experimental study for the water solubility of tribromoneopentyl was submitted. 

Using OECD Guideline 105, a water solubility of 1,930 mg/L at 20.1°C was measured. 

Log Kow: 

Conclusion: 

The available log Kow data are adequate. 

Basis for Conclusion: 

A confidential experimental study for the log Kow of tribromoneopentyl was submitted. Using

OECD Guideline 117, a log Kow of 2.6 was measured using the HPLC method.

Oxidation/Reduction: No data

Melting Point:

Conclusion: 

The available melting point data are adequate. 

Basis for Conclusion: 

The melting point of tribromoneopentyl has been reported as 62-67°C in confidential EPA 

databases. 

2-21
Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: 

Conclusion: 

The available explosivity data are adequate. 

Basis for Conclusion: 

A confidential study was submitted indicating that tribromoneopentyl alcohol has a low 

explosion severity potential in a 20 litre sphere test. 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

2-22
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: The available aerobic biodegradation data are adequate. 

Basis for Conclusion: Submitted confidential studies indicate that tribromoneopentyl alcohol 

underwent 2.5% CO2 evolution over 28 days in an OECD 310 test and 77% removal as DOC 

using OECD 302B in 36 days after a 10-day lag period (MC). In addition, a submitted 

confidential study indicates that tribromoneopentyl alcohol is not ready biodegradable. 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

2-23
Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

2-24
References 

AmeriBrom, Inc. 1982a. Acute oral toxicity in the rat. Final Report. TSCA 8D submission by 

AmeriBrom, Inc., 1990, OTS0530263. 

AmeriBrom, Inc. 1982b. Primary eye irritation study in rabbits. Final Report. TSCA 8D 

submission by AmeriBrom, Inc., 1990, OTS0530264. 

AmeriBrom, Inc. 1982c. Primary dermal irritation study in rabbits. Final Report. TSCA 8D 

submission by AmeriBrom, Inc., 1990, OTS0530265. 

AmeriBrom, Inc. 1982d. Mutagenicity test according to “The Ames” method. TSCA 8D 

submission by AmeriBrom, Inc., 1990, OTS0530266. 

AmeriBrom, Inc. 1990. Assessment of mutagenic potential in histidine autotrophs of 

Salmonella typhimurium (The Ames Test). Final Report. TSCA 8D submission by AmeriBrom, 

Inc., 1990, OTS0530270. 

Biochemical Research Laboratory. no date. Toxicological properties and industrial handling 

hazards of tribromoneopentyl glycerol alcohol. TSCA 8D submission by The Dow Chemical 

Company, 1990, OTS0528750. 

Humiston, CG; Kociba, RJ; Wade, CE. 1973. Results of a 30-day dietary feeding study in rats 

maintained on diets containing tribromoneopentyl alcohol, FR-1360. Halogen Research 

Laboratory, Chemical Biology Research, Dow Chemical USA, Midland, Michigan. TSCA 8D 

submission by The Dow Chemical Company, 1990, OTS0528744. TSCA 8D submission by 

Ethyl Corporation, 1990, OTS0528518. 

Keeler, PA; Yakel, HO; Rampy, LW. 1974. Eye irritation and skin sensitization properties of a 

sample of FR-1138 (dibromoneopentyl glycol). Toxicology Research Laboratory, Dow 

Chemical USA. TSCA 8D submission by Dow Chemical Company, no date of receipt, 

OTS0516120. 

Litton Bionetics, Inc. 1975a. Mutagenic evaluation of compound 236-2-60 B, “pure” 

tribromoneopentyl alcohol >99%. Kensington, Maryland. TSCA 8D submission by The Dow 

Chemical Company, 1990, OTS0530089. 

Litton Bionetics, Inc. 1975b. Mutagenic evaluation of compound 236-2-60 D, “plant” 

tribromoneopentyl alcohol. Kensington, Maryland. TSCA 8D submission by The Dow 

Chemical Company, 1990, OTS0530090. 

2-25
Norris, JM; Kociba, R; Leong, BK. 1972a. Single dose oral lethality and acute vapor inhalation 

toxicity of FR-1360 (tribromoneopentyl alcohol) in rats. Dow Chemical USA, Midland, 

Michigan. TSCA 8D submission by The Dow Chemical Company, 1990, OTS0528751. TSCA 

8D submission by Ethyl Corporation, 1990, OTS0528517. 

Norris, JM; Kociba, R; Pernell, H. 1972b. Acute oral lethality and acute vapor inhalation 

toxicity of FR-1138 (dibromoneopentyl glycerol). TSCA 8D submission by Chemical Biology 

Research, Dow Chemical USA, 1972, OTS0516117. 

NTP (National Toxicology Program). 2004. NTP studies on 3-bromo-2,2-bis(bromomethyl) 

propanol: 1983 Salmonella study details. Online at http://ntp-apps.niehs.hih.gov/. 

Toxicology Research Laboratory. 1976. Toxicological properties and industrial handling 

hazards of: tribromoneopentyl alcohol. TSCA 8D submission by The Dow Chemical Company, 

1990, OTS0530138. 

U.S. EPA. 1991. Alpha2u-globulin: Association with chemically induced renal toxicity and 

neoplasia in the male rat. Prepared for the Risk Assessment Forum, Washington, DC. 

EPA/625/3-91/019F. 

2-26
Flame Retardant Alternatives

 Tris(1,3-dichloro-2-propyl) Phosphate

Hazard Review

3-1
Tris(1,3-dichloro-2-propyl) phosphate:

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal T

Inhalation * 

Eye irritation T

Dermal irritation T

Skin sensitization T

Subchronic Toxicity 

28-Day oral 

90-Day oral * 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects 

*

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental T

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

T

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

T

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

T

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

* 

Additional Y

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity * 

Genotoxicity 

Gene mutation in vitro T

Gene mutation in vivo T

Chromosomal T

aberrations in vitro 

Chromosomal * 

aberrations in vivo 

DNA damage and 

repair 

T

Other 

3-2
 Tris(1,3-dichloro-2-propyl) phosphate:

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

T

Oxidation/reduction 

Melting point T

Boiling point T

Vapor pressure * 

Odor T

Oxidation/reduction 

chemical 

incompatibility 

Flammability T

Explosivity 

Corrosion 

characteristics 

pH Y

UV/visible absorption T

Viscosity T

Density/relative 

density/bulk density 

T

Dissociation constant in 

water 

Y

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish T

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish * 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis * 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 * 

Daphnia acute EC50 * 

Mysid shrimp acute 

LC50 

Green algae EC50, * 

NOAEC, LOAEC 

Fish chronic NOAEC, 

LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic * 

EC50, LC50, NOAEC, 

LOAEC 

3-3
Chemical Identity 

2-Propanol, 1,3-dichloro-, phosphate (3:1) 

CAS 

MF 

MW

SMILES 

Synonyms 

13674-87-8 

C9H15Cl6O4P 

430.91 

ClCC(CCl)OP(

Tris(1,3-dichlor

=O)(OC(CCl)CCl)OC(CCl)CCl 

o-2-propyl) phosphate, TDCPP, Fyrol FR-2 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401). 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Several acute oral lethality studies were available in a variety of species: rabbits, rats, and mice. 

These studies were from the older (pre 1980) literature, did not report substance purity, and do 

not fully conform to OPPTS or OECD guidelines, but given the magnitude of the LD50 values 

the data are adequate for the evaluation of acute oral toxicity. Acute oral LD50 values generally 

exceeded the current limit dose of 2,000 mg/kg. Reports that specified a 14-day observation 

period are presented in detail. 

Critical Studies: 

Type: Acute oral toxicity 

Species, strain, sex, number: Rabbit, Dutch-belted, 5 males/group 

Doses: 0, 5,000, 7,500, and 10,000 mg/kg 

Purity: Fyrol FR-2; purity not specifically reported 

Vehicle: Not reported by Akzo-Nobel 

Method: 14-Day post-dosing observation period; observations limited to mortality, clinical 

signs, and necropsy. LD50 calculated according to Litchfield and Wilcoxon. 

Results: Clinical signs shortly after dosing included ataxia, weakness, and diarrhea; survivors 

normal by day 9. Necropsy revealed no abnormalities. Acute oral male rabbit LD50 = 6,800 

mg/kg (95% CI 5,615-8,234 mg/kg). 

Reference: Robust summary from Akzo-Nobel, 2001a, unpublished study conducted 1982 

Type: Acute oral toxicity 

3-4
Species, strain, sex, number: Rat, Sprague-Dawley, 5 males/group 

Dose: 1,000, 2,150, 5,640, or 10,000 mg/kg 

Purity: Fyrol FR-2; purity not specifically reported 

Vehicle: None 

Observation period: 14 days post dosing 

Method: 14-Day post-dosing observation period; observations limited to mortality, clinical 

signs, and necropsy; LD50 calculated according to Litchfield and Wilcoxon; not specified 

whether fed or fasted at time of dosing. 

Results: No effects at 1,000 mg/kg. Dose-related depression at or above 2,160 mg/kg; survivors 

normal by day 5. No gross lesions in survivors; fatalities had congestion of heart, lung, and 

liver. Acute rat oral LD50 = 3,160 mg/kg (95% CI 2,050-4,800 mg/kg) 

Reference: Stauffer, 1972d; robust summary from Akzo-Nobel, 2001a 

Type: Acute oral toxicity 

Species, strain, sex, number: Mouse, Slc/ddY, 10/sex/dose 

Purity: Not reported 

Doses: For males: 0, 2,210, 2,380, 2,570, 2,780, 3,000, 3,240, and 3,500 mg/kg. For females: 0, 

2,890, 2,040, 2,210, 2,380, 2,570, and 2,780 mg/kg. 

Vehicle: Olive oil 

Method: Observed for mortality and clinical signs for14 days. No body weight or gross 

necropsy examination. 

Results: Treated animals exhibited ataxic gait, hyperactivity, convulsion and death. No 

mortality was observed in controls or in males at 2,210 mg/kg or females at 1,890 mg/kg. The 

LD50 values were 2,670 mg/kg (2,520-2,830 mg/kg) for male mice and 2,250 (2,120-2,380 

mg/kg) for female mice. 

Reference: Kamata et al., 1989 

Additional Studies and Information: 

Other studies available only in secondary sources reported similar results. An oral LD50 of 

>2,000 mg/kg was reported in male and female rats exposed to Tolgard TDCP MK1(Cuthbert, 

1989a as reported in WHO, 1998); clinical signs observed during the first 5 days after dosing 

included hypokinesia, piloerection, soiled coats, ataxia, chromodacryorrhea, rhinorrhea, and 

salivation. 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged adequate to meet the endpoint. 

3-5
Basis for Conclusion: 

The available studies predate the preferred study guidelines, and did not report purity, but 

together indicated no mortality at the guideline limit dose of 2,000 mg/kg. The report specifying 

a 14-day observation period is presented in more detail. 

Type: Acute dermal toxicity 

Species, strain, sex, number: Rabbit, New Zealand albino, sex not specified, 4 

Dose: 4,640 mg/kg 

Purity: Fyrol FR-2; Stauffer, no data 

Vehicle: None 

Exposure period: 24 Hour 

Method: 4 Rabbits tested occluded; 14-day observation period. Gross necropsy. 

Results: Mortality after 14 days = 0/4. No overt signs of toxicity and no gross necropsy 

findings. Therefore, dermal acute LD50 >4,640 mg/kg. 

Reference: Stauffer, 1973a; additional information from robust summary in Akzo-Nobel, 2001a 

Additional Studies and Information: 

Other studies available only in secondary sources with minimal detail. A dermal LD50 of 

>2,000 mg/kg was reported in male and female Sprague-Dawley rats exposed to Tolgard TDCP 

MK1 (Cuthbert, 1989b as reported in WHO, 1998). No deaths and no clinical signs were noted 

24 hours after treatment. 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300; OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available study on TDCPP predates the preferred guidelines. The duration was shorter than 

currently recommended and no deaths were observed. Analysis of aerosol particle size, 

however, was not mentioned so it is not known whether the size was respirable. Necropsies 

were not performed. 

Type: Acute inhalation toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 5 males and 5 females 

Doses: 9.8 mg/L (9,800 mg/m3

) 

Purity: No data 

Vehicle: None 

Duration: 1 hour 

Method: Observation period = 14 days. Observed daily for signs of toxicity and for mortality. 

3-6
Results: No mortality after 14 days; initial signs of moderate depression 

Reference: Stauffer,1973b 

Additional Studies and Information: 

Other studies available only in secondary sources reported similar results. An acute inhalation 

LC50 of >5,220 mg/m3 was reported for Sprague-Dawley rats exposed to aerosol of TDCPP 

(Amgard TDCP) (Anderson, 1990 as reported in WHO, 1998). 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Two reasonably adequate studies report similar results in rabbits: mild reversible irritation of the 

conjunctiva. The studies are summarized below. 

Type: Acute eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, sex not specified; 6 

Doses: 0.1 mL 

Purity: No data, Stauffer Fyrol FR-2 

Vehicle: None 

Method: Cited CFR [U.S. Federal Hazardous Substances Labelling Act] Section 191.12, 

chapter 1, title 21. Following instillation of TDCPP, eyes were examined at 24, 48, and 72 

hours. 

Results: Mild conjunctival effects in 3/6 that cleared by 48 hours. 

Reference: Stauffer, 1972c 

Type: Acute (24-hour) eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, male and female; 9 total 

Doses: 0.1 mL 

Purity: No data 

Vehicle: None 

Method: U.S. EPA Hazard Evaluation. 1978. Fed. Reg. 43: 163: pp. 37331-37402. Thirty 

seconds following instillation of TDCPP, the treated eyes of three rabbits were washed, treated 

eyes were not washed in 6 rabbits. The untreated eye of each animal served as a control. The 

cornea, iris and conjunctiva of each eye were examined at 24, 48, and 72 hours, and at 4 and 7 

days after instillation of TDCPP using the Draize scoring method. 

Results: No signs of eye irritation were observed (average total Draize score of zero). 

Reference: Stauffer, 1979; robust summary from Akzo-Nobel, 2001a for study dated 1979 

3-7
Additional Studies and Information: 

One hour following application of Tolgard TDCP MK1 to the eyes of New Zealand White 

rabbits, slight conjunctival redness and slight discharge were noted (Cuthbert and Jackson, 1990 

as reported in WHO, 1998); effects cleared by 24 hours. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Two reasonably adequate studies, patterned after guidelines in effect at the time, provide similar 

results, indicating that TDCPP was a non-irritant when applied for 4 hours (consistent with 

current guidelines) and a mild irritant when applied for 24 hours to rabbit skin. Additional 

studies provide support. The studies are summarized below. 

Critical Studies: 

Type: Acute (24-hour) dermal irritation 

Species, strain, sex, number: Rabbit, New Zealand, sex not specified, 6 

Doses: 0.5 mL 

Purity: Not reported; Stauffer Fyrol FR-2 

Vehicle: None 

Method: Cites “EPA protocol”. Back hair was shaved, each rabbit tested on intact and abraded 

skin, occlusive dressing removed after 24 hours, observations at 24 and 72 hours. 

Results: No edema on intact or abraded skin in any of the 6 rabbits. Mild erythema was visible 

at 24 hours but cleared by 72 hours, resulting in a score of 0.63. The report classified TDCPP as 

a mild irritant. 

Reference: Stauffer, 1979 

Type: Acute (4-hour) dermal irritation 

Species, strain, sex, number: Rabbit, not specified (but New Zealand white rabbits were used in 

an eye irritation test conducted at the same time) 

Doses: 0.5 mL 

Purity: Not reported; Stauffer Fyrol FR-2 

Vehicle: None 

Method: Back hair shaved, each rabbit tested on intact and abraded skin, occlusive dressing 

removed after 4 hours, observations at 4, 24 and 48 hours. 

Results: No erythema or edema on intact or abraded skin in any of the 6 rabbits. 

Reference: Stauffer, 1972c 

3-8
Additional Studies: 

Another study, on Tolgard TDCPP MK1, reported well-defined (score 2) erythema in 2 New 

Zealand White rabbits and slight erythema in a third rabbit 1 hour after patch removal, but 

duration of exposure was not specified (Cuthbert, 1989c as reported in WHO, 1998). Effects 

cleared by 48 hours. The substance was classified as a skin irritant. 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study that reported negative results in a skin sensitization study in guinea pigs 

was submitted that allows this endpoint to be adequately characterized. 

A robust summary in a submission to the HPV Challenge program was located for an 

unpublished industrial study stated to have been conducted under guideline. The summary 

probably has not been reviewed by EPA, since this endpoint is not required for the HPV 

program. Furthermore, the summary omits information necessary to determine study adequacy, 

such as: the strain, sex, group size, substance purity, and dose levels. The summary claimed that 

the doses were selected according to guideline, but the exact levels are not stipulated in the 

guideline. Without the additional information, this study cannot be evaluated for adequacy. 

Critical Studies: 

Type: Dermal sensitization study 

Species, strain, sex, number: Guinea pig, strain and sex not reported 

Doses: Stated as according to guideline, but exact doses are not stipulated in guideline. 

Purity: Not reported; Fyrol FR-2 

Vehicle: Water 

Method: Three pairs of intradermal injections into shaved shoulder: 1:1 Freunds Complete 

Adjuvent (FCA) and saline, the test material, and 1:1 FCA and test material. Controls received 

water in place of the test material. On day 6, 24 hours before topical induction application, 

sodium lauryl sulfate was applied to sites to enhance local irritation. On day 7, test substance 

was applied to sites (water for controls). On day 21, animals received challenge dose by dermal 

application, occluded for 24 hours. Sites observed for irritation and sensitization (Grade 0-4). 

Results: The sensitization score for Fyrol FR-2 was zero, indicating the substance is not a 

chemical sensitizer. 

Reference: Robust summary in Akzo-Nobel, 2001b for unpublished and unidentified study 

dated 2001 

3-9
SUBCHRONIC TOXICITY 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

Conclusion: 

The available subchronic oral toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A Japanese 90-day dietary study in mice (Kamata et al. 1989) provides limited relevant 

information in the English abstract and data tables. The study was not adequate to characterize 

this endpoint because histopathological analysis was apparently limited to the liver. A fertility 

study by Wilczynski et al. (1983), discussed under the Reproductive Toxicity endpoint, 

evaluated male rabbits exposed by oral gavage for 12 weeks, but did not involve treated females. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

No study of this type was located. 

90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

Type: 90-Day repeated oral 

Species, strain, sex, number: Mouse, Slc/ddY, 12/sex/dose 

Doses: TDCPP at dietary concentrations of 0, 0.01, 0.04, 0.13, 0.42, and 1.33% in the diet, 

resulting in reported average daily doses of 0, 13.2, 47.3, 171.0, 576.0, and 1,792.3 mg/kg/day in 

males and 0, 15.3, 62.5, 213.6, 598.0, and 1,973.1 mg/kg/day in female mice 

Purity: Not reported 

Vehicle: None; added to diet 

Exposure period, frequency: 90 days, ad lib 

Method: Body weight, food consumption measured weekly. At 1 and 3 months in half the 

animals, hematologic (erythrocyte, hemoglobin, hematocrit, and leukocyte counts) and clinical 

chemistry parameters (total protein, albumin, albumin/globulin ratio, blood urea nitrogen, 

glucose, total cholesterol, alkaline phosphatase, aspartate aminotransferase, alanine 

aminotransferase). At 1 and 3 months, half the animals were necropsied and absolute and 

relative organ weights were determined for brain, heart, lung, liver, kidney, and spleen. The 

liver was examined for microscopic histopathology; the English text does not mention whether 

other tissues were examined. 

Results: At the highest dietary level, 1.33%, all mice exhibited emaciation, rough hair, and 

tremor and died within 1 month. At 1.33%, food consumption was reduced and body weight loss 

occurred in both sexes. Mean body weight gain was reduced by about 10% (estimated from 

graph) in males at 0.42% throughout the study. The following statistically significant changes 

3-10
occurred in treated groups compared to controls. Slight anemia (reduced hemoglobin; p<0.05) in 

males at 0.42% after 3 months. Anemia (reduced hemoglobin at $0.13% after 1 month and at 

0.42% at 3 months, erythrocyte and hematocrit at 0.42% at 1 and 3 months) in females (3-month 

values p<0.01). Albumin/globulin ratios elevated in all treated male groups at 3 months. 

Alkaline phosphatase elevated in females at 0.42% at 1 month but not later. Dose-related organ 

weight elevations compared to controls observed at 3 months in males included relative liver 

weight (+32-51%) at $0.13% and relative kidney weight (+39%) at 0.42%. Significant 

elevations in organ weights in females at 3 months included relative liver weight (+16-51%) at 

$0.04%, absolute (+30%) and relative (+34-40%) kidney weights at $0.13%, and absolute liver 

weight (+40%) at 0.42%. The statistical significance of these organ weight elevations was 

p<0.01 for rats exposed at $0.13% and p<0.05 for rats exposed at 0.04.%. Histopathology of the 

liver (slight focal necrosis) was observed in only two females at 0.42%. The dietary level of 

0.01% is a NOAEL of 15.3 mg/kg/day and the dietary level of 0.04% is a LOAEL of 62.5 

mg/kg/day for liver and kidney weight elevations in female mice. 

Reference: Kamata et al., 1989 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No studies of this type were located. 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

Conclusion: 

No available subchronic dermal toxicity data. 

Basis for Conclusion: 

No data exist for the subchronic dermal toxicity endpoint. 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD 

Guideline 410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

No studies of either type were located. 

3-11
Subchronic Inhalation Toxicity (90-day) 

Conclusion: 

No available subchronic inhalation toxicity data. 

Basis for Conclusion: 

No repeated-exposure inhalation toxicity studies were located. 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD 

Guideline 413) 

No studies of this type were located. 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A fertility assay in male rabbits exposed by oral gavage for 12 weeks prior to mating 

(Wilczynski et al., 1983) partially characterizes this endpoint, but is not sufficient to satisfy the 

reproductive toxicity endpoint since it was described only in an abstract and females were not 

tested. Other studies (Hazleton, 1978; Tanaka et al., 1981) described below under 

Developmental Toxicity reported that in pregnant female rats exposed orally to TDCPP, adverse 

reproductive effects occurred only at maternally lethal doses. However, no study evaluated 

reproductive function in females treated prior to mating. 

The 2-year feeding bioassay in rats by Freudenthal and Henrich (2000; Bio/Dynamics, 1980, 

1981), discussed below under Chronic Toxicity, provides reproductive histopathology data that 

are, however, insufficient to satisfy the reproductive toxicity endpoint. This study provided 

histopathology results for the testis, epididymis, seminal vesicle, ovary, and uterus for the 

control and high-dose groups (0 and 80 mg/kg/day) after 1 year (10 scheduled 

sacrifices/sex/group) and for survivors in all groups after 2 years; unscheduled sacrifices (rats 

killed in a moribund state) were also examined. The 2-year exposure is too long to represent 

reproductive toxicity, because of the confounding effects of aging; the results pointed to doserelated effects in male reproductive organs (at $5 mg/kg/day, atrophy and decreased secretory 

product of the seminal vesicles; at $20 mg/kg/day, testicular germinal atrophy with 

oligospermia; and at 80 mg/kg/day, oligospermia and luminal accumulation of degenerated 

seminal products in the epididymis). No significant effect was observed in females. The tested 

doses, which were considerably lower than the guideline limit dose of 1,000 mg/kg/day, were not 

3-12
high enough to induce significant reproductive histopathology after one year of exposure; 1/10 

high-dose males had oligospermia. Thus, a LOAEL for reproductive effects following 

subchronic (90-day) exposure is not available and cannot be extrapolated from the existing data, 

but the chronic data indicate a LOAEL of 5 mg/kg/day for atrophy and decreased secretory 

product of the seminal vesicles. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

No studies were available that met the specific designs of the three protocols listed above. 

Additional Studies: 

A study described in an abstract by Wilczynski et al. (1983) addresses fertility in male rabbits 

exposed by oral gavage for 12 weeks prior to mating. 

Type: Fertility 

Species, strain, sex, number: Rabbit, strain not specified, 10 males/dose 

Purity: Not reported 

Doses: 0, 2, 20, or 200 mg/kg/day 

Vehicle: Not reported 

Exposure duration, frequency: 12 weeks, once by oral gavage daily 

Method: Males treated for 12 weeks, then mated with untreated females. Body weight, clinical 

signs, clinical chemistry, hematology, mating behavior, male fertility, sperm quantity and 

quality, kidney and liver weights, gross and microscopic pathology (range of organs examined 

not specified). 

Results: High-dose animals had significantly increased absolute kidney weight and relative liver 

weight. TDCPP had no effect on male reproductive parameters; there was no histopathology in 

kidneys, liver, pituitaries, testes, or epididymides. 

Reference: Wilczynski et al., 1983 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged adequate to meet the endpoint. 

3-13
Basis for Conclusion: 

Developmental toxicity studies in two strains of rats exposed to Fyrol FR-2 by oral gavage 

followed methods consistent with OECD Guideline 414 (one study pre-dated the guideline). 

Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; OECD 

Guideline 414) 

Type: Prenatal developmental toxicity 

Species, strain, sex, number: Rat, Wistar, 15 pregnant females at the highest dose, 23-24 

pregnant females in controls and other dose groups. 

Purity: not reported 

Doses: 0, 25, 50, 100, 200, and 400 mg/kg/day 

Vehicle: Olive oil 

Exposure duration, frequency: Once by oral gavage daily on gestational days (GD) 7-19. 

Method: Body weight, food consumption, clinical signs, pregnancy rates, and necropsy of dams, 

kidney weight; uterine contents (including implants and resorption) at day 20 of gestation, 

corpora lutea; fetal viability, sex ratio and weight, crown-rump length, and external and skeletal 

abnormalities. 

Seven dams from each of the control and #200 mg/kg/day groups were permitted to litter 

normally and evaluated for implantation sites, delivery index, number of live offspring at birth 

and survival on PND 4, at 4th week, and at 10th week. Litters were culled to 10 offspring on 

postnatal day 4 (PND 4) and subjected to behavioral tests (open field, water maze, rota rod, 

inclined screen, pain reflex and Preyer’s reflex). Absolute organ weights of 10 organs plus 

testis, uterus and ovary were measured in offspring. 

Results: Maternal mortality occurred only at 400 mg/kg/day: 11/15 died. Food consumption 

was suppressed at 400 mg/kg/day and slightly at 200 mg/kg/day. At 400 mg/kg/day, mean body 

weight loss occurred during GD 7-15, resulting in significantly (p<0.05) reduced terminal body 

weight on GD20: ~17% lower than control group. Absolute and relative kidney weights were 

significantly increased at 200 and 400 mg/kg/day. TDCPP at #200 mg/kg/day had no effect on 

corpora lutea or mean numbers of implants, fetal body weight, fetal sex ratio, or the number of 

dead or live fetuses. The numbers of dead fetuses and live fetuses were significantly (p<0.01) 

changed compared to controls by the loss of one whole litter at 400 mg/kg/day. No increase in 

malformations was observed in treated groups. For maternal toxicity, the NOAEL was 100 

mg/kg/day and the LOAEL was 200 mg/kg/day for increased kidney weight. For fetal toxicity, 

the NOAEL was 200 mg/kg/day and the LOAEL was 400 mg/kg/day for increased fetal death; 

the highest dose of 400 mg/kg/day was a NOAEL for teratogenicity. 

Postnatal observations: TDCPP at #200 mg/kg/day had no effect on implantation, delivery, 

postnatal survival, behavior, functional test results, or absolute organ weights of offspring. 

Reference: Tanaka et al., 1981 

Type: Prenatal developmental toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 20 pregnant females/dose 

Purity: not reported 

3-14
Doses: 0, 25, 100, and 400 mg/kg/day 

Vehicle: Corn oil 

Exposure duration, frequency: Once by oral gavage daily on gestational days 6-15 

Method: Body weight, food consumption, clinical signs, pregnancy rates, and necropsy of dams; 

uterine contents (including implants and resorption) at day 19 of gestation, corpora lutea; fetal 

viability and weight, crown-rump length, external, visceral (1/3 fetuses), and skeletal 

abnormalities; extensive statistical analyses. 

Results: High-dose dams exhibited clinical signs (urine stains, hunched appearance, and 

alopecia); sporadic signs of urine stains and hunched appearance occurred in a few mid-dose 

dams, but not at the low-dose. Food consumption was statistically lower in mid-dose dams on 

days 7-11 and in high-dose group throughout (days 7-15). During Days 6-11, significant 

(p<0.05) reductions in body weight gain in mid-dose dams and mean body weight loss at the 

high dose; on days 11-15, only high-dose dams showed reduced body weight gain. Overall body 

weights reduced in high-dose dams. TDCPP had no effect on implantation efficiency or mean 

number of corpora lutea. Treatment at the high dose significantly (p<0.05) increased the number 

of resorptions (to 14.4% compared to 6.7% in controls) and reduced fetal viability (to 85.6% 

compared to 93.3% for controls). Decreased skeletal development in the high-dose groups is 

related to growth retardation and decreased fetal size. The incidence of malformations was not 

related to treatment. The study indicates a NOAEL of 25 mg/kg/day and a LOAEL of 100 

mg/kg/day for maternal toxicity (clinical signs and transient reduction in body weight gain) and a 

NOAEL of 100 mg/kg/day and a LOAEL of 400 mg/kg/day for developmental toxicity 

(increased resorptions and fetal mortality). 

Reference: Hazleton, 1978 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

No studies with the specific designs of the two tests listed above were available. 

CHRONIC TOXICITY 

Conclusion: 

The available chronic toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The combined chronic toxicity/carcinogenicity assay in dietarily exposed rats is consistent with 

the guideline (Freudenthal and Henrich, 2000; Bio/Dynamics, 1980). 

3-15
• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

No studies of this type were located. 

Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

The protocol of a 2-year feeding bioassay in rats was consistent with this guideline (Freudenthal 

and Henrich, 2000; Bio/Dynamics, 1980). The published article focused on tumor results rather 

than non-neoplastic effects. 

Type: Combined oral chronic toxicity and carcinogenicity assay 

Species, strain, sex, number: Rat, Sprague-Dawley, 60/sex/group 

Purity: 95% 

Doses: 0, 5, 20, and 80 mg/kg body weight/day 

Vehicle: None other than feed 

Route: In feed; diets blended weekly to achieve target doses 

Exposure duration, frequency: 2 years, ad lib 

Method: Examined twice daily for mortality and clinical signs, weekly physical examination. 

Body weights and food consumption weekly for the first 13 weeks and biweekly thereafter. 

Ophthalmoscopic examinations every 6 months. Extensive hematology, clinical chemistry and 

urinalysis parameters at 3, 6, 12, 18, and 24 months. Ten/sex/dose randomly chosen for 

termination at 12 months; the remainder at 24 months. Gross necropsy including organ weights 

(8 organs plus gonads); histopathology of more than 30 tissues in control and high-dose rats; at 

low- and mid-doses, histopathology limited to liver, kidneys, testes, and adrenals. Statistical 

analyses. 

Results: The following changes compared to controls were statistically significant (p<0.05). 

Mortality increased in high-dose males (to 61.7% vs 43.3% for controls). Lower body weights 

in high-dose males and females. Treatment had no effect on feed consumption. Signs of anemia 

(lower hemoglobin, hematocrit, erythrocyte counts) in high-dose rats. At the mid-dose, 

increased absolute and relative kidney weight males and females, absolute liver weight and 

relative thyroid weight in males, and relative liver weight in females. At the high dose, 

increased relative liver weight in males and absolute and relative thyroid weights in females. 

Increases in the incidences of the following nonneoplastic lesions were statistically significant 

(p<0.05) in treated groups compared to the control groups; changes were not strictly dose-related 

in that incidences were depressed in high-dose groups. Kidney lesions (convoluted tubule 

hyperplasia) in males at $20 mg/kg/day and in females at 80 mg/kg/day. Other systemic lesions 

at 80 mg/kg/day involved the parathyroid (hyperplasia) in males and the liver (foci) and spleen 

(erythroid/myeloid hyperplasia) in females. Reproductive system lesions in males involved 

seminal vesicles (atrophy, decreased secretory product) at $5 mg/kg/day, testes (eosinophilic 

material in lumen, periarteritis nodosa) at $20 mg/kg/day, and epididymis (oligospermia and 

degenerated seminal product) at 80 mg/kg/day. (Tumor incidences are reported below under 

Carcinogenicity.) The authors reported the lowest dose of 5 mg/kg/day as a NOAEL and the 

3-16
mid-dose of 20 mg/kg/day as a LOAEL. However, as evaluated in NRC (2000), the lowest dose 

of 5 mg/kg/day was a LOAEL for atrophy and decreased secretory product of the seminal 

vesicle. 

Reference: Freudenthal and Henrich, 2000; also Bio/Dynamics (1980), fiche 27 of 32 and 

Bio/Dynamics (1981) fiche 6 of 6. 

CARCINOGENICITY 

Conclusion: 

The available carcinogenicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Increased tumor incidences were observed in a combined chronic toxicity/carcinogenicity assay 

in rats exposed to TDCPP in the diet (Freudenthal and Henrich, 2000). 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

No studies of this type were located. 

Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

A 2-year feeding bioassay by Freudenthal and Henrich (2000) was consistent with this guideline. 

Type: Combined oral chronic toxicity and carcinogenicity assay 

Species, strain, sex, number: Rat, Sprague-Dawley, 60/sex/group 

Purity: 95% 

Doses: 0, 5, 20, and 80 mg/kg body weight/day 

Vehicle: None other than feed 

Route: In feed; diets blended weekly to achieve target doses 

Exposure duration, frequency: 2, ad lib 

Method: See description above under Chronic Toxicity 

Results: The following neoplastic changes compared to controls were statistically significant 

(p<0.05). Dose-related increased incidences at $20 mg/kg/day of renal cortical adenomas in 

both sexes and testicular interstitial tumors in males, and at 80 mg/kg/day, of hepatocellular 

adenomas and carcinomas combined in both sexes and adrenal cortical adenomas in females. 

The NRC (2000) concluded that this study provides sufficient evidence of carcinogenicity of 

TDCPP in rats following chronic oral exposure. 

Reference: Freudenthal and Henrich, 2000; also Bio/Dynamics (1980, 1981) 

3-17
NEUROTOXICITY 

Conclusion: 

The available neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The delayed neurotoxicity component is satisfied by the existing data, but a developmental 

toxicity study by Tanaka et al. (1981) that included postnatal behavioral examinations did not 

fully satisfy the developmental neurotoxicity component. TDCPP gave negative results in single 

acute and subchronic oral delayed neurotoxicity studies in hens and in limited postnatal testing 

in rats exposed during gestation. A 2-year feeding bioassay in rats by Freudenthal and Henrich, 

2000; Bio/Dynamics, 1980), discussed above under the Chronic Toxicity and Carcinogenicity 

endpoints, reported no lesions of the cervical spinal cord, but a slight (not statistically 

significant) increase in the incidence of gliomas of the brain in rats exposed to TDCPP at 80 

mg/kg/day. The study authors could not determine whether this effect was related to exposure. 

Delayed Neurotoxicity 

Conclusion: 

The available delayed neurotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Several acute studies and one subchronic study for delayed neurotoxicity in the hen, summarized 

below, give no evidence of acute cholinergic toxicity, inhibition of neurotoxic esterase (NTE) 

activity, or delayed neurotoxicity for TDCPP. These studies, performed prior to the existence of 

the guidelines, do not entirely conform to current guidelines, and may lack detail such as the 

purity of the TDCPP sample. The lack of significant NTE inhibition following dosing with 

10,000 mg/kg suggests that no additional testing for delayed neurotoxicity is needed for TDCPP. 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Unpublished industrial acute (1- or 5-day) and subchronic (90-day) delayed neurotoxicity assays, 

which pre-date the guideline, are missing some details. One acute study employed a gavage dose 

5 times higher than now specified under the guideline. The subchronic assay had a longer 

duration and a larger group size than specified under the guideline. 

3-18
Critical Studies 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Hen, White Leghorn, 4/dose 

Purity: Fyrol FR-2, purity not reported, clear colorless liquid 

Doses: 420 mg/kg (highest dose specified in protocol) 

Vehicle: test substance diluted 50% in corn oil 

Positive control: 90 or 120 mg/kg/day tri-ortho-tylol phosphate (TOCP) 

Route: Gavage 

Exposure duration, frequency: Once daily on five consecutive days 

Method: Navy MIL-H-19457B (SHIPS) protocol. Hens were weighed and graded on days 7, 9, 

11, 14, 16, 18, 21, and 23 after the first dose for no signs, doubtful/minor signs, positive paralytic 

signs, advanced paralytic signs, or death. Scores on the 21st day were compared with results for 

TOCP. Necropsy not performed. 

Results: No overt signs of neurotoxicity in with TDCPP treatment. Positive control caused 

inability to walk, hypertension, ataxia, and prostration. 

Reference: Bullock and Kamienski, 1972 as described in WHO, 1998; Stauffer 1972a 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Hen, White Leghorn, 4/dose for TDCPP, 3/dose for controls 

Purity: Fyrol FR-2, clear colorless liquid; one part of the report stated that the purity was not 

reported, whereas another part of the report indicated purity >99%. 

Doses: 10,000 mg/kg 

Vehicle: None 

Positive control: 500 mg/kg tri-ortho-cresyl phosphate (TOCP) 

Negative control: 15 mg/kg tetraethyl pyrophosphate (TEPP) 

Route: Oral gavage 

Exposure duration, frequency: Once 

Method: Twenty minutes before dosing, hens received atropine and 2-PAM to protect against 

cholinergic effects. Hens were observed for toxic signs at 2-hour intervals for the first 8 hours. 

Mortalities were recorded after 24 hours. Brains were harvested 24 hours after dosing and 

analyzed for neurotoxic esterase (NTE) activity. 

Results: Toxic signs were not reported specifically for TDCPP, but for all compounds tested at 

the maximum tolerated dose, signs included listlessness and ataxia. Inhibition of NTE activity 

was 7% for TDCPP and the negative control TEPP, but 85% for the positive control (TOCP). 

The current guideline specifies that testing is not necessary at doses above 2,000 mg/kg. 

Reference: Stauffer, 1978 

Type: Subchronic oral delayed neurotoxicity 

Species, strain, sex, number: Hen, adult, White Leghorn, 10/dose 

Purity: Not reported 

Doses: 0, 4, 20, and 100 mg/kg/day 

Vehicle: Not reported 

Route: Oral Gavage 

3-19
Exposure duration, frequency: 90 days, daily 

Method: Body weight. Daily observations for mortality and behavioral changes; evaluated for 

signs of motor weakness 3 times per week. At termination, hens were necropsied and brain 

(multiple sections), sciatic nerve, and spinal cord (cervical, thoracic and lumbar) were examined 

histopathologically. TOCP was the positive control. 

Results: Hens treated with TDCPP at the high dose exhibited mean reductions in body weight 

during the latter part of the study, but no overt signs of neurotoxicity and no histopathological 

effects in the nervous tissues. Conversely, the positive control hens exhibited consistently lower 

body weight gain, clinical signs of toxicity (locomotor impairment and ataxia) that became more 

severe with time. Histopathology results were not reported for the positive control. 

Reference: Robust summary from Akzo-Nobel, 2001a; unpublished, unidentified study dated 

1979 

Neurotoxicity (Adult) 

Conclusion: 

The available adult neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The chronic oral bioassay by Freudenthal and Henrich (2000; Bio/Dynamics,1980, 1981) 

reported no lesions of the brain or spinal cord in rats exposed to TDCPP at doses as high as 80 

mg/kg/day for 2 years, but no functional tests of neurotoxicity were performed. 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

No studies of this type were located. 

Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS Harmonized 

Guideline 870.6300) 

Conclusion: 

The available developmental neurotoxicity data were judged inadequate to meet the endpoint, 

although the available tests suggest that TDCPP is not a developmental neurotoxin. 

Basis for Conclusion: 

No studies of this specific design were located. A Japanese-language gavage study by Tanaka et 

al. (1981), described above under Developmental Toxicity, included postnatal neurobehavioral 

tests (open field, water maze, rota rod, inclined screen, pain reflex, and Preyer’s reflex) of 

sensory and motor function in rats. Full descriptions of these tests were not available in the 

3-20
English summary and therefore could not be compared to the guideline protocol. The study 

reported no adverse effect in these tests for offspring of dams that were exposed on gestational 

days 7-15 at doses as high as 200 mg/kg/day (the highest tested non-lethal dose that was a 

LOAEL for increased kidney weight). This study does not fully satisfy the developmental 

neurotoxicity endpoint because it omitted some parameters specified under the guideline: 

developmental landmarks for sexual maturity, auditory startle test, and neurohistopathological 

examinations. 

Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) 

• OPPTS Harmonized Guideline 870.6500 

• Peripheral Nerve Function (rodent) 

• OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred) 

• OPPTS Harmonized Guideline 870.6855 

These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, 

or because of structural similarity of the substance to neurotoxicants that affect these endpoints. 

These studies may be combined with other toxicity studies. 

Conclusion: These endpoints do not appear to be applicable to TDCPP. 

Basis for Conclusion: Although there are no studies addressing these endpoints, there are no 

reliable data for TDCPP, and no structure-activity considerations, that indicate a need for these 

follow-up studies. 

Other Neurotoxicity Data 

Cholinesterase inhibition 

Fyrol FR-2 administered at 0, 2,000, or 3,980 mg/kg in corn oil was administered to groups of 10 

male Sprague-Dawley rats by oral gavage had no effect on plasma or erythrocyte cholinesterase 

levels measured 4 or 14 hours after dosing (Stauffer, 1972b). 

IMMUNOTOXICITY 

Conclusion: 

The available immunotoxicity data were judged inadequate to meet the endpoint. 

3-21
Basis for Conclusion: 

The only study evaluating the potential immunotoxicity of TDCPP (Luster et al., 1981) predates 

the guideline for immunotoxicity (note that the OPPTS guideline cites other works by this 

author). There is some uncertainty as the test material, reported as Fyrol FR2, but mis-identified 

by the authors as tris(2,3-dichloropropyl) phosphate. The study methods differed from the 

guideline in the short exposure period (4 rather than 28 days), parenteral administration (rather 

than oral or inhalation route), measurement of serum immunoglobulins in non-immunized rather 

than immunized mice, and the omission of some tests (enumeration of immunological cell 

subpopulations, test for NK-cell activity). The results do not provide dose–response information 

as to immunotoxicity of TDCPP following subchronic exposure by oral or inhalation routes of 

exposure. 

Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

Critical study 

Type: Immunotoxicity, subcutaneous, acute 

Species, strain, sex, number: Mouse, B6C3F1, 6-8 females/dose 

Doses: 0, 0.25, 2.5, or 25 mg/kg/day (Total cumulative doses of 0, 1, 10, or 100 mg/kg) 

Identity: Stauffer Fyrol FR-2, lot 4670-3-23. This is the same lot as TDCPP tested in the 2-year 

oral assay by Freudenthal and Henrich (2000) 

Purity: Stauffer, purity >95% 

Vehicle: Corn oil 

Route: Subcutaneous injection 

Exposure duration, frequency: 4 days, once daily 

Method: Observations included body weight, hematology, clinical chemistry (5 parameters) 

terminal necropsy, organ weights (liver, spleen and thymus), histopathology of spleen, thymus, 

and eight other organs, plaque-forming assay response to sheep red blood cells, and serum 

immunoglobulin quantification (non-immunized mice only). Non-guideline tests included 

proliferative capacity of granulocyte-macrophage progenitor cells (bone marrow), in vitro 

lymphoproliferative (LP) responses to mitogens, delayed hypersensitivity response to keyhole 

limpet hemocyanin. Extensive statistical analysis. 

Results: Twenty percent of high-dose mice exhibited lymphoid depletion of the thymus. 

Statistically significant decreases in vitro lipopolysaccharide (B-cell antigen) at 2.5 mg/kg/day 

and concanavalin A (T-cell antigen) at 25 mg/kg/day. 

Reference: Luster et al., 1981 

GENOTOXICITY 

Conclusion: The available genotoxicity data were judged adequate to meet the endpoint. 

3-22
C

Basis for Conclusion: 

TDCPP has been tested in in vitro and in vivo genotoxicity assays conducted in prokaryotic and 

eukaryotic cells under methods similar to guidelines. Results of in vivo tests (mutation in 

Drosophila, chromosomal aberration in mice) were negative, but positive results were reported 

in several in vitro assays (mutagenicity in bacterial and mammalian cells, chromosomal 

aberration). 

Gene Mutation in Vitro: 

Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA97, TA98, TA100, TA1535, TA1537 

Metabolic activation: Tested with and without S9 from livers of Aroclor-induced male 

Sprague-Dawley rats or male Hamsters 

Concentrations: 0, five concentrations between 10 and 10,000 :g/plate. 

Purity: 94.4% 

Method: Preincubation (20 minutes) and plate incorporation (48 hours) at 37°C. Positive 

controls were used; DMSO was the solvent. Triplicate plates per concentration. All assays 

repeated within 1 week. 

Results: In three different laboratories, TDCPP tested positive in strains TA97 and TA100 in the 

presence of S9 from Aroclor-induced hamster liver and in strain TA1535 in the presence of S9 

from Aroclor-induced rat or hamster liver. Positive controls gave expected increases. Solvent 

control and all other test combinations were negative. 

Reference: Mortelmans et al., 1986 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA98, TA100, TA1535, TA1537, TA1538 

Metabolic activation: Tested with and without Kanechlor 500 (PCB)-induced liver S9 from 

male Wistar rats 

Concentrations: 0, 10, 30, 100, and 300 :g/plate. 

Purity: Assayed as ~94% TDCPP, plus ~6% bis(1-chloromethyl-2-chloroethyl)(2,3­

dichloropropyl) phosphate. 

Method: Plate incorporation, 48-hour incubation at 37°C. Cited Ames protocol, which 

presumes the use of replicates and positive controls. 

Results: No increase in revertants in any strain without activation or in strains TA98, TA1537, 

or TA1538 with activation. Weak increases in TA100 and TA1535 at the highest concentrations 

with S9. 

Reference: Nakamura et al., 1979 

3-23
C

Additional Studies 

Other S. typhimurium assays in which S9 was prepared from phenobarbital-induced rat liver 

reported mutagenicity of TDCPP in strain TA98 by liquid preincubation assay (Abe and Urano, 

1994) and in TA100 by plate incorporation assay (Gold et al., 1978; Soederlund et al., 1985). 

Majeska and Matheson (1983) reported dose-related positive results for TDCPP and its 

metabolite 1,3-dichloro-2-propanol in TA100 with S9 (phenobarbital-induced) in standard plate 

assays at concentrations up to 500 :g/plate. In a liquid preincubation quantitative assay, results 

for TDCPP were essentially negative—only increasing mutation frequencies at cytotoxic 

concentrations (survival <3%). However, its metabolites increased mutant frequencies with less 

cytotoxicity: 1,3-dichloro-2-propanone positive at <80% survival and 1,3-dichloro-2-propanol 

positive at <30% survival. 

TDCPP was not mutagenic in S. typhimurium strains TA100, TA1535, or TA1538 without 

activation or when Aroclor-induction was used to prepare the S9 fraction (Prival et al., 1977); 

the highest exposure level was 10 :L per plate. 

In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

Type: Mammalian Cell Gene Mutation Test: Forward Mutation 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: Tested with and without phenobarbital-induced liver S9 from male mice 

Concentrations: 0, and five concentrations up to ~32 nL/mL without S9, and six concentrations 

up to 70 nL/mL with S9. Test conditions chosen based on preliminary assays so that 50% 

growth reduction occurred at highest concentration. 

Purity: Not reported 

Method: Selection of forward mutation from TK+/- to TK-/- genotype. Activity compared to 

tris(2,3-dibromopropyl)phosphate (TBPP). 

Results: TDCPP yielded negative results with or without activation. TBPP was negative 

without, but positive with activation. 

Reference: Brusick et al., 1979; also Litton Bionetics, Inc., 1977 

Type: Mammalian Cell Gene Mutation Test: Forward Mutation 

Species, strain: V79 Chinese hamster lung cells 

Metabolic activation: Tested with phenobarbital-induced liver S9 from male rats 

Concentrations: 0, 0.02 mM TDCPP. Test conditions chosen based on preliminary assays. 

Purity: Not reported 

Method: In two experiments, selection of 6-thioguanine-resistant colonies. Activity compared 

to tris(2,3-dibromopropyl)phosphate (TBPP). 

Results: TDCPP with S9 did not increase mutation frequency. TBPP yielded positive results. 

Reference: Soederlund et al., 1985 

3-24
Gene Mutation in Vivo: 

C Sex-linked Recessive Lethal test in Drosophila melanogaster (OPPTS Harmonized 

Guideline 870.5275) 

Type: Sex-linked Recessive Lethal test 

Species, strain: Drosophila melanogaster, 100 males/concentration 

Metabolic activation: None 

Concentrations: 2.5 and 25% in feed (1% gum tragacanth in 3% sucrose) 

Purity: Technical-grade Fyrol FR-2, purity not reported 

Method: TDCPP added to feed of males for 24 hours, subsequently mated with virgin 

unexposed females 

Results: No evidence of toxicity or increase in the percentage of sex-linked recessive lethal 

mutations. 

Reference: Brusick and Jagannath, 1977 as described in WHO, 1998; also Litton Bionetics, Inc., 

1976 

Chromosomal Aberration in Vitro: 

C In Vitro Mammalian Chromosome Aberration Test (OPPTS Harmonized Guideline 

870.5375) 

Type: In vitro chromosome aberration assay 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: None, phenobarbital-induced or PCB-induced 

Concentrations: 0, 0.01 to 0.1 :L/mL for non-induced, phenobarbital-induced or PCB-induced 

mouse 

Purity: Not reported 

Method: 4-hour exposure to TDCPP with or without activation. Chromosomal aberrations 

scored in 50 metaphase spreads per concentration. 

Results: TDCPP caused increases chromosomal aberrations (up to 40%) with PCB- or 

phenobarbital-induction compared to noninduced S9. 

Reference: Brusick et al., 1979; also Litton Bionetics, Inc., 1977 

Additional Information 

One confidential study reported negative results for TDCPP in cultured Chinese hamster ovary 

cells with or without metabolic activation. Another confidential study reported positive results 

in human lymphocytes with metabolic activation. 

C In vitro Sister Chromatid Exchange Assay (OPPTS Harmonized Guideline 

870.5900) 

Type: In vitro sister chromatid exchange assay 

3-25
Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: None, phenobarbital-induced or PCB-induced 

Concentrations: 0, 0.005-0.03 :L/mL for phenobarbital-induced (4 concentrations), and 6 

concentrations up to 0.070 :L/mL for non-induced or PCB-induced mouse 

Purity: Not reported 

Method: Ten cells per concentration were analyzed. 

Results: TDCPP increased the incidence of sister chromatid exchanges in mouse lymphocytes 

under all three test conditions. 

Reference: Brusick et al., 1979; also Litton Bionetics, Inc., 1977 

Additional Information 

One submitted confidential study reported negative results in a sister chromatid exchange assay. 

The data for this study are not adequate because the cell line was not identified. Fyrol FR-2 did 

not induce sister chromatid exchanges when applied to 3- to 4-day-old chicken embryos (Bloom, 

1984). 

Chromosomal Aberration in Vivo: 

C	 Mammalian Bone Marrow Chromosomal Aberration Test (OPPTS Harmonized 

Guideline 870.5385) 

The available study provides sufficient evidence that TDCPP did not induce chromosomal 

aberrations in mice exposed at the maximum tolerated dose of 760 mg/kg. 

Type: Bone marrow chromosomal aberration in vivo 

Species, strain: Mouse, CD-1, 4-8 males/group 

Metabolic activation: None 

Concentrations: 0, 0.05, 0.17, and 0.5 mL/kg; using the specific gravity of 1.52, the doses were 

0, 76, 260, or 760 mg/kg. The highest dose was the maximum tolerated dose. Negative control 

was DMSO 

Exposure duration, frequency: By oral gavage in once or daily on 5 consecutive days. 

Purity: Technical grade; Not reported 

Method: Mice were sacrificed at 6, 24, and 48 hours after single dose or 6 hours after the last of 

5 doses. Between 233 and 400 cells were scored, rather than 500/animal. Triethylenemelamine 

was positive control. 

Results: No evidence of increased frequency of chromosomal aberrations with TDCPP. TBPP 

was also negative at doses up to 1,000 mg/kg. Positive control produce expected large increase 

in micronucleated polychromatic erythrocytes. 

Reference: Brusick et al., 1979; Litton Bionetics, Inc., 1978 

C Mammalian erythrocyte micronucleus test (OPPTS Harmonized Guideline 

870.5395) 

3-26
C

TDCPP administered as 2,000 mg/kg by an unspecified route to mice did not induce micronuclei 

in bone marrow erythrocytes (Thomas and Collier, 1985 as reported in WHO, 1998). 

DNA Damage and Repair 

Unscheduled DNA synthesis in mammalian cells in culture (OPPTS Harmonized 

Guideline 870.5550) 

Type: Unscheduled DNA synthesis in mammalian cells (hepatocytes) in culture 

Species, strain: Rat, Wistar, male 

Metabolic activation: With or without phenobarbital-induction 

Concentrations: 0, 0.05, and 0.1 mM 

Purity: Not reported 

Vehicle: DMSO 

Method: Cultured hepatocytes exposed to TDCPP or TBPP for 18-19 hours. Incorporation of 

radiothymidine into DNA. 

Results: TDCPP was not genotoxic at 0.05 mM, but at 0.1 mM, a moderate response was 

observed in hepatocytes from untreated rats, but not phenobarbital-treated rats. TBPP, the 

positive control, yielded positive results in induced and non-induced hepatocytes. 

Reference: Soederlund et al., 1985 

Additional Information 

A confidential study reported negative results for TDCPP and its metabolites (not identified) in 

cultured primary hepatocytes from male Sprague-Dawley rats. 

3-27
Ecotoxicity 

Aquatic Organism Toxicity 

Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 850.1075; 

OECD Guideline 203) 

Conclusion: 

The available acute toxicity data for freshwater fish (cold- and warm-water species) and 

saltwater fish were judged inadequate to meet the endpoint. The available acute fish toxicity 

studies are summarized in Table 3-1. However, if the results of the SafePharm study (1993a), 

cited by IPCS (1998) (see below), are confirmed independently, the acute toxicity data for cold 

freshwater fish species might meet the endpoint given the high degree of agreement of the two 

available studies in rainbow trout. 

Basis for Conclusion: 

Freshwater Fish 

Ahrens et al. (1979) tested the toxicity to goldfish (Carassius auratus) of tris (1,3-dichloro-2­

propyl) phosphate (TDCPP) released from fabric treated with the flame retardant. Laundered or 

unlaundered sections of garment that had been treated with Fyrol FR-2, were placed in tanks 

with six goldfish. Fish in the tank with the unlaundered section became sluggish and all died 

within 3 hours. The concentration of Fyrol FR-2 in the test water reached 30 mg/L. Fish 

exposed for 96 hours to the laundered section of garment did not exhibit signs of toxicity. In 

another study, TDCPP in water at 1 mg/L was not toxic to goldfish after 168 hours, but 5 mg/L 

of TDCPP killed all (6/6) goldfish within 24 hours (Eldefrawi et al., 1977). The studies by 

Ahrens et al. (1979) and Eldefrawi et al. (1977) did not evaluate toxicity using a range of 

concentrations of TDCPP in water and, thus, cannot be used to derive an LC50. 

Sasaki et al. (1981) estimated that the 96-hour LC50 values for killifish (Oryzias latipes) and 

goldfish were 3.6 mg/L and 5.1 mg/L, respectively. It appears that mortality was not evaluated 

in a control group of fish. It is unclear if the TDCPP concentrations in water reported by Sasaki 

et al. (1981) are measured or nominal values. The latter point is important because a parallel 

study indicated that the amount of TDCPP added to test water declines rapidly and less than 40% 

of the original amount of TDCPP remains in the test water after 96 hours (Sasaki et al., 1981). 

Thus, the lethal concentrations of TDCPP could be lower than the reported LC50 values. 

Sasaki et al. (1981) reported deformation of the spine in 7/10 killifish exposed to 3.5 mg/L 

TDCPP for 24 hours. However, Sasaki et al. (1981) do not provide sufficient information 

regarding the spine deformation in killifish to make meaningful use of these observations. It is 

unclear whether the deformations were observed in the acute toxicity study or in a separate assay 

using killifish only. It appears that deformation was tested at only one concentration and a 

control group of fish was not evaluated. 

3-28
Another study showed that the 96-hour LC50 of TDCPP in rainbow trout (currently classified as 

Oncorhynchus mykiss) was 1.4 mg/L (95% CI: 0.9-1.9 mg/L) (Unpublished study conducted in 

1990, summarized in Akzo-Nobel, Inc., 2001a,b). A NOEC was not observed since one fish 

died at 0.63 mg/L, the lowest concentration tested. Compound purity was not provided in the 

summary and the reported concentrations of TDCPP in the test water appear to be nominal 

values. The guideline for acute toxicity in fish (OPPTS 850.1075) indicates that test 

concentrations must be measured during the test if, as was the case in this study, aeration is used. 

Thus, the study reported by Akzo-Nobel, Inc. (2001a,b) does not meet the criteria established by 

the guideline. The studies by Sasaki et al. (1981) and Akzo-Nobel, Inc. (2001a,b) suggest that 

the 96-hour LC50 for TDCPP in fish is in the range of 1 to 5 mg/L, making it moderately toxic to 

fish. However, the data are inadequate to satisfy the acute toxicity endpoint for freshwater fish. 

A 96-hour LC50 of 1.1 mg/L and a NOEC of 0.56 mg/L for TDCPP in rainbow trout 

(SafePharm, 1993a) were reported in IPCS (1998). Although the results of the study by 

SafePharm (1993a) are in agreement with those of Akzo-Nobel, Inc. (2001a,b), the study by 

SafePharm (1993a), or a study summary, was not available to allow for an independent 

evaluation of these data. Confirmation of the results of the study by SafePharm (1993a) might 

allow the acute toxicity endpoint for freshwater fish to be satisfied. 

Marine Fish 

No acute toxicity studies in saltwater fish species were located. 

3-29
Table 3-1. Summary of available acute fish toxicity studies for tris(1,3-dichloro-2-propyl)phosphate [TDCPP] (CASR

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Ahrens et al., 1979 

Goldfish (Carassius auratus) 

None Static None 6 Yes. The 

concentration of Fyrol FR-2 in water was determined by gas chromatograp hy. 

pH: NR Temp: 20°C DO: NR Hardness: NR Water volume: 20 L Electrical conductivity: 290 micromhos/cm 

None 

3-30
Table 3-1. Summary of available acute fish toxicity studies for tris(1,3-dichloro-2-propyl)phosphate [TDCPP] (CASR

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

AkzoNobel, Inc., 2001a,b (Study conducted in 1990) 

Rainbow trout (Salmo gairdneri) 

1.4 mg/L (95% CI: 0.9-1.9 mg/L) 

Static Controls, 0.63, 

1.25, 2.5, 5, 10 mg/L 

10 No pH: 7.14-7.78 

Temp: 11.8-14.8 °C. DO: 92-100% of air saturation value Hardness: 218-228 mg/L as CaCO3. 

None reported 

3-31
Table 3-1. Summary of available acute fish toxicity studies for tris(1,3-dichloro-2-propyl)phosphate [TDCPP] (CASR

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Eldefrawi et al., 1977 

Goldfish (Carassius auratus) 

None Static 1 and 5 mg/L in 

water 

6 None 

reported 

pH: NR Temp: 20°C DO: NR Hardness: NR Electrical conductivity: 290 

micromhos/cm 

Water or acetone 

3-32
Table 3-1. Summary of available acute fish toxicity studies for tris(1,3-dichloro-2-propyl)phosphate [TDCPP] (CASR

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Sasaki et al., 1981 

Killifish (Oryzias latipes) 

Killifish: 3.6 mg/L 

Static NR 7 to 9 Unclear if 

conducted 

pH: NR Temp: 25°C. DO: NR Hardness: NR Electrical conductivity: NR 

NR 

Goldfish (Carassius auratus) 

Goldfish: 5.1 mg/L 

aStudies that were either published in a foreign language or that were not readily and that were not critical to the hazard assessment were not retrievebNR: Not reported 

3-33
Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD 202) 

Conclusion: 

The available acute toxicity data for freshwater invertebrates were judged inadequate to meet the 

endpoint. However, if the results of the study cited by IPCS (1998) (see below) are confirmed 

independently, the data might meet the endpoint given the high degree of agreement of the two 

available studies in freshwater invertebrates. 

Basis for Conclusion: 

The available data are summarized in Table 3-2. A flow-through study revealed a 48-hour LC50 

of TDCPP with Daphnia magna of 3.8 mg/L (95% CI: 3.5-4.2 mg/L) and a NOEC of 1.6 mg/L 

(Unpublished study conducted in 1999, summarized in Akzo-Nobel, Inc., 2001a,b). Although 

some of the conditions of the study design (such as number of organisms, and water temperature 

and chemistry) appear to meet OPPTS Harmonized Guideline 850.1010, other aspects of the 

study, including compound purity and condition and fertility of the organisms in culture, were 

not reported in the summary. The amount of solvent used in the control group and the TDCPP 

treatments might have exceeded the recommended maximum solvent concentration, as per the 

OPPTS Guideline (100 mg/L), but this does not appear to have affected the study results. A 48­

hour LC50 of 4.6 mg/L and a NOEC of 1.8 mg/L were reported for daphnia in a study by 

SafePharm (1993b), as cited in IPCS (1998). Although the results of the study by SafePharm 

(1993b) are in agreement with those of Akzo-Nobel, Inc. (2001a,b), the study by SafePharm 

(1993b), or a study summary, was not available to allow for an independent evaluation of these 

data. Confirmation of the results of the study by SafePharm (1993b) might allow the acute 

freshwater invertebrate toxicity endpoint to be satisfied. 

Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

Conclusion: 

No available acute marine/estuarine invertebrate toxicity data. 

Basis for Conclusion: 

No acute toxicity studies in marine/estuarine invertebrate species were located. 

3-34
Table 3-2. Summary of available acute invertebrate toxicity studies for tris(1,3-dichloro-2-propyl)phosphate [TDCPP] (CA

Study Reference 

Species Tested 

48-Hour LC50 

Selected Study Design Parameters 

Com

Study Type 

Concentrations Tested 

No. of Organisms/ Concentration 

Analytical Monitoring 

Water Chemistry Solvent 

AkzoNobel, Inc., 2001a,b (Study conducted in 1999) 

Daphnia magna 

3.8 mg/L (95% CI: 3.5­4.2 mg/L) 

Flowthrough Negative control, solvent control 

(dimethylformamide), 0.98, 1.6, 2.8, 3.8, 5.1 mg/L 

10 Yes pH: 8.3 

Temp: 20±2°C DO: $8.5 mg/L (94% of air saturation value) Hardness: 126 mg/L as CaCO3. 

Dimethylformamide Daph

solvenormthe 0Mortmg/L 80%(15%were termThe the cTDCto be This maxiof 10based dime0.1 mof 30of 0.

aStudies that were either published in a foreign language or that were not readily and that were not critical to the hazard assessment were not retrieve

3-35
Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

Conclusion: 

No available chronic toxicity data for freshwater and marine fish. 

Basis for Conclusion: 

No chronic toxicity studies in freshwater and marine fish were located. 

Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1300; 

OECD 211) and Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized 

Guideline 850.1350) 

Conclusion: 

No available chronic toxicity data for freshwater and marine/estuarine invertebrates. 

Basis for Conclusion: 

No chronic toxicity studies in freshwater and marine/estuarine invertebrates were located. 

Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Conclusion: 

The available algal toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are summarized in Table 3-3. The summary of a 96-hour algal toxicity study 

(Unpublished study conducted in 1992, summarized in Akzo-Nobel, Inc., 2001a,b) indicates that 

the study does not meet the OPPTS Harmonized Guideline 850.5400. The pH and temperature 

of the test water during the study were outside of the acceptable ranges for Selenastrum 

capricornutum, as per Guideline 850.5400. Moreover, the two highest concentrations tested 

exceed the estimated water solubility of TDCPP (42 mg/L) and the concentrations tested were 

apparently not verified analytically. Additional information, including test substance purity, 

hardness, DO, TOC, TSS, exposure vessel size and head space, and measured chemical 

concentrations, were not provided in the summary. Also, there is no evidence that positive 

controls were used in order to establish that the algae were responding in the expected manner to 

a known chemical. The deviations from the OPPTS Guideline indicate that the study is 

inadequate to satisfy the algal toxicity endpoint. Another study indicates that TDCPP at 10 mg/L 

had no effect on growth or biomass of the algal species Scenedesmus subspicatus exposed for 72 

3-36
hours (Unpublished study conducted by SafePharm, 1994, cited in IPCS, 1998). The study, or a 

study summary, was not available for the study by SafePharm (1994) to allow for an independent 

evaluation of these data. 

3-37
Table 3-3. Summary of available algal toxicity studies for tris(1,3-dichloro-2-propyl)phosphate [TDCPP] (CASRN: 

Study Reference 

Species Tested 

EC50, NOAEC, 

and LOAEC 

Selected Study Design Parametersb 

Study Type 

Concentration Range Tested 

Analytical Monitoring 

Water Chemistry Solvent 

AkzoNobel, Inc., 2001a,b (Study conducted in 1992) 

Selenastrum capricornutum 

96-hour EbC50 (biomass) = 12 mg/L (95% CI: 10-15 mg/L). 96-hour ErC50 (growth rate) = 39 mg/L (95% CI: 31-50 mg/L). 96-hour NOAEC: 6 mg/L. 

Static 0 (negative 

control), 2, 6, 18, 54, or 162 mg/L 

No Temp: 21°C 

pH: 6.7-7.9 DO: NR Hardness: NR 

None reported 

aStudies that were either published in a foreign language or that were not readily and that were not critical to the hazard assessment were not retrieveb NR: Not reported. 

3-38
Terrestrial Organism Toxicity 

Acute Oral (OPPTS Harmonized Guideline 850.2100), Dietary (OPPTS Harmonized 

Guideline 850.2200; OECD Guideline 205), or Reproductive Toxicity (OPPTS Harmonized 

Guideline 850.2300; OECD Guideline 206) in Birds 

Conclusion: 

No available acute oral, dietary, and reproductive toxicity data. 

Basis for Conclusion: 

No acute oral, dietary, or reproductive toxicity studies in birds were located. 

Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

Conclusion: 

The available earthworm subchronic toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No earthworm subchronic toxicity studies were located. An acute (14-hour) LC50 of 130 mg/kg 

soil and a NOEC of 100 mg/kg soil with the earthworm, Eisenia fetida (SafePharm, 1996), were 

reported in IPCS 1998. However, the study has also been reported to be a 14-day subchronic 

toxicity study (NICNAS, 2001). The study, or a study summary, was not available for an 

independent evaluation of the study and the results. 

3-39
Physical/Chemical Properties 

Tris(1,3-dichloro-2-propyl) phosphate 

CAS 13674-87-8 

MF C9H15Cl6O4P 

MW 430.91 

SMILES ClCC(CCl)OP(=O)(OC(CCl)CCl)OC(CCl)CCl 

Physical/Chemical Properties 

Water Solubility: 

Conclusion: The available water solubility data are adequate.

Basis for Conclusion: The key study (highlighted) was performed according to a reliable

method, and is in reasonable agreement with other values reported in the literature. 

Solubility (mg/L) References 

42 Akzo Nobel, 2001a,b: Water Solubility determination according to OECD Guideline 

105 (shake-flask method) 

7 Aston et al., 1996 (24/C); Hollifield, 1979; SRC, 2004 (PHYSPROP Database, 24/C); 

HSDB, 2003 (24/C) 

100 Eldefrawi et al., 1977; WHO, 1998 (30/C); Budavari, 2001 (The Merck Index); Lewis, 

2000 (Sax’s Dangerous Properties of Industrial Materials) 

110 CERI, 1999 

18.1 Confidential submitted study using shake flask method 

Log Kow: 

Conclusion: The available log Kow data are adequate.

Basis for Conclusion: The key study (highlighted) was performed according to a reliable

method. 

Log Kow Reference 

2.4 Akzo Nobel, 2001a,b: Determination of Octanol-Water Partition Coefficient 

According to OECD Guideline 117 (HPLC Method) 

3.8 WHO, 1998 

3.65 SRC, 2004 (PHYSPROP Database); HSDB, 2003 

3.75 Shake-flask method, Sasaki et al., 1981 

3.69 Confidential submitted study using the HPLC method 

3-40
Oxidation/Reduction: No data 

Melting Point: 

Conclusion: The available melting point data for TDCPP are adequate. 

Basis for Conclusion: The key study (highlighted) was performed according to a reliable 

method. It is noted that the other literature data do not agree with the key study; however, the 

methods used to measure the melting points are not provided in any of the sources. As an 

OECD-guideline compliant method, the key study is better described and better supported. 

Melting Point (/C) References 

-58 Akzo Nobel, 2001a,b: melting point determination by DSC (compliant with OECD 

Guideline 102), freezing point was determined to be -40/C, melting point -58/C 

27 CERI, 1999 

26.66 Akzo Nobel, 2003 

Boiling Point: 

Conclusion: The boiling point data are adequate. 

Basis for Conclusion: A variety of literature sources report the same value for the boiling point,

although there is some indication that the compound may decompose at or near the boiling point. 

Since experimental details are not provided in any of the sources, it is not possible to determine

whether the temperatures reported are decomposition or boiling temperatures. Nevertheless,

given the high boiling point reported for this material, the available data are adequate to

characterize its potential volatility. 

Boiling Point (/C/torr) References 

236-237/5 SRC, 2004 (PHYSPROP database); Budavari, 2001 (The Merck Index); 

Lewis, 2000 (Sax’s Dangerous Properties of Industrial Materials); 

WHO, 1998 

200/4 Akzo Nobel, 2003 

Dec. >200/4 WHO, 1998 

Gradual Dec. >200 HSDB, 2003 

Vapor Pressure: 

Conclusion: The available vapor pressure data are not adequate 

Basis for Conclusion: Although this measured vapor pressure is reported in two sources, it 

appears to be very high relative to the boiling points reported for this chemical. For comparison, 

an estimated vapor pressure (EPIWIN) is also included in the table below. The vapor pressure 

remains a data need. 

3-41
Vapor Pressure (torr//C) Reference 

0.01/30 WHO, 1998; Akzo Nobel, 2001a,b 

2.98 x10-7 EPIWIN, 2000; v. 3.11 estimate 

Odor: 

Conclusion: The odor of this compound has been adequately characterized.

Basis for Conclusion: Although no standardized tests are available for characterizing chemical

odors, the two descriptions found are similar, and are consistent with the low volatility expected

for this chemical. 

Odor Reference 

Mild Odor HSDB, 2003 

Bland Odor Akzo Nobel, 2003 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: 

Conclusion: The flammability (as the flash point and autoignition temperature) has been 

adequately characterized. 

Basis for Conclusion: Studies on the flash point and autoingition temperature of this chemical 

were located and appear reasonable given the other physical/chemical properties available for 

this compound. 

Flash Point Reference 

252/C (coc) WHO, 1998; HSDB, 2003 

>107.22/C (Seta closed cup) Akzo Nobel, 2003 

Autoignition Temperature Reference 

512.77/C Akzo Nobel, 2003 

Explosivity: No data 

Corrosion Characteristics: No data 

3-42
pH: 

This chemical does not contain functional groups expected to influence the pH of aqueous 

solutions. Data for this endpoint are therefore not applicable. 

UV/Visible Adsorption: No data 

Viscosity: 

Conclusion: The viscosity of this chemical at various temperatures has been adequately

characterized. 

Basis for Conclusion: Studies on the viscosity of this chemical were located and appear

reasonable given the other physical/chemical properties available for this compound.

Viscosity (cP) Reference 

1,800 at 25/C WHO, 1998; Akzo Nobel, 2003 

2,200 at 0/C Akzo Nobel, 2003 

540 at 40/C Akzo Nobel, 2003 

Density/Relative Density/Bulk Density: 

Conclusion: The density of this compound has been adequately characterized. 

Basis for Conclusion: Consistent data are provided in several reputable sources. 

Density Reference 

1.52 at 25/C Specific gravity. WHO, 1998 

1.5022 at 20/C Specific gravity. Budavari, 2001 (The Merck Index); Lewis, 2000 (Sax’s Dangerous 

Properties of Industrial Materials) 

1.48 kg/L at 25/C Bulk density. HSDB, 2003 

Dissociation Constant in Water: 

This compound does not have functional groups that are expected to dissociate in water. This 

endpoint is therefore not applicable. 

Henry’s Law Constant: No data 

3-43
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: The bioconcentration factor has been adequately characterized. 

Basis for Conclusion: The two studies cited in the table below provide consistent information

for killifish under both static and flow-through conditions, over a variety of observation times,

and with varying initial concentrations of test substance. The BCF was also measured in

goldfish; the reported BCFs are independent of study length. 

Reference Species BCF 

Key Design Parameters 

Comments 

Exp. 

type 

Range 

(ppb) 

Study 

length T (/C) 

Sasaki et 

al., 1981 

Killifish 113 

110 

77 

Static 1,000 

initial 

24 hours 

55 hours 

96 hours 

25 Half-life for elimination 

of the test compound in 

water + fish = 31 hours. 

Sasaki et Goldfish 5 Static 1,000 24 hours 25 Half-life for elimination 

al., 1981 3 initial 96 hours of the test compound in 

water + fish = 42 hours. 

Sasaki et 

al., 1982 

Killifish 46±5 

32±4 

31±6 

59±16 

49±12 

Flowthrough 

(all) 

400 

300 

40 

40 

80 

3 days 

4 days 

6 days 

30 days 

32 days 

25 BCF is independent of 

concentration; continuous 

(flow-through) results 

correlate to static results 

(Sasaki et al., 1981). 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: 

Conclusion: The metabolism of TDCPP in fish is not adequately characterized in the literature. 

Basis for Conclusion: The depuration rate is adequately described in killifish, however, the 

metabolite distribution is not addressed. 

3-44
Species Rate Comment Reference 

Killifish Elimination half-life, 1.65 hours Depuration rate ­

elimination of TDCPP 

when exposed fish are 

moved to clean water. 

Sasaki et al., 1982 

Killifish Apparent metabolism is much 

faster in killifish than in goldfish. 

(Quantitative data are not 

provided.) 

~10% of applied TDCPP 

remains in the water in 

the presence of killifish 

after 96 hours. Control 

(no fish) has no change in 

TPP concentration. 

Sasaki et al., 1981 

Goldfish Apparent metabolism is much 

slower than in killifish. 

(Quantitative data are not 

provided.) 

~25% of applied TDCPP 

remains in the water after 

96 hours in presence of 

goldfish. 

Sasaki et al., 1981 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: The biodegradation of TDCPP under aerobic conditions has been adequately 

characterized. 

Basis for Conclusion: The key study (highlighted) was performed according to a GLPcompliant OECD guideline test. The other data located in the literature are generally in 

agreement with the key study. 

Study type/ 

Method Innoculum Acclim Degradation Time Comments Reference 

OECD 

Guideline 

301B 

Modified 

Sturm Test 

Activated 

sludge 

0% by CO2 

evolution. 

DOC red. not 

calculated 

due to 

solubility 

issues. 

28 days Initial concentrations 

2, 10 mg/L. GLPcompliant. 

Also reported: 

1) Closed bottle test 

(OECD Guideline 

301D) showed no 

inhibition of bacterial 

cultures in 10 days. 

Akzo Nobel, 

2001a,b; Akzo 

Chemicals 

Incorporated, 

1990 

3-45
Study type/ 

Method Innoculum Acclim Degradation Time Comments Reference 

Japanese 

MITI test 

Activated 

sludge 

avg. 1% by 

BOD 

28 days Initial concentrations 

100 mg/L (test 

substance), 30 mg/L 

(sludge). 

CERI, 1999; 

HSDB, 2003; 

Chemicals 

Inspection and 

Testing 

Institute, 1992 

OECD 302C 0% by O2 

uptake 

28 days WHO, 1998 

River DieAway Water from 

Oh River 

(Osaka, 

Japan) 

Neya River 

(Osaka, 

Japan) 

Seawater 

(Osaka Bay) 

12.5% 

18.5% 

0% 

5.4% 

0% 

22% 

7 days 

14 days 

7 days 

14 days 

7 days 

14 days 

Initial concentrations 

20 mg/L in Oh River 

water and 1 mg/L in 

Neya River water. 

Concentration in 

seawater not 

reported. 

Analysis by 

Molybdenum Blue 

calorimetric assay for 

increase in phosphate 

ion. 

WHO, 1998 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: 

Conclusion: The available pyrolysis data are not adequate. 

Basis for Conclusion: Although a semi-quantitative description of the pyrolysis products is

given in the Choudry and Hutzinger paper, the list of degradates provided accounts for only 60%

of the total mass expected and doesn’t contain any oxygenated or phosphorus-containing

compounds. Therefore, this study does not provide a complete profile of the pyrolysis of

TDCPP. 

Pyrolysis Products Reference 

Relative mol.% degradates, 0.1 mole TDCPP heated at 250-260/C under 

reduced pressure (3 mm Hg), overall yield 60 wt%: trans-1,3­

dichloropropene 26.7%, cis-1,3-dichloropropene 36.0%, 1,2,3­

trichloropropane 34.4%, 1-chloro-2-propene 2.9%. 

Choudhry and Hutzinger, 1982 

Thermal oxidative degradation in air at 370/C: Hydrogen halides, 

halogenated C2 and C3 species, acrolein 

HSDB, 2003 

3-46
Pyrolysis Products Reference 

When heated to decomposition, it emits toxic fumes of Cl+

 and POx Lewis, 2000 (Sax’s Dangerous 

Properties of Industrial Materials) 

Hydrolysis as a Function of pH: 

Conclusion: The hydrolysis rate data are adequate. The hydrolysis products are not described. 

Basis for Conclusion: The studies cited below were GLP-compliant tests run according to 

accepted guidelines. 

T1/2 pH Temp. Comment Reference 

>1 year 

>1 year 

14.7 

days 

4 

7 

9 

50/C OECD 111; EPA Ser. 835 OPPTS No. 835.2110. 

GLP-compliant. 

Initial concentration, 10 mg/L. Study length, 5 

days. Preliminary study. 

Akzo Nobel, 2001a,b 

28 days 9 40/C OECD 111; EPA Ser. 835 OPPTS No. 835.2110. 

GLP-compliant. 

Definitive 30-day study. 

Akzo Nobel, 2001a,b 

128 

days 

9 20/C OECD 111; EPA Ser. 835 OPPTS No. 835.2110. 

GLP-compliant. 

Definitive 30-day study. 

Akzo Nobel, 2001a,b 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

3-47
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oral toxicity in male rats. Report T-4100-2. TSCA 8e submission by Stauffer Chemical 

Company (1981), OTS0204911 (fiche 3). 

Stauffer (Stauffer Chemical Co.). 1973a. Toxicology reports on Fyrol FR-2. Vol I of II: Acute 

Dermal toxicity in rabbits. Report T-4287. TSCA 8e submission by Stauffer Chemical Company 

(1981), OTS0204911 (fiche 3). 

Stauffer (Stauffer Chemical Co.). 1973b. Toxicology reports on Fyrol FR-2. Vol I of II: Acute 

inhalation toxicity. Report T-4782. TSCA 8e submission by Stauffer Chemical Company 

(1981), OTS0204911 (fiche 3). 

Stauffer (Stauffer Chemical Co.). 1978. Toxicology reports on Fyrol FR-2. Vol I of II: 

Summary of in vitro delayed neurotoxicity evaluation. Report T-6303. TSCA 8e submission by 

Stauffer Chemical Company (1981), OTS0204911 (fiche 3). 

Stauffer (Stauffer Chemical Co.). 1979. Toxicology reports on Fyrol FR-2. Vol I of II: 24­

hour skin irritation, eye irritation. Report T-6773. TSCA 8e submission by Stauffer Chemical 

Company (1981), OTS0204911 (fiche 3). 

Stauffer (Stauffer Chemical Co.). 1981. Toxicology reports on Fyrol FR-2 (volume I-II with 

attachments and cover letter dated 020381. Stauffer Western Research Center. EPA Doc. No 

8EHQ-9-0281-0401 Fiche No. OTS0204911. 

Tanaka, S; Nakaura, S, Kawashima, K; et al. 1981. Effect of oral administration of tris(1,3­

dichloroisopropyl)phosphate to pregnant rats on prenatal and postnatal developments. Eisei 

Shikenjo Hokoku 99: 50-55. [In Japanese with abstract and tables in English] 

3-52
Thomas, MB; Collier, TA. 1985. Tolgard T.D.C.P. LV: OECD 474 Micronucleus study in the 

mouse. Experiment No. 164/8507. Safepharm Laboratories. Cited in WHO (1998). 

WHO. 1998. International Programme on Chemical Safety (IPCS), Environmental Health 

Criteria 209, Flame retardants: tris(chloropropyl)phosphate and tris(2-chloroethyl)phosphate. 

World Health Organisation. Available online at 

www.inchem.org/documetns/ehc/ehc/ehc209.htm. Accessed July 2004. 

Wilczynski, SI; Killinger, JM; Zwicker, GM; et al. 1983. Fyrol FR-2 fertility study in male 

rabbits. Toxicologist. 3: 22 (abstract). 

3-53
Flame Retardant Alternatives

Proprietary A: Chloroalkyl phosphate (1)

Hazard Review

4-1
Proprietary A: Chloroalkyl phosphate (1)

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal T

Inhalation * 

Eye irritation T

Dermal irritation T

Skin sensitization T

Subchronic Toxicity 

28-Day oral 

90-Day oral * 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects 

*

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental T

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

T

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

T

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

T

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

* 

Additional Y

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity * 

Genotoxicity 

Gene mutation in vitro T

Gene mutation in vivo T

Chromosomal T

aberrations in vitro 

Chromosomal * 

aberrations in vivo 

DNA damage and 

repair 

T

Other 

4-2
Proprietary A: Chloroalkyl phosphate (1)

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

T

Oxidation/reduction 

Melting point T

Boiling point T

Vapor pressure * 

Odor T

Oxidation/reduction 

chemical 

incompatibility 

Flammability T

Explosivity 

Corrosion 

characteristics 

pH Y

UV/visible absorption T

Viscosity T

Density/relative 

density/bulk density 

T

Dissociation constant in 

water 

Y

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish T

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish * 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis * 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 * 

Daphnia acute EC50 * 

Mysid shrimp acute 

LC50 

Green algae EC50, * 

NOAEC, LOAEC 

Fish chronic NOAEC, 

LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic * 

EC50, LC50, NOAEC, 

LOAEC 

4-3
Chemical Identity 

Proprietary A: Chloroalkyl phosphate (1) 

CAS 

MF 

MW 

SMILES 

Synonyms 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401). 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Several acute oral lethality studies were available in a variety of species: rabbits, rats, and mice. 

These studies were from the older (pre 1980) literature, did not report substance purity, and do 

not fully conform to OPPTS or OECD guidelines, but given the magnitude of the LD50 values 

the data are adequate for the evaluation of acute oral toxicity. Acute oral LD50 values generally 

exceeded the current limit dose of 2,000 mg/kg. Reports that specified a 14-day observation 

period are presented in detail. 

Critical Studies: 

Type: Acute oral toxicity 

Species, strain, sex, number: Rabbit, Dutch-belted, 5 males/group 

Doses: 0, 5,000, 7,500, and 10,000 mg/kg 

Purity: [Formulation 2]; purity not specifically reported 

Vehicle: Not reported 

Method: 14-Day post-dosing observation period; observations limited to mortality, clinical 

signs, and necropsy. LD50 calculated according to Litchfield and Wilcoxon. 

Results: Clinical signs shortly after dosing included ataxia, weakness, and diarrhea; survivors 

normal by day 9. Necropsy revealed no abnormalities. Acute oral male rabbit LD50 = 6,800 

mg/kg (95% CI 5,615-8,234 mg/kg). 

Reference: Robust summary from Ref. 4 

Type: Acute oral toxicity 

4-4
Species, strain, sex, number: Rat, Sprague-Dawley, 5 males/group 

Dose: 1,000, 2,150, 5,640, or 10,000 mg/kg 

Purity: [Formulation 2]; purity not specifically reported 

Vehicle: None 

Observation period: 14 days post dosing 

Method: 14-Day post-dosing observation period; observations limited to mortality, clinical 

signs, and necropsy; LD50 calculated according to Litchfield and Wilcoxon; not specified 

whether fed or fasted at time of dosing. 

Results: No effects at 1,000 mg/kg. Dose-related depression at or above 2,160 mg/kg; survivors 

normal by day 5. No gross lesions in survivors; fatalities had congestion of heart, lung, and 

liver. Acute rat oral LD50 = 3,160 mg/kg (95% CI 2,050-4,800 mg/kg) 

Reference: Ref. 53; robust summary from Ref. 4 

Type: Acute oral toxicity 

Species, strain, sex, number: Mouse, Slc/ddY, 10/sex/dose 

Purity: Not reported 

Doses: For males: 0, 2,210, 2,380, 2,570, 2,780, 3,000, 3,240, and 3,500 mg/kg. For females: 0, 

2,890, 2,040, 2,210, 2,380, 2,570, and 2,780 mg/kg. 

Vehicle: Olive oil 

Method: Observed for mortality and clinical signs for14 days. No body weight or gross 

necropsy examination. 

Results: Treated animals exhibited ataxic gait, hyperactivity, convulsion and death. No 

mortality was observed in controls or in males at 2,210 mg/kg or females at 1,890 mg/kg. The 

LD50 values were 2,670 mg/kg (2,520-2,830 mg/kg) for male mice and 2,250 (2,120-2,380 

mg/kg) for female mice. 

Reference: Ref. 30 

Additional Studies and Information: 

Other studies available only in secondary sources reported similar results. An oral LD50 of 

>2,000 mg/kg was reported in male and female rats exposed to [Formulation 3] (Ref. 18 as 

reported in Ref. 61); clinical signs observed during the first 5 days after dosing included 

hypokinesia, piloerection, soiled coats, ataxia, chromodacryorrhea, rhinorrhea, and salivation. 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged adequate to meet the endpoint. 

4-5
Basis for Conclusion: 

The available studies predate the preferred study guidelines, and did not report purity, but 

together indicated no mortality at the guideline limit dose of 2,000 mg/kg. The report specifying 

a 14-day observation period is presented in more detail. 

Type: Acute dermal toxicity 

Species, strain, sex, number: Rabbit, New Zealand albino, sex not specified, 4 

Dose: 4,640 mg/kg 

Purity: [Formulation 2], no data 

Vehicle: None 

Exposure period: 24 Hour 

Method: 4 Rabbits tested occluded; 14-day observation period. Gross necropsy. 

Results: Mortality after 14 days = 0/4. No overt signs of toxicity and no gross necropsy 

findings. Therefore, dermal acute LD50 >4,640 mg/kg. 

Reference: Ref. 54; additional information from robust summary in Ref. 4 

Additional Studies and Information: 

Other studies available only in secondary sources with minimal detail. A dermal LD50 of 

>2,000 mg/kg was reported in male and female Sprague-Dawley rats exposed to [Formulation 3] 

(Ref. 19 as reported in Ref. 61). No deaths and no clinical signs were noted 24 hours after 

treatment. 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300; OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available study on Proprietary A predates the preferred guidelines. The duration was shorter 

than currently recommended and no deaths were observed. Analysis of aerosol particle size, 

however, was not mentioned so it is not known whether the size was respirable. Necropsies 

were not performed. 

Type: Acute inhalation toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 5 males and 5 females 

Doses: 9.8 mg/L (9,800 mg/m3

) 

Purity: No data 

Vehicle: None 

Duration: 1 hour 

Method: Observation period = 14 days. Observed daily for signs of toxicity and for mortality. 

4-6
Results: No mortality after 14 days; initial signs of moderate depression 

Reference: Ref. 55 

Additional Studies and Information: 

Other studies available only in secondary sources reported similar results. An acute inhalation 

LC50 of >5,220 mg/m3 was reported for Sprague-Dawley rats exposed to aerosol of Proprietary 

A [Formulation 1] (Ref. 7 as reported in Ref. 61). 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Two reasonably adequate studies report similar results in rabbits: mild reversible irritation of the 

conjunctiva. The studies are summarized below. 

Type: Acute eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, sex not specified; 6 

Doses: 0.1 mL 

Purity: No data, [Formulation 2] 

Vehicle: None 

Method: Cited CFR [U.S. Federal Hazardous Substances Labelling Act] Section 191.12, 

chapter 1, title 21. Following instillation of Proprietary A, eyes were examined at 24, 48, and 72 

hours. 

Results: Mild conjunctival effects in 3/6 that cleared by 48 hours. 

Reference: Ref. 52 

Type: Acute (24-hour) eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, male and female; 9 total 

Doses: 0.1 mL 

Purity: No data 

Vehicle: None 

Method: U.S. EPA Hazard Evaluation. 1978. Fed. Reg. 43: 163: pp. 37331-37402. Thirty 

seconds following instillation of Proprietary A, the treated eyes of three rabbits were washed, 

treated eyes were not washed in 6 rabbits. The untreated eye of each animal served as a control. 

The cornea, iris and conjunctiva of each eye were examined at 24, 48, and 72 hours, and at 4 and 

7 days after instillation of Proprietary A using the Draize scoring method. 

Results: No signs of eye irritation were observed (average total Draize score of zero). 

Reference: Ref. 57; robust summary from Ref. 4 

4-7
Additional Studies and Information: 

One hour following application of [Formulation 3] to the eyes of New Zealand White rabbits, 

slight conjunctival redness and slight discharge were noted (Ref. 21 as reported in Ref. 61); 

effects cleared by 24 hours. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Two reasonably adequate studies, patterned after guidelines in effect at the time, provide similar 

results, indicating that Proprietary A was a non-irritant when applied for 4 hours (consistent with 

current guidelines) and a mild irritant when applied for 24 hours to rabbit skin. Additional 

studies provide support. The studies are summarized below. 

Critical Studies: 

Type: Acute (24-hour) dermal irritation 

Species, strain, sex, number: Rabbit, New Zealand, sex not specified, 6 

Doses: 0.5 mL 

Purity: Not reported; [Formulation 2] 

Vehicle: None 

Method: Cites “EPA protocol”. Back hair was shaved, each rabbit tested on intact and abraded 

skin, occlusive dressing removed after 24 hours, observations at 24 and 72 hours. 

Results: No edema on intact or abraded skin in any of the 6 rabbits. Mild erythema was visible 

at 24 hours but cleared by 72 hours, resulting in a score of 0.63. The report classified 

Proprietary A as a mild irritant. 

Reference: Ref. 57 

Type: Acute (4-hour) dermal irritation 

Species, strain, sex, number: Rabbit, not specified (but New Zealand white rabbits were used in 

an eye irritation test conducted at the same time) 

Doses: 0.5 mL 

Purity: Not reported; [Formulation 2] 

Vehicle: None 

Method: Back hair shaved, each rabbit tested on intact and abraded skin, occlusive dressing 

removed after 4 hours, observations at 4, 24 and 48 hours. 

Results: No erythema or edema on intact or abraded skin in any of the 6 rabbits. 

Reference: Ref. 52 

4-8
Additional Studies: 

Another study, on [Formulation 3], reported well-defined (score 2) erythema in 2 New Zealand 

White rabbits and slight erythema in a third rabbit 1 hour after patch removal, but duration of 

exposure was not specified (Ref. 20 as reported in Ref. 61). Effects cleared by 48 hours. The 

substance was classified as a skin irritant. 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential negative study of skin sensitization in guinea pigs was submitted that meets the 

requirements for the endpoint. 

A robust summary was located for an unpublished industrial study stated to have been conducted 

under guideline. The summary omits information necessary to determine study adequacy, such 

as: the strain, sex, group size, substance purity, and dose levels. The summary claimed that the 

doses were selected according to guideline, but the exact levels are not stipulated in the 

guideline. Without the additional information, the study cannot be evaluated for adequacy. 

Critical Studies: 

Type: Dermal sensitization study 

Species, strain, sex, number: Guinea pig, strain and sex not reported 

Doses: Stated as according to guideline, but exact doses are not stipulated in guideline. 

Purity: Not reported; [Formulation 2] 

Vehicle: Water 

Method: Three pairs of intradermal injections into shaved shoulder: 1:1 Freunds Complete 

Adjuvent (FCA) and saline, the test material, and 1:1 FCA and test material. Controls received 

water in place of the test material. On day 6, 24 hours before topical induction application, 

sodium lauryl sulfate was applied to sites to enhance local irritation. On day 7, test substance 

was applied to sites (water for controls). On day 21, animals received challenge dose by dermal 

application, occluded for 24 hours. Sites observed for irritation and sensitization (Grade 0-4). 

Results: The sensitization score for [Formulation 2] was zero, indicating the substance is not a 

chemical sensitizer. 

Reference: Robust summary in Ref. 5 

SUBCHRONIC TOXICITY 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

4-9
Conclusion: 

The available subchronic oral toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A Japanese 90-day dietary study in mice (Ref. 30) provides limited relevant information in the 

English abstract and data tables. The study was not adequate to characterize this endpoint 

because histopathological analysis was apparently limited to the liver. A fertility study by Ref. 

62, discussed under the Reproductive Toxicity endpoint, evaluated male rabbits exposed by oral 

gavage for 12 weeks, but did not involve treated females. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

No study of this type was located. 

90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

Type: 90-Day repeated oral 

Species, strain, sex, number: Mouse, Slc/ddY, 12/sex/dose 

Doses: Proprietary A at dietary concentrations of 0, 0.01, 0.04, 0.13, 0.42, and 1.33% in the diet, 

resulting in reported average daily doses of 0, 13.2, 47.3, 171.0, 576.0, and 1,792.3 mg/kg/day in 

males and 0, 15.3, 62.5, 213.6, 598.0, and 1,973.1 mg/kg/day in female mice 

Purity: Not reported 

Vehicle: None; added to diet 

Exposure period, frequency: 90 days, ad lib 

Method: Body weight, food consumption measured weekly. At 1 and 3 months in half the 

animals, hematologic (erythrocyte, hemoglobin, hematocrit, and leukocyte counts) and clinical 

chemistry parameters (total protein, albumin, albumin/globulin ratio, blood urea nitrogen, 

glucose, total cholesterol, alkaline phosphatase, aspartate aminotransferase, alanine 

aminotransferase). At 1 and 3 months, half the animals were necropsied and absolute and 

relative organ weights were determined for brain, heart, lung, liver, kidney, and spleen. The 

liver was examined for microscopic histopathology; the English text does not mention whether 

other tissues were examined. 

Results: At the highest dietary level, 1.33%, all mice exhibited emaciation, rough hair, and 

tremor and died within 1 month. At 1.33%, food consumption was reduced and body weight loss 

occurred in both sexes. Mean body weight gain was reduced by about 10% (estimated from 

graph) in males at 0.42% throughout the study. The following statistically significant changes 

occurred in treated groups compared to controls. Slight anemia (reduced hemoglobin; p<0.05) in 

males at 0.42% after 3 months. Anemia (reduced hemoglobin at $0.13% after 1 month and at 

0.42% at 3 months, erythrocyte and hematocrit at 0.42% at 1 and 3 months) in females (3-month 

values p<0.01). Albumin/globulin ratios elevated in all treated male groups at 3 months. 

4-10
Alkaline phosphatase elevated in females at 0.42% at 1 month but not later. Dose-related organ 

weight elevations compared to controls observed at 3 months in males included relative liver 

weight (+32-51%) at $0.13% and relative kidney weight (+39%) at 0.42%. Significant 

elevations in organ weights in females at 3 months included relative liver weight (+16-51%) at 

$0.04%, absolute (+30%) and relative (+34-40%) kidney weights at $0.13%, and absolute liver 

weight (+40%) at 0.42%. The statistical significance of these organ weight elevations was 

p<0.01 for rats exposed at $0.13% and p<0.05 for rats exposed at 0.04.%. Histopathology of the 

liver (slight focal necrosis) was observed in only two females at 0.42%. The dietary level of 

0.01% is a NOAEL of 15.3 mg/kg/day and the dietary level of 0.04% is a LOAEL of 62.5 

mg/kg/day for liver and kidney weight elevations in female mice. 

Reference: Ref. 30 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No studies of this type were located. 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

Conclusion: 

No available subchronic dermal toxicity data. 

Basis for Conclusion: 

No data exist for the subchronic dermal toxicity endpoint. 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD 

Guideline 410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

No studies of either type were located. 

Subchronic Inhalation Toxicity (90-day) 

Conclusion: 

No available subchronic inhalation toxicity data. 

4-11
Basis for Conclusion: 

No repeated-exposure inhalation toxicity studies were located. 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD 

Guideline 413) 

No studies of this type were located. 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A fertility assay in male rabbits exposed by oral gavage for 12 weeks prior to mating (Ref. 62) 

partially characterizes this endpoint, but is not sufficient to satisfy the reproductive toxicity 

endpoint since it was described only in an abstract and females were not tested. Other studies 

(Ref. 26, 59) described below under Developmental Toxicity reported that in pregnant female 

rats exposed orally to Proprietary A, adverse reproductive effects occurred only at maternally 

lethal doses. However, no study evaluated reproductive function in females treated prior to 

mating. 

The 2-year feeding bioassay in rats by Ref. 24 (Ref. 9, 9a), discussed below under Chronic 

Toxicity, provides reproductive histopathology data that are, however, insufficient to satisfy the 

reproductive toxicity endpoint. This study provided histopathology results for the testis, 

epididymis, seminal vesicle, ovary, and uterus for the control and high-dose groups (0 and 80 

mg/kg/day) after 1 year (10 scheduled sacrifices/sex/group) and for survivors in all groups after 

2 years; unscheduled sacrifices (rats killed in a moribund state) were also examined. The 2-year 

exposure is too long to represent reproductive toxicity, because of the confounding effects of 

aging; the results pointed to dose-related effects in male reproductive organs (at $5 mg/kg/day, 

atrophy and decreased secretory product of the seminal vesicles; at $20 mg/kg/day, testicular 

germinal atrophy with oligospermia, and at 80 mg/kg/day, atrophy and decreased secretory 

product of the seminal vesicles and oligospermia and luminal accumulation of degenerated 

seminal products in the epididymis). No significant effect was observed in females. The tested 

doses, which were considerably lower than the guideline limit dose of 1,000 mg/kg/day, were not 

high enough to induce significant reproductive histopathology after one year of exposure; 1/10 

high-dose males had oligospermia. Thus, a LOAEL for reproductive effects following 

subchronic (90-day) exposure is not available and cannot be extrapolated from the existing data, 

but the chronic data indicate a LOAEL of 5 mg/kg/day for atrophy and decreased secretory 

product of the seminal vesicles. 

4-12
• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

No studies were available that met the specific designs of the three protocols listed above. 

Additional Studies: 

A study described in an abstract by Ref. 62 addresses fertility in male rabbits exposed by oral 

gavage for 12 weeks prior to mating. 

Type: Fertility 

Species, strain, sex, number: Rabbit, strain not specified, 10 males/dose 

Purity: Not reported 

Doses: 0, 2, 20, or 200 mg/kg/day 

Vehicle: Not reported 

Exposure duration, frequency: 12 weeks, once by oral gavage daily 

Method: Males treated for 12 weeks, then mated with untreated females. Body weight, clinical 

signs, clinical chemistry, hematology, mating behavior, male fertility, sperm quantity and 

quality, kidney and liver weights, gross and microscopic pathology (range of organs examined 

not specified). 

Results: High-dose animals had significantly increased absolute kidney weight and relative liver 

weight. Proprietary A had no effect on male reproductive parameters; there was no 

histopathology in kidneys, liver, pituitaries, testes, or epididymides. 

Reference: Ref. 62 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Developmental toxicity studies in two strains of rats exposed to [Formulation 2] by oral gavage 

followed methods consistent with OECD Guideline 414 (one study pre-dated the guideline). 

4-13
Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; OECD 

Guideline 414) 

Type: Prenatal developmental toxicity 

Species, strain, sex, number: Rat, Wistar, 15 pregnant females at the highest dose, 23-24 

pregnant females in controls and other dose groups. 

Purity: not reported 

Doses: 0, 25, 50, 100, 200, and 400 mg/kg/day 

Vehicle: Olive oil 

Exposure duration, frequency: Once by oral gavage daily on gestational days (GD) 7-19. 

Method: Body weight, food consumption, clinical signs, pregnancy rates, and necropsy of dams, 

kidney weight; uterine contents (including implants and resorption) at day 20 of gestation, 

corpora lutea; fetal viability, sex ratio and weight, crown-rump length, and external and skeletal 

abnormalities. 

Seven dams from each of the control and #200 mg/kg/day groups were permitted to litter 

normally and evaluated for implantation sites, delivery index, number of live offspring at birth 

and survival on PND 4, at 4th week, and at 10th week. Litters were culled to 10 offspring on 

postnatal day 4 (PND 4) and subjected to behavioral tests (open field, water maze, rota rod, 

inclined screen, pain reflex and Preyer’s reflex). Absolute organ weights of 10 organs plus 

testis, uterus and ovary were measured in offspring. 

Results: Maternal mortality occurred only at 400 mg/kg/day: 11/15 died. Food consumption 

was suppressed at 400 mg/kg/day and slightly at 200 mg/kg/day. At 400 mg/kg/day, mean body 

weight loss occurred during GD 7-15, resulting in significantly (p<0.05) reduced terminal body 

weight on GD20: ~17% lower than control group. Absolute and relative kidney weights were 

significantly increased at 200 and 400 mg/kg/day. Proprietary A at #200 mg/kg/day had no 

effect on corpora lutea or mean numbers of implants, fetal body weight, fetal sex ratio, or the 

number of dead or live fetuses. The numbers of dead fetuses and live fetuses were significantly 

(p<0.01) changed compared to controls by the loss of one whole litter at 400 mg/kg/day. No 

increase in malformations was observed in treated groups. For maternal toxicity, the NOAEL 

was 100 mg/kg/day and the LOAEL was 200 mg/kg/day for increased kidney weight. For fetal 

toxicity, the NOAEL was 200 mg/kg/day and the LOAEL was 400 mg/kg/day for increased fetal 

death; the highest dose of 400 mg/kg/day was a NOAEL for teratogenicity. 

Postnatal observations: Proprietary A at #200 mg/kg/day had no effect on implantation, 

delivery, postnatal survival, behavior, functional test results, or absolute organ weights of 

offspring. 

Reference: Ref. 59 

Type: Prenatal developmental toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 20 pregnant females/dose 

Purity: not reported 

Doses: 0, 25, 100, and 400 mg/kg/day 

Vehicle: Corn oil 

Exposure duration, frequency: Once by oral gavage daily on gestational days 6-15 

4-14
Method: Body weight, food consumption, clinical signs, pregnancy rates, and necropsy of dams; 

uterine contents (including implants and resorption) at day 19 of gestation, corpora lutea; fetal 

viability and weight, crown-rump length, external, visceral (1/3 fetuses), and skeletal 

abnormalities; extensive statistical analyses. 

Results: High-dose dams exhibited clinical signs (urine stains, hunched appearance, and 

alopecia); sporadic signs of urine stains and hunched appearance occurred in a few mid-dose 

dams, but not at the low-dose. Food consumption was statistically lower in mid-dose dams on 

days 7-11 and in high-dose group throughout (days 7-15). During Days 6-11, significant 

(p<0.05) reductions in body weight gain in mid-dose dams and mean body weight loss at the 

high dose; on days 11-15, only high-dose dams showed reduced body weight gain. Overall body 

weights reduced in high-dose dams. Proprietary A had no effect on implantation efficiency or 

mean number of corpora lutea. Treatment at the high dose significantly (p<0.05) increased the 

number of resorptions (to 14.4% compared to 6.7% in controls) and reduced fetal viability (to 

85.6% compared to 93.3% for controls). Decreased skeletal development in the high-dose 

groups is related to growth retardation and decreased fetal size. The incidence of malformations 

was not related to treatment. The study indicates a NOAEL of 25 mg/kg/day and a LOAEL of 

100 mg/kg/day for maternal toxicity (clinical signs and transient reduction in body weight gain) 

and a NOAEL of 100 mg/kg/day and a LOAEL of 400 mg/kg/day for developmental toxicity 

(increased resorptions and fetal mortality). 

Reference: Ref. 26 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

No studies with the specific designs of the two tests listed above were available. 

CHRONIC TOXICITY 

Conclusion: 

The available chronic toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The combined chronic toxicity/carcinogenicity assay in dietarily exposed rats is consistent with 

the guideline (Ref. 9, 24). 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

No studies of this type were located. 

4-15
Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

The protocol of a 2-year feeding bioassay in rats was consistent with this guideline (Ref. 9, 24). 

The published article focused on tumor results rather than non-neoplastic effects. 

Type: Combined oral chronic toxicity and carcinogenicity assay 

Species, strain, sex, number: Rat, Sprague-Dawley, 60/sex/group 

Purity: 95% 

Doses: 0, 5, 20, and 80 mg/kg body weight/day 

Vehicle: None other than feed 

Route: In feed; diets blended weekly to achieve target doses 

Exposure duration, frequency: 2 years, ad lib 

Method: Examined twice daily for mortality and clinical signs, weekly physical examination. 

Body weights and food consumption weekly for the first 13 weeks and biweekly thereafter. 

Ophthalmoscopic examinations every 6 months. Extensive hematology, clinical chemistry and 

urinalysis parameters at 3, 6, 12, 18, and 24 months. Ten/sex/dose randomly chosen for 

termination at 12 months; the remainder at 24 months. Gross necropsy including organ weights 

(8 organs plus gonads); histopathology of more than 30 tissues in control and high-dose rats; at 

low- and mid-doses, histopathology limited to liver, kidneys, testes, and adrenals. Statistical 

analyses. 

Results: The following changes compared to controls were statistically significant (p<0.05). 

Mortality increased in high-dose males (to 61.7% vs 43.3% for controls). Lower body weights 

in high-dose males and females. Treatment had no effect on feed consumption. Signs of anemia 

(lower hemoglobin, hematocrit, erythrocyte counts) in high-dose rats. At the mid-dose, 

increased absolute and relative kidney weight males and females, absolute liver weight and 

relative thyroid weight in males, and relative liver weight in females. At the high dose, 

increased relative liver weight in males and absolute and relative thyroid weights in females. 

Increases in the incidences of the following nonneoplastic lesions were statistically significant 

(p<0.05) in treated groups compared to the control groups; changes were not strictly dose-related 

in that incidences were depressed in high-dose groups. Kidney lesions (convoluted tubule 

hyperplasia) in males at $20 mg/kg/day and in females at 80 mg/kg/day. Other systemic lesions 

at 80 mg/kg/day involved the parathyroid (hyperplasia) in males and the liver (foci) and spleen 

(erythroid/myeloid hyperplasia) in females. Reproductive system lesions in males involved 

seminal vesicles (atrophy, decreased secretory product) at $5 mg/kg/day, testes (eosinophilic 

material in lumen, periarteritis nodosa) at $20 mg/kg/day, and epididymis (oligospermia and 

degenerated seminal product) at 80 mg/kg/day. (Tumor incidences are reported below under 

Carcinogenicity.) The authors reported the lowest dose of 5 mg/kg/day as a NOAEL and the 

mid-dose of 20 mg/kg/day as a LOAEL. However, as evaluated in NRC (2000), the lowest dose 

of 5 mg/kg/day was a LOAEL for atrophy and decreased secretory product of the seminal 

vesicle. 

Reference: Ref. 24; also Ref. 9 and 9a. 

4-16
CARCINOGENICITY 

Conclusion: 

The available carcinogenicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Increased tumor incidences were observed in a combined chronic toxicity/carcinogenicity assay 

in rats exposed to Proprietary A in the diet (Ref. 24). 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

No studies of this type were located. 

Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

A 2-year feeding bioassay by Ref. 24 was consistent with this guideline. 

Type: Combined oral chronic toxicity and carcinogenicity assay 

Species, strain, sex, number: Rat, Sprague-Dawley, 60/sex/group 

Purity: 95% 

Doses: 0, 5, 20, and 80 mg/kg body weight/day 

Vehicle: None other than feed 

Route: In feed; diets blended weekly to achieve target doses 

Exposure duration, frequency: 2, ad lib 

Method: See description above under Chronic Toxicity 

Results: The following neoplastic changes compared to controls were statistically significant 

(p<0.05). Dose-related increased incidences at $20 mg/kg/day of renal cortical adenomas in 

both sexes and testicular interstitial tumors in males, and at 80 mg/kg/day, of hepatocellular 

adenomas and carcinomas combined in both sexes and adrenal cortical adenomas in females. 

Ref. 40 concluded that this study provides sufficient evidence of carcinogenicity of Proprietary 

A in rats following chronic oral exposure. 

Reference: Ref. 24; also Ref. 9, 9a 

NEUROTOXICITY 

Conclusion: 

The available neurotoxicity data were judged inadequate to meet the endpoint. 

4-17
Basis for Conclusion: 

The delayed neurotoxicity component is satisfied by the existing data, but a developmental 

toxicity study by Ref. 59 that included postnatal behavioral examinations did not fully satisfy the 

developmental neurotoxicity component. Proprietary A gave negative results in single acute and 

subchronic oral delayed neurotoxicity studies in hens and in limited postnatal testing in rats 

exposed during gestation. A 2-year feeding bioassay in rats by Ref. 24, discussed above under 

the Chronic Toxicity and Carcinogenicity endpoints, reported no lesions of the cervical spinal 

cord, but a slight (not statistically significant) increase in the incidence of gliomas of the brain in 

rats exposed to Proprietary A at 80 mg/kg/day. The study authors could not determine whether 

this effect was related to exposure. 

Delayed Neurotoxicity 

Conclusion: 

The available delayed neurotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Several acute studies and one subchronic study for delayed neurotoxicity in the hen, summarized 

below, give no evidence of acute cholinergic toxicity, inhibition of neurotoxic esterase (NTE) 

activity, or delayed neurotoxicity for Proprietary A. These studies, performed prior to the 

existence of the guidelines, do not entirely conform to current guidelines, and may lack detail 

such as the purity of the Proprietary A sample. The lack of significant NTE inhibition following 

dosing with 10,000 mg/kg suggests that no additional testing for delayed neurotoxicity is needed 

for Proprietary A. 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Unpublished industrial acute (1- or 5-day) and subchronic (90-day) delayed neurotoxicity assays, 

which pre-date the guideline, are missing some details. One acute study employed a gavage dose 

5 times higher than now specified under the guideline. The subchronic assay had a longer 

duration and a larger group size than specified under the guideline. 

Critical Studies 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Hen, White Leghorn, 4/dose 

Purity: [Formulation 2], purity not reported, clear colorless liquid 

Doses: 420 mg/kg (highest dose specified in protocol) 

Vehicle: test substance diluted 50% in corn oil 

Positive control: 90 or 120 mg/kg/day tri-ortho-tylol phosphate (TOCP) 

4-18
Route: Gavage 

Exposure duration, frequency: Once daily on five consecutive days 

Method: Navy MIL-H-19457B (SHIPS) protocol. Hens were weighed and graded on days 7, 9, 

11, 14, 16, 18, 21, and 23 after the first dose for no signs, doubtful/minor signs, positive paralytic 

signs, advanced paralytic signs, or death. Scores on the 21st day were compared with results for 

TOCP. Necropsy not performed. 

Results: No overt signs of neurotoxicity in with Proprietary A treatment. Positive control 

caused inability to walk, hypertension, ataxia, and prostration. 

Reference: Ref. 14 as described in Ref. 61; Ref. 50 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Hen, White Leghorn, 4/dose for Proprietary A, 3/dose for controls 

Purity: [Formulation 2], clear colorless liquid; one part of the report stated that the purity was 

not reported, whereas another part of the report indicated purity >99%. 

Doses: 10,000 mg/kg 

Vehicle: None 

Positive control: 500 mg/kg tri-ortho-cresyl phosphate (TOCP) 

Negative control: 15 mg/kg tetraethyl pyrophosphate (TEPP) 

Route: Oral gavage 

Exposure duration, frequency: Once 

Method: Twenty minutes before dosing, hens received atropine and 2-PAM to protect against 

cholinergic effects. Hens were observed for toxic signs at 2-hour intervals for the first 8 hours. 

Mortalities were recorded after 24 hours. Brains were harvested 24 hours after dosing and 

analyzed for neurotoxic esterase (NTE) activity. 

Results: Toxic signs were not reported specifically for Proprietary A, but for all compounds 

tested at the maximum tolerated dose, signs included listlessness and ataxia. Inhibition of NTE 

activity was 7% for Proprietary A and the negative control tetraethyl pyrophosphate, but 85% for 

the positive control (TOCP). The current guideline specifies that testing is not necessary at 

doses above 2,000 mg/kg. 

Reference: Ref. 56 

Type: Subchronic oral delayed neurotoxicity 

Species, strain, sex, number: Hen, adult, White Leghorn, 10/dose 

Purity: Not reported 

Doses: 0, 4, 20, and 100 mg/kg/day 

Vehicle: Not reported 

Route: Oral Gavage 

Exposure duration, frequency: 90 days, daily 

Method: Body weight. Daily observations for mortality and behavioral changes; evaluated for 

signs of motor weakness 3 times per week. At termination, hens were necropsied and brain 

(multiple sections), sciatic nerve, and spinal cord (cervical, thoracic and lumbar) were examined 

histopathologically. TOCP was the positive control. 

Results: Hens treated with Proprietary A at the high dose exhibited mean reductions in body 

weight during the latter part of the study, but no overt signs of neurotoxicity and no 

4-19
histopathological effects in the nervous tissues. Conversely, the positive control hens exhibited 

consistently lower body weight gain, clinical signs of toxicity (locomotor impairment and ataxia) 

that became more severe with time. Histopathology results were not reported for the positive 

control. 

Reference: Robust summary from Ref. 4 

Neurotoxicity (Adult) 

Conclusion: 

The available adult neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The chronic oral bioassay by (Ref. 9, 9a, 24) reported no lesions of the brain or spinal cord in 

rats exposed to TDCPP at doses as high as 80 mg/kg/day for 2 years, but no functional tests of 

neurotoxicity were performed. 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

No studies of this type were located. 

Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS Harmonized 

Guideline 870.6300) 

Conclusion: 

The available developmental neurotoxicity data were judged inadequate to meet the endpoint, 

although the available tests suggest that Proprietary A is not a developmental neurotoxin. 

Basis for Conclusion: 

No studies of this specific design were located. A Japanese-language gavage study by Ref. 59, 

described above under Developmental Toxicity, included postnatal neurobehavioral tests (open 

field, water maze, rota rod, inclined screen, pain reflex, and Preyer’s reflex) of sensory and 

motor function in rats. Full descriptions of these tests were not available in the English summary 

and therefore could not be compared to the guideline protocol. The study reported no adverse 

effect in these tests for offspring of dams that were exposed on gestational days 7-15 at doses as 

high as 200 mg/kg/day (the highest tested non-lethal dose that was a LOAEL for increased 

kidney weight). This study does not fully satisfy the developmental neurotoxicity endpoint 

because it omitted some parameters specified under the guideline: developmental landmarks for 

sexual maturity, auditory startle test, and neurohistopathological examinations. 

4-20
Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) 

• OPPTS Harmonized Guideline 870.6500 

• Peripheral Nerve Function (rodent) 

• OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred) 

• OPPTS Harmonized Guideline 870.6855 

These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, 

or because of structural similarity of the substance to neurotoxicants that affect these endpoints. 

These studies may be combined with other toxicity studies. 

Conclusion: These endpoints do not appear to be applicable to Proprietary A. 

Basis for Conclusion: Although there are no studies addressing these endpoints, there are no 

reliable data for Proprietary A, and no structure-activity considerations, that indicate a need for 

these follow-up studies. 

Other Neurotoxicity Data 

Cholinesterase inhibition 

[Formulation 2] administered at 0, 2,000, or 3,980 mg/kg in corn oil was administered to groups 

of 10 male Sprague-Dawley rats by oral gavage had no effect on plasma or erythrocyte 

cholinesterase levels measured 4 or 14 hours after dosing (Ref. 51). 

IMMUNOTOXICITY 

Conclusion: 

The available immunotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The only study evaluating the potential immunotoxicity of Proprietary A (Ref. 35) predates the 

guideline for immunotoxicity (note that the OPPTS guideline cites other works by this author). 

There is some uncertainty as the test material, reported as [Formulation 2], but mis-identified by 

the authors as [Chemical 1]. The study methods differed from the guideline in the short 

exposure period (4 rather than 28 days), parenteral administration (rather than oral or inhalation 

route), measurement of serum immunoglobulins in non-immunized rather than immunized mice, 

and the omission of some tests (enumeration of immunological cell subpopulations, test for NKcell activity). The results do not provide dose–response information as to immunotoxicity of 

Proprietary A following subchronic exposure by oral or inhalation routes of exposure. 

4-21
Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

Critical study 

Type: Immunotoxicity, subcutaneous, acute 

Species, strain, sex, number: Mouse, B6C3F1, 6-8 females/dose 

Doses: 0, 0.25, 2.5, or 25 mg/kg/day (Total cumulative doses of 0, 1, 10, or 100 mg/kg) 

Identity: [Formulation 2]; this is the same as Proprietary A tested in the 2-year oral assay by 

Ref. 24 

Purity: purity >95% 

Vehicle: Corn oil 

Route: Subcutaneous injection 

Exposure duration, frequency: 4 days, once daily 

Method: Observations included body weight, hematology, clinical chemistry (5 parameters) 

terminal necropsy, organ weights (liver, spleen and thymus), histopathology of spleen, thymus, 

and eight other organs, plaque-forming assay response to sheep red blood cells, and serum 

immunoglobulin quantification (non-immunized mice only). Non-guideline tests included 

proliferative capacity of granulocyte-macrophage progenitor cells (bone marrow), in vitro 

lymphoproliferative (LP) responses to mitogens, delayed hypersensitivity response to keyhole 

limpet hemocyanin. Extensive statistical analysis. 

Results: Twenty percent of high-dose mice exhibited lymphoid depletion of the thymus. 

Statistically significant decreases in vitro lipopolysaccharide (B-cell antigen) at 2.5 mg/kg/day 

and concanavalin A (T-cell antigen) at 25 mg/kg/day. 

Reference: Ref. 35 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Proprietary A has been tested in in vitro and in vivo genotoxicity assays conducted in prokaryotic 

and eukaryotic cells under methods similar to guidelines. Results of in vivo tests (mutation in 

Drosophila, chromosomal aberration in mice) were negative, but positive results were reported 

in several in vitro assays (mutagenicity in bacterial and mammalian cells, chromosomal 

aberration). 

Gene Mutation in Vitro: 

Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

4-22

C
Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA97, TA98, TA100, TA1535, TA1537 

Metabolic activation: Tested with and without S9 from livers of Aroclor-induced male 

Sprague-Dawley rats or male Hamsters 

Concentrations: 0, five concentrations between 10 and 10,000 :g/plate. 

Purity: 94.4% 

Method: Preincubation (20 minutes) and plate incorporation (48 hours) at 37°C. Positive 

controls were used; DMSO was the solvent. Triplicate plates per concentration. All assays 

repeated within 1 week. 

Results: In three different laboratories, Proprietary A tested positive in strains TA97 and TA100 

in the presence of S9 from Aroclor-induced hamster liver and in strain TA1535 in the presence 

of S9 from Aroclor-induced rat or hamster liver. Positive controls gave expected increases. 

Solvent control and all other test combinations were negative. 

Reference: Ref. 37 

Type: Bacterial reverse mutation 

Species, strain: Salmonella typhimurium TA98, TA100, TA1535, TA1537, TA1538 

Metabolic activation: Tested with and without Kanechlor 500 (PCB)-induced liver S9 from 

male Wistar rats 

Concentrations: 0, 10, 30, 100, and 300 :g/plate. 

Purity: Assayed as ~94% Proprietary A, plus ~6% [Chemical 7] 

Method: Plate incorporation, 48-hour incubation at 37°C. Cited Ames protocol, which 

presumes the use of replicates and positive controls. 

Results: No increase in revertants in any strain without activation or in strains TA98, TA1537, 

or TA1538 with activation. Weak increases in TA100 and TA1535 at the highest concentrations 

with S9. 

Reference: Ref. 38 

Additional Studies 

Other S. typhimurium assays in which S9 was prepared from phenobarbital-induced rat liver 

reported mutagenicity of Proprietary A in strain TA98 by liquid preincubation assay (Ref. 1) and 

in TA100 by plate incorporation assay (Ref. 25, 48). Ref. 36 reported dose-related positive 

results for Proprietary A and its metabolite [Chemical 8] in TA100 with S9 (phenobarbitalinduced) in standard plate assays at concentrations up to 500 :g/plate. In a liquid preincubation 

quantitative assay, results for Proprietary A were essentially negative—only increasing mutation 

frequencies at cytotoxic concentrations (survival <3%). However, its metabolites increased 

mutant frequencies with less cytotoxicity: [Chemical 9] positive at <80% survival and [Chemical 

8] positive at <30% survival. 

Proprietary A was not mutagenic in S. typhimurium strains TA100, TA1535, or TA1538 without 

activation or when Aroclor-induction was used to prepare the S9 fraction (Ref. 41); the highest 

exposure level was 10 :L per plate. 

4-23
C In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

Type: Mammalian Cell Gene Mutation Test: Forward Mutation 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: Tested with and without phenobarbital-induced liver S9 from male mice 

Concentrations: 0, and five concentrations up to ~32 nL/mL without S9, and six concentrations 

up to 70 nL/mL with S9. Test conditions chosen based on preliminary assays so that 50% 

growth reduction occurred at highest concentration. 

Purity: Not reported 

Method: Selection of forward mutation from TK+/- to TK-/- genotype. Activity compared to 

[Chemical 2]. 

Results: Proprietary A yielded negative results with or without activation. [Chemical 2] was 

negative without, but positive with activation. 

Reference: Ref. 12; also Ref. 33 

Type: Mammalian Cell Gene Mutation Test: Forward Mutation 

Species, strain: V79 Chinese hamster lung cells 

Metabolic activation: Tested with phenobarbital-induced liver S9 from male rats 

Concentrations: 0, 0.02 mM Proprietary A. Test conditions chosen based on preliminary 

assays. 

Purity: Not reported 

Method: In two experiments, selection of 6-thioguanine-resistant colonies. Activity compared 

to [Chemical 2]. 

Results: Proprietary A with S9 did not increase mutation frequency. [Chemical 2] yielded 

positive results. 

Reference: Ref. 48 

Gene Mutation in Vivo: 

C Sex-linked Recessive Lethal test in Drosophila melanogaster (OPPTS Harmonized 

Guideline 870.5275) 

Type: Sex-linked Recessive Lethal test 

Species, strain: Drosophila melanogaster, 100 males/concentration 

Metabolic activation: None 

Concentrations: 2.5 and 25% in feed (1% gum tragacanth in 3% sucrose) 

Purity: Technical-grade [Formulation 2], purity not reported 

Method: Proprietary A added to feed of males for 24 hours, subsequently mated with virgin 

unexposed females 

Results: No evidence of toxicity or increase in the percentage of sex-linked recessive lethal 

mutations. 

Reference: Ref. 11 as described in Ref. 61; also Ref. 32 

4-24
Chromosomal Aberration in Vitro: 

C In Vitro Mammalian Chromosome Aberration Test (OPPTS Harmonized Guideline 

870.5375) 

Type: In vitro chromosome aberration assay 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: None, phenobarbital-induced or PCB-induced 

Concentrations: 0, 0.01 to 0.1 :L/mL for non-induced, phenobarbital-induced or PCB-induced 

mouse 

Purity: Not reported 

Method: 4-hour exposure to Proprietary A with or without activation. Chromosomal aberrations 

scored in 50 metaphase spreads per concentration. 

Results: Proprietary A caused increases chromosomal aberrations (up to 40%) with PCB- or 

phenobarbital-induction compared to noninduced S9. 

Reference: Ref. 12; also Ref. 33 

Additional Information 

Two confidential studies were submitted. One reported negative results in cultured Chinese 

hamster ovary cells with or without metabolic activation. Another reported positive results in 

human lymphocytes with metabolic activation. 

C In vitro Sister Chromatid Exchange Assay (OPPTS Harmonized Guideline 

870.5900) 

Type: In vitro sister chromatid exchange assay 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: None, phenobarbital-induced or PCB-induced 

Concentrations: 0, 0.005-0.03 :L/mL for phenobarbital-induced (4 concentrations), and 6 

concentrations up to 0.070 :L/mL for non-induced or PCB-induced mouse 

Purity: Not reported 

Method: Ten cells per concentration were analyzed. 

Results: Proprietary A increased the incidence of sister chromatid exchanges in mouse 

lymphocytes under all three test conditions. 

Reference: Ref. 12; also Ref. 33 

Additional Information 

One submitted confidential study reported negative results in a sister chromatid exchange assay. 

[Formulation 2] did not induce sister chromatid exchanges when applied to 3- to 4-day-old 

chicken embryos (Ref. 10). 

4-25
Chromosomal Aberration in Vivo: 

C Mammalian Bone Marrow Chromosomal Aberration Test (OPPTS Harmonized 

Guideline 870.5385) 

The available study provides sufficient evidence that Proprietary A did not induce chromosomal 

aberrations in mice exposed at the maximum tolerated dose of 760 mg/kg. 

Type: Bone marrow chromosomal aberration in vivo 

Species, strain: Mouse, CD-1, 4-8 males/group 

Metabolic activation: None 

Concentrations: 0, 0.05, 0.17, and 0.5 mL/kg; using the specific gravity of 1.52, the doses were 

0, 76, 260, or 760 mg/kg. The highest dose was the maximum tolerated dose. Negative control 

was DMSO 

Exposure duration, frequency: By oral gavage in once or daily on 5 consecutive days. 

Purity: Technical grade; Not reported 

Method: Mice were sacrificed at 6, 24, and 48 hours after single dose or 6 hours after the last of 

5 doses. Between 233 and 400 cells were scored, rather than 500/animal. Triethylenemelamine 

was positive control. 

Results: No evidence of increased frequency of chromosomal aberrations with Proprietary A. 

[Chemical 2] was also negative at doses up to 1,000 mg/kg. Positive control produce expected 

large increase in micronucleated polychromatic erythrocytes. 

Reference: Ref. 12; Ref. 34 

C Mammalian erythrocyte micronucleus test (OPPTS Harmonized Guideline 

870.5395) 

Proprietary A administered as 2,000 mg/kg by an unspecified route to mice did not induce 

micronuclei in bone marrow erythrocytes (Ref. 60 as reported in Ref. 61). 

DNA Damage and Repair: 

C Unscheduled DNA synthesis in mammalian cells in culture (OPPTS Harmonized 

Guideline 870.5550) 

Type: Unscheduled DNA synthesis in mammalian cells (hepatocytes) in culture 

Species, strain: Rat, Wistar, male 

Metabolic activation: With or without phenobarbital-induction 

Concentrations: 0, 0.05, and 0.1 mM 

Purity: Not reported 

Vehicle: DMSO 

Method: Cultured hepatocytes exposed to Proprietary A or [Chemical 2] for 18-19 hours. 

Incorporation of radiothymidine into DNA. 

4-26
Results: Proprietary A was not genotoxic at 0.05 mM, but at 0.1 mM, a moderate response was 

observed in hepatocytes from untreated rats, but not phenobarbital-treated rats. [Chemical 2], 

the positive control, yielded positive results in induced and non-induced hepatocytes. 

Reference: Ref. 48 

Additional Information 

A submitted confidential study reported negative results for Proprietary A in cultured primary 

hepatocytes from male Sprague-Dawley rats. 

4-27
Ecotoxicity 

Aquatic Organism Toxicity 

Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 850.1075; 

OECD Guideline 203) 

Conclusion: 

The available acute toxicity data for freshwater fish (cold- and warm-water species) and 

saltwater fish were judged inadequate to meet the endpoints. The available acute fish toxicity 

studies are summarized in Table 4-1. However, if the results of Ref. 42, cited by Ref. 29 (see 

below), are confirmed independently, the acute toxicity endpoint for cold freshwater fish species 

might be satisfied given the high degree of agreement of the two available studies in rainbow 

trout. 

Basis for Conclusion: 

Freshwater Fish 

Ref. 2 tested the toxicity to goldfish (Carassius auratus) of Proprietary A released from fabric 

treated with the flame retardant. Laundered or unlaundered sections of garment that had been 

treated with [Formulation 2], were placed in tanks with six goldfish. Fish in the tank with the 

unlaundered section became sluggish and all died within 3 hours. The concentration of 

[Formulation 2] in the test water reached 30 mg/L. Fish exposed for 96 hours to the laundered 

section of garment did not exhibit signs of toxicity. In another study, Proprietary A in water at 1 

mg/L was not toxic to goldfish after 168 hours, but 5 mg/L of Proprietary A killed all (6/6) 

goldfish within 24 hours (Ref. 22). Ref. 2 and 21 did not evaluate toxicity using a range of 

concentrations of Proprietary A in water and, thus, cannot be used to derive an LC50. 

Ref. 46 estimated that the 96-hour LC50 values for killifish (Oryzias latipes) and goldfish were 

3.6 mg/L and 5.1 mg/L, respectively. It appears that mortality was not evaluated in a control 

group of fish. It is unclear if the Proprietary A concentrations in water reported by Ref. 46 are 

measured or nominal values. The latter point is important because a parallel study indicated that 

the amount of Proprietary A added to test water declines rapidly and less than 40% of the 

original amount of Proprietary A remains in the test water after 96 hours (Ref. 46). Thus, the 

lethal concentrations of Proprietary A could be lower than the reported LC50 values. 

Ref. 46 reported deformation of the spine in 7/10 killifish exposed to 3.5 mg/L Proprietary A for 

24 hours. However, Ref. 46 does not provide sufficient information regarding the spine 

deformation in killifish to make meaningful use of these observations. It is unclear whether the 

deformations were observed in the acute toxicity study or in a separate assay using killifish only. 

It appears that deformation was tested at only one concentration and a control group of fish was 

not evaluated. 

4-28
Another study showed that the 96-hour LC50 of Proprietary A in rainbow trout (currently 

classified as Oncorhynchus mykiss) was 1.4 mg/L (95% CI: 0.9-1.9 mg/L) (Unpublished study 

conducted in 1990, summarized in Ref. 4, 5). A NOEC was not observed since one fish died at 

0.63 mg/L, the lowest concentration tested. Compound purity was not provided in the summary 

and the reported concentrations of Proprietary A in the test water appear to be nominal values. 

The guideline for acute toxicity in fish (OPPTS 850.1075) indicates that test concentrations must 

be measured during the test if, as was the case in this study, aeration is used. Thus, the study 

reported by Ref. 4, 5 does not meet the criteria established by the guideline. The studies by Ref. 

46 and Ref. 4, 5 suggest that the 96-hour LC50 for Proprietary A in fish is in the range of 1 to 5 

mg/L, making it moderately toxic to fish. However, the data are inadequate to satisfy the acute 

toxicity endpoint for freshwater fish. A 96-hour LC50 of 1.1 mg/L and a NOEC of 0.56 mg/L for 

Proprietary A in rainbow trout (Ref. 42) were reported in Ref. 29. Although the results of the 

study by Ref. 42 are in agreement with those of Ref. 4, 5, the study by Ref. 42, or a study 

summary, was not available to allow for an independent evaluation of these data. Confirmation 

of the results of the study by Ref. 42 might allow the acute toxicity endpoint for freshwater fish 

to be satisfied. 

Marine Fish 

No acute toxicity studies in saltwater fish species were located. 

4-29
Table 4-1. Summary of available acute fish toxicity studies for Proprietary Aa 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Ref. 2 Goldfish 

(Carassius auratus) 

None Static None 6 Yes. The 

concentration of [Formulation 2] in water was determined by gas chromatograp hy. 

pH: NR Temp: 20°C DO: NR Hardness: NR Water volume: 20 L Electrical conductivity: 290 micromhos/cm 

None 

4-30
Table 4-1. Summary of available acute fish toxicity studies for Proprietary Aa 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Ref. 4, 5 Rainbow 

trout (Salmo gairdneri) 

1.4 mg/L (95% CI: 0.9-1.9 mg/L) 

Static Controls, 0.63, 

1.25, 2.5, 5, 10 mg/L 

10 No pH: 7.14-7.78 

Temp: 11.8-14.8 °C. DO: 92-100% of air saturation value Hardness: 218-228 mg/L as CaCO3. 

None reported 

4-31
Table 4-1. Summary of available acute fish toxicity studies for Proprietary Aa 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Ref. 22 Goldfish 

(Carassius auratus) 

None Static 1 and 5 mg/L in 

water 

6 None 

reported 

pH: NR Temp: 20°C DO: NR Hardness: NR Electrical conductivity: 290 

micromhos/cm 

Water or acetone 

4-32
Table 4-1. Summary of available acute fish toxicity studies for Proprietary Aa 

Study Reference 

Species Tested 

96-Hour LC50 

Selected Study Design Parametersb 

Study Type 

Concentrations Tested 

No. of Fish/ Conc 

Analytical Monitoring Water Chemistry Solvent 

Ref. 46 Killifish 

(Oryzias latipes) 

Killifish: 3.6 mg/L 

Static NR 7 to 9 Unclear if 

conducted 

pH: NR Temp: 25°C. DO: NR Hardness: NR Electrical conductivity: NR 

NR 

Goldfish (Carassius auratus) 

Goldfish: 5.1 mg/L 

aStudies that were either published in a foreign language or that were not readily and that were not critical to the hazard assessment were not retrievebNR: Not reported 

4-33
Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD 202) 

Conclusion: 

The acute toxicity data for freshwater invertebrates were judged inadequate to meet the endpoint. 

However, if the results of the study cited by Ref. 29 (see below) are confirmed independently, 

the endpoint might be satisfied given the high degree of agreement of the two available studies in 

freshwater invertebrates. 

Basis for Conclusion: 

The available data are summarized in Table 4-2. A flow-through study revealed a 48-hour LC50 

of Proprietary A with Daphnia magna of 3.8 mg/L (95% CI: 3.5-4.2 mg/L) and a NOEC of 1.6 

mg/L (Unpublished study conducted in 1999, summarized in Ref. 4, 5). Although some of the 

conditions of the study design (such as number of organisms, and water temperature and 

chemistry) appear to meet OPPTS Harmonized Guideline 850.1010, other aspects of the study, 

including compound purity and condition and fertility of the organisms in culture, were not 

reported in the summary. The amount of solvent used in the control group and the Proprietary A 

treatments might have exceeded the recommended maximum solvent concentration, as per the 

OPPTS Guideline (100 mg/L), but this does not appear to have affected the study results. A 48­

hour LC50 of 4.6 mg/L and a NOEC of 1.8 mg/L were reported for daphnia in a study by Ref. 43, 

as cited in Ref. 29. Although the results of the study by Ref. 43 are in agreement with those of 

Ref. 4, 5, the study by Ref. 43, or a study summary, was not available to allow for an 

independent evaluation of these data. Confirmation of the results of the study by Ref. 43 might 

allow the acute freshwater invertebrate toxicity endpoint to be satisfied. 

Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

Conclusion: 

No available acute marine/estuarine invertebrate toxicity data. 

Basis for Conclusion: 

No acute toxicity studies in marine/estuarine invertebrate species were located. 

4-34
Table 4-2. Summary of available acute invertebrate toxicity studies for Proprietary Aa 

Study Reference 

Species Tested 

48-Hour LC50 

Selected Study Design Parameters 

Com

Study Type 

Concentrations Tested 

No. of Organisms/ Concentration 

Analytical Monitoring 

Water Chemistry Solvent 

Ref. 4, 5 Daphnia 

magna 

3.8 mg/L (95% CI: 3.5­4.2 mg/L) 

Flowthrough Negative control, solvent control 

(dimethylformamide), 0.98, 1.6, 2.8, 3.8, 5.1 mg/L 

10 Yes pH: 8.3 

Temp: 20±2°C DO: $8.5 mg/L (94% of air saturation value) Hardness: 126 mg/L as CaCO3. 

Dimethylformamide Daph

solvenormthe 0Mortmg/L 80%(15%were termThe the cPropestim300 mrecomconcestimdime0.1 mof 30of 0.

aStudies that were either published in a foreign language or that were not readily and that were not critical to the hazard assessment were not retrieve

4-35
Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

Conclusion: 

No available chronic toxicity data for freshwater and marine fish. 

Basis for Conclusion: 

No chronic toxicity studies in freshwater and marine fish were located. 

Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1300; 

OECD 211) and Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized 

Guideline 850.1350) 

Conclusion: 

No available chronic toxicity data for freshwater and marine/estuarine invertebrates. 

Basis for Conclusion: 

No chronic toxicity studies in freshwater and marine/estuarine invertebrates were located. 

Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Conclusion: 

The available algal toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are summarized in Table 4-3. The summary of a 96-hour algal toxicity study 

(Unpublished study conducted in 1992, summarized in Ref. 4, 5) indicates that the study does 

not meet the OPPTS Harmonized Guideline 850.5400. The pH and temperature of the test water 

during the study were outside of the acceptable ranges for Selenastrum capricornutum, as per 

Guideline 850.5400. Moreover, the two highest concentrations tested exceed the estimated 

water solubility of Proprietary A (42 mg/L) and the concentrations tested were apparently not 

verified analytically. Additional information, including test substance purity, hardness, DO, 

TOC, TSS, exposure vessel size and head space, and measured chemical concentrations, were 

not provided in the summary. Also, there is no evidence that positive controls were used in 

order to establish that the algae were responding in the expected manner to a known chemical. 

The deviations from the OPPTS Guideline indicate that the study is inadequate to satisfy the 

algal toxicity endpoint. Another study indicates that Proprietary A at 10 mg/L had no effect on 

growth or biomass of the algal species Scenedesmus subspicatus exposed for 72 hours 

4-36
(Unpublished study conducted by Ref. 44, cited in Ref. 29). The study, or a study summary, was 

not available for the study by Ref. 44 to allow for an independent evaluation of these data. 

4-37
Table 4-3. Summary of available algal toxicity studies for Proprietary Aa 

Study Reference 

Species Tested 

EC50, NOAEC, 

and LOAEC 

Selected Study Design Parametersb 

Study Type 

Concentration Range Tested 

Analytical Monitoring 

Water Chemistry Solvent 

Ref. 4, 5 Selenastrum 

capricornutum 

96-hour EbC50 (biomass) = 12 mg/L (95% CI: 10-15 mg/L). 96-hour ErC50 (growth rate) = 39 mg/L (95% CI: 31-50 mg/L). 96-hour NOAEC: 6 mg/L. 

Static 0 (negative 

control), 2, 6, 18, 54, or 162 mg/L 

No Temp: 21°C 

pH: 6.7-7.9 DO: NR Hardness: NR 

None reported 

aStudies that were either published in a foreign language or that were not readily and that were not critical to the hazard assessment were not retrieveb NR: Not reported. 

4-38
Terrestrial Organism Toxicity 

Acute Oral (OPPTS Harmonized Guideline 850.2100), Dietary (OPPTS Harmonized 

Guideline 850.2200; OECD Guideline 205), or Reproductive Toxicity (OPPTS Harmonized 

Guideline 850.2300; OECD Guideline 206) in Birds 

Conclusion: 

No available acute oral, dietary, and reproductive toxicity data for birds. 

Basis for Conclusion: 

No acute oral, dietary, or reproductive toxicity studies in birds were located. 

Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

Conclusion: 

The available earthworm subchronic toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No earthworm subchronic toxicity studies were located. An acute (14-hour) LC50 of 130 mg/kg 

soil and a NOEC of 100 mg/kg soil with the earthworm, Eisenia fetida (Ref. 45), were reported 

in Ref. 29. However, the study has also been reported to be a 14-day subchronic toxicity study 

(Ref. 39). The study, or a study summary, was not available for an independent evaluation of the 

study and the results. 

4-39
Physical/Chemical Properties 

CAS 

MF 

MW 

SMILES 

Physical/Chemical Properties 

Water Solubility: 

Conclusion: The available water solubility data are adequate.

Basis for Conclusion: The key study (highlighted) was performed according to a reliable

method, and is in reasonable agreement with other values reported in the literature. 

Solubility (mg/L) References 

42 Ref. 4, 5; water solubility determination according to OECD Guideline 105 (shakeflask method) 

7 Ref. 8 (24/C); Ref. 27; Ref. 49 (24/C); Ref. 28 (24/C) 

100 Ref. 13, 21, 31, 61 (30/C) 

110 Ref. 15 

18.1 Confidential submitted study using shake flask method 

Log Kow: 

Conclusion: The available log Kow data are adequate.

Basis for Conclusion: The key study was performed according to a reliable method. 

Log Kow Reference 

2.4 4, 5; determination of Octanol-Water Partition Coefficient According to OECD 

Guideline 117 (HPLC Method) 

3.8 Ref. 61 

3.65 Ref. 28, 49 

3.75 Shake-flask method, Ref. 46 

3.69 Confidential submitted study using the HPLC method 

Oxidation/Reduction: No data 

Melting Point: 

4-40 
Conclusion: The available melting point data for Proprietary A are adequate. 

Basis for Conclusion: The key study was performed according to a reliable method. It is noted 

that the other literature data do not agree with the key study; however, the methods used to 

measure the melting points are not provided in any of the sources. As an OECD-guideline 

compliant method, the key study is better described and better supported. 

Melting Point (/C) References 

-58 Ref. 4, 5: melting point determination by DSC (compliant with OECD Guideline 102), 

freezing point was determined to be -40/C, melting point -58/C 

27 Ref. 15 

26.66 Ref. 6 

Boiling Point: 

Conclusion: The boiling point data are adequate. 

Basis for Conclusion: A variety of literature sources report the same value for the boiling point,

although there is some indication that the compound may decompose at or near the boiling point. 

Since experimental details are not provided in any of the sources, it is not possible to determine

whether the temperatures reported are decomposition or boiling temperatures. Nevertheless,

given the high boiling point reported for this material, the available data are adequate to

characterize its potential volatility. 

Boiling Point (/C/torr) References 

236-237/5 Ref. 13, 31, 49, 61 

200/4 Ref. 6 

Dec. >200/4 Ref. 61 

Gradual Dec. >200 Ref. 28 

Vapor Pressure: 

Conclusion: The available vapor pressure data are not adequate 

Basis for Conclusion: Although this measured vapor pressure is reported in two sources, it 

appears to be very high relative to the boiling points reported for this chemical. For comparison, 

an estimated vapor pressure (Ref. 23) is also included in the table below. The vapor pressure 

remains a data need. 

4-41
Vapor Pressure (torr//C) Reference 

0.01/30 Ref. 4, 5, 61 

2.98 x10-7 Ref. 23 estimate 

Odor: 

Conclusion: The odor of this compound has been adequately characterized.

Basis for Conclusion: Although no standardized tests are available for characterizing chemical

odors, the two descriptions found are similar, and are consistent with the low volatility expected

for this chemical. 

Odor Reference 

Mild Odor Ref. 28 

Bland Odor 6 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: 

Conclusion: The flammability (as the flash point and autoignition temperature) has been 

adequately characterized. 

Basis for Conclusion: Studies on the flash point and autoingition temperature of this chemical 

were located and appear reasonable given the other physical/chemical properties available for 

this compound. 

Flash Point Reference 

252/C (coc) Ref. 28, 61 

>107.22/C (Seta closed cup) Ref. 6 

Autoignition Temperature Reference 

512.77/C Ref. 6 

Explosivity: No data 

Corrosion Characteristics: No data 

4-42
pH: 

This chemical does not contain functional groups expected to influence the pH of aqueous 

solutions. Data for this endpoint are therefore not applicable. 

UV/Visible Adsorption: No data 

Viscosity: 

Conclusion: The viscosity of this chemical at various temperatures has been adequately

characterized. 

Basis for Conclusion: Studies on the viscosity of this chemical were located and appear

reasonable given the other physical/chemical properties available for this compound.

Viscosity (cP) Reference 

1,800 at 25/C Ref. 6, 61 

2,200 at 0/C Ref. 6 

540 at 40/C Ref. 6 

Density/Relative Density/Bulk Density: 

Conclusion: The density of this compound has been adequately characterized. 

Basis for Conclusion: Consistent data are provided in several reputable sources. 

Density Reference 

1.52 at 25/C Specific gravity. Ref. 61 

1.5022 at 20/C Specific gravity. Ref. 13, 31 

1.48 kg/L at 25/C Bulk density. Ref. 28 

Dissociation Constant in Water: 

This compound does not have functional groups that are expected to dissociate in water. This 

endpoint is therefore not applicable. 

Henry’s Law Constant: No data 

4-43
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: The bioconcentration factor has been adequately characterized. 

Basis for Conclusion: The two studies cited in the table below provide consistent information

for killifish under both static and flow-through conditions, over a variety of observation times,

and with varying initial concentrations of test substance. The BCF was also measured in

goldfish; the reported BCFs are independent of study length. 

Reference Species BCF 

Key Design Parameters 

Comments 

Exp. 

type 

Range 

(ppb) 

Study 

length T (/C) 

Ref. 46 Killifish 113 

110 

77 

Static 1,000 

initial 

24 hours 

55 hours 

96 hours 

25 Half-life for elimination 

of the test compound in 

water + fish = 31 hours. 

Ref. 46 Goldfish 5 Static 1,000 24 hours 25 Half-life for elimination 

3 initial 96 hours of the test compound in 

water + fish = 42 hours. 

Ref. 47 Killifish 46±5 

32±4 

31±6 

59±16 

49±12 

Flowthrough 

(all) 

400 

300 

40 

40 

80 

3 days 

4 days 

6 days 

30 days 

32 days 

25 BCF is independent of 

concentration; continuous 

(flow-through) results 

correlate to static results 

(Ref. 46). 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: 

Conclusion: The metabolism of Proprietary A in fish is not adequately characterized in the

literature. 

Basis for Conclusion: The depuration rate is adequately described in killifish, however, the

metabolite distribution is not addressed.

4-44
Species Rate Comment Reference 

Killifish Elimination half-life, 1.65 hours Depuration rate ­

elimination of Proprietary 

A when exposed fish are 

moved to clean water. 

Ref. 47 

Killifish Apparent metabolism is much 

faster in killifish than in goldfish. 

(Quantitative data are not 

provided.) 

~10% of applied 

Proprietary A remains in 

the water in the presence 

of killifish after 96 hours. 

Control (no fish) has no 

change in TPP 

concentration. 

Ref. 46 

Goldfish Apparent metabolism is much 

slower than in killifish. 

(Quantitative data are not 

provided.) 

~25% of applied 

Proprietary A remains in 

the water after 96 hours 

in presence of goldfish. 

Ref. 46 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: The biodegradation of Proprietary A under aerobic conditions has been adequately 

characterized. 

Basis for Conclusion: The key study (highlighted) was performed according to a GLPcompliant OECD guideline test. The other data located in the literature are generally in 

agreement with the key study. 

Study type/ 

Method Innoculum Acclim Degradation Time Comments Reference 

OECD 

Guideline 

301B 

Modified 

Sturm Test 

Activated 

sludge 

0% by CO2 

evolution. 

DOC red. not 

calculated 

due to 

solubility 

issues. 

28 days Initial concentrations 

2, 10 mg/L. GLPcompliant. 

Also reported: 

1) Closed bottle test 

(OECD Guideline 

301D) showed no 

inhibition of bacterial 

cultures in 10 days. 

Ref. 3, 4, 5 

4-45
Study type/ 

Method Innoculum Acclim Degradation Time Comments Reference 

Japanese 

MITI test 

Activated 

sludge 

avg. 1% by 

BOD 

28 days Initial concentrations 

100 mg/L (test 

substance), 30 mg/L 

(sludge). 

Ref. 15, 16, 28 

OECD 302C 0% by O2 

uptake 

28 days Ref. 61 

River DieAway Water from 

Oh River 

(Osaka, 

Japan) 

Neya River 

(Osaka, 

Japan) 

Seawater 

(Osaka Bay) 

12.5% 

18.5% 

0% 

5.4% 

0% 

22% 

7 days 

14 days 

7 days 

14 days 

7 days 

14 days 

Initial concentrations 

20 mg/L in Oh River 

water and 1 mg/L in 

Neya River water. 

Concentration in 

seawater not 

reported. 

Analysis by 

Molybdenum Blue 

calorimetric assay for 

increase in phosphate 

ion. 

Ref. 61 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: 

Conclusion: The available pyrolysis data are not adequate. 

Basis for Conclusion: Although a semi-quantitative description of the pyrolysis products is

given in Ref. 18, the list of degradates provided accounts for only 60% of the total mass

expected and doesn’t contain any oxygenated or phosphorus-containing compounds. Therefore,

this study does not provide a complete profile of the pyrolysis of Proprietary A. 

Pyrolysis Products Reference 

Relative mol.% degradates, 0.1 mole Proprietary A heated at 250-260/C 

under reduced pressure (3 mm Hg), overall yield 60 wt%: [Chemical 3] 

26.7%, [Chemical 4] 36.0%, [Chemical 5] 34.4%, [Chemical 6] 2.9%. 

Ref. 18 

Thermal oxidative degradation in air at 370/C: Hydrogen halides, 

halogenated C2 and C3 species, acrolein 

Ref. 28 

When heated to decomposition, it emits toxic fumes of Cl+

 and POx Ref. 31 

4-46
Hydrolysis as a Function of pH: 

Conclusion: The hydrolysis rate data are adequate. The hydrolysis products are not described. 

Basis for Conclusion: The studies cited below were GLP-compliant tests run according to 

accepted guidelines. 

T1/2 pH Temp. Comment Reference 

>1 year 

>1 year 

14.7 

days 

4 

7 

9 

50/C OECD 111; EPA Ser. 835 OPPTS No. 835.2110. 

GLP-compliant. 

Initial concentration, 10 mg/L. Study length, 5 

days. Preliminary study. 

Ref. 4, 5 

28 days 9 40/C OECD 111; EPA Ser. 835 OPPTS No. 835.2110. 

GLP-compliant. 

Definitive 30-day study. 

Ref. 4, 5 

128 

days 

9 20/C OECD 111; EPA Ser. 835 OPPTS No. 835.2110. 

GLP-compliant. 

Definitive 30-day study. 

Ref. 4, 5 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

4-47
Flame Retardant Alternatives

Proprietary B: Aryl phosphate

Hazard Review

5-1
Proprietary B: Aryl phosphate

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral * 

Dermal * 

Inhalation 

Eye irritation * 

Dermal irritation * 

Skin sensitization 

Subchronic Toxicity 

28-Day oral * 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

T

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro * 

Gene mutation in vivo * 

Chromosomal 

aberrations in vitro 

Chromosomal * 

aberrations in vivo 

DNA damage and * 

repair 

Other * 

5-2
Proprietary B: Aryl phosphate

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It 

does not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 * 

Daphnia acute * 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

5-3
Chemical Identity 

Proprietary B: Aryl phosphate 

Synonym 

CAS 

MF 

MW 

SMILES 

Many of the available health effects studies were conducted with commercial mixtures that 

commonly contained triphenyl phosphate as well as Proprietary B. The available information 

regarding the composition of these mixtures is presented below, but the composition of the 

actual samples tested in the health effects studies usually was not reported. 

[Formulation 1] is reported to contain 60-100% Proprietary B and 15-40% triphenyl phosphate 

(Ref. 24) and [Formulation 2] is reported to contain 60-100% Proprietary B and 4-7% triphenyl 

phosphate (Ref. 25). 

Major Components of [Formulation 3] and [Formulation 4] as reported in Ref. 34 

Component [Formulation 3] [Formulation 4] 

Total Proprietary B 49 61 

[Chemical 1] 8 11 

[Chemical 2] 6 7 

[Chemical 3] 2 5 

[Chemical 4] 21 27 

[Chemical 5] 12 11 

Triphenyl Phosphate 33 18 

5-4
Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for limit tests on undefined flame retardants for which compositional 

information was not provided. The authors of the studies referred to them as “non-definitive”, 

possibly because of the small group sizes (which, however, are consistent with current 

guidelines); in other respects the studies follow current guidelines. 

Additional Studies and Information: 

No deaths were observed in Sprague-Dawley rats (3/sex) given [Formulation 1] (mixture of 

Proprietary B and triphenyl phosphate) as a single oral dose of 5,000 mg/kg (Ref. 13). Clinical 

signs, which included tremors (0/3 males, 1/3 females), oral discharge, ataxia (0/3 males, 1/3 

females), decreased locomotion (1/3 males, 1/3 females), chromorhinorrhea, chromodacryorrhea, 

and abdominogenital staining, subsided by day 11. No effects on body weight gain and no gross 

internal lesions were observed. 

A parallel acute oral study on Sprague-Dawley rats (3/sex) given [Formulation 2] at a dose of 

5,000 mg/kg, reported clinical signs (abdominogenital staining and chromorhinorrhea) on the 

first 2 days post dosing, but no mortality, body weight gain effects, or gross internal lesions were 

reported (Ref. 17). 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for limit tests on undefined flame retardants for which compositional 

information was not provided. The authors of the studies referred to them as “non-definitive”, 

possibly because of the small group sizes (which, however, are consistent with current 

guidelines); in other respects, the studies follow current guidelines. 

5-5
Additional Studies and Information: 

No deaths were observed among Sprague-Dawley rats (3/sex) that were dermally exposed to 

[Formulation 1] (mixture of Proprietary B and triphenyl phosphate) at a dose of 2,000 mg/kg for 

24 hours under an occlusive covering (Ref. 14). There were no effects on body weight gain, no 

signs of irritation on the test site, and no gross internal lesions observed. 

In a parallel study in Sprague-Dawley rats (3/sex) dermally treated with 2,000 mg/kg 

[Formulation 2], all but one female gained weight, but there were no deaths, signs of irritation, or 

gross internal lesions (Ref, 18). 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300; OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline. A non-guideline study 

evaluated neurotoxicity of combustion products of an Proprietary B/triphenyl phosphate mixture 

in the presence of cyclic phosphonate compounds. 

Additional Studies and Information: 

Preliminary results of a study were reported (Ref. 38) investigating whether toxic compounds 

were formed when cyclic phosphonate compounds were thermally decomposed in the presence 

of other phosphate compounds in trimethylol polyol-based urethane foam. When rats were 

exposed (head only) for 20 minutes to smoke and decomposition gases from foam containing 

equal proportions of the cyclic phosphonate compounds and a mixture of Proprietary B and 

triphenyl phosphate, no convulsive seizures, characteristic of exposure to toxic bicyclic 

phosphites or phosphates, were observed. 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for undefined flame retardants for which compositional information was 

not provided. The authors of the studies referred to them as “non-definitive”, although they were 

consistent with current guidelines. 

5-6
Additional Studies and Information: 

Slight conjunctival erythema was observed in the eyes of 1/1 male and 1/2 female New Zealand 

White rabbits 24 hours after instillation with 0.01 mL of [Formulation 1] (mixture of Proprietary 

B and triphenyl phosphate) but was resolved by 48 hours (Ref. 15). No conjunctival discharge 

or effects on the cornea or iris were observed. The material was tentatively characterized as 

“practically non-irritating”, based on a maximum irritation score of 1.3/110 at 24 hours. 

In a parallel study in New Zealand White rabbits (1 male and 2 females) instilled with 0.01 mL 

[Formulation 2], there were no signs of eye irritation observed at 1, 24, 48, or 72 hours (Ref. 19). 

The material was tentatively characterized as non-irritating to the eyes based on a primary 

irritation index of 0/110 at all timepoints. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for undefined flame retardants for which compositional information was 

not provided. The authors of the studies on the Durad materials referred to them as “nondefinitive”, although they were consistent with current guidelines. 

Additional Studies: 

No dermal irritation (erythema or edema) was observed in one male and two female New 

Zealand White rabbits that were dermally exposed for 4 hours to [Formulation 1] (mixture of 

Proprietary B and triphenyl phosphate) on two occluded test sites (0.5 mL per site) and examined 

at 4.5, 24, 48, or 72 hours (Ref. 16). The material was tentatively rated as non-irritating to intact 

rabbit skin, based on scores of 0/8.0 at all timepoints. 

In a parallel dermal irritation study in one male and two female New Zealand White rabbits 

exposed for 4 hours to [Formulation 2] on two occluded test sites (0.5 mL per site), no irritation 

was observed at times between 4.5 and 72 hours (Ref. 20). The material was tentatively rated as 

non-irritating to intact rabbit skin, based on scores of 0/8.0 at all timepoints. 

In skin irritation assays in male New Zealand White rabbits (6/group), 24-hour topical 

administration (0.5 mL/site) of [Formulation 4] or [Formulation 10] did not elicit erythema or 

edema to intact or abraded skin (examined at 24 and 72 hours) (Ref. 6). The mean primary 

dermal irritation indices were 0/2.0 for both materials, which were characterized as non-irritating 

to skin. 

5-7
Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

SUBCHRONIC TOXICITY

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental)

Conclusion: 

The available subchronic oral toxicity data were judged inadequate to meet the endpoint.

Basis for Conclusion: 

A confidential study was submitted that reported preliminary results of a 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening study in rats exposed by oral gavage. 

Preliminary results suggested adrenal and liver effects, with adrenal weight effects in females at a 

LOAEL of 25 mg/kg/day. These data are not adequate because the final results were not available. 

No other verifiable data were available for defined substances tested under guideline methods. A 

study on undefined [Formulation 4] appeared to follow the guideline for a 28-day oral study, but was 

only available as an incomplete robust summary. The unexplained mortality in this study indicates 

that it may not be an adequate study. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

As described in an incomplete robust summary (results were not presented quantitatively) for an 

HPV submission, Sprague-Dawley rats (10/sex) received [Formulation 4] in the diet at 

concentrations of 0, 0.1, 0.5, or 1.0% for 28 days (Ref. 5). Treatment had no effect on survival (but 

12 rats died: 1 control, 4 low-dose, 4 mid-dose, and 3 high-dose rats). Treatment also had no effect 

on urinalysis results, incidence of gross lesions at necropsy, or histology of the liver and kidney 

(histology examined only in high dose animals and controls). It was not specified whether animals 

that died during the study were necropsied or examined histologically. Reduced feed consumption 

was observed in the mid-dose group in both sexes and reduced body weight gain was noted in highdose females. Abnormalities (not specified) were observed in clinical chemistry measurements in 

mid- and high-dose groups and in hematology parameters at the high dose. Relative liver weights 

5-8
were elevated in all treated groups. The unexplained mortality during this short term study raises 

concern for study adequacy. 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90-day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD 

Guideline 413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported preliminary results of a 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening study in rats exposed by oral gavage. 

Preliminary results suggest an ovarian weight effect at $25 mg/kg/day, and an epididymal weight 

effect and reduced fertility at 100 and 400 mg/kg/day. These data are not adequate because the final 

results were not available. No other pertinent studies were located that addressed the reproductive 

toxicity endpoints in the guidelines listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

5-9
DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported preliminary results of a 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening assay in rats exposed by oral gavage. 

Preliminary results suggest reduced pre- and post-natal survival at 400 mg/kg/day. These data are 

not adequate because the final results were not available. No other pertinent studies were located 

that addressed the developmental toxicity endpoints in the guidelines listed below. 

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines 

listed below. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

5-10
Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

Additional information 

As described in an unvalidated robust summary, 3 days of exposure to [Formulation 7], tested 

without metabolic activation at concentrations between 0.04 and 5.0 :g/mL, did not induce cell 

transformation in cultured Balb/c-3T3 cells (Ref. 36). 

NEUROTOXICITY 

Conclusion: 

The available neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Available acute and 28-day studies indicate that there is a risk of delayed neurotoxicity from 

exposure to Proprietary B. Most studies either were conducted on undefined substances or were not 

described in sufficient detail. A summary of a study on purified components of [Formulated] flame 

retardants suggests that [Chemical 4] or [Chemical 2] are the neurotoxic components of these 

mixtures; however, details of the in vivo study in hens were not located. The neurotoxicity of 

Proprietary B preparations would be dependent on the relative content of [Formulation 11] isomers. 

No data are available for the full battery of tests for functional neurotoxicity or for developmental 

neurotoxicity. 

Delayed Neurotoxicity 

Conclusion: 

The available delayed neurotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The acute study (experiment A) on a defined Proprietary B mixture departed from guideline in that 

enzyme inhibition was assayed 24 hours after dosing rather than 48 hours, but reported significant 

suppression of both brain neurotoxic esterase and plasma cholinesterase levels. The longer study 

did not conduct a complete battery of neurobehavioral tests as stipulated under the guideline, but 

5-11
reported adverse effects on motor coordination at all doses on the day of treatment. The highest dose 

(11,700 mg/kg) exceeded that recommended under the guideline, but that deviation does not affect 

the conclusion of the study. Studies on purified components of [Formulated] flame retardants 

identified the neurotoxic components, but were not adequately described. The majority of studies 

suggest that delayed neurotoxicity may result from exposure to oral doses in excess of 1,000 mg//kg. 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Critical Studies 

Type: Acute oral delayed neurotoxicity

Species, strain, sex, number: Hen, 12-14 months old, White Leghorn, 4/dose for experiment A;

10-12/dose for experiment B.

Purity: Proprietary B with the composition as in the following table.

Composition of Proprietary B assayed by Ref. 37 

Component Percent 

Total Proprietary B <75

 [Chemical 4] 24

 [Chemical 6] 18

 [Chemical 2] 10

 [Chemical 7] 10

 [Chemical 5] 6

 [Chemical 8] 7

 [Chemical 9] <1 

Triphenyl Phosphate 24 

Doses: Experiment A. Six doses between 12 and 11,700 mg/kg;

Experiment B. 0, 12, or 370 mg/kg in corn oil or 11,700 mg/kg undiluted

Vehicle: Corn oil

Positive control: Tri-ortho-cresyl phosphate (TOCP)

Route: Oral (not specified)

Exposure duration, frequency: Experiment A, single treatment followed 24 hours later by

biochemical assay; Experiment B, 6 weeks, single treatments 3 weeks apart; study terminated 3

weeks after second dose.

Method: Experiment A. Brain neurotoxic esterase (NTE) and plasma cholinesterase (PChE)

measurements recorded 24 hours after single treatment with Proprietary B, corn oil or TOCP.

5-12
Experiment B. Doses were chosen based on results of experiment A to represent minimal, 50%, and 

maximal inhibition of brain NTE. Body weight and food consumption measured every 3-4 days, 

walking behavior evaluated weekly. Neurohistopathology evaluated at termination. 

Results: Experiment A. The NOAELs for inhibition of NTE or PChE were 12 and 180 mg/kg, 

respectively. Doses about 1,000 mg/kg and higher caused ~70% inhibition of NTE and ~80% 

inhibition of PChE. The positive control (500 mg/kg of TOCP) inhibited brain NTE by 85.2% and 

PChE by 70%. 

Experiment B. Proprietary B had no effect on mortality. Few adverse signs visible at or below 370 

mg/kg. All treated at 11,700 mg/kg showed motor incoordination beginning day 1, with feather loss 

7-11 days later. Body weights not affected at lowest dose. Body weight effects at mid- and highdose are uncertain because text and graph do not match; one dose caused transient weight loss on 

days 22-38 and the other persistent weight loss from day 22 to the end of the study. TOCP caused 

persistent weight loss beginning day 5. Food consumption was transiently reduced in all groups 

(including positive and negative controls) on day 2 and 23, also on day 18 for TOCP. Significant 

transient, dose-dependent impairment of gait was observed on day 1 and 22 for hens treated with 

Proprietary B at all doses. Hens treated with TOCP showed significant impairment on day 1 and 

15, with gradual worsening to the end of the study. Neurohistopathological examinations revealed 

no significant difference between Proprietary B treatment and corn oil controls, whereas TOCP 

caused a significant increase in axonal degeneration in brain, spinal cord (cervical, thoracic and 

sacro-lumbar), and bilateral degeneration of the sciatic nerve. 

Reference: Ref. 37 

Additional Studies: 

As described in Ref. 44, a series of acute delayed neurotoxicity assays were conducted on 

[Formulated] flame retardants. No ataxia was observed in groups of 4 hens treated with 

[Formulation 5] at doses of 2,000, 4,000, or 8,000 mg/kg; 3/30 hens treated with 16,000 mg/kg 

showed ataxia (Ref. 7). Only 1/10 hens treated with [Formulation 6] at 20,000 mg/kg exhibited 

ataxia (Ref. 8). In one study on [Formulation 4], no ataxia was observed at doses of 500, 1,000, or 

2,000 mg/kg, whereas 2/10 treated at 4,000 mg/kg showed ataxia (Ref. 9); inhibition of brain NTE 

was 79.5% at the highest dose. In a second study on [Formulation 4], incidences of ataxia (0/10, 

3/10, 1/10 and 1/10) and neurohistopathological lesions (1/10, 0/10, 1/10, and 2/10) were not 

precisely related to the respective doses of 3,000, 5,000, 7,000, and 9,000 mg/kg (Ref. 10). For 

[Formulation 3], incidences of ataxia (1/9, 4/10, 6/10 and 3/10) and neurohistopathology (0/10, 4/10, 

7/10 and 1/10) were observed in the 2,000, 4,000, 6,000, and 8,000 mg/kg groups, respectively (Ref. 

11). 

A subchronic (91-day) oral neurotoxicity assay is summarized briefly in a TSCA 8e submission 

(Ref. 12), and in more detail by Ref. 44 and in a robust summary in an HPV submission (Ref. 23; 

U.S. EPA comments not available). In this study, hens (20/group) were administered [Formulation 

3] (mixture of Proprietary B and triphenyl phosphate) daily at doses of 0, 10, 20, 90, and 270 

mg/kg/day. Deaths occurred in all dose groups as follows: 2/20 vehicle controls, 4/20 positive 

controls, 3/20 at 10 mg/kg/day, 5/20 at 90 mg/kg/day, and 6/20 at 270 mg/kg/day. Ataxia was 

observed in 4/20 at 90 mg/kg/day and 9/20 at 270 mg/kg/day. Histopathological examination of 

5-13
nervous tissue of 10 hens/group revealed the following: significant degeneration at 3 levels of the 

spinal cord in 3 vehicle controls, significant degeneration of the spinal cord in TOCP hens, 

degeneration of the spinal cord and peripheral nerves in hens of the 90 and 270 mg/kg/day groups, 

with a dose-response relationship for severity and incidence (further details not reported). No ataxia 

or brain histopathology was observed at 10 or 20 mg/kg/day. 

[Formulation 4] and [Formulation 6] were given in two 2,000 mg/kg doses 21 days apart to hens 

(4/group) (Ref. 22). Neither compound caused body weight effects, clinical signs of neurotoxicity 

or an increase in gross internal lesions at necropsy (21 days after the second dose). There was no 

evidence of neurohistopathology in hens treated with [Formulation 4], but one out of four hens 

treated with [Formulation 6] had unilateral brain lesions at two histological levels. 

Proprietary B at tested positive for neurotoxicity in hens treated at three 21-day intervals with 10,000 

mg/kg (Ref. 33). Effects included gross paralysis with demyelination confirmed histopathologically. 

Several components of the [Formulated] series of flame retardants were isolated to >99% purity and 

tested at doses as high as 1,000 mg/kg in hens for neurotoxicity and suppression of neurotoxic 

esterase (Ref. 29). Details of these studies were not located. Three isomers of [Chemical 1] and 

[Chemical 5] elicited no signs of neurotoxicity and no suppression of NTE levels. [Chemical 5] was 

also judged to be non-neurotoxic, eliciting no ataxia or other signs of neurotoxicity and insignificant 

suppression of NTE (-4% or -15%) in two tests. Both [Chemical 2] and [Chemical 4] were positive, 

eliciting ataxia and neurotoxicity at 1,000 mg/kg, but not at lower doses; [Chemical 2] suppressed 

NTE by 85% and [Chemical 4] suppressed NTE by 79 and 90% in two assays. The author suggested 

that neurotoxicity was associated with triaryl phosphates containing a 2-alkyl substituent with an 

oxidizable alpha-hydrogen. 

In a two-hen screening test, a single 1,000 mg/kg dose of [Formulation 3] administered in gelatin 

capsules to two hens resulted in a 53.1% inhibition of neurotoxic esterase activity in the brain (Ref. 

42). The report was not clear as to the day on which the hens were sacrificed. 

No neurotoxicity studies were located that followed or were similar to the guidelines listed below. 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity Study (OPPTS Harmonized Guideline 870.6300) 

Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) OPPTS Harmonized Guideline 

870.6500 

• Peripheral Nerve Function (rodent) OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred) OPPTS Harmonized Guideline 

870.6855 

5-14
These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, or 

because of structural similarity of the substance to neurotoxicants that affect these endpoints. These 

studies may be combined with other toxicity studies. 

Other Neurotoxicity Data 

Cholinesterase inhibition 

[Formulation 3] at doses of 15, 20, or 25 mL/kg did not inhibit blood cholinesterase activity, but 

neither species of animal (3/group) nor the specific biological material assayed were reported (Ref. 

4). 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data. 

Basis for Conclusion: 

No immunotoxicity study was located that followed or was similar to the guideline listed below. 

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No verifiable genotoxicity data were located. The available studies were only accessible as robust 

summaries in a IUCLID Dataset that had not undergone review by the European Commission (Ref. 

3). Furthermore, the data were unpublished industry-sponsored studies on commercial products for 

which no contemporaneous component analyses were provided. Current compositional information 

taken from MSDS documents are presented in the following table. The results of these studies are 

summarized below despite their uncertain validity. In general, not enough details were provided to 

ascertain whether protocols met the standards of OPPT or OECD guidelines. 

5-15
Percentage of Proprietary B and triphenyl phosphate in Currently Available Commercial Products 

Product Proprietary B (%) triphenyl phosphate (%) Reference 

[Formulation 7] 60-100 15-40 Ref. 26 

[Formulation 8] 60-100 10-30 Ref. 27 

[Formulation 9] 60-100 7-13 Ref. 28 

[Formulation 2] 60-100 4-7 Ref. 25 

Gene Mutation in Vitro: 

• Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

As described in unvalidated robust summaries, negative results were reported for mutagenicity 

assays in Salmonella typhimurium with or without metabolic activation. [Formulation 7] and 

[Formulation 9] were tested in strains TA98, TA100, and TA1537 at concentrations as high as 1.62 

mg/mL (Ref. 1, 2). [Formulation 9] and [Formulation 2] were tested in strains TA98, TA100, 

TA1535, TA1537, and TA1538 at concentrations as high as 0.1 mL per plate (Ref. 31, 32). 

• In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

As described in an unvalidated robust summary, [Formulation 7] at concentrations of 0.0013-0.1 

:L/mL was not mutagenic to cultured mouse lymphoma L5178Y TK+/- cells without metabolic 

activation (Ref. 30). Results in the presence of metabolic activation were equivocal in that a doseresponse was observed, but none of the cultures exhibiting >10% total growth had mutant 

frequencies 2-fold greater than background. 

Gene Mutation in Vivo 

• Sex-linked Recessive Lethal test in Drosophila melanogaster (OPPTS Harmonized 

Guideline 870.5275) 

As described in an unvalidated robust summary, [Formulation 7] (32.5, 75, or 150 mg/mL) fed to 

adult male fruit flies for 3 days did not induce heritable mutations (Ref. 43). 

Chromosomal Aberration in Vitro 

No pertinent studies were located. 

Chromosomal Aberration in Vivo 

5-16
• Mammalian Bone Marrow Chromosomal Aberration Test (OPPTS Harmonized 

Guideline 870.5385) 

As described in an unvalidated robust summary no increase in chromosomal aberrations was 

observed in the bone marrow of Chinese hamsters (8/sex/group), 16, 24, or 48 hours after receiving 

a single oral dose of 5,000 mg/kg [Formulation 7] by gavage (Ref. 41). The summary 

indicated that the study was conducted under OECD Guideline 475 and GLP. Another unvalidated 

robust summary reported that a significant increase (compared to controls) in the incidence of bone 

marrow cells with chromosomal anomalies was observed in Chinese hamsters (6/sex/group) 24 

hours after receiving the second of two consecutive daily doses of 2,500 or 5,000 mg/kg/day 

[Formulation 7] by oral gavage (Ref. 40); no increase was observed in animals receiving 1,250 

mg/kg/day. 

DNA Damage and Repair 

• Unscheduled DNA synthesis in mammalian cells in culture (OPPTS Harmonized 

Guideline 870.5550) 

As described in an unvalidated robust summary, [Formulation 7] tested without metabolic activation 

at concentrations between 0.6 and 75 nL/mL did not cause unscheduled DNA synthesis in cultured 

rat hepatocytes (Ref. 35). 

Other 

• In vivo Sister Chromatid Exchange Assay (OPPTS Harmonized Guideline 870.5915) 

As described in an unvalidated robust summary, there was no increase in the frequency of sister 

chromatid exchanges in bone marrow cells of Chinese hamsters (4/sex/group) 24 hours after 

receiving a single oral dose of 1250, 2,500, or 5,000 mg/kg [Formulation 7] by gavage in 

carboxymethylcellulose (Ref. 39). 

5-17
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

The available acute toxicity data for fish, aquatic invertebrates, and algae were judged inadequate 

to meet the endpoints. 

Basis for Conclusion: 

Summaries were located for several acute toxicity studies of Proprietary B in an HPV test plan 

submission and accompanying robust summaries (Ref. 23); however, EPA comments on this 

submission were not available. The summaries included two 96-hour studies in fathead minnows 

(Pimephales promelas), three 96-hour studies in rainbow trout (Oncorhynchus mykiss), and three 

48-hour studies in Daphnia magna. According to Ref. 21, all of the studies were conducted with 

100% Proprietary B; however, other reports have identified the tested material in some of these 

studies as [Formulation 1] (Ref. 24) or [Formulation 4] (Ref. 21). [Formulation 1] is a mixture 

containing 60-100% Proprietary B and 15-40% triphenyl phosphate (Ref. 24). [Formulation 4] has 

been reported to contain 61% Proprietary B and 18% triphenyl phosphate (Ref. 34; see table at 

beginning of Human Health Effects for details). The available study summaries and Material Safety 

Data Sheets are insufficient to precisely establish the composition of the materials tested in the acute 

toxicity studies. Without precise knowledge of the composition of the tested materials, it is not 

possible to use these studies to make a definitive statement regarding the acute toxicity of 

Proprietary B. The publicly available information regarding the acute toxicity of Proprietary B to 

freshwater fish or aquatic invertebrates is insufficient to satisfy the endpoints in the guideline 

protocols listed below. 

A confidential study was submitted that reported a freshwater daphnid 48-hour EC50 >0.77 mg/L, 

the maximum test concentration. This concentration is above the water solubility limit of Proprietary 

B. 

A confidential study was also submitted that reported a freshwater green algal 72-hour EC50 of 

approximately 0.480 mg/L. This concentration is above the water solubility limit of Proprietary B. 

The available data were judged inadequate to meet this endpoint 

No pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

5-18
• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish or aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

5-19
Physical/Chemical Properties 

Proprietary B 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

5-20
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: 

The available aerobic biodegradation data are not adequate. 

Basis for Conclusion: 

A single confidential ready biodegradation study, indicating that Proprietary B is not ready 

biodegradable, was submitted. This study is not sufficient to fully characterize the aerobic 

biodegradation of Proprietary B under environmental conditions. 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

5-21
Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

5-22
Flame Retardant Alternatives

Proprietary C: Chloroalkyl phosphate (2)

Hazard Review

6-1
Proprietary C: Chloroalkyl phosphate (2)

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal T

Inhalation * 

Eye irritation T

Dermal irritation T

Skin sensitization T

Subchronic Toxicity 

28-Day oral T

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental * 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional * 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro T

Gene mutation in vivo T

Chromosomal T

aberrations in vitro 

Chromosomal T

aberrations in vivo 

DNA damage and 

repair 

Other 

6-2
Proprietary C: Chloroalkyl phosphate (2)

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

T

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 T

Daphnia acute T

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, T

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic T

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

6-3
Chemical Identity 

Proprietary C: Chloroalkyl phosphate (2) 

Synonym 

CAS 

MF 

MW 

SMILES 

Test materials used in health effects studies included two formulations, [Formulation 1] and 

[Formulation 2]. Analysis of [Formulation 1] indicated an approximate ~85% content of Proprietary 

C, 6.7% [Chemical 1], and 5-10% related compounds. The following table shows a comparison of 

properties and of impurities in [Formulation 1] and a sample of [Formulation 2] (Ref. 11). [Chemical 

2] was an additive to prevent scorching during foam preparation; it is a neuroleptic agent. Results 

for [Formulation 2]and [Formulation 3] are provided as supplemental information only, as current 

products do not contain [Chemical 2]. 

A Comparison of [Formulation 1] with [Formulation 2] (Ref. 11) 

[Formulation 1] [Formulation 2] 

Acidity (mg KOH/g) 0.1-1.0 1.6 

Color (APHA) 100-200 500+ 

Viscosity (corrected to 25°C) 2,000-3,500 cp 3,950 

[Chemical Group 1] 100-500 ppm less than detectable 

[Chemical 1] (%) 4-9% 9.0% 

[Chemical 2] absent 1.5-2.0% 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

6-4
Basis for Conclusion: 

Acute oral toxicity studies on undiluted [Formulation 1] (~85% Proprietary C) conformed to OPPTS 

or OECD guidelines except that survivors were not necropsied. The LD50 exceeded the current 

limit dose of 5,000 mg/kg for acute oral toxicity. 

Critical Study: 

Type: Acute oral toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 5/sex/group 

Doses: Two tests performed, the first at 5,000 mg/kg (sample 83341) and the second at 2,000 mg/kg 

(sample 83365) 

Purity: ~85% Proprietary C in [Formulation 1]; also contains ~6.7% [Chemical 1] and 5-10% 

“related compounds” 

Vehicle: None 

Observation period: 14 days 

Method: Rats observed for clinical signs frequently on the first day and daily for 14 days. Animals 

dying prematurely were given a gross necropsy examination. 

Results: Rats were fasted prior to dosing. Clinical signs included decreased activity, respiratory 

distress, lacrimation, oral discharge, soft stool, decreased feces, and perianal discharge. There were 

no specific signs of cholinesterase inhibition (myosis or fasciculations). After day 2, all low-dose 

survivors showed no clinical signs of toxicity. Necropsy findings included effects in the 

gastrointestinal system (stomach containing air and reddish-yellow material, small intestine 

containing mucoid material, injected blood vessels of stomach and small intestines), kidney (dark 

coloration and congestion), thymus (dark coloration and mottling), lungs (redness), lymph nodes 

(darkened), and liver (pale). Mortality, all within 48 hours of dosing, was 1/10 at the low dose and 

8/10 at the high dose. Acute oral LD50 (not calculated) was between 2,000 and 5,000 mg/kg. 

Comment: The doses used in this study were equivalent to limit doses under OPPT guidelines 

Reference: Ref. 6 

Additional information: 

An acute oral toxicity study conducted by Ref. 21 that reported an LD50 of 160 mg/kg in SpragueDawley rats exposed to [Formulation 3] in 10% aqueous solution was not considered, since 

compositional data were not available. Analysis of a similar material ([Formulation 2]) indicated 

that the [Chemical 1] content was twice that of [Formulation 1], and also indicated the presence of 

1.5-2% [Chemical 2], a neuroleptic agent that may have contributed to the higher relative toxicity 

compared to [Formulation 1] (Ref. 11). 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged adequate to meet the endpoint. 

6-5
Basis for Conclusion: 

Despite not fully conforming to OPPTS or OECD guidelines, the available study on [Formulation 

1] appears to be adequate since neither clinical signs nor mortality were observed at the limit dose 

of 2,000 mg/kg. A similar LD50 was reported for [Formulation 3]. 

Critical Study: 

Type: Acute dermal toxicity 

Species, strain, sex, number: Rabbit, New Zealand albino, 3/sex 

Dose: 2,000 mg/kg 

Purity: ~85% Proprietary C in [Formulation 1] 

Vehicle: None 

Exposure period: 24 hours 

Method: Hair was clipped from entire trunk of each rabbit. Skin of 1 male and 2 females was left 

intact; skin of 2 males and 1 female was abraded. Test material applied under occlusive bandage. 

Animals examined for clinical signs “frequently” during first day and daily for 14 days. Test sites 

were washed with saline after 24 hours; irritation assessed at 26 hours, 72 hours, and 7 days. No 

gross necropsy was performed. 

Results: No deaths occurred; therefore, the acute dermal LD50 exceeded 2,000 mg/kg in rabbits. 

There were no clinical signs of toxicity and no body weight effects. 

Reference: Ref. 7 

Additional information: 

An acute dermal LD50 exceeding 5,010 mg/kg in rabbits was reported for [Formulation 3] (Ref. 21). 

No compositional information was available for this material, but analysis of [Formulation 2] 

indicated that the [Chemical 1] content was twice that of [Formulation 1], and also indicated the 

presence of 1.5-2% [Chemical 2], a neuroleptic agent (Ref. 11). 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300; OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No verifiable acute inhalation toxicity data were located, but an incomplete robust summary for a 

study apparently conducted under the guideline was available in an unevaluated IUCLID Dataset 

(Ref. 3). 

According to a robust summary for a GLP-compliant study (Ref. 3), the acute (4-hour) inhalation 

LC50 for Proprietary C (as [Formulation 4] or [Formulation 5]) exceeded 1.65 mg/L. 

6-6
Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

An acute eye irritation study on [Formulation 1] was essentially consistent with OPPTS and OECD 

guidelines. The only effect was conjunctival irritation that was resolved by 24 hours. 

Critical Study: 

Type: Acute eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, sex not reported, 6 

Doses: 0.1 mL 

Purity: ~85% Proprietary C in [Formulation 1] 

Vehicle: None 

Method: 0.1 mL of the neat test material was instilled into one eye and not washed. The eyes were 

scored for irritation at 1, 24, 48, and 72 hours. 

Results: The average scores (maximal possible 110) were 5.0, 0, 0, and 0 at 1, 24, 48, and 72 hours, 

respectively, based on conjunctival effects. No irritation of the cornea or iris was observed. 

Reference: Ref. 8 

Additional information: 

An acute eye irritation study on [Formulation 3] reported conjunctival effects persisting to 24 hours, 

but resolved by 42 hours (Ref. 21). Compositional information was not available for this material, 

but analysis of a related substance ([Formulation 2]) indicated that its greater irritation properties, 

relative to [Formulation 1], might be attributed to its greater acidity: titration with 1.6 mg KOH/g, 

compared to 0.1-1.0 mg KOH/g, respectively (Ref. 11). A submitted confidential study reported 

slight eye (conjunctival) irritation. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

An acute (24-hour) dermal irritation study for [Formulation 1] was consistent with OPPTS and 

OECD guidelines. The test material was characterized as non-irritating. 

6-7
Critical Study: 

Type: Acute (24-hour) dermal irritation 

Species, strain, sex, number: Rabbit, New Zealand White, 3/sex 

Doses: 0.5 mL to each test site (abraded, non-abraded) on each animal 

Purity: ~85% Proprietary C in [Formulation 1] 

Vehicle: None 

Method: Hair was clipped from sides and backs of 6 rabbits; on one side, skin was abraded with 

point of 22 gauge needle. The test material was applied occluded; after 1 hour, Elizabethan collars 

were used to prevent disturbance of test sites. Sites were cleaned after 24 hours. Sites were 

examined for irritation at 26 hours and 72 hours after application. 

Results: Males showed no signs of irritation (erythema or edema). No edema was observed in 

females. Barely perceptible irritation (erythema) was detected in 2/3 females at 26 hours (mean 

scores of 0.3 on intact and 0.2 on abraded skin), but in none at 72 hours; the primary irritation index 

was 0.1/8.0. The study authors characterized the material as a “non irritant” to skin following 

occlusive exposure for 24 hours. 

Reference: Ref. 9 

Additional information: 

A 4-hour dermal irritation study in rabbits exposed to [Formulation 3] also reported erythema but 

no edema, with effects resolving by 48 hours (Ref. 21). No compositional information was available 

for this material, but analysis of [Formulation 1] indicated that the [Chemical 1] content was twice 

that of [Formulation 1] and its acidity was greater: titration with 1.6 mg KOH/g, compared to 0.1-1.0 

mg KOH/g, respectively (Ref. 11). Of two submitted confidential skin irritation studies, one 

reported slight irritation (erythema) and another reported mild irritation (erythema and edema). 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available studies, two of which indicate no evidence of dermal sensitization and one of which 

indicates evidence of mild dermal sensitization, appear to have been consistent with OPPTS and 

OECD guidelines. Few details were available for the Buehler test on [Formulation 1] (~85% 

Proprietary C), but this method is one considered preferable under OPPTS guideline 870.2600. No 

sensitization was reported for [Formulation 2], although analyses suggest that it is less pure than 

[Formulation 1], having double the content of [Chemical 1] and slightly greater acidity than the 

latter, and containing 1.5-20% [Chemical 2] as a scorch inhibitor (Ref. 11). 

6-8
Critical Studies: 

Type: Dermal sensitization (Buehler) study 

Species, strain, sex, number: Guinea pig, Hartley albino, 5/sex/group 

Doses: Not reported, but probably 0.5 mL, since Buehler method is cited. 

Purity: ~85% Proprietary C in [Formulation 1] 

Vehicle: None 

Method: Cited as Ritz and Buehler. The test material was applied dermally once per week for 3 

weeks. Fourteen and 21 days after the third application, challenge and rechallenge doses were 

applied to treated animals and to a set of previously untreated controls (5/sex). Skin responses were 

evaluated at 24 and 48 hours after the initial challenge and rechallenge. 

Result: No sensitization reactions were observed. 

Reference: Ref. 19 

Type: Dermal sensitization study 

Species, strain, sex, number: Guinea pig, albino, 10 males/group 

Doses: 0.05 mL of 10% or 25% (v/v) 

Purity: Not reported; [Formulation 2] 

Vehicle: 13% guinea pig fat dissolved in 50/50 acetone/dioxane (FAD) 

Method: The test material was applied to shaved intact shoulder skin and gently rubbed in with a 

Teflon rod. Sensitization by 4 sacral intradermal injections of 0.1 mL of 1% solution in DMSO. 

Challenge after 2 weeks by 0.05 mL of 10 or 25% (v/v) in FAD applied to shaved intact shoulder 

skin. Groups of previously exposed animals (10/dose) were also given the challenge doses. 

Result: Reactions after 1 day were negative for all groups. The authors conclude that the material 

is not a dermal sensitizer. 

Reference: Ref. 4 

Additional information: 

One-inch squares of acetate fiber with 5.0% [Formulation 2] did not elicit skin reactions when 

applied for 6 days to the skin of 211 human subjects (Ref. 4). Two weeks later, no sensitization 

reactions were observed following a 48-hour challenge application. A confidential sensitization 

study reported mild skin sensitization in a guinea pig maximization test, with 17% of the animals 

showing positive results. 

SUBCHRONIC TOXICITY 

Conclusion: 

The available subchronic toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A submitted confidential 28-day or gavage study was consistent with guidelines. 

6-9
Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

C Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

A confidential, 4-week, repeated-dose oral gavage study in rats was submitted. The NOAEL and 

LOAEL were 15 and 150 mg/kg/day, respectively, based on liver effects 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the 

guidelines listed below. 

C 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

C Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 411) 

Subchronic Inhalation Toxicity (90-day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines 

listed below. 

Additional Information 

A confidential, 4-week repeated-dose oral gavage study in rats was submitted. No histopathology 

was found in the reproductive organs in either sex at a NOAEL of 600 mg/kg/day; however, the 

study duration was relatively short and reproductive function was not tested. 

6-10
C Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

C Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

C Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Although [Formulation 2] apparently has a similar if lower Proprietary C content compared to 

[Formulation 1] (~85% Proprietary C), it also contains 1.5-2.0% [Chemical 2] as an anti-scorching 

additive (Ref. 11). The presence of [Chemical 2], a neuroleptic, could confound the identification 

of the maternal NOAEL/LOAEL values. The small group size prevents the identification of fetal 

NOAEL/LOAEL values. 

Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; OECD 

Guideline 414) 

Type: Prenatal developmental toxicity 

Species, strain, sex, number: Rat, CD, 5 pregnant females/group 

Purity: Not reported; [Formulation 2] 

Doses: 0 (distilled water at volume of high-dose), 100, 200, 400, 800, and 1,600 mg/kg/day 

Vehicle: none 

Exposure duration, frequency: gestational days (GD) 6-19 

Method: Pregnant rats were treated once daily on GD 6-17 by oral gavage and were observed once 

daily on GD 6-20 for mortality and clinical signs. Maternal body weights were measured on GD 

0, 6, 9, 12, 16, and 20. Dams dying prematurely were necropsied to determine cause of death. 

Examinations of thoracic and abdominal cavities for gross lesions, ovaries, and uterine contents were 

conducted on all surviving dams on GD 20. Endpoints included fetal viability, early and late 

resorptions, post- implantation loss, total implantations, and corpora lutea. 

Results: Maternal mortality was observed in 5/5 at 1,600 mg/kg/day (GD 7 and 8) and 1/5 at 800 

mg/kg/day (GD 9); causes of death were not determined. Treatment-related clinical signs were not 

observed at #200 mg/kg/day. Clinical signs included dry red matter around the nose and forepaws 

(in 1 rat at 400 mg/kg/day and 2 rats at 800 mg/kg/day), and staining of the anogenital area (in 4/5 

rats at 800 mg/kg/day). Maternal body weight gain was reduced by 32% at 800 mg/kg/day (largely 

because of weight loss during GD6-9), but not affected at lower doses. A slight increase in mean 

postimplantation losses (1.0 per dam) at 800 mg/kg/day (compared to 0.6 per dam in concurrent 

6-11
controls) was similar to the mean historical control value of 0.9 per dam. No other significant 

treatment-related effects were observed. The maternal NOAEL was 400 mg/kg/day and the LOAEL 

was 800 mg/kg/day for clinical signs (anogenital staining) and increased mortality (1/5). 

[Formulation 2] was not a specific developmental toxicant as the only effect in offspring (marginally 

increased postimplantation loss) occurred at a maternally toxic dose (800 mg/kg/day). The small 

group size (four surviving dams) does not permit accurate identification of fetal NOAEL/LOAEL 

values. 

Reference: Ref. 5 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

No studies were located that followed or were similar to the two tests listed above. 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines 

listed below. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

6-12
• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

The available neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No neurotoxicity studies were available that followed guideline methods. However, inhibition of 

cholinesterase activity, an optional parameter for delayed neurotoxicity in hens under OPPTS 

Guideline 870.6100, was noted in rats orally exposed to [Formulation 1] (~85% Proprietary C) (Ref. 

10, 14). 

No studies were located that followed or were similar to the guidelines listed below. 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

• Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) (OPPTS Harmonized 

Guideline 870.6500) 

• Peripheral Nerve Function (rodent) (OPPTS Harmonized Guideline 870.6850) 

• Sensory Evoked Potentials (rat, pigmented strain preferred) (OPPTS Harmonized 

Guideline 870.6855) 

These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, or 

because of structural similarity of the substance to neurotoxicants that affect these endpoints. These 

studies may be combined with other toxicity studies. 

Additional Neurotoxicity Studies: 

A submitted confidential, 4-week repeated-dose oral gavage study in rats included a neurotoxicity 

screening battery. No behavioral effects or neurohistopathology were found at a NOAEL of 600 

mg/kg/day. 

Cholineserase Inhibition 

Depression of serum cholinesterase activity was observed in male and female Sprague-Dawley rats 

given 500 or 1,500 mg/kg [Formulation 1] (~85% Proprietary C) by gavage (Ref. 10); females were 

6-13
more sensitive than males. Suppression was by ~33% in males and ~78% in females after 1 hour 

and was maximal at 8 hours by ~62% in males and ~93% in females. 

In a study comparing three different [Formulation 1] samples (from two different manufacturing 

protocols), female Sprague-Dawley rats (4/group) were treated with 0 or 250 mg/kg by oral gavage 

in 50% aqueous polyethylene glycol 200 (Ref. 14). Four hours later, serum cholinesterase activity 

was suppressed by 60-70% for [Sample 1] and [Sample 2] and by ~30% for [Sample 3]. 

Groups of four female Sprague-Dawley rats were administered [Formulation 1] at 0, 15, 50, 150, 

500, or 1,500 mg/kg by oral gavage in 50% aqueous polyethylene glycol 200 (Ref. 12). After 4 

hours, depression of serum cholinesterase activity was statistically significant and dose-related, 

compared to controls in groups treated at $50 mg/kg. In this study, brain cholinesterase levels were 

not significantly affected four hours after treatment at doses as high as 1,500 mg/kg. 

Groups of three female New Zealand white rabbits were untreated (controls) or dermally 

administered 2,000 mg/kg [Formulation 1] (Ref. 13). Dermal treatment caused no significant 

suppression of cholinesterase activity measured in serum and whole blood at 7 or 24 hours or in 

brain at 24 hours. 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the endpoints in the guidelines listed below. 

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Mutagenicity testing of [Formulation 1] (~85% Proprietary C) in mammalian cells in vitro was 

conducted under methods equivalent to OPPTS and OECD guidelines. The chromosomal aberration 

endpoint for Proprietary C is satisfied by adequate submitted confidential studies: a chromosomal 

aberrations assay in human lymphocytes in vitro and an in vivo micronucleus assay in mice. 

6-14
Gene Mutation in Vitro: 

• Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

No verifiable studies were located for bacterial mutagenicity assays following or similar to the 

guideline listed above, but a robust summary for a GLP-compliant study was included in an 

unevaluated IUCLID Dataset (Ref. 3). 

As described in an incomplete robust summary Ref. 2 conducted a mutagenicity (Ames) assay in 

Salmonella typhimurium strains TA98 and TA100 for Proprietary C (Formulation 4 or Formulation 

5) (Ref. 3). Results were negative with or without metabolic activation at concentrations as high as 

5 mg/plate. This study would not completely satisfy the guideline, since only two strains were 

tested. 

• In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

Critical Study: 

Type: Mammalian Cell Gene Mutation Test: Forward Mutation 

Species, strain: Mouse lymphoma L5178Y 

Metabolic activation: Tested with and without Aroclor-1242-induced liver S9 from SpragueDawley rat 

Concentrations: 0.01-0.8 :L/mL without S9 and 0.06-0.15 :L/mL with S9 

Purity: ~85% Proprietary C as [Formulation 1]; also contains 6.7% [Chemical 1], and 5-10% related 

compounds 

Method: Selection of forward mutation from TK+/- to TK-/- genotype. Activity compared to positive 

controls (ethylmethylsulfonate and dimethylbenzanthracene) and vehicle (DMSO). 

Results: No increase in forward mutations was observed. 

Reference: Ref. 15 

Additional information: 

Similar mouse lymphoma mutagenicity assays conducted on [Formulation 1] containing 0.05-0.25% 

[Chemical 3] also yielded negative results (Ref. 16, 17, 18). 

Chromosomal Aberration in Vitro: 

In Vitro Mammalian Chromosome Aberration Test (OPPTS Harmonized Guideline 

870.5375) 

A submitted confidential study reported negative results for chromosomal aberrations in cultured 

human lymphocytes. 

6-15

C
C

Chromosomal Aberrations in Vivo: 

Mammalian erythrocyte micronucleus test (OPPTS Harmonized Guideline 870.5395) 

A submitted confidential study reported negative results for micronucleus formation in bone marrow 

of mice exposed by oral gavage. 

No genotoxicity studies relevant to the following categories or to other types of genotoxic effects 

were submitted. 

Gene Mutation in Vivo 

DNA Damage and Repair 

6-16
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

C The currently available data were judged adequate to meet the endpoints for acute freshwater 

toxicity to fish, aquatic invertebrates, and algae. 

C The existing data for acute marine/estuary toxicity for fish, aquatic invertebrates, and algae 

were judged inadequate to meet these endpoints. 

Basis for Conclusion: 

A study exists of the acute toxicity to mysid shrimp of wastewater generated during the manufacture 

of the flame-retardant compound [Formulation 1] (Ref. 20). A handwritten correction on the title 

page of the study indicates that the wastewater samples were from the production of [Formulation 

1], not [Formulation 4]. [Formulation 1] contains Proprietary C; however, the wastewater samples 

used in the study contained a mixture of compounds, none of which appeared to be Proprietary C. 

No pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

C Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

A confidential study with a 96-hour LC50 of 52.2 mg/L in freshwater fish was submitted. These data 

were judged adequate to meet the endpoint. 

C Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

A confidential study with a 48-hour EC50 of 41.9 mg/L in freshwater invertebrates was submitted. 

These data were judged adequate to meet the endpoint. 

C	 Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

A study exists of the acute toxicity to mysid shrimp of wastewater generated during the manufacture 

of the flame-retardant compound [Formulation 1] (Ref. 20). A handwritten correction on the title 

page of the study indicates that the wastewater samples were from the production of [Formulation 

1], not [Formulation 4]. [Formulation 1] contains Proprietary C; however, the wastewater samples 

used in the study contained a mixture of compounds, none of which appeared to be Proprietary C. 

6-17
C

C

Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

A confidential study with 96-hour EC50 values for freshwater algal growth inhibition and growth 

rate inhibition of 20.1 and 38.5 mg/L, respectively, was submitted. These data were judged adequate 

to meet the endpoint. 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

C Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

C Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

A confidential chronic toxicity to freshwater invertebrates study was submitted. The 23-day EC50 

for parental mortality was 7.31 mg/L. The NOEC and LOEC for impaired reproduction were $3.68 

mg/L and >3.68 mg/L, respectively. These data were judged adequate to meet the endpoint. 

Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

No relevant data were located for chronic toxicity to marine/estuarine invertebrates. 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

6-18
• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

6-19
Physical/Chemical Properties 

Proprietary C 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): 

Conclusion: 

The available water solubility data are adequate. 

Basis for Conclusion: 

A confidential experimental study for the water solubility of Proprietary C was submitted. Using 

OECD Guideline 105, a water solubility of 232 mg/L at 20°C was measured. 

Log Kow: 

Conclusion: 

The available log Kow data are adequate. 

Basis for Conclusion: 

A confidential experimental study for the log Kow of Proprietary C was submitted. Using OECD 

Guideline 107, a log Kow of 2.83 was measured using the shake flask method. 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

6-20
Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

6-21
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: Confidential experimental studies on the biodegradation of Proprietary 

C indicate 37% oxygen uptake after 28 days in OECD 302C, 5% degradation in modified Sturm test 

over 28 days, and 8-15% inhibition to activated sludge. 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: 

Conclusion: 

The available hydrolysis data are adequate. 

Basis for Conclusion: 

A confidential experimental study on the hydrolysis of Proprietary C was submitted. Conducted 

according to EEC guideline C.7, the hydrolytic stability of Proprietary C at pH 4, 7, and 9 was 

6-22
determined at 50°C and it was found to undergo <10% degradation after 5 days. The hydrolysis 

half-life at 25°C was determined to be greater than 1 year. 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

6-23
Flame Retardant Alternatives

Proprietary D: Reactive brominated flame retardant

Hazard Review

7-1
Proprietary D: Reactive brominated flame retardant

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral * 

Dermal * 

Inhalation * 

Eye irritation * 

Dermal irritation * 

Skin sensitization 

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Y

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro * 

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

7-2
Proprietary D: Reactive brominated flame retardant

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 * 

Daphnia acute 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

7-3
Chemical Identity 

Proprietary D: Reactive brominated flame retardant 

Synonyms 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

An acute oral study to determine the LD50 of Proprietary D was conducted on rats, but was available 

only as an incomplete robust summary. 

As described in an incomplete robust summary, Sprague-Dawley rats (5/sex) were administered a 

single dose of 10,000 mg/kg of Proprietary D orally in corn oil, and observed for 4 hours and then 

daily for 14 days. No deaths occurred, and no gross lesions were seen at necropsy. Therefore, the 

LD50 was >10,000 mg/kg (Ref. 2). 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

An acute dermal study was conducted in rabbits, but was available only as an incomplete robust 

summary. 

As described in an incomplete robust summary, New Zealand white rabbits (2/sex) were exposed 

to a single application of 20,000 mg/kg of Proprietary D applied dermally to intact and abraded skin 

of the back and flank under an occlusive dressing for 24 hours. The dressings were then removed 

7-4
and the application sites were washed. There were no animal deaths. Therefore, the dermal LD50 

was >20,000 mg/kg. Very slight to slight erythema, edema, and atonia were noted during the 14-day 

observation period (Ref. 2). 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

An acute inhalation study in rats was available only as an incomplete robust summary. 

As described in an incomplete robust summary, Charles River CD rats (5/sex) were exposed to 0.008 

mg/L of Proprietary D as a saturated vapor for 1 hour. There were no animal deaths and no signs 

of toxicity during the exposure or the 14-day observation period, and no gross lesions were observed 

at necropsy. Thus, the LC50 was >0.008 mg/L (Ref. 5). 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available acute eye irritation data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Two acute eye irritation studies in rabbits were available only as an incomplete data summaries in 

an HPV submission. 

As described in the data summary, Proprietary D (dose not reported) was instilled into the right eye 

of 6 rabbits. Observations recorded at 1, 24, 48, and 72 hours after treatment reported no positive 

ocular scores, and found the test material was not irritating to the eyes. The study was conducted 

according to Good Laboratory Practices (Ref. 6). 

An additional study described in the data summary, instilled 0.1 mL of Proprietary D in the right 

sacs of the right eyes of 6 New Zealand albino rabbits (3/sex). In the 72-hour observation period, 

redness and chemosis of the conjuctiva were reported. Discharge was also noted in 1 rabbit at 24 

hours. 

7-5
Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available acute dermal irritation data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

An acute dermal irritation study in rabbits was available only as an incomplete data summary in an 

HPV submission. 

As described in the data summary, a single application of 0.5 mL Proprietary D was made to the 

clipped backs of 6 New Zealand albino rabbits (3/sex) under a gauze patch and wrapped with an airtight occlusive wrap (duration not reported). The skin of 3 rabbits was abraded. Observations 

recorded at 24, 48, and 72 hours after treatment reported no irritation on the intact skin, and 

erythema and edema on the abraded skin. The primary irritation index, according to the method of 

Draize, was 0.7, and the chemical was not considered to be a primary skin irritant (Ref. 3). 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines

listed below.

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental)

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

7-6
• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines 

listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the developmental toxicity endpoints in the 

guidelines listed below. 

7-7
• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines

listed below.

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines

listed below.

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

7-8
Basis for Conclusion: 

No pertinent neurotoxicity studies were located that addressed the endpoints in the guidelines listed 

below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

• Note this guideline is not relevant for Proprietary D, which is not an 

organophosphorus substance. 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No pertinent studies of immunotoxicity were located that addressed the endpoints in the guideline

listed below.

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available gene mutation data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Two in vitro gene mutation studies were conducted, but were only available as incomplete robust 

summaries. Studies of chromosomal aberrations were not available, however, and are needed for 

adequate characterization of the genotoxicity endpoint. 

7-9
C

Gene Mutation in vitro 

Bacterial Reverse Mutation Test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

An in vitro gene mutation study reported negative results in Salmonella typhimurium bacteria 

(strains not specified) and in Saccharomyces cerevisiae (D4) at concentrations up to 1.0 μg/plate of 

Proprietary D, with and without metabolic activation (Ref. 3). 

An additional in vitro gene mutation study, reported negative results in Salmonella typhimurium 

bacteria (TA 1535, TA 1537, TA 98, and TA 100) at concentrations up to 5,000 μg/plate (which was 

cytotoxic) of [Formulation 1] (a trade name for Proprietary D), with and without metabolic 

activation. Negative and positive controls were used (Ref. 4). 

No genotoxicity studies relevant to the below categories or to other types of genotoxic effects were 

located. 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

7-10
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

The available acute toxicity data for fish, aquatic invertebrates, and algae were judged inadequate 

to meet the endpoints. 

Basis for Conclusion: 

A data summary was located for a 96-hour acute toxicity study in bluegill sunfish (Lepomis 

macrochirus) exposed to Proprietary D (Ref. 1). Fish were exposed to aqueous dilutions of the test 

material at 0, 10, 18, 32, 56, and 100 mg/L. Acetone was used as a carrier solvent. The test waters 

were completely opaque at the two highest concentrations. The calculated 96-hour LC50 was 12 

mg/L (95% CI: 1-18 mg/L). Study details were unavailable to conduct a thorough, independent 

review of the study. The concentrations in the test waters were not analytically verified; however, 

the opacity of the water at the two highest concentrations suggest that the test material was not well 

dissolved. The available data are not adequate to satisfy the acute toxicity endpoint for freshwater 

fish. 

No pertinent acute toxicity studies with marine fish, aquatic invertebrates, or algae were located that 

followed or were similar to the guideline protocols listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that followed 

or were similar to the guideline protocols listed below. 

7-11
• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that followed or were similar to the guideline 

protocols listed below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD Guideline 

205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

7-12
Physical/Chemical Properties 

Proprietary D: Reactive brominated flame retardant 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

7-13
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: No data 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

7-14
Flame Retardant Alternatives

Proprietary E: Tetrabromophthalate diol diester

Hazard Review

8-1
Proprietary E: Tetrabromophthalate diol diester

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral 

Dermal 

Inhalation 

Eye irritation 

Dermal irritation 

Skin sensitization 

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro 

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other 

8-2
Proprietary E: Tetrabromophthalate diol diester 

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 

Daphnia acute 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

8-3
Chemical Identity 

Proprietary E: Tetrabromophthalate diol diester 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Conclusion: 

No available acute toxicity data.

Basis for Conclusion:

No acute toxicity studies were located that addressed the endpoints in the guidelines listed below.

• Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 

420, 423, 401) 

• Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 

402) 

• Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 

403) 

• Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

• Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 

404) 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

8-4
SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines 

listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

8-5
• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the developmental toxicity endpoints in the

guidelines listed below.

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines

listed below.

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

8-6
Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No neurotoxicity studies were located that addressed the endpoints in the guidelines listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No immunotoxicity studies were located that addressed the endpoints in the guidelines listed below.

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

8-7
GENOTOXICITY 

Conclusion: 

No available genotoxicity data.

Basis for Conclusion:

No genotoxicity studies relevant to the below categories or to other types of genotoxic effects were

located.

Gene Mutation in Vitro 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

8-8
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

No available acute toxicity data for fish, aquatic invertebrates, and algae. 

Basis for Conclusion: 

No pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

8-9
Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

8-10
Physical/Chemical Properties 

Proprietary E: Tetrabromophthalate diol diester 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

8-11
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: No data 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

8-12
Flame Retardant Alternatives

Proprietary F: Halogenated aryl ester

Hazard Review

9-1
Proprietary F: Halogenated aryl ester

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal 

Inhalation 

Eye irritation 

Dermal irritation 

Skin sensitization 

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro 

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other 

9-2
Proprietary F: Halogenated aryl ester 

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish T

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

T

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

T

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 T

Daphnia acute T

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, T

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

9-3
Chemical Identity 

Proprietary F: Halogenated aryl ester 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available acute oral lethality study was conducted according to EEC acute toxicity methods for 

fixed-dose studies. Methodological procedures appear consistent with OECD methods for acute oral 

toxicity testing (i.e., OECD Guideline 401). The study appears adequate. 

Type: Acute oral LD50 

Species, strain, sex, number: Rat, Sprague-Dawley, 5 males and 5 females 

Dose: 2000 mg/kg 

Purity: 99.7% 

Vehicle: Not indicated 

Observation period: 14 days post dosing 

Method: Directive 92/69/EEC (OJ No. L383A, 29.12.92), Part B, Method B.1 bis. Acute toxicity 

(oral), fixed-dose method. 

Results: No deaths; therefore, LD50 >2000 mg/kg. Piloerection and hunched posture in 10/10 rats; 

recovery by post-exposure day 4. 

Reference: Ref. 1 

No studies were submitted that conformed to the following guidelines. 

C Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 

402) 

C Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 

403) 

C Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

9-4
C Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 

404) 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

9-5
REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines 

listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the developmental toxicity endpoints in the 

guidelines listed below. 

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

9-6
CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines

listed below.

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines

listed below.

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No neurotoxicity studies were located that addressed the endpoints in the guidelines listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Neurotoxicity (Adult) 

9-7
• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No immunotoxicity studies were located that addressed the endpoints in the guidelines listed below.

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

No available genotoxicity data.

Basis for Conclusion:

No genotoxicity studies relevant to the below categories or to other types of genotoxic effects were

located.

Gene Mutation in Vitro 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

9-8
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

• The available acute freshwater toxicity data for fish, aquatic invertebrates, and algae were 

judged adequate to meet the endpoints. 

• The available acute marine/estuary toxicity data for fish, aquatic invertebrates, and algae 

were judged inadequate to meet the endpoints. 

Basis for Conclusion: 

Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 850.1075; 

OECD Guideline 203) 

A confidential 96-hour study in fish was located that reported no effects at saturation. These data 

allow this endpoint to be adequately characterized. 

Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; OECD 

Guideline 202) 

A confidential study in daphnid was located that reported a 24-hour EC50 of 1.2 mg/L and a 48-hour 

EC50 of 0.42 mg/L. These data allow this endpoint to be adequately characterized. 

Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

A confidential 96-hour study in green algae was located that reported no effects at saturation. These 

data allow this endpoint to be adequately characterized. 

No additional acute toxicity studies with freshwater or saltwater fish, aquatic invertebrates, or algae 

were located that followed or were similar to the guideline protocols listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

9-9
Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

9-10
Physical/Chemical Properties 

Proprietary F: Halogenated aryl ester 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: 

Conclusion: The flammability (as the flash point) has been adequately characterized. 

Basis for Conclusion: The key study was performed according to EEC Methods, Directive 

92/69/EEC (OJ No. L383A, 29.12.92), Part A, Method A9, flash point. 

Flash Point: 215°C (Ref. 2) 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

9-11
Henry’s Law Constant: No data 

9-12
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: 

The available bioconcentration data are adequate. 

Basis for Conclusion: 

A confidential guideline study submitted on Proprietary F indicates that the bioconcentration factor 

is 1.7-6.2. 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: 

The available aerobic biodegradation data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary F indicates that its half life is 3.5 days in water in a 

shake flask die-away test. It was also found to undergo 6% biodegradation after 28 days in closed 

bottle test in a submitted confidential study. 

9-13
Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: 

Conclusion: 

The available hydrolysis as a function of pH data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary F indicates that its hydrolysis half life is >1 year at 

pH 4, 7, and 9. 

Sediment/Water Biodegradation: 

Conclusion: 

The available sediment/water biodegradation data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary F indicates that its half life is 8.5 days in sediment in 

a shake flask die-away test. 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: 

Conclusion: 

The available soil adsorption data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary F indicated that the soil adsorption coefficient is 

>28,840. 

9-14
Flame Retardant Alternatives

Proprietary G: Triaryl phosphate, isopropylated

Hazard Review

10-1
Proprietary G: Triaryl phosphate, isopropylated

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral * 

Dermal * 

Inhalation 

Eye irritation * 

Dermal irritation * 

Skin sensitization 

Subchronic Toxicity 

28-Day oral * 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

T

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro * 

Gene mutation in vivo * 

Chromosomal 

aberrations in vitro 

Chromosomal * 

aberrations in vivo 

DNA damage and * 

repair 

Other * 

10-2
Proprietary G: Triaryl phosphate, isopropylated

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 * 

Daphnia acute * 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

10-3
Chemical Identity 

Proprietary G: Triaryl phosphate, isopropylated 

Synonym: 

CAS 

MF 

MW 

SMILES 

Many of the available health effects studies were conducted with commercial mixtures that 

commonly contained triphenyl phosphate as well as Proprietary G. The available information 

regarding the composition of these mixtures is presented below, but the composition of the actual 

samples tested in the health effects studies usually was not reported. 

[Formulation 1] is reported to contain 60-100% Proprietary G and 15-40% triphenyl phosphate (Ref. 

24) and [Formulation 2] is reported to contain 60-100% Proprietary G and 4-7% triphenyl phosphate 

(Ref. 25). 

Major Components of [Formulation 3] and [Formulation 4] as reported in Ref. 34 

Component [Formulation 3] [Formulation 4] 

Total Proprietary G 49 61 

[Chemical 1] 8 11 

[Chemical 2] 6 7 

[Chemical 3] 2 5 

[Chemical 4] 21 27 

[Chemical 5] 12 11 

Triphenyl Phosphate 33 18 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged inadequate to meet the endpoint. 

10-4
Basis for Conclusion: 

The available data are for limit tests on undefined flame retardants for which compositional 

information was not provided. The authors of the studies referred to them as “non-definitive”, 

possibly because of the small group sizes (which, however, are consistent with current guidelines); 

in other respects the studies follow current guidelines. 

Additional Studies and Information: 

No deaths were observed in Sprague-Dawley rats (3/sex) given [Formulation 1] (mixture of 

Proprietary G and triphenyl phosphate) as a single oral dose of 5,000 mg/kg (Ref. 13). Clinical 

signs, which included tremors (0/3 males, 1/3 females), oral discharge, ataxia (0/3 males, 1/3 

females), decreased locomotion (1/3 males, 1/3 females), chromorhinorrhea, chromodacryorrhea, 

and abdominogenital staining, subsided by day 11. No effects on body weight gain and no gross 

internal lesions were observed. 

A parallel acute oral study on Sprague-Dawley rats (3/sex) given [Formulation 2] at a dose of 5,000 

mg/kg, reported clinical signs (abdominogenital staining and chromorhinorrhea) on the first 2 days 

post dosing, but no mortality, body weight gain effects, or gross internal lesions were reported (Ref. 

17). 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for limit tests on undefined flame retardants for which compositional 

information was not provided. The authors of the studies referred to them as “non-definitive”, 

possibly because of the small group sizes (which, however, are consistent with current guidelines); 

in other respects, the studies follow current guidelines. 

Additional Studies and Information: 

No deaths were observed among Sprague-Dawley rats (3/sex) that were dermally exposed to 

[Formulation 1] (mixture of Proprietary G and triphenyl phosphate) at a dose of 2,000 mg/kg for 24 

hours under an occlusive covering (Ref. 14). There were no effects on body weight gain, no signs 

of irritation on the test site, and no gross internal lesions observed. 

In a parallel study in Sprague-Dawley rats (3/sex) dermally treated with 2,000 mg/kg 

[Formulation 2], all but one female gained weight, but there were no deaths, signs of irritation, or 

gross internal lesions (Ref, 18). 

10-5
Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300; OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline. A non-guideline study 

evaluated neurotoxicity of combustion products of an Proprietary G/triphenyl phosphate mixture in 

the presence of cyclic phosphonate compounds. 

Additional Studies and Information: 

Preliminary results of a study were reported (Ref. 38) investigating whether toxic compounds were 

formed when cyclic phosphonate compounds were thermally decomposed in the presence of other 

phosphate compounds in trimethylol polyol-based urethane foam. When rats were exposed (head 

only) for 20 minutes to smoke and decomposition gases from foam containing equal proportions of 

the cyclic phosphonate compounds and a mixture of Proprietary G and triphenyl phosphate, no 

convulsive seizures, characteristic of exposure to toxic bicyclic phosphites or phosphates, were 

observed. 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for undefined flame retardants for which compositional information was not 

provided. The authors of the studies referred to them as “non-definitive”, although they were 

consistent with current guidelines. 

Additional Studies and Information: 

Slight conjunctival erythema was observed in the eyes of 1/1 male and 1/2 female New Zealand 

White rabbits 24 hours after instillation with 0.01 mL of [Formulation 1] (mixture of Proprietary G 

and triphenyl phosphate) but was resolved by 48 hours (Ref. 15). No conjunctival discharge or 

effects on the cornea or iris were observed. The material was tentatively characterized as 

“practically non-irritating”, based on a maximum irritation score of 1.3/110 at 24 hours. 

In a parallel study in New Zealand White rabbits (1 male and 2 females) instilled with 0.01 mL 

[Formulation 2], there were no signs of eye irritation observed at 1, 24, 48, or 72 hours (Ref. 19). 

10-6
The material was tentatively characterized as non-irritating to the eyes based on a primary irritation 

index of 0/110 at all timepoints. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available data are for undefined flame retardants for which compositional information was not 

provided. The authors of the studies on the Durad materials referred to them as “non-definitive”, 

although they were consistent with current guidelines. 

Additional Studies: 

No dermal irritation (erythema or edema) was observed in one male and two female New Zealand 

White rabbits that were dermally exposed for 4 hours to [Formulation 1] (mixture of Proprietary G 

and triphenyl phosphate) on two occluded test sites (0.5 mL per site) and examined at 4.5, 24, 48, 

or 72 hours (Ref. 16). The material was tentatively rated as non-irritating to intact rabbit skin, based 

on scores of 0/8.0 at all timepoints. 

In a parallel dermal irritation study in one male and two female New Zealand White rabbits exposed 

for 4 hours to [Formulation 2] on two occluded test sites (0.5 mL per site), no irritation was observed 

at times between 4.5 and 72 hours (Ref. 20). The material was tentatively rated as non-irritating to 

intact rabbit skin, based on scores of 0/8.0 at all timepoints. 

In skin irritation assays in male New Zealand White rabbits (6/group), 24-hour topical 

administration (0.5 mL/site) of [Formulation 4] or [Formulation 10] did not elicit erythema or edema 

to intact or abraded skin (examined at 24 and 72 hours) (Ref. 6). The mean primary dermal irritation 

indices were 0/2.0 for both materials, which were characterized as non-irritating to skin. 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

10-7
SUBCHRONIC TOXICITY 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

Conclusion: 

The available subchronic oral toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported preliminary results of a 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening study in rats exposed by oral gavage. 

Preliminary results suggested adrenal and liver effects, with adrenal weight effects in females at a 

LOAEL of 25 mg/kg/day. These data are not adequate because the final results were not available. 

No other verifiable data were available for defined substances tested under guideline methods. A 

study on undefined [Formulation 4] appeared to follow the guideline for a 28-day oral study, but was 

only available as an incomplete robust summary. The unexplained mortality in this study indicates 

that it may not be an adequate study. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

As described in an incomplete robust summary (results were not presented quantitatively) for an 

HPV submission, Sprague-Dawley rats (10/sex) received [Formulation 4] in the diet at 

concentrations of 0, 0.1, 0.5, or 1.0% for 28 days (Ref. 5). Treatment had no effect on survival (but 

12 rats died: 1 control, 4 low-dose, 4 mid-dose, and 3 high-dose rats). Treatment also had no effect 

on urinalysis results, incidence of gross lesions at necropsy, or histology of the liver and kidney 

(histology examined only in high dose animals and controls). It was not specified whether animals 

that died during the study were necropsied or examined histologically. Reduced feed consumption 

was observed in the mid-dose group in both sexes and reduced body weight gain was noted in highdose females. Abnormalities (not specified) were observed in clinical chemistry measurements in 

mid- and high-dose groups and in hematology parameters at the high dose. Relative liver weights 

were elevated in all treated groups. The unexplained mortality during this short term study raises 

concern for study adequacy. 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

10-8
• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90-day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD 

Guideline 413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported preliminary results of a 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening study in rats exposed by oral gavage. 

Preliminary results suggest an ovarian weight effect at $25 mg/kg/day, and an epididymal weight 

effect and reduced fertility at 100 and 400 mg/kg/day. These data are not adequate because the final 

results were not available. No other pertinent studies were located that addressed the reproductive 

toxicity endpoints in the guidelines listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported preliminary results of a 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening assay in rats exposed by oral gavage. 

Preliminary results suggest reduced pre- and post-natal survival at 400 mg/kg/day. These data are 

not adequate because the final results were not available. No other pertinent studies were located 

that addressed the developmental toxicity endpoints in the guidelines listed below. 

10-9
• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines 

listed below. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

Additional information 

As described in an unvalidated robust summary, 3 days of exposure to [Formulation 7], tested 

without metabolic activation at concentrations between 0.04 and 5.0 :g/mL, did not induce cell 

transformation in cultured Balb/c-3T3 cells (Ref. 36). 

10-10
NEUROTOXICITY 

Conclusion: 

The available neurotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

Available acute and 28-day studies indicate that there is a risk of delayed neurotoxicity from 

exposure to Proprietary G. Most studies either were conducted on undefined substances or were not 

described in sufficient detail. A summary of a study on purified components of [Formulated] flame 

retardants suggests that [Chemical 4] or [Chemical 2] are the neurotoxic components of these 

mixtures; however, details of the in vivo study in hens were not located. The neurotoxicity of 

Proprietary G preparations would be dependent on the relative content of [Formulation 11] isomers. 

No data are available for the full battery of tests for functional neurotoxicity or for developmental 

neurotoxicity. 

Delayed Neurotoxicity 

Conclusion: 

The available delayed neurotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The acute study (experiment A) on a defined Proprietary G mixture departed from guideline in that 

enzyme inhibition was assayed 24 hours after dosing rather than 48 hours, but reported significant 

suppression of both brain neurotoxic esterase and plasma cholinesterase levels. The longer study 

did not conduct a complete battery of neurobehavioral tests as stipulated under the guideline, but 

reported adverse effects on motor coordination at all doses on the day of treatment. The highest dose 

(11,700 mg/kg) exceeded that recommended under the guideline, but that deviation does not affect 

the conclusion of the study. Studies on purified components of [Formulated] flame retardants 

identified the neurotoxic components, but were not adequately described. The majority of studies 

suggest that delayed neurotoxicity may result from exposure to oral doses in excess of 1,000 mg//kg. 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Critical Studies 

Type: Acute oral delayed neurotoxicity

Species, strain, sex, number: Hen, 12-14 months old, White Leghorn, 4/dose for experiment A;

10-12/dose for experiment B.

Purity: Proprietary G with the composition as in the following table.

10-11
Composition of Proprietary G assayed by Ref. 37 

Component Percent 

Total Proprietary G <75

 [Chemical 4] 24

 [Chemical 6] 18

 [Chemical 2] 10

 [Chemical 7] 10

 [Chemical 5] 6

 [Chemical 8] 7

 [Chemical 9] <1 

Triphenyl Phosphate 24 

Doses: Experiment A. Six doses between 12 and 11,700 mg/kg; 

Experiment B. 0, 12, or 370 mg/kg in corn oil or 11,700 mg/kg undiluted 

Vehicle: Corn oil 

Positive control: Tri-ortho-cresyl phosphate (TOCP) 

Route: Oral (not specified) 

Exposure duration, frequency: Experiment A, single treatment followed 24 hours later by 

biochemical assay; Experiment B, 6 weeks, single treatments 3 weeks apart; study terminated 3 

weeks after second dose. 

Method: Experiment A. Brain neurotoxic esterase (NTE) and plasma cholinesterase (PChE) 

measurements recorded 24 hours after single treatment with Proprietary G, corn oil or TOCP. 

Experiment B. Doses were chosen based on results of experiment A to represent minimal, 50%, and 

maximal inhibition of brain NTE. Body weight and food consumption measured every 3-4 days, 

walking behavior evaluated weekly. Neurohistopathology evaluated at termination. 

Results: Experiment A. The NOAELs for inhibition of NTE or PChE were 12 and 180 mg/kg, 

respectively. Doses about 1,000 mg/kg and higher caused ~70% inhibition of NTE and ~80% 

inhibition of PChE. The positive control (500 mg/kg of TOCP) inhibited brain NTE by 85.2% and 

PChE by 70%. 

Experiment B. Proprietary G had no effect on mortality. Few adverse signs visible at or below 370 

mg/kg. All treated at 11,700 mg/kg showed motor incoordination beginning day 1, with feather loss 

7-11 days later. Body weights not affected at lowest dose. Body weight effects at mid- and highdose are uncertain because text and graph do not match; one dose caused transient weight loss on 

days 22-38 and the other persistent weight loss from day 22 to the end of the study. TOCP caused 

persistent weight loss beginning day 5. Food consumption was transiently reduced in all groups 

(including positive and negative controls) on day 2 and 23, also on day 18 for TOCP. Significant 

transient, dose-dependent impairment of gait was observed on day 1 and 22 for hens treated with 

Proprietary G at all doses. Hens treated with TOCP showed significant impairment on day 1 and 

15, with gradual worsening to the end of the study. Neurohistopathological examinations revealed 

10-12
no significant difference between Proprietary G treatment and corn oil controls, whereas TOCP 

caused a significant increase in axonal degeneration in brain, spinal cord (cervical, thoracic and 

sacro-lumbar), and bilateral degeneration of the sciatic nerve. 

Reference: Ref. 37 

Additional Studies: 

As described in Ref. 44, a series of acute delayed neurotoxicity assays were conducted on 

[Formulated] flame retardants. No ataxia was observed in groups of 4 hens treated with 

[Formulation 5] at doses of 2,000, 4,000, or 8,000 mg/kg; 3/30 hens treated with 16,000 mg/kg 

showed ataxia (Ref. 7). Only 1/10 hens treated with [Formulation 6] at 20,000 mg/kg exhibited 

ataxia (Ref. 8). In one study on [Formulation 4], no ataxia was observed at doses of 500, 1,000, or 

2,000 mg/kg, whereas 2/10 treated at 4,000 mg/kg showed ataxia (Ref. 9); inhibition of brain NTE 

was 79.5% at the highest dose. In a second study on [Formulation 4], incidences of ataxia (0/10, 

3/10, 1/10 and 1/10) and neurohistopathological lesions (1/10, 0/10, 1/10, and 2/10) were not 

precisely related to the respective doses of 3,000, 5,000, 7,000, and 9,000 mg/kg (Ref. 10). For 

[Formulation 3], incidences of ataxia (1/9, 4/10, 6/10 and 3/10) and neurohistopathology (0/10, 4/10, 

7/10 and 1/10) were observed in the 2,000, 4,000, 6,000, and 8,000 mg/kg groups, respectively (Ref. 

11). 

A subchronic (91-day) oral neurotoxicity assay is summarized briefly in a TSCA 8e submission 

(Ref. 12), and in more detail by Ref. 44 and in a robust summary in an HPV submission (Ref. 23; 

U.S. EPA comments not available). In this study, hens (20/group) were administered [Formulation 

3] (mixture of Proprietary G and triphenyl phosphate) daily at doses of 0, 10, 20, 90, and 270 

mg/kg/day. Deaths occurred in all dose groups as follows: 2/20 vehicle controls, 4/20 positive 

controls, 3/20 at 10 mg/kg/day, 5/20 at 90 mg/kg/day, and 6/20 at 270 mg/kg/day. Ataxia was 

observed in 4/20 at 90 mg/kg/day and 9/20 at 270 mg/kg/day. Histopathological examination of 

nervous tissue of 10 hens/group revealed the following: significant degeneration at 3 levels of the 

spinal cord in 3 vehicle controls, significant degeneration of the spinal cord in TOCP hens, 

degeneration of the spinal cord and peripheral nerves in hens of the 90 and 270 mg/kg/day groups, 

with a dose-response relationship for severity and incidence (further details not reported). No ataxia 

or brain histopathology was observed at 10 or 20 mg/kg/day. 

[Formulation 4] and [Formulation 6] were given in two 2,000 mg/kg doses 21 days apart to hens 

(4/group) (Ref. 22). Neither compound caused body weight effects, clinical signs of neurotoxicity 

or an increase in gross internal lesions at necropsy (21 days after the second dose). There was no 

evidence of neurohistopathology in hens treated with [Formulation 4], but one out of four hens 

treated with [Formulation 6] had unilateral brain lesions at two histological levels. 

Proprietary G at tested positive for neurotoxicity in hens treated at three 21-day intervals with 

10,000 mg/kg (Ref. 33). Effects included gross paralysis with demyelination confirmed 

histopathologically. 

10-13
Several components of the [Formulated] series of flame retardants were isolated to >99% purity and 

tested at doses as high as 1,000 mg/kg in hens for neurotoxicity and suppression of neurotoxic 

esterase (Ref. 29). Details of these studies were not located. Three isomers of [Chemical 1] and 

[Chemical 5] elicited no signs of neurotoxicity and no suppression of NTE levels. [Chemical 5] was 

also judged to be non-neurotoxic, eliciting no ataxia or other signs of neurotoxicity and insignificant 

suppression of NTE (-4% or -15%) in two tests. Both [Chemical 2] and [Chemical 4] were positive, 

eliciting ataxia and neurotoxicity at 1,000 mg/kg, but not at lower doses; [Chemical 2] suppressed 

NTE by 85% and [Chemical 4] suppressed NTE by 79 and 90% in two assays. The author suggested 

that neurotoxicity was associated with triaryl phosphates containing a 2-alkyl substituent with an 

oxidizable alpha-hydrogen. 

In a two-hen screening test, a single 1,000 mg/kg dose of [Formulation 3] administered in gelatin 

capsules to two hens resulted in a 53.1% inhibition of neurotoxic esterase activity in the brain (Ref. 

42). The report was not clear as to the day on which the hens were sacrificed. 

No neurotoxicity studies were located that followed or were similar to the guidelines listed below. 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity Study (OPPTS Harmonized Guideline 870.6300) 

Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat) OPPTS Harmonized Guideline 

870.6500 

• Peripheral Nerve Function (rodent) OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred) OPPTS Harmonized Guideline 

870.6855 

These studies may be indicated, for example, to follow up neurotoxic signs seen in other studies, or 

because of structural similarity of the substance to neurotoxicants that affect these endpoints. These 

studies may be combined with other toxicity studies. 

Other Neurotoxicity Data 

Cholinesterase inhibition 

[Formulation 3] at doses of 15, 20, or 25 mL/kg did not inhibit blood cholinesterase activity, but 

neither species of animal (3/group) nor the specific biological material assayed were reported (Ref. 

4). 

10-14
IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data. 

Basis for Conclusion: 

No immunotoxicity study was located that followed or was similar to the guideline listed below. 

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No verifiable genotoxicity data were located. The available studies were only accessible as robust 

summaries in a IUCLID Dataset that had not undergone review by the European Commission (Ref. 

3). Furthermore, the data were unpublished industry-sponsored studies on commercial products for 

which no contemporaneous component analyses were provided. Current compositional information 

taken from MSDS documents are presented in the following table. The results of these studies are 

summarized below despite their uncertain validity. In general, not enough details were provided to 

ascertain whether protocols met the standards of OPPT or OECD guidelines. 

Percentage of Proprietary G and triphenyl phosphate in Currently Available Commercial Products 

Product Proprietary G (%) triphenyl phosphate (%) Reference 

[Formulation 7] 60-100 15-40 Ref. 26 

[Formulation 8] 60-100 10-30 Ref. 27 

[Formulation 9] 60-100 7-13 Ref. 28 

[Formulation 2] 60-100 4-7 Ref. 25 

Gene Mutation in Vitro: 

• Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

10-15
As described in unvalidated robust summaries, negative results were reported for mutagenicity 

assays in Salmonella typhimurium with or without metabolic activation. [Formulation 7] and 

[Formulation 9] were tested in strains TA98, TA100, and TA1537 at concentrations as high as 1.62 

mg/mL (Ref. 1, 2). [Formulation 9] and [Formulation 2] were tested in strains TA98, TA100, 

TA1535, TA1537, and TA1538 at concentrations as high as 0.1 mL per plate (Ref. 31, 32). 

• In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

As described in an unvalidated robust summary, [Formulation 7] at concentrations of 0.0013-0.1 

:L/mL was not mutagenic to cultured mouse lymphoma L5178Y TK+/- cells without metabolic 

activation (Ref. 30). Results in the presence of metabolic activation were equivocal in that a doseresponse was observed, but none of the cultures exhibiting >10% total growth had mutant 

frequencies 2-fold greater than background. 

Gene Mutation in Vivo 

• Sex-linked Recessive Lethal test in Drosophila melanogaster (OPPTS Harmonized 

Guideline 870.5275) 

As described in an unvalidated robust summary, [Formulation 7] (32.5, 75, or 150 mg/mL) fed to 

adult male fruit flies for 3 days did not induce heritable mutations (Ref. 43). 

Chromosomal Aberration in Vitro 

No pertinent studies were located. 

Chromosomal Aberration in Vivo 

• Mammalian Bone Marrow Chromosomal Aberration Test (OPPTS Harmonized 

Guideline 870.5385) 

As described in an unvalidated robust summary no increase in chromosomal aberrations was 

observed in the bone marrow of Chinese hamsters (8/sex/group), 16, 24, or 48 hours after 

receiving a single oral dose of 5,000 mg/kg [Formulation 7] by gavage (Ref. 41). The summary 

indicated that the study was conducted under OECD Guideline 475 and GLP. Another unvalidated 

robust summary reported that a significant increase (compared to controls) in the incidence of bone 

marrow cells with chromosomal anomalies was observed in Chinese hamsters (6/sex/group) 24 

hours after receiving the second of two consecutive daily doses of 2,500 or 5,000 mg/kg/day 

[Formulation 7] by oral gavage (Ref. 40); no increase was observed in animals receiving 1,250 

mg/kg/day. 

DNA Damage and Repair 

• Unscheduled DNA synthesis in mammalian cells in culture (OPPTS Harmonized 

Guideline 870.5550) 

10-16
As described in an unvalidated robust summary, [Formulation 7] tested without metabolic activation 

at concentrations between 0.6 and 75 nL/mL did not cause unscheduled DNA synthesis in cultured 

rat hepatocytes (Ref. 35). 

Other 

• In vivo Sister Chromatid Exchange Assay (OPPTS Harmonized Guideline 870.5915) 

As described in an unvalidated robust summary, there was no increase in the frequency of sister 

chromatid exchanges in bone marrow cells of Chinese hamsters (4/sex/group) 24 hours after 

receiving a single oral dose of 1250, 2,500, or 5,000 mg/kg [Formulation 7] by gavage in 

carboxymethylcellulose (Ref. 39). 

10-17
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

The available acute toxicity data for fish, aquatic invertebrates, and algae were judged inadequate 

to meet the endpoints. 

Basis for Conclusion: 

Summaries were located for several acute toxicity studies of Proprietary G in an HPV test plan 

submission and accompanying robust summaries (Ref. 23); however, EPA comments on this 

submission were not available. The summaries included two 96-hour studies in fathead minnows 

(Pimephales promelas), three 96-hour studies in rainbow trout (Oncorhynchus mykiss), and three 

48-hour studies in Daphnia magna. According to Ref. 21, all of the studies were conducted with 

100% Proprietary G; however, other reports have identified the tested material in some of these 

studies as [Formulation 1] (Ref. 24) or [Formulation 4] (Ref. 21). [Formulation 1] is a mixture 

containing 60-100% Proprietary G and 15-40% triphenyl phosphate (Ref. 24). [Formulation 4] has 

been reported to contain 61% Proprietary G and 18% triphenyl phosphate (Ref. 34; see table at 

beginning of Human Health Effects for details). The available study summaries and Material Safety 

Data Sheets are insufficient to precisely establish the composition of the materials tested in the acute 

toxicity studies. Without precise knowledge of the composition of the tested materials, it is not 

possible to use these studies to make a definitive statement regarding the acute toxicity of 

Proprietary G. The publicly available information regarding the acute toxicity of Proprietary G to 

freshwater fish or aquatic invertebrates is insufficient to satisfy the endpoints in the guideline 

protocols listed below. 

A confidential study was submitted that reported a freshwater daphnid 48-hour EC50 >0.77 mg/L, 

the maximum test concentration. This concentration is above the water solubility limit of Proprietary 

G. A confidential study was also submitted that reported a freshwater green algal 72-hour EC50 of 

approximately 0.480 mg/L. This concentration is also above the water solubility limit of Proprietary 

G. The available data were judged inadequate to meet this endpoint. 

No pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

10-18
Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

10-19
Physical/Chemical Properties 

Proprietary G: Triaryl phosphate, isopropylated 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

10-20
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: 

The available aerobic biodegradation data are not adequate. 

Basis for Conclusion: 

A single confidential ready biodegradation study, indicating that Proprietary G is not ready 

biodegradable, was submitted. This study is not sufficient to fully characterize the aerobic 

biodegradation of Proprietary G under environmental conditions. 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

10-21
Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

10-22
Flame Retardant Alternatives

Proprietary H: Halogenated aryl ester

Hazard Review

11-1
Proprietary H: Halogenated aryl ester

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal 

Inhalation 

Eye irritation 

Dermal irritation 

Skin sensitization 

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro 

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other 

11-2
Proprietary H: Halogenated aryl ester

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish T

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

T

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

T

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 T

Daphnia acute T

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, T

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

11-3
Chemical Identity 

Proprietary H: Halogenated aryl ester 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

The available acute oral lethality study was conducted according to EEC acute toxicity methods for 

fixed-dose studies. Methodological procedures appear consistent with OECD methods for acute oral 

toxicity testing (i.e., OECD Guideline 401). The study appears adequate. 

Type: Acute oral LD50 

Species, strain, sex, number: Rat, Sprague-Dawley, 5 males and 5 females 

Dose: 2000 mg/kg 

Purity: 99.7% 

Vehicle: Not indicated 

Observation period: 14 days post dosing 

Method: Directive 92/69/EEC (OJ No. L383A, 29.12.92), Part B, Method B.1 bis. Acute toxicity 

(oral), fixed-dose method. 

Results: No deaths; therefore, LD50 >2000 mg/kg. Piloerection and hunched posture in 10/10 rats; 

recovery by post-exposure day 4. 

Reference: Ref. 1 

No studies were submitted that conformed to the following guidelines. 

C Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 

402) 

C Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 

403) 

C Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

11-4
C Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 

404) 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

11-5
REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines

listed below.

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the developmental toxicity endpoints in the

guidelines listed below.

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

11-6
Basis for Conclusion: 

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines 

listed below. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines

listed below.

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No neurotoxicity studies were located that addressed the endpoints in the guidelines listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

11-7
IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No immunotoxicity studies were located that addressed the endpoints in the guidelines listed below.

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

No available genotoxicity data.

Basis for Conclusion:

No genotoxicity studies relevant to the below categories or to other types of genotoxic effects were

located.

Gene Mutation in Vitro 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

11-8
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

• The available acute freshwater toxicity data for fish, aquatic invertebrates, and algae were 

judged adequate to meet the endpoints. 

• The available acute marine/estuary toxicity data for fish, aquatic invertebrates, and algae 

were judged inadequate to meet the endpoints. 

Basis for Conclusion: 

Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 850.1075; 

OECD Guideline 203) 

A confidential 96-hour study in fish was located that reported no effects at saturation. These data 

allow this endpoint to be adequately characterized. 

Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; OECD 

Guideline 202) 

A confidential study in daphnid was located that reported a 24-hour EC50 of 1.2 mg/L and a 48-hour 

EC50 of 0.42 mg/L. These data allow this endpoint to be adequately characterized. 

Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

A confidential 96-hour study in green algae was located that reported no effects at saturation. These 

data allow this endpoint to be adequately characterized. 

No additional acute toxicity studies with freshwater or saltwater fish, aquatic invertebrates, or algae 

were located that followed or were similar to the guideline protocols listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

11-9
Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

11-10
Physical/Chemical Properties 

Proprietary H: Halogenated aryl ester 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: 

Conclusion: The flammability (as the flash point) has been adequately characterized. 

Basis for Conclusion: The key study was performed according to EEC Methods, Directive 

92/69/EEC (OJ No. L383A, 29.12.92), Part A, Method A9, flash point. 

Flash Point: 215°C (Ref. 2) 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

11-11
Henry’s Law Constant: No data 

11-12
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: 

The available bioconcentration data are adequate. 

Basis for Conclusion: 

A confidential guideline study submitted on Proprietary H indicates that the bioconcentration factor 

is 1.7-6.2. 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: 

The available aerobic biodegradation data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary H indicates that its half life is 3.5 days in water in a 

shake flask die-away test. It was also found to undergo 6% biodegradation after 28 days in closed 

bottle test in a submitted confidential study. 

11-13
Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: 

Conclusion: 

The available hydrolysis as a function of pH data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary H indicates that its hydrolysis half life is >1 year at 

pH 4, 7, and 9. 

Sediment/Water Biodegradation: 

Conclusion: 

The available sediment/water biodegradation data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary H indicates that its half life is 8.5 days in sediment 

in a shake flask die-away test. 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: 

Conclusion: 

The available soil adsorption data are adequate. 

Basis for Conclusion: 

A confidential study submitted on Proprietary H indicates that the soil adsorption coefficient is 

>28,840. 

11-14
Flame Retardant Alternatives

Proprietary I: Organic phosphate ester

Hazard Review

12-1
Proprietary I: Organic phosphate ester

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal T

Inhalation T

Eye irritation T

Dermal irritation T

Skin sensitization T

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

T

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

T

Reproduction and 

fertility effects 

T

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

T

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro T

Gene mutation in vivo 

Chromosomal T

aberrations in vitro 

Chromosomal T

aberrations in vivo 

DNA damage and 

repair 

Other 

12-2
Proprietary I: Organic phosphate ester

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point T

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH Y

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Y

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish T

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation T

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

T

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 T

Daphnia acute 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

12-3
Chemical Identity 

Proprietary I: Organic phosphate ester 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401) 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential acute oral toxicity study was submitted that reported an LD50 greater than 5 g/kg for 

rats. These data allow this endpoint to be adequately characterized. 

Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential acute dermal toxicity study was submitted that reported an LD50 greater than 5 g/kg 

for rats. These data allow this endpoint to be adequately characterized. 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD 

Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged adequate to meet the endpoint. 

12-4
Basis for conclusion: 

A confidential acute inhalation toxicity study was submitted that reported an LC50 greater than 1.55 

mg/L for rats. These data allow this endpoint to be adequately characterized. 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 

405) 

Conclusion: 

The available acute eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported mild and transient eye irritation in rabbits. These 

data allow this endpoint to be adequately characterized. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available acute dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported negative results for skin irritation in rabbits. These 

data allow this endpoint to be adequately characterized. 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The available skin sensitization data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported negative results for skin sensitization in guinea 

pigs. These data allow this endpoint to be adequately characterized. 

SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data. 

12-5
C

Basis for Conclusion: 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

A confidential reproductive/developmental screening assay satisfies the requirements for this 

endpoint. 

Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

A confidential reproductive/developmental screening study was submitted that found no 

reproductive effects at doses up to 1000 mg/kg/day. 

No other pertinent studies were located that addressed reproductive toxicity endpoints in the 

guidelines listed below. 

12-6
C Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

C Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged adequate to meet the endpoint.

Basis for Conclusion:

A confidential reproductive/developmental screening assay satisfies the requirements for this

endpoint.

C Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

C Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

C Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

A confidential reproductive/developmental screening study was submitted that found no 

developmental effects at doses up to 1000 mg/kg/day. 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines

listed below.

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

12-7
CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines

listed below.

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No neurotoxicity studies were located that addressed the endpoints in the guidelines listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No immunotoxicity studies were located that addressed the endpoints in the guidelines listed below.

12-8
• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Adequate studies are available for gene mutations in bacterial and mammalian cells in vitro, and 

chromosomal aberrations in vitro and for micronucleus formation in vivo. All tests yielded negative 

results for genotoxicity. 

Gene Mutation in Vitro: 

C Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; 

OECDGuideline 471) 

Confidential studies were submitted that found negative results for gene mutation in Salmonella and 

Escherichia coli. 

C In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

A confidential study was submitted that found negative results for gene mutation in cultured mouse 

lymphoma cells. 

Chromosomal Aberrations in Vitro: 

C In Vitro Mammalian Chromosome Aberration Test (OPPTS Harmonized Guideline 

870.5375) 

A confidential study was submitted that reported negative results for an in vitro chromosomal 

aberrations assay. 

Chromosomal Aberrations in Vivo: 

C Mammalian erythrocyte micronucleus test (OPPTS Harmonized Guideline 870.5395) 

A confidential study was submitted that reported negative results for micronucleus formation in mice 

exposed by intraperitoneal injection. 

12-9
No studies were located that were relevant to the categories below. 

Gene Mutation in Vivo 

DNA Damage and Repair 

12-10
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

The available data for the acute toxicity endpoint for fish were judged adequate to meet this 

endpoint. The currently available data for the acute toxicity endpoints for aquatic invertebrates or 

algae were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

A confidential study was submitted that reported a freshwater fish 96-hour LC50 = 0.205 mg/L. 

These data were judged adequately to meet this endpoint. A confidential study was submitted that 

reported a freshwater daphnid 48-hour LC50 > 0.846 mg/L. These data were judged inadequate to 

meet this endpoint. 

No other pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

The available chronic toxicity data for fish and aquatic invertebrates were judged inadequate to meet 

the endpoints. 

Basis for Conclusion: 

A confidential chronic toxicity study was submitted that reported a fish LOEC of 0.088 mg/L, based 

on reduced larval survival and growth. These data were judged in adequate to meet this endpoint. 

A confidential chronic toxicity study was submitted that reported a daphnid LOEC of 0.147 mg/L. 

These data were judged inadequate to meet this endpoint. 

No other pertinent chronic toxicity studies with fish or aquatic invertebrates were located that 

addressed the endpoints in the guidelines listed below. 

12-11
• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

12-12
Physical/Chemical Properties 

Proprietary I: Organic phosphate ester 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): 

Conclusion: 

The available water solubility data are adequate. 

Basis for Conclusion: 

A confidential guideline study indicating that the water solubility of Proprietary I is 0.8 mg/L was 

submitted.. 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Boiling Point: 

Conclusion: 

The available boiling point data are adequate. 

Basis for Conclusion: 

A confidential guideline study indicating that the boiling point of Proprietary I is >300 degrees C 

at 760 mm Hg was submitted. 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

12-13
Explosivity: No data 

Corrosion Characteristics: No data 

pH: It is anticipated that the pH for this compound will be not applicable because the functional 

groups present are not expected to affect the pH of an aqueous solution. 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: It is anticipated that the dissociation constant for this compound 

will be not applicable because the functional groups present are not expected to dissociate. 

Henry’s Law Constant: No data 

12-14
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: 

The available bioconcentration data are adequate. 

Basis for Conclusion: 

A confidential guideline study indicating that the bioconcentration factor of Proprietary I is 245 was 

submitted. 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: 

The available aerobic biodegradation data are adequate. 

Basis for Conclusion: 

Submitted confidential guideline studies indicated that Proprietary I underwent 2.3% degradation 

after 28 days in the MITI-II test and 30% removal in 28 days (52% removal in 140 days) in a closed 

bottle test. 

12-15
Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: 

Conclusion: 

The available hydrolysis data are adequate. 

Basis for Conclusion: 

A confidential guideline study was submitted and indicated that Proprietary I had a half-life at pH 

9 and 25 degrees C of 20 days. 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

12-16
Flame Retardant Alternatives

Proprietary J: Aryl phosphate

Hazard Review

13-1
Proprietary J: Aryl phosphate

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral T

Dermal T

Inhalation * 

Eye irritation T

Dermal irritation T

Skin sensitization 

Subchronic Toxicity 

28-Day oral * 

90-Day oral * 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal * 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental * 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

T

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro * 

Gene mutation in vivo 

Chromosomal * 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other * 

13-2
Proprietary J: Aryl phosphate

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility T

Octanol/water partition 

coefficient 

T

Oxidation/reduction 

Melting point T

Boiling point T

Vapor pressure T

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity T

Density/relative 

density/bulk density 

T

Dissociation constant in 

water 

Henry’s Law constant T

Environmental Fate 

Bioconcentration 

Fish * 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water T

Photolysis in soil 

Aerobic biodegradation * 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

T

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption * 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 * 

Daphnia acute * 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm EC50, 

LC50, NOAEC, 

LOAEC 

13-3
Chemical Identity 

Proprietary J: Aryl phosphate 

Synonyms 

CAS 

MF 

MW 

SMILES 

Omitted from this report are a number of studies conducted on [Formulation 2] (~43% Proprietary 

J). The omitted studies included 21-day dermal toxicity, 90-day aerosol inhalation toxicity, and 90­

day oral (feeding) toxicity in rats and neurotoxicity studies in hens. Replacement studies 

subsequently commissioned by the contracting company are reviewed here. 

Many health effects studies have been conducted on commercial products that are mixtures of 

Proprietary J and closely related compounds: [Chemical 1], [Chemical 2], and [Chemical 3]. 

Typical composition data for these products are given in Table 13-1 below. 

Table 13-1. Composition data (%) for selected t-butylated aryl phosphate products 

Component 

[Formulation 

1]a 

[Formulation 

2]b 

[Formulation 

3]c 

[Formulation 

4]d 

[Formulation 

5]e 

Proprietary J 43 43 >99 30-35 

73 

[Chemical Class 1] 23 

[Chemical 1] 14 30-35 

[Chemical 2] 2 10-15 

[Chemical 3] 34 40 15-25 27 

stabilizers <1 

a

Ref. 15 

b

Ref. 42 

c

Ref. 7 

d

Ref. 22 

e

Ref. 63. Ref. 58 reported that [Formulation 5] was [Chemical Class 1], but did not report the precise concentration of 

Proprietary J. After saponification, the isomer distribution of the [Chemical Class 2] portion was 39.2% [Chemical 4] 

and [Chemical 5] and 59.7% [Chemical 6]. 

13-4
Human Health Endpoints 

ACUTE TOXICITY 

Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 420, 

423, 401). 

Conclusion: 

The available acute oral toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Despite reporting deficiencies in some studies (lack of precise information on substance purity, 

group size), the available data indicate acute oral LD50 values exceeding 5,000 mg/kg for [Chemical 

Class 1] tested by methods equivalent to guidelines. 

Critical Studies: 

Type: Acute oral toxicity 

Species, strain, sex, number: Rat, CD Sprague-Dawley, 5/sex 

Doses: 5,000 mg/kg 

Purity: isomeric mixture of [Chemical Class 1] as [Formulation 7] (Ref. 7) 

Vehicle: None 

Method: Based on OECD Guideline 401. Rats examined for mortality and clinical signs frequently 

on day 1, twice daily thereafter to day 14. Body weights recorded on days 1, 8, and 15. Gross 

necropsy on all rats. 

Results: No deaths. Clinical signs in all rats after dosing included pilo-erection, hunched posture, 

and abnormal gait (waddling). Half of the animals had diarrhea. Clinical signs resolved by day 8. 

There were no effects on body weight gain or terminal necropsy findings. Acute oral LD50 was 

greater than 5,000 mg/kg in rats. 

Reference: Ref. 25 

Type: Acute oral toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 3/sex 

Dose: 5,000 mg/kg 

Purity: Not reported; isomeric mixture of Proprietary J as [Formulation 10]. Ref. 20 reports 

composition of 60-100% [Chemical Class 1] and 7-13% [Chemical 3]. 

Vehicle: None 

Observation period: 14 days 

Method: Rats observed 14 days after single dose, gross necropsy on all rats. Body weights recorded 

days 0, 7, and 14. 

13-5
Results: No deaths. Clinical signs included abdominogenital staining, chromorhinorrhea, and 

decreased locomotion, all subsiding by day 10. All rats gained weight. No gross lesions. The LD50 

exceeded 5,000 mg/kg. 

Comment: This study was equivalent to a limit test under OPPTS 870.1100 except that the group 

size was 3/sex rather than 5/sex. 

Reference: Ref. 16 

Type: Acute oral toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, males and females, numbers not reported 

Dose: 15,800 mg/kg 

Purity: Near pure Proprietary J 

Vehicle: None 

Observation period: 14 days 

Method: Rats observed 14 days after single dose. 

Results: The LD50 exceeded 15,800 mg/kg in rats (specific mortality results were not reported). 

Reference: Ref. 34 

Additional Studies and Information: 

Ref. 10 evaluated the oral toxicity of [Chemical Class 1] administered to rabbits by oral gavage in 

8% gum acacia; rabbits were observed “several days” for clinical signs of toxicity. There were no 

effects in single rabbits receiving 1,000 or 3,000 mg/kg of Proprietary J or [Chemical 1], or 1,000 

mg/kg of [Chemical 2]. 

In another study, male rabbits were administered [Chemical Class 1] by oral gavage in 5% gum 

acacia and observed for varying amounts of time (Ref. 11). One rabbit received 2,000 mg/kg of 

Proprietary J and was observed for 5 days and two rabbits received 5,000 mg/kg and were observed 

for 4 or 16 days. All showed hepatic degeneration and two had kidney effects (tubular degeneration 

and congestion or swelling); necrosis of the stomach (high dose) and moderate lung congestion (low 

dose) were seen in single animals. A parallel experiment with rabbits treated with [Chemical 1] had 

similar results: liver effects in 1/1 at 2,000 mg/kg (killed day 5) and 2/2 at 5,000 mg/kg (killed day 

4 or 17), and lung congestion and cloudy swelling of the kidneys in one high- and one low-dose 

animal. No deaths and no overt clinical signs were seen in rabbits treated with either compound. 

A related compound, [Chemical 2] (containing 1-2% [Chemical 5]), was administered at doses of 

3,000 or 10,000 mg/kg by oral gavage in olive oil to rats (Ref. 12). Mortality was 1/5 at the low 

dose and 1/3 at the high dose, but the length of the observation period was not reported. 

As described in a robust summary, there were no deaths and no gross lesions in Sprague-Dawley rats 

(5/sex) orally exposed to 5,000 mg/kg [Formulation 5] (see Note e in Table 1) and observed for 14 

days (Ref. 53 cited in Ref. 1). Clinical signs (depression, diarrhea, and stains on fur and around the 

nose) resolved by day 6. A letter from Ref. 52 to EPA suggests that this study was conducted under 

the 1978 EPA proposed test guidelines. 

13-6
Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 402) 

Conclusion: 

The available acute dermal toxicity data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Despite reporting deficiencies in some studies (lack of precise information on substance purity, 

group size), the available data indicate acute dermal LD50 values exceeding 2,000 mg/kg for 

Proprietary J tested by methods equivalent to guidelines. 

Critical Studies 

Type: Acute (24-hour) dermal toxicity 

Species, strain, sex, number: Rat, Sprague-Dawley, 3/sex 

Dose: 2,000 mg/kg 

Purity: Not reported; isomeric mixture of Proprietary J as [Formulation 10] 

Vehicle: None 

Exposure period: 24 hours 

Method: Undiluted test material applied to intact clipped dorsal skin. Treated areas occluded, 

washed after 24 hours with methanol and then water. Animals observed for 3 hours after dosing and 

daily thereafter for 14 days. Body weights recorded on days 0, 7, and 14. All subjected to gross 

necropsy. 

Results: No deaths, clinical signs, local irritation of the application site, or gross necropsy lesions. 

All rats gained weight. The acute dermal LD50 exceeded 2,000 mg/kg in rats. 

Comment: This study was equivalent to a limit test under OPPTS 870.1200 except that the group 

size was 3/sex rather than 5/sex. 

Reference: Ref. 17 

Type: Acute (24-hour) dermal toxicity 

Species, strain, sex, number: Rabbit, New Zealand albino, male and female, numbers not reported 

Dose: 7,900 mg/kg 

Purity: near pure Proprietary J 

Vehicle: None 

Exposure period: 24 hours 

Method: Undiluted test material applied to intact clipped dorsal skin. Treated areas occluded, 

washed (liquid unspecified) after 24 hours. Animals held for 14 days after which all subjected to 

gross necropsy. 

Results: The acute dermal LD50 exceeded 7,900 mg/kg. The study did not report necropsy findings 

or specific mortality results. 

Reference: Ref. 34 

13-7
As described in a robust summary, mortality was 1/10 among New Zealand White rabbits (5/sex) 

that received a dose of 2,000 mg/kg [Formulation 5] (see Note e in Table 1) on intact and abraded 

skin and were observed for 14 days (Ref. 54 cited in Ref. 1). Clinical signs included depression and 

mild diarrhea. No gross lesions were observed at necropsy. A letter from Ref. 52 to EPA suggests 

that this study was conducted under 1978 EPA proposed test guidelines. 

Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300; OECD Guideline 403) 

Conclusion: 

The available acute inhalation toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The only relevant data were for a study available only as a robust summary and for which the 

Proprietary J content was uncertain. 

As described in a robust summary, no mortality and no body weight effects were observed among 

Sprague-Dawley rats (5/sex) that were exposed for 4 hours to an aerosol of [Formulation 5] (see 

Note e in Table 1) at the highest attainable concentration, 3.1 mg/L (Ref. 54 cited in Ref. 1); the 

particle size distribution of 2.5-2.8 :m suggests that the particles were respirable. Ruffled fur was 

the only clinical sign observed over a period of 14 days. The only gross lesions observed were lung 

effects (reddened or whitish coloration) in two females. 

Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

Conclusion: 

The available eye irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Despite some uncertainty as to the purity of test substances, the available studies used methods 

equivalent to the guidelines and agreed that Proprietary J was not an eye irritant. 

Type: Acute eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, 3 (sex not reported) 

Doses: 0.1 mL 

Purity: Not reported; isomeric mixture of Proprietary J as [Formulation 7] 

Vehicle: None 

Method: Cites OECD Guideline 405. Eyes examined after 1 hour, then 1, 2, 3, 4, and 7 days. 

Results: No positive responses; no damage to cornea or iris. Mild conjunctival inflammation was 

observed in 3/3 animals 1 hour after instillation only. All normal by 24 hours. 

Reference: Ref. 27 

13-8
Type: Acute (4-hour) eye irritation 

Species, strain, sex, number: Rabbit, New Zealand White, 3 females 

Doses: 0.1 mL 

Purity: Not reported; isomeric mixture of Proprietary J as [Formulation 10]. Ref. 20 reports 

composition of 60-100% [Chemical Class 1] and 7-13% [Chemical 3]. 

Vehicle: None 

Method: Instilled into eye. Eyes assessed via Draize method at 1, 24, 48, and 72 hours. 

Results: No eye irritation was observed at any timepoint. 

Comment: Although the study was designated “non-definitive”, it was consistent with the OPPTS 

guideline. 

Reference: Ref. 18 

Additional information 

As described in a robust summary, 0.1 mL [Formulation 5] (see Note e in Table 1) was a mild ocular 

irritant to rabbits (Ref. 56 cited in Ref. 1). Mild redness of the conjunctiva persisted to 24 hours in 

2/9 and to 48 hours in 1/9, but was resolved by 72 hours. The eye irritation observed in this study 

may reflect compositional differences between [Formulation 5] and the other Proprietary J materials 

tested. 

Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 404) 

Conclusion: 

The available dermal irritation data were judged adequate to meet the endpoint. 

Basis for Conclusion: 

Despite some uncertainty as to the purity of test substances, the available studies used methods 

equivalent to the guidelines. Results indicated no or mild dermal irritation. 

Critical Studies: 

Type: Acute (4-hour) dermal irritation 

Species, strain, sex, number: Rabbit, New Zealand White, 3 

Doses: 0.5 mL 

Purity: Not reported; isomeric mixture of Proprietary J as [Formulation 7] (relationship to the 

composition of [Formulation 3] reported in Table 1 is not known) 

Vehicle: None 

Method: Followed OECD Guideline 404. Hair clipped. Material applied for 4 hours to 

approximately 10-cm square area on back, semi-occlusive dressing. Site rinsed with water, 

examined after 30 minutes and days 2, 3, and 4; additional observations on days 5 through 11. 

Results: Very slight or well-defined erythema with or without very slight edema was seen in two 

animals immediately, persisting though day 8 and day 10. Very slight erythema without edema in 

13-9
third animal on days 2 and 3 only. A 4-hour exposure to the test material elicited mild reversible 

irritation. 

Reference: Ref. 26 

Type: Acute (4-hour) dermal irritation 

Species, strain, sex, number: Rabbit, New Zealand White, 2 males and 1 female 

Doses: 0.5 mL 

Purity: Not reported; isomeric mixture of Proprietary J as [Formulation 10]. Ref. 20 reports 

composition of 60-100% [Chemical Class 1] and 7-13% [Chemical 3]. 

Vehicle: None 

Method: Test material applied to clipped, intact skin and occluded. After 4 hours, sites were wiped 

clean with methanol and rinsed with tap water. Scoring for irritation was done 30 minutes after 

wiping and then daily for 3 days. Clinical signs were observed. 

Results: No signs of irritation (erythema or edema) were noted at any timepoint. The primary 

irritation index was 0/8.0; the material was non-irritating to intact rabbit skin 

Reference: Ref. 19 

As described in a robust summary, [Formulation 5] (see Note e in Table 1) was a mild dermal irritant 

to rabbits, yielding a primary irritation score of 0.50 (Ref. 57 cited in Ref. 1). 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

No available skin sensitization data. 

Basis for Conclusions: 

No pertinent studies were located that followed or were similar to the guideline listed above, or were 

otherwise relevant to skin sensitization. 

SUBCHRONIC TOXICITY

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental)

Conclusion: 

The available subchronic oral toxicity data were judged marginally adequate to meet the endpoint.

Basis for Conclusion: 

A 90-day oral toxicity assay on 73% [Formulation 11] was similar to guidelines except for the lack 

of testing for ophthalmological effects and neurological function and that the high dose was 

significantly lower than the limit dose. The study did identify target organs that might show 

13-10
histopathology at higher exposure levels. The Proprietary J content of tested materials was less than 

50% in a 1-month assay. 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

Ref. 42 exposed groups of Sprague-Dawley rats (10/sex/group) to diets providing [Formulation 2] 

(43% Proprietary J, see Table 1) at target doses of 0, 250, 500, 750, 1,000, or 2,000 mg/kg/day 

(nominal doses of 213, 442, 660, 898, and 1,710 for males and 234, 454, 690, 898, and 1,867 for 

females) for 1 month. Reduced food consumption was observed in males at 2,000 mg/kg/day; 

reduced body weight gain in males at $750 mg/kg/day and females at 2,000 mg/kg/day. There were 

no deaths, but hepatic enlargement was noted in all groups in a dose-related fashion; discoloration 

of kidneys was observed in male rats at $500 mg/kg/day. The lowest dose was a LOAEL; 

methodological limitations of the study include the lack of examinations for histopathology, 

hematology, or clinical chemistry. 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408) 

Type: 90-day oral (diet) toxicity in rodents 

Species, strain, sex, number: Rat, Sprague-Dawley (20/sex/group) 

Doses: 0, 100, 400, or 1,600 ppm [Formulation 5]; average intakes of 0, 6.6, 26.7 or 107.5 

mg/kg/day in males and 0, 7.7, 30.0 or 124.8 mg/kg/day in females. 

Purity: About 73% isomeric mixture of [Formulation 11] and 27% triphenyl phosphate as 

[Formulation 5]. 

Vehicle: Feed 

Method: Rats were examined twice daily for clinical signs and mortality, weekly physical 

examinations (with palpation) and measurements of body weights and food consumption. 

Hematology, clinical chemistry and urinalyses were performed prior to testing, at mid-test and just 

prior to termination. At termination, all animals were subjected to gross necropsy; organ weights 

of adrenal, brain, heart, liver, kidney and gonads were recorded. More than 30 organs/tissues were 

examined for histopathology in all groups. Brain cholinesterase was measured at termination in all 

groups. 

Results: Treatment had no significant effect on survival, food consumption, body weight gain, 

hematology or clinical chemistry parameters, cholinesterase values, or the incidence of gross or 

microscopic lesions (including reproductive organs, brain and spinal cord). At the highest dose, there 

were statistically significant increases in absolute and relative liver weights in males (increased 18­

24%) and females (increased ~15%), relative kidney weights in males (increased 6%), and absolute 

and relative adrenal weights in females (increased 12-14.7%). These changes were not accompanied 

by histopathological lesions or changes in clinical chemistry parameters. In this study, 400 ppm 

(26.7 mg/kg/day for males and 30 mg/kg/day for females) was a NOAEL and 1600 ppm (107.5 

mg/kg/day for males and 124.8 mg/kg/day for females) was a LOAEL for increased liver weights 

in both sexes and adrenal weights in females. The study is marginally acceptable because the 

highest dose was considerably lower than the limit dose of 1000 mg/kg/day. The study does, 

13-11
however, identify target organs that might show lesions if testing were conducted at higher exposure 

levels. 

Reference: (Ref. 59, 60, 63) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

No relevant studies were located that followed or were similar to the guideline listed above. 

Subchronic Dermal Toxicity (21/28-day or 90-day) 

Conclusion: 

The available subchronic dermal toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available study was conducted on a substance with a Proprietary J content of less than 50%. 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

[Formulation 2] (43% Proprietary J; see Table 1) was applied to intact and abraded skin of New 

Zealand White rabbits (10/sex/group) at doses levels of 10, 100, or 1,000 mg/kg/day, 5 days/week 

for 3 weeks (Ref. 6); controls were treated with distilled water. Treatment-related effects included 

skin changes at the application site (edema at 1,000 mg/kg/day in males and $10 mg/kg/day in 

females; atonia at $100 mg/kg/day in both sexes; desquamation at $10 mg/kg/day in both sexes; and 

fissuring at 1,000 mg/kg/day in both sexes), higher blood urea nitrogen values at 1,000 mg/kg/day 

in both sexes, and dose-related depression of plasma cholinesterase at $100 mg/kg/day, and of 

erythrocyte and brain cholinesterase at $10 mg/kg/day in both sexes. Changes in other parameters 

(mortality, clinical signs, body weight, hematology, clinical chemistry, organ weights, gross or 

microscopic lesions) were not related to treatment. 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

No relevant studies were located that followed or were similar to the guideline listed above. 

13-12
Subchronic Inhalation Toxicity (90-day) 

Conclusion: 

No available subchronic inhalation toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that followed or were similar to the guideline listed below, or were 

otherwise relevant to subchronic inhalation toxicity. 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD 

Guideline 413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

The available reproductive toxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

No studies were located that followed or were similar to the three guidelines listed below. No 

histopathology of the male (testes, epididymides, prostate) or female (ovary, uterus, cervix, vagina) 

reproductive organs was observed in rats fed diets containing up to 1600 ppm [Formulation 5] (73% 

[Formulation 11]; see Note e to Table 1) for 3 months (Ref. 59, 60, 63). 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

The available developmental toxicity data were judged inadequate to meet the endpoint. 

13-13
Basis for Conclusion: 

The only available developmental toxicity data are for formulations containing only about 43% 

Proprietary J. 

Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; OECD 

Guideline 414) 

Ref. 32, 33 evaluated the developmental toxicity of [Formulation 2] (43% Proprietary J, see Table 

1) in rats. In a pilot study (Ref. 32), pregnant CD rats (5/group) received undiluted [Formulation 

2] at doses of 250, 500, 1,000, 2,500, or 5,000 mg/kg/day by oral gavage on gestational days (GD) 

6-19; controls received 4.2 mL of water per day. Treatment had no effect on survival, behavior, or 

maternal necropsy findings. Anogenital staining was observed in all test groups (incidences of 1/5, 

2/5, 2/5, 5/5, and 4/5 in the lowest-to-highest dose groups, respectively) and red and/or brown matter 

around the nose, mouth, and forelimbs in all receiving 5,000 mg/kg/day. Dose-related reductions 

in body weight gain for GD 0-20 were observed at $1,000 mg/kg/day, but were only biologically 

significant at the highest dose (-33% compared to control). At the highest dose, decreases in viable 

fetuses and increases in mean postimplantation losses compared to historical controls were observed 

at 5,000 mg/kg/day (values for concurrent controls were higher than historical control value). 

In the main study (Ref. 33), groups of 25 pregnant CD rats received 2.542 mL of water or undiluted 

[Formulation 2] at doses of 300, 100, or 3,000 mg/kg/day by oral gavage on GD 6-19. Treatment 

had no significant effect on maternal survival, behavior, body weight gain, the incidence of gross 

necropsy findings, or most reproductive/developmental parameters (mean number of viable fetuses, 

postimplantation loss, early or late resorptions, total implantations, corpora lutea, fetal sex 

distribution, mean fetal body weight, and incidences of external malformations and visceral 

variations). High-dose dams had a higher incidence of clinical signs (all with yellow staining of 

anogenital area and half with dried red matter on nose and forepaws) compared to other groups. At 

3,000 mg/kg/day, there was a slight increase compared to controls in the percentage of litters with 

skeletal malformations (3/24 or12% vs 1/20 or 5%); the percentage in historical controls was 6.23% 

No relevant studies were located that followed or were similar to the two tests listed below. 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data. 

13-14
Basis for Conclusion: 

No pertinent studies following or similar to the guidelines listed below or otherwise relevant to 

chronic toxicity were located. 

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

Basis for Conclusion: 

No pertinent studies following or similar to the guidelines listed below or otherwise relevant to 

carcinogenicity were located. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No studies examined developmental neurotoxicity or neurological function. Acceptable negative 

are available for delayed neurotoxicity in adults. In the 90-day oral toxicity assay by (Ref. 59, 60, 

63) described above, rats exposed to [Formulation 5] (73% Formulation 11]; see Note e to Table 1) 

in the diet at concentrations up to 1600 ppm exhibited no neurohistopathology and no inhibition of 

brain cholinesterase activity. 

Delayed Neurotoxicity 

Conclusion: 

The available delayed neurotoxicity data were judged adequate to meet the endpoint. 

13-15
Basis for Conclusion: 

The available studies were consistent with guidelines and overall suggest that exposure to large 

doses of Proprietary J does not evoke delayed neurotoxicity in hens 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Critical Studies 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Hen, “hybrid”, females, older than 14 months, 4 water controls and 

8 treated with Proprietary J 

Purity: Not reported; >99% Proprietary J as [Formulation 3] (see Table 1) 

Doses: The plan was 1,000 mg/kg, 5 times daily for 5 consecutive days (total 25,000 mg/kg); 

because of shortage of material, only 3 doses were given on day 4, so 7 doses were given on day 5 

to make up the difference. 

Vehicle: None 

Positive control: None 

Route: Oral gavage 

Exposure duration, frequency: 5 days, 5 times daily 

Method: Observations for up to 32 days. Birds examined daily for signs of neurotoxicity; body 

weights, food consumption, egg numbers, and egg weights recorded twice weekly. 

Results: There were no signs of ataxia. Mortality rates, body weight gain, and feed consumption 

did not differ between test and control groups; egg production in test group was about 50% of 

controls although egg weights were slightly higher in test animals. 

Reference: Ref. 28 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Chicken, White Leghorn, females, 9/group 

Purity: near pure Proprietary J 

Doses: 10,000 mg/kg, twice daily (20 mg/kg/day) 

Vehicle: None 

Positive control: Corn oil 

Route: Oral gavage 

Exposure duration, frequency: Twice daily for three consecutive days; dosing regimen repeated 

21 days later. 

Method: Daily observations for mortality and neurotoxicity for up to 42 days. Body weights 

recorded at 0, 21, and 42 days. At gross necropsy, brain, spinal cord, and sciatic nerve were 

examined for histopathology. The neurotoxicity study was preceded by an acute oral toxicity assay 

in hens given 10,000 mg/kg. 

Results: There were no signs of ataxia or neurohistopathological lesions in 9 hens treated with 

Proprietary J at cumulative doses of 120,000 mg/kg. Other [Chemical Class 3] chemicals tested at 

the same time were neurotoxic. The positive control, tri-ortho-cresyl phosphate (TOCP), caused 

13-16
neurotoxicity in 4/4 hens treated with 300 mg/kg/day for 5 days (cumulative dose of 1,500 mg/kg). 

The acute oral LD50 in hens exceeded 10,000 mg/kg (no mortality data reported). 

Reference: Ref. 34 

Type: Acute oral delayed neurotoxicity 

Species, strain, sex, number: Hen, female, older than 14 months, 4 control and 8 test birds 

Purity: Not reported; [Formulation 3] is >99% Proprietary J and <1% stabilizers (Ref. 7) 

Doses: 1,000 mg/kg five times daily for five consecutive days (= 25,000 mg/kg total) 

Vehicle: None 

Positive control: None 

Negative control: Water 

Route: Oral gavage 

Exposure duration, frequency: five days, five times daily 

Method: Observations for up to 32 days. Birds examined daily for signs of neurotoxicity; body 

weights, food consumption, egg numbers, and egg weights recorded twice weekly. 

Results: No ataxia observed; no treatment-related effects on mortality or body weight gain. Mean 

daily food consumption in test animals was about 15% lower than in controls, largely because intake 

was reduced by 47% during days 0-4. In test group, egg production was about 70% of controls and 

egg weights about 11% lower than in controls. 

Reference: Ref. 30 

Additional Studies: 

Several components of the [Formulation 6] series of flame retardants were isolated to >99% purity 

and tested at doses as high as 1,000 mg/kg in mature hens for neurotoxicity and suppression of 

neurotoxic esterase (Ref. 24). Details of these studies were not located. [Chemical 2], [Chemical 

1], and Proprietary J elicited no signs of neurotoxicity and no suppression of NTE levels. [Chemical 

7] was also judged to be non-neurotoxic, eliciting no ataxia or other signs of neurotoxicity and 

insignificant suppression of NTE (-4% or -15%) in two tests. However, [Chemical 8] was 

neurotoxic, eliciting ataxia and neurotoxicity, as well as suppression of NTE levels (by -71% and 

-57 to -62% in two tests) at 1 mL/kg. The author suggested that neurotoxicity was associated with 

[Chemical Class 1] with an oxidizable alpha-hydrogen. 

Hens given [Formulation 4] (100% [Chemical Class 1]; 30-35% Proprietary J, see Table 1) at a dose 

of 5,000 mg/kg/day on five consecutive days by oral gavage lost weight and developed paralysis 

(4/4) and 3/4 died before the end of the test (Ref. 14). The study authors suggested that residual 

[Chemical Class 4] chemicals may have been responsible for the observed neurotoxicity. 

Hens treated with 2,000 mg/kg of [Formulation 10] did not elicit clinical signs of neurotoxicity, 

lesions of the nervous system, or depression in NTE, whereas hens treated with TOCP at 500 mg/kg 

showed all of these effects (Ref. 35 abstract as described in Ref. 61). 

There was no effect on survival or walking behavior among a group of 15 hens (12-14 months old) 

given oral doses of 11, 679 mg/kg [Formulation 5] (see Note e in Table 1) on days 1 and 21 under 

13-17
EPA proposed guidelines (Ref. 58). All showed slight motor incoordination on day 1; body weights 

were reduced on day 38, but terminal weights were as in corn oil controls. Neurohistopathology and 

feed consumption were equivalent to corn oil controls. Hens treated with TOCP had increased 

mortality, progressive leg weakness, persistently reduced feed intake and body weight loss, and 

significant axonal degeneration. 

No neurotoxicity studies were located that were relevant to the categories listed below. 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

Additional neurotoxicity studies: 

• Schedule-Controlled Operant Behavior (mouse or rat); OPPTS Harmonized Guideline 

870.6500 

• Peripheral Nerve Function (rodent); OPPTS Harmonized Guideline 870.6850 

• Sensory Evoked Potentials (rat, pigmented strain preferred); OPPTS Harmonized Guideline 

870.6855 

These additional neurotoxicity studies may be indicated, for example, to follow up 

neurotoxic signs seen in other studies, or because of structural similarity of the 

substance to neurotoxicants that affect these endpoints. These studies may be 

combined with other toxicity studies. 

Other Neurotoxicity Data 

Cholinesterase inhibition 

In five hens that received 25,000 mg/kg of [Formulation 7] in divided doses (8, 8, and 9 g/kg at 4­

hour intervals) by oral gavage, plasma cholinesterase (pChE) levels 30-60 minutes later were about 

60-70% of pre-dose levels (Ref. 29); 9 days later, pChE levels had risen to 83.1% of the pre-dose 

level. One bird that showed clinical signs (quiet with subdued behavior) after dosing did not show 

appreciable recovery of pChE on day 9. The authors concluded that because of the very high dose 

administered, the test material was not a significant inhibitor of plasma cholinesterase. 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data. 

13-18
Basis for Conclusion: 

No pertinent studies were located that followed or were similar to the guideline listed below, or were 

otherwise relevant to immunotoxicity. 

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

GENOTOXICITY 

Conclusion: 

The available genotoxicity data were judged inadequate to meet the endpoint. 

Basis for Conclusion: 

The available studies followed methods equivalent to guidelines, but tested materials for which the 

Proprietary J content was low (less than 50%) or uncertain; the latter studies were only available as 

robust summaries. None of the studies indicate the Proprietary J-containing mixtures are mutagenic 

in bacteria or mammalian cells. 

Gene Mutation in Vitro: 

• Bacterial Reverse Mutation test (OPPTS Harmonized Guideline 870.5100; OECD 

Guideline 471) 

[Formulation 1] (typical analysis 43% Proprietary J; see Table 1) was not mutagenic in S. 

typhimurium strains TA98, TA100, TA1535, TA1537, or TA1538 with or without metabolic 

activation (Ref. 15). 

[Formulation 2] (typical analysis 43.2% Proprietary J, see Table 1) at concentrations between 0.01 

and 10 :L/plate produced negative results in S. typhimurium strains TA98, TA100, TA1535, 

TA1537, or TA1538 and Saccharomyces cerevesiae D4 with or without metabolic activation (Ref. 

36). 

As described in a robust summary, [Formulation 5] (see Note e in Table 1) at concentrations 

between 0.005 and 10 :g/plate produced negative results in S. typhimurium strains TA98, TA100, 

TA1535, TA1537, or TA1538 with or without metabolic activation (Ref. 38); cytotoxicity was 

observed at 0.1 :g/plate and higher. 

• In vitro Mammalian Cell Gene Mutation Test (OPPTS Harmonized Guideline 

870.5300; OECD Guideline 476) 

13-19
[Formulation 2] (typically 43% Proprietary J, see Table 1) at concentrations between 0.011 and 0.1 

:L/mL (0.2 :L/mL was cytotoxic) did not induce forward mutations in cultured mouse lymphoma 

L5178Y/TK+/- cells with or without metabolic activation (Ref. 37). 

As described in a robust summary, [Formulation 5] (see Note e in Table 1) at concentrations 

between 0.975 and 125 nL/mL ($15.6 nL/mL was cytotoxic) did not induce forward mutations in 

cultured mouse lymphoma L5178Y/TK+/- cells with or without metabolic activation (Ref. 39). 

Chromosomal Aberration in Vitro 

• In Vitro Mammalian Chromosome Aberration Test (OPPTS Harmonized Guideline 

870.5375) 

As described in a robust summary, [Formulation 5] (see Note e in Table 1) at concentrations 

between 0.625 and 20 nL/mL ($2.5 nL/mL was cytotoxic) did not increase the frequency of 

chromosomal aberrations in cultured mouse lymphoma L5178Y/TK+/- cells with or without 

metabolic activation (Ref. 40). 

No studies were located that were relevant to the categories listed below. 

Gene Mutation in Vivo 

Chromosomal Aberration in Vivo 

DNA Damage and Repair 

Other 

• In vitro Sister Chromatid Exchange Assay (OPPTS Harmonized Guideline 870.5900) 

As described in a robust summary, [Formulation 5] (see Note e in Table 1) at concentrations 

between 0.625 and 20 nL/mL ($2.5 nL/mL was cytotoxic) did not increase the frequency of sister 

chromatid exchanges in cultured mouse lymphoma L5178Y/TK+/- cells with or without metabolic 

activation (Ref. 40). 

13-20
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

The available acute toxicity data for fish, aquatic invertebrates, and algae were judged inadequate 

to meet the endpoints. 

Basis for Conclusion: 

Summary data were located for a screening-level assessment of the acute toxicity of Proprietary J 

to rainbow trout and bluegill (Ref. 31). Proprietary J was dissolved in acetone and added to water. 

Fish were exposed to aqueous solutions of 0.1, 1.0, 10.0, or 100 mg Proprietary J/L for 96 hours. 

The estimated 96-hour LC50 values for rainbow trout and bluegill were 1.1 and 1.0 mg/L, 

respectively. The two highest test concentrations exceeded the reported water solubility of 

Proprietary J (Ref. 49). The summary did not provide sufficient information regarding study 

conditions, including test substance purity, to allow for an independent evaluation of the studies. 

Summary data were located for studies of the toxicity of Proprietary J to Daphnia magna and the 

midge Chironomus tentans (Ref. 62). The reported 48-hour LC50values for D. magna and C. tentans 

were 0.30 and 0.15 mg/L, respectively. Study details, including test substance purity, were not 

presented in the summary, so the results could not be independently evaluated. 

Summaries were located for studies of the acute toxicity of the commercial aryl phosphate ester 

mixtures [Formulation 8], [Formulation 9], and [Formulation 2] to fish, aquatic invertebrates, and 

algae (revised HPV Robust Summaries submitted by Ref. 2, as part of the HPV Challenge Program). 

Although some of the tested products may have contained Proprietary J, their actual composition 

was not presented in the study summaries. Without precise knowledge of the composition of the 

tested materials, it is not possible to use these studies to make a definitive statement regarding the 

toxicity of Proprietary J. [Formulation 2] has been reported (by a different chemical company) to 

contain <50% Proprietary J (Table 1). 

Studies of the acute toxicity of [Formulation 8] to rainbow trout, bluegill, fathead minnow, channel 

catfish (Ref. 8), D. magna, the midge C. plumosus, the amphipod Gammarus pseudolimnaeus, and 

algae (Ref. 50) were located. [Formulation 8] contains 15-20% [Chemical 3] and unspecified 

amounts of at least five other compounds (Ref. 8). Chemical analysis of the aqueous test solutions 

in a chronic toxicity study (discussed below) (Ref. 8) suggested that the concentration of Proprietary 

J in the test waters may have been 40% or less of nominal concentrations of [Formulation 8]. Given 

that the organisms in these tests were exposed to a mixture of compounds, which was predominantly 

not Proprietary J, it is concluded that it is not possible to use these studies to make a definitive 

statement regarding the toxicity of Proprietary J. 

13-21
No additional, pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located 

that addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

The available chronic toxicity data for fish and aquatic invertebrates were judged inadequate to meet 

the endpoints. 

Basis for Conclusion: 

Studies of the chronic toxicity of the commercial phosphate ester compound [Formulation 8] to 

fathead minnow (Ref. 8), Daphnia magna, the midge Chironomus plumosus, and the amphipod 

Gammarus pseudolimnaeus (Ref. 50) were located. Formulation 8] contains 15-20% [Chemical 3] 

(Ref. 8). Measured concentrations of Proprietary J in the test waters were 25% to 40% of nominal 

concentrations of [Formulation 8] (Ref. 8). Thus, the organisms in these tests were exposed to 

aqueous solutions that contained a mixture of compounds that were predominantly not Proprietary 

J. Therefore, it is concluded that it is not possible to use these studies to make a definitive statement 

regarding the toxicity of Proprietary J. 

No additional, pertinent chronic toxicity studies with fish or aquatic invertebrates were located that 

addressed the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

13-22
Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

13-23
Physical/Chemical Properties 

Proprietary J: Aryl phosphate 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): 

Conclusion: The available water solubility data are adequate.

Basis for Conclusion: Ref. 49 gives a measured value for the water solubility of Proprietary J. 

Solubility (mg/L) References 

3.20 Ref. 49, 51 

Log Kow: 

Conclusion: The data for this endpoint are adequate. 

Basis of Conclusion: The Log Kow values of 5.12 are identical as found in two sources Ref. 49 and 

Ref. 3). Ref. 4 estimates the Log Kow value based on HPLC that are in reasonable agreement with 

the key study indicated above. Ref. 45, however, gives a Log Kow value of 13.2, which is much 

higher than that found in the other sources and this value does not appear reasonable for compounds 

of this class. 

Log Kow Reference 

5.12 Ref. 3, 49, 51 

3.23 4.76 6.44 Ref. 4 (estimated from reverse phase HPLC data by Ref. 48) 

13.2 Ref. 45 

13.3 Ref. 13 

Oxidation/Reduction: No data 

Melting Point: 

Conclusion: The data are adequate for this endpoint.

Basis for Conclusion: A value of -20 /C is given for the melting point of Proprietary J. Another

study provides a pour point for Proprietary J that is in reasonable agreement with the melting point

value.

13-24
Melting Point (/C) Reference 

-20 Ref. 13 

-21 (pour point) Ref. 45 

Boiling Point: 

Conclusion: The available boiling point data are adequate to characterize this endpoint. 

Basis for Conclusion: Two sources contained measured boiling point information. A third source 

required calculating the boiling point from the Clausius-Clapeyron equation using data measured 

by Ref. 9. The boiling points given here (including the calculated boiling point) are within a 

reasonable range of each other. 

BP (/C/torr) References 

261/6 Ref. 49, 51 

425/760 

dec. 405 

Ref. 9 (extrapolated according to the Clausius-Clapeyron Equation using experimentallyderived parameters: Log P(torr) = -A/T + C, where T is in Kelvin, A= 4444, C=9.24) 

The decomposition temperature was reported in this same paper. 

420/760 Ref. 4 (estimated using Meissner’s method) 

155/2 Ref. 13 

Vapor Pressure (torr): 

Conclusion: The majority of available vapor pressure data give an adequate endpoint. 

Basis for Conclusion: Two sources contained measured vapor pressure data. These two values were 

in agreement with each other. The third source required calculating the boiling point from the 

Clausius-Clapeyron equation using data measured by Ref. 9. The calculated value was in reasonable 

agreement with the measured values. 

VP (torr//C) Reference 

1.40x10-6/25 Ref. 51; Ref. 4 (measured) 

4.6x10-7 Ref. 4 (estimated from b.p. using Method 2 in Ref. 21) 

2.16x10-6/25 Ref. 9 (extrapolated according to the Clausius-Clapeyron Equation using experimentallyderived parameters Log P(torr) = -A/T + C, where T is in Kelvin, A= 4444, C=9.24) 

1.35/200 Ref. 45 

10.2/250 Ref. 13 

13-25
Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion characteristics: No data 

pH: No data 

UV/VIS absorption: No data 

Viscosity: 

Conclusion: The viscosity of this compound has been adequately characterized. 

Basis for Conclusion: A single study on the viscosity of Proprietary J was located and appears

reasonable given the other physical/chemical properties available for this compound.

Viscosity at 25 /C Reference 

58 Ref. 13 

Density/Relative Density/Bulk Density: 

Conclusion: The density of this compound has been adequately characterized.

Basis for Conclusion: A single study on the density of Proprietary J was located and appears

reasonable given the other physical/chemical properties available for this compound.

Density Reference 

1.175-1.185 Ref. 13 

Dissociation Constant in Water: No data 

Henry’s Law Constant: 

Conclusion: The data are adequate to characterize the Henry’s Law constant. 

Basis for Conclusion: The key study provides an estimated Henry’s Law constant based on 

measured vapor pressure and water solubility data and is taken from Ref. 45. This is a reasonable 

method for estimating a Henry’s Law constant. The other studies identified provide estimates 

although they are based on estimated vapor pressures and not experimental values and are not 

sufficiently reliable to categorize this end point. 

13-26
Henry’s Law Constant Reference 

8.48x10-7 atm-m3

/mole Ref. 45, 51 

7.2x10-8 atm-m3

/mole Ref. 4 (calculated from vapor pressure of 4.6x10-7 mm Hg and water solubility 

3.2) 

2.2x10-7 atm-m3

/mole Ref. 4 (calculated from vapor pressure of 1.4x10-6 mm Hg and water solubility 

3.2) 

2.15x10-5 atm-m3

/mole Ref. 46 

13-27
Environmental Fate 

Bioconcentration 

Fish: 

Conclusion: The bioconcentration of Proprietary J has not been adequately characterized. 

Basis for Conclusion: Studies conducted by Ref. 44 give three different methods for determining 

the BCF value for both rainbow trout and fathead minnows. The first two methods used were Biofac 

and initial rate. Biofac is a computer program that requires constant water concentration for its 

calculations. The “initial rate” method assumes that the rate of uptake of Proprietary J from water 

is much greater than the rate of clearance during the initial exposure period. The static test method 

yields equilibrium BCFs if the fish exposure continues until a maximum concentration is observed. 

The maximum concentration was not reached in rainbow trout, so the BCFs may be underestimated. 

Although the maximum concentrations appeared to have been reached in fathead minnows, further 

studies conducted by Ref. 46 show the BCF value for fathead minnows measured using the static 

test method may be very different to those measured previously (Ref. 44) using this same method. 

Given that none of these tests were conducted according to EPA or OECD guidelines, and that the 

results vary widely, this endpoint is not adequately characterized by the available experimental data. 

Reference Species BCF 

Key Design Parameters 

Comments 

Exp. 

type 

Range 

(ppb) 

Study 

length T (/C) 

Ref. 44 Rainbow 

trout 

1096 Static 1.8-55 1-24 

hours 

10 The calculation of BCF 

from this method comes 

from the following 

equation: 

k1=[CFish(max)k2]/[A 

exp(-Btmax)] and is 

based on the total 14C. 

Ref. 44 Rainbow 

trout 

1335 Biofac 1.8-55 1-24 

hours 

10 k1 and k2 values were 

estimated by use of this 

nonlinear regression 

program. In these 

calculations, the initial 

exposure concentration (0 

hr) was used. 

Ref. 44 Rainbow 

trout 

2298 Initial 

rate 

1.8-55 1-24 

hours 

10 The calculation of BCF 

from this method comes 

from the following 

equation: 

k1=()CFish/)t)Cw 

13-28
Reference Species BCF 

Key Design Parameters 

Comments 

Exp. 

type 

Range 

(ppb) 

Study 

length T (/C) 

Ref. 44 Fathead 

minnow 

498 Biofac 0.8-36.5 1-24 

hours 

10 k1 and k2 values were 

estimated by use of this 

nonlinear regression 

program. In these 

calculations, the initial 

exposure concentration (0 

hours) was used. 

Ref. 44 Fathead 

minnow 

785 Static 0.8-36.5 1-24 

hours 

10 The calculation of BCF 

from this method comes 

from the following 

equation: 

k1=[CFish(max)k2]/[A 

exp(-Btmax)] 

Ref. 44 Fathead 

minnow 

3316 Initial 

rate 

0.8-36.5 1-24 

hours 

10 The calculation of BCF 

from this method comes 

from the following 

equation: 

k1=()CFish/)t)Cw 

Ref. 45 Rainbow 

trout 

1096 Static 5-50 24 hours Ref. 45 takes this value 

from Ref. 44. 

Ref. 45 Fathead 

minnow 

785 Static 5-50 24 hours Ref. 45 takes this value 

from Ref. 44. 

Ref. 46 Fathead 

minnow 

528 50 8 hours 

Ref. 4 Estimated 4400 The value is estimated 

from measured values of 

Log Kow from Ref. 49 and 

Ref. 41 using the 

equation in Ref. 5). 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

13-29
Degradation and Transport 

Photolysis in the Atmosphere: No data 

Photolysis in Water: 

Conclusion: This endpoint has been adequately characterized.

Basis for Conclusion: The products from the photolysis of Proprietary J in water as determined by

GC/MS have been summarized (Ref. 13). The products are [Chemical 9] and [Chemical 10].

Photolysis in Soil: No data 

Aerobic Biodegradation: 

Conclusion: The biodegradation of Proprietary J under aerobic conditions has not been adequately 

characterized. 

Basis for Conclusion: Several different types of studies have been carried out and the weight of 

evidence indicates that Proprietary J is likely to biodegrade under aerobic conditions. Only the 

studies by Ref. 23 differ greatly from those in other literature sources, which is likely a result of the 

water/sediment innoculum used. 

Study type/ 

Method Innoculum Acclim Degradation Time Comments Reference 

ThompsonDuthie-Sturm 

Procedure 

Activated 

sludge 

90% as CO2 

Evolution 

28 days Ref. 43 

Monsanto Activated 43% as CO2 28 days Ref. 43 

Shake Flask sludge Evolution 

Procedure 

River Dieaway 4 days 50% 11 days The initial 

concentration 

was 1 ppm; after 

4 days, 50% 

primary 

degradation 

occurred. 

Ref. 43, 49 

Simulated 

Biological 

Treatment/ 

SCAS 

Activated 

sludge 

93+ 

84+/-3 

9 weeks 

8 weeks 

3 mg/L/24 hours 

13 mg/L/24 

hours 

Ref. 13, 49 

Activated 

sludge 

24-hour 

cycle 

>93 

84+/-3 

1 day 3 ppm/cycle 

13ppm/cycle 

Ref. 43 

13-30
Study type/ 

Method Innoculum Acclim Degradation Time Comments Reference 

SCAS and 

RDA 

Analytical 

Method 

(Method AC72-M-S) 

Activated 

sludge with 

domestic 

sewage feed 

75.9% 

recovery 

24 hours Mixed liquor 

extraction 

Ref. 43 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

Sediment/Water Biodegradation: 

Conclusion: The biodegradation of Proprietary J in the presence of pond and/or river sediment has 

been adequately characterized. 

Basis for Conclusion: Biodegradation of Proprietary J has been studied under a variety of 

conditions and temperatures in the presence of both river and pond sediment. The weight of 

evidence indicates the potential for Proprietary J to degrade under these environmental conditions. 

Sediment Temp. T1/2 Comments Reference 

Pond water 25 0.44 

days 

Time interval was 0-3 days. Ref. 46 

Pond sediment 25 39 Static conditions. Sediment was collected from 

a pond made specifically for this experiment at 

Glenlea Research Station, University of 

Manitoba. 

Initial Proprietary J concentration 0.10 :g/mL. 

Sediment:water ratio 1:10. 

Time interval was 2-105 days. 

Ref. 46 

Pond sediment 25 4.2 Time interval was 0-6 days. Ref. 47 

Pond sediment 10 5.5 Time interval was 0-6 days. Ref. 47 

Sedimentwater 

microcosms 

39% (0.1 mg concentration), 

18% (1 mg concentration), and 

5% (10 mg concentration) mineralization after 

8 weeks with innoculum from Lake Chicot, AR 

after 1 week of lag time. 

Ref. 23 

13-31
Sediment Temp. T1/2 Comments Reference 

Sedimentwater 

microcosms 

14% (0.1 mg concentration), 

8% (1 mg concentration), and 

2% (10 mg concentration) mineralization after 

8 weeks with innoculum from Little Dixie 

Reservoir, MO after 1 week of lag time. 

Ref. 23 

Sedimentwater 

microcosms 

12.5% (0.1 mg concentration and 10 mg 

concentration) mineralization after 8 weeks 

with innoculum from Redfish Bay, TX. 

Ref. 23 

Sedimentwater 

microcosms 

1.9% (0.1 mg concentration) and 

1.8% (10 mg concentration) mineralization 

after 8 weeks with innoculum DeGray 

Reservior, AR. 

Ref. 23 

Sedimentwater 

microcosms 

9.9% (0.1 mg concentration) and 

6% (10 mg concentration) mineralization after 

8 weeks with innoculum Arkansas River, AR. 

Ref. 23 

Pond sediment 5 16.1 Time interval was 0-6 days. Ref. 47 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: 

Conclusion: The Koc has not been adequately characterized.

Basis for Conclusion: In both literature reports (Ref. 45 and Ref. 4), the values obtained for the Koc

are calculated. No experimental values for this endpoint were located.

Koc Source Reference 

14600 Calculated from Kow using the 

Kenaga and Goring equation 

Ref. 45 

2300 Calculated from water solubility 

using the Kenaga and Goring 

equation 

Ref. 4 

13-32
Flame Retardant Alternatives

Proprietary K: Aryl phosphate

Hazard Review

14-1
Proprietary K: Aryl phosphate

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral 

Dermal 

Inhalation 

Eye irritation 

Dermal irritation 

Skin sensitization 

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro 

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other 

14-2
Proprietary K: Aryl phosphate

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 

Daphnia acute 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

14-3
Chemical Identity 

Proprietary K: Aryl phosphate 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Conclusion: 

No available acute toxicity data.

Basis for Conclusion:

No acute toxicity studies were located that addressed the endpoints in the guidelines listed below.

• Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 

420, 423, 401) 

• Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 

402) 

• Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 

403) 

• Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

• Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 

404) 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion: 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

14-4
SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines 

listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

14-5
• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the developmental toxicity endpoints in the

guidelines listed below.

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines

listed below.

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

14-6
Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No neurotoxicity studies were located that addressed the endpoints in the guidelines listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No immunotoxicity studies were located that addressed the endpoints in the guidelines listed below.

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

14-7
GENOTOXICITY 

Conclusion: 

No available genotoxicity data.

Basis for Conclusion:

No genotoxicity studies relevant to the below categories or to other types of genotoxic effects were

located.

Gene Mutation in Vitro 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

14-8
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

No available acute toxicity data for fish, aquatic invertebrates, and algae. 

Basis for Conclusion: 

No pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

14-9
Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

14-10
Physical/Chemical Properties 

Proprietary K: Aryl phosphate 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

14-11
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: No data 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

14-12
Flame Retardant Alternatives

Proprietary L: Aryl phosphate

Hazard Review

15-1
Proprietary L: Aryl phosphate

Existing Data Summary Table – Human Health Endpoints

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

Acute Toxicity 

Oral 

Dermal 

Inhalation 

Eye irritation 

Dermal irritation 

Skin sensitization 

Subchronic Toxicity 

28-Day oral 

90-Day oral 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

21/28-Day dermal 

90-Day dermal 

90-Day inhalation 

Reproductive 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Reproduction and 

fertility effects

 Developmental 

Toxicity 

Reproduction/ 

developmental toxicity 

screen 

Combined repeated 

dose with reproduction/ 

developmental toxicity 

screen 

Prenatal developmental 

Chronic Toxicity 

Chronic toxicity (two 

species) 

Combined chronic 

toxicity/ 

carcinogenicity 

Carcinogenicity 

Carcinogenicity (rat 

and mouse) 

Combined chronic 

toxicity/ 

carcinogenicity 

Neurotoxicity 

Acute and 28-day 

delayed neurotoxicity 

of organophosphorus 

substances (hen) 

Neurotoxicity 

screening battery 

(adult) 

Developmental 

neurotoxicity 

Additional 

neurotoxicity studies 

Immunotoxicity 

Immunotoxicity 

Genotoxicity 

Gene mutation in vitro 

Gene mutation in vivo 

Chromosomal 

aberrations in vitro 

Chromosomal 

aberrations in vivo 

DNA damage and 

repair 

Other 

15-2
Proprietary L: Aryl phosphate

Existing Data Summary Table – Properties, Fate, and Ecotoxicity

T= Endpoint characterized by existing data * = Data available but not adequate Y = Endpoint not applicable 

As noted in this key, a check mark indicates that an endpoint was adequately characterized by existing studies. It does 

not indicate a positive or negative result for that particular endpoint. 

P/Chem Properties 

Water solubility 

Octanol/water partition 

coefficient 

Oxidation/reduction 

Melting point 

Boiling point 

Vapor pressure 

Odor 

Oxidation/reduction 

chemical 

incompatibility 

Flammability 

Explosivity 

Corrosion 

characteristics 

pH 

UV/visible absorption 

Viscosity 

Density/relative 

density/bulk density 

Dissociation constant in 

water 

Henry’s Law constant 

Environmental Fate 

Bioconcentration 

Fish 

Daphnids 

Green algae 

Oysters 

Earthworms 

Metabolism in fish 

Degradation and 

Transport 

Photolysis, atmosphere 

Photolysis, water 

Photolysis in soil 

Aerobic biodegradation 

Anaerobic 

biodegradation 

Porous pot test 

Pyrolysis 

Hydrolysis as a 

function of pH 

Sediment/water 

biodegradation 

Soil biodegradation w/ 

product identification 

Indirect photolysis in 

water 

Sediment/soil 

adsorption/desorption 

Ecotoxicity 

Aquatic Toxicity 

Fish acute LC50 

Daphnia acute 

EC50 

Mysid shrimp acute 

LC50 

Green algae EC50, 

NOAEC, LOAEC 

Fish chronic 

NOAEC, LOAEC 

Daphnia chronic 

NOAEC, LOAEC 

Mysid shrimp chronic 

NOAEC, LOAEC 

Terrestrial 

Organism Toxicity 

Bird LD50 (two 

species) 

Bird LC50 (two 

species) 

Bird reproduction 

Earthworm subchronic 

EC50, LC50, NOAEC, 

LOAEC 

15-3
Chemical Identity 

Proprietary L: Aryl phosphate 

Synonyms 

CAS 

MF 

MW 

SMILES 

Human Health Endpoints 

ACUTE TOXICITY 

Conclusion: 

No available acute toxicity data.

Basis for Conclusion:

No acute toxicity studies were located that addressed the endpoints in the guidelines listed below.

• Acute Oral Toxicity (OPPTS Harmonized Guideline 870.1100; OECD Guidelines 425, 

420, 423, 401) 

• Acute Dermal Toxicity (OPPTS Harmonized Guideline 870.1200; OECD Guideline 

402) 

• Acute Inhalation Toxicity (OPPTS Harmonized Guideline 870.1300 (OECD Guideline 

403) 

• Acute Eye Irritation (OPPTS Harmonized Guideline 870.2400; OECD Guideline 405) 

• Acute Dermal Irritation (OPPTS Harmonized Guideline 870.2500; OECD Guideline 

404) 

Skin Sensitization (OPPTS Harmonized Guideline 870.2600; OECD Guideline 429) 

Conclusion: 

The skin sensitization endpoint is not satisfied. 

Basis for Conclusion 

No studies were located that followed or were similar to the guideline listed above or otherwise 

addressed skin sensitization. 

15-4
SUBCHRONIC TOXICITY 

Conclusion: 

No available subchronic toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the subchronic toxicity endpoints in the guidelines 

listed below. 

Subchronic Oral Toxicity (28-day, 90-day, or combined with reproductive/developmental) 

• Repeated Dose 28-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 

870.3050; OECD Guideline 407) 

• 90-Day Oral Toxicity in Rodents (OPPTS Harmonized Guideline 870.3100; OECD 

Guideline 408), 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422), respectively. 

Subchronic Dermal Toxicity (21/28-day or 90-day). 

• 21/28-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3200 (OECD Guideline 

410) 

• 90-Day Dermal Toxicity (OPPTS Harmonized Guideline 870.3250; OECD Guideline 

411) 

Subchronic Inhalation Toxicity (90 day) 

• 90-Day Inhalation Toxicity (OPPTS Harmonized Guideline 870.3465; OECD Guideline 

413) 

REPRODUCTIVE TOXICITY 

Conclusion: 

No available reproductive toxicity data. 

Basis for Conclusion: 

No pertinent studies were located that addressed the reproductive toxicity endpoints in the guidelines 

listed below. 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

15-5
• Reproduction and Fertility Effects (OPPTS Harmonized Guideline 870.3800; OECD 

Guideline 416) 

DEVELOPMENTAL TOXICITY 

Conclusion: 

No available developmental toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the developmental toxicity endpoints in the

guidelines listed below.

• Prenatal Developmental Toxicity Study (OPPTS Harmonized Guideline 870.3700; 

OECD Guideline 414) 

• Combined Repeated Dose Toxicity Study with the Reproduction/Developmental 

Toxicity Screening Test (OPPTS Harmonized Guideline 870.3650; OECD Guideline 

422) 

• Reproduction/Developmental Toxicity Screening (OPPTS Harmonized Guideline 

870.3550; OECD Guideline 421) 

CHRONIC TOXICITY 

Conclusion: 

No available chronic toxicity data.

Basis for Conclusion:

No pertinent studies were located that addressed the chronic toxicity endpoints in the guidelines

listed below.

• Chronic Toxicity (OPPTS Harmonized Guideline 870.4100; OECD Guideline 452) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

CARCINOGENICITY 

Conclusion: 

No available carcinogenicity data. 

15-6
Basis for Conclusion: 

No pertinent studies were located that addressed the carcinogenicity endpoints in the guidelines 

listed below. 

• Carcinogenicity (OPPTS Harmonized Guideline 870.4200; OECD Guideline 451) 

• Combined Chronic Toxicity/Carcinogenicity (OPPTS Harmonized Guideline 870.4300; 

OECD Guideline 453) 

NEUROTOXICITY 

Conclusion: 

No available neurotoxicity data. 

Basis for Conclusion: 

No neurotoxicity studies were located that addressed the endpoints in the guidelines listed below. 

Delayed Neurotoxicity 

• Acute and 28-Day Delayed Neurotoxicity of Organophosphorus Substances (OPPTS 

Harmonized Guideline 870.6100; OECD Guideline 418, 419) 

Neurotoxicity (Adult) 

• Neurotoxicity Screening Battery (OPPTS Harmonized Guideline 870.6200; OECD 

Guideline 424) 

Developmental Neurotoxicity 

• Developmental Neurotoxicity: Developmental Neurotoxicity Study (OPPTS 

Harmonized Guideline 870.6300) 

IMMUNOTOXICITY 

Conclusion: 

No available immunotoxicity data.

Basis for Conclusion:

No immunotoxicity studies were located that addressed the endpoints in the guidelines listed below.

• Immunotoxicity (OPPTS Harmonized Guideline 870.7800) 

15-7
GENOTOXICITY 

Conclusion: 

No available genotoxicity data.

Basis for Conclusion:

No genotoxicity studies relevant to the below categories or to other types of genotoxic effects were

located.

Gene Mutation in Vitro 

Gene Mutation in Vivo 

Chromosomal Aberrations in Vitro 

Chromosomal Aberrations in Vivo 

DNA Damage and Repair 

15-8
Ecotoxicity 

Acute Toxicity to Aquatic Organisms 

Conclusion: 

No available acute toxicity data for fish, aquatic invertebrates, and algae. 

Basis for Conclusion: 

No pertinent acute toxicity studies with fish, aquatic invertebrates, or algae were located that 

addressed the endpoints in the guidelines listed below. 

• Acute Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1075; OECD Guideline 203) 

• Acute Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 850.1010; 

OECD Guideline 202) 

• Acute Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1035) 

• Algal Toxicity (OPPTS Harmonized Guideline 850.5400; OECD Guideline 201) 

Chronic Toxicity to Aquatic Organisms 

Conclusion: 

No available chronic toxicity data for fish and aquatic invertebrates. 

Basis for Conclusion: 

No pertinent chronic toxicity studies with fish or aquatic invertebrates were located that addressed 

the endpoints in the guidelines listed below. 

• Chronic Toxicity to Freshwater and Marine Fish (OPPTS Harmonized Guideline 

850.1400; OECD Guideline 210) 

• Chronic Toxicity to Freshwater Invertebrates (OPPTS Harmonized Guideline 

850.1300; OECD Guideline 211) 

• Chronic Toxicity to Marine/Estuarine Invertebrates (OPPTS Harmonized Guideline 

850.1350) 

15-9
Acute and Subchronic Toxicity to Terrestrial Organisms 

Conclusion: 

No available acute and subchronic toxicity data for terrestrial organisms. 

Basis for Conclusion: 

No pertinent acute oral, acute dietary, or reproductive toxicity studies with birds and no subchronic 

toxicity studies with earthworms were located that addressed the endpoints in the guidelines listed 

below. 

• Acute Oral Toxicity in Birds (OPPTS Harmonized Guideline 850.2100) 

• Acute Dietary Toxicity in Birds (OPPTS Harmonized Guideline 850.2200; OECD 

Guideline 205) 

• Reproductive Toxicity in Birds (OPPTS Harmonized Guideline 850.2300; OECD 

Guideline 206) 

• Earthworm Subchronic Toxicity (OPPTS Harmonized Guideline 850.6200; OECD 

Guideline 207) 

15-10
Physical/Chemical Properties 

Proprietary L: Aryl phosphate 

CAS 

MF 

MW 

SMILES 

Water Solubility (mg/L): No data 

Log Kow: No data 

Oxidation/Reduction: No data 

Melting Point: No data 

Vapor Pressure (torr): No data 

Odor: No data 

Oxidation/Reduction Chemical Incompatibility: No data 

Flammability: No data 

Explosivity: No data 

Corrosion Characteristics: No data 

pH: No data 

UV/VIS Absorption: No data 

Viscosity: No data 

Density/Relative Density/Bulk Density: No data 

Dissociation Constant in Water: No data 

Henry’s Law Constant: No data 

15-11
Environmental Fate 

Bioconcentration 

Fish: No data 

Daphnids: No data 

Green Algae: No data 

Oysters: No data 

Earthworms: No data 

Fish Metabolism: No data 

Degradation 

Photolysis in the Atmosphere: No data 

Photolysis in Water: No data 

Photolysis in Soil: No data 

Aerobic Biodegradation: No data 

Anaerobic Biodegradation: No data 

Porous Pot Test: No data 

Pyrolysis: No data 

Hydrolysis as a Function of pH: No data 

Sediment/Water Biodegradation: No data 

Soil Biodegradation with Product Identification: No data 

Indirect Photolysis in Water: No data 

Sediment/Soil Adsorption/Desorption: No data 

15-12
Disclaimer 

This document has not been through a formal external peer review process and does not 

necessarily reflect all of the most recent policies of the U.S. Environmental Protection Agency 

(EPA), in particular those now under development. The use of specific trade names or the 

identification of specific products or processes in this document are not intended to represent an 

endorsement by EPA or the U.S. Government. Discussion of environmental statutes is intended 

for information purposes only; this is not an official guidance document and should not be relied 

upon to determine applicable regulatory requirements. 

For More Information 

To learn more about the Design for the Environment (DfE) Furniture Flame Retardancy 

Partnership or the DfE Program, please visit the DfE Program web site at: www.epa.gov/dfe 

To obtain copies of DfE Program technical reports, pollution prevention case studies, and project 

summaries, please contact: 

National Service Center for Environmental Publications 

U.S. Environmental Protection Agency 

P.O. Box 42419 

Cincinnati, OH 45242 

Phone: (513) 489-8190, (800) 490-9198 

Fax: (513) 489-8695 

E-mail: ncepimal@one.net 

Acknowledgments 

This alternatives assessment was prepared by Eastern Research Group and Syracuse Research 

Corporation under funding from the U.S. Environmental Protection Agency’s Design for the 

Environment (DfE) Program in the Economics, Exposure, and Technology Division (EETD) of 

the Office of Pollution Prevention and Toxics (OPPT) and Region IX. 

This document was produced as part of the DfE Furniture Flame Retardancy Partnership, under 

the direction of the project’s steering committee. Special thanks to the Risk Assessment Division 

of OPPT, for their assistance in evaluating the chemicals in the report. Many thanks also to all 

the stakeholders who participated in the technical workgroups and who provided valuable input 

for the report. 
United States


Environmental Protection Agency


Design for the Environment (7406M)


EPA 742-R-05-002B


September 2005


www.epa.gov/dfe