Furniture Flame Retardancy Partnership: 

Environmental Profiles of Chemical Flame-Retardant 

Alternatives for Low-Density Polyurethane Foam 

Volume 1 

September 2005
EXECUTIVE SUMMARY 

Issue 

Efforts to improve the fire safety of furniture protect property and save lives. Fires involving 

ignition of residential upholstered furniture constitute a leading cause of fire deaths and serious 

injuries associated with consumer products. According to the Consumer Product Safety 

Commission staff, the average annual fire losses for the years 1995-1999 were 460 deaths, 1,110 

injuries and $130 million in property damage (CPSC, 2004). Flame retardants delay ignition and 

have proven to save lives. While benefits achieved through enhanced fire safety are critical, they 

should be achieved in a manner that minimizes risk to human health and the environment. The 

work summarized in this report arose from concern over potential human health and 

environmental impacts from the use of pentabromodiphenyl ether (pentaBDE). This chemical 

flame retardant has been used in the manufacture of low-density, flexible polyurethane foam for 

upholstered furniture (residential, business and institutional), mattresses, bedding, carpet 

underlay and other articles. Studies around the world have found pentaBDE to be widespread in 

the environment and in human tissues. Recently the use of pentaBDE has been banned in the 

European Union, and legislation has been passed to restrict its use in Hawaii and California in 

2006 (January 1 and June 1, respectively). 

In late 2003, Great Lakes Chemical Corporation, the sole U.S. manufacturer of the commercial 

mixture known as pentaBDE, announced a voluntary phase-out of this chemical in the United 

States by December 31, 2004. This phase-out, along with anticipated implementation of more 

stringent national fire safety standards in residential upholstered furniture, has made finding 

alternatives to pentaBDE a critical priority for the furniture industry and all parties involved. 

Partnership and Scope 

EPA’s Design for the Environment Program and Region IX have joined with a broad set of 

stakeholders to form the Furniture Flame Retardancy Partnership. Key players involved in the 

Partnership include members of the furniture industry, chemical manufacturers, environmental 

groups, fire safety advocates, the Consumer Product Safety Commission and the National 

Institute of Standards and Technology. 

The Partnership is working to identify and assess environmentally safer chemical alternatives to 

pentaBDE and to investigate other technologies for improving furniture fire safety. The primary 

purpose of this report is to provide up-to-date and objective information that will allow the 

furniture industry and chemical manufacturers to factor human health and environmental 

considerations into decision-making when identifying replacements for pentaBDE. The hazard, 

exposure and environmental assessment of chemical flame-retardant alternatives in this report is 

intended to be a first step in providing information that will serve as a basis for making 

decisions. Additional objectives of this report are to inform the reader of some considerations to 

take into account when selecting a replacement for pentaBDE and to introduce alternative 

technologies that may impact future methods of flame-retarding furniture. 

The Partnership recognizes that no single alternative is expected to provide an ideal solution to 

address every issue. Rather, the project members hope to provide the best available information 

on the human health and environmental attributes of the leading chemical alternatives to 

pentaBDE so that individual companies and consumers can make educated decisions that will 

i 
best suit their needs. Some information on alternative technologies, e.g. barrier fabrics, for 

flame-retarding furniture is provided, but not extensively discussed in this report. 

Results 

This report is the first product of the Furniture Flame Retardancy Partnership. To provide 

information for decision-making, the Partnership evaluated the leading chemical alternatives for 

flame retarding low-density flexible polyurethane foam. Leading U.S. flame-retardant chemical 

manufacturers identified 14 chemical formulations that are potentially viable substitutes for 

pentaBDE in large-scale production of low-density flexible polyurethane foam. EPA assessed the 

hazards, potential exposures and tendency to bioaccumulate and persist in the environment for 

the chemicals in each formulation. Section 4 of this report is a summary of EPA’s qualitative 

assessment, which is based on known or estimated effects on various toxicological and 

environmental endpoints. This section includes a summary chart (Table 4-1) with information on 

potential routes of exposure, based on physical and chemical properties. Section 4 also includes 

an explanation of how the information in the chart was developed. 

Conclusions 

This report summarizes the level of potential hazard associated with relevant endpoints for the 

chemical formulations. Table 4-1 provides the best available information for making educated 

decisions about these alternative chemical products. 

The Partnership plans to develop and implement a process to identify additional toxicological 

data needed for adequately assessing the flame-retardant alternatives in Table 4-1. Industry will 

support this process and develop data to satisfy these needs over time for endpoints that have a 

moderate or high level of concern. Those flame-retardant products that emerge as the most 

popular replacement products for pentaBDE deserve this greater level of scrutiny based on their 

potential for exposure to humans and the environment during manufacture, use and disposal. The 

stakeholders in this Partnership will use the data summarized in Table 4-1 to affirm short-term 

decisions. EPA has developed this alternatives assessment to serve as a model for addressing 

emerging chemical concerns. 

Next Steps 

In the future, the Partnership intends to evaluate additional chemical flame retardants and other 

materials that may be necessary to meet planned national fire safety standards. The Partnership 

would also like to develop a furniture design challenge to encourage the safest means (new 

designs, chemicals and materials) to meet furniture fire safety standards. Finally, the Partnership 

would like to stimulate innovation by providing EPA recognition for next-generation, safer 

chemical flame retardants and safer non-chemical technologies. 

Updated information on the Furniture Flame Retardancy Partnership will be available on EPA’s 

Design for the Environment website: http://www.epa.gov/dfe/projects/flameret/index.htm. 

ii 
TABLE OF CONTENTS 

Volume 1 

 Executive Summary ........................................................................................................... i 
 

List of Acronyms................................................................................................................v 
 

About the Partnership...................................................................................................... vii
 

1.0 Introduction .................................................................................................................... 1-1 
 

1.1 Purpose of the PentaBDE Alternatives Analysis .................................................. 1-1 
 

1.2 Scope of the PentaBDE Alternatives Analysis......................................................1-3 
 

2.0 Types of Chemical Flame Retardants ............................................................................ 2-1 
 

2.1 General Characteristics of Chemical Flame Retardants........................................ 2-1 
 

2.1.1 General Mechanisms of Flame Retardancy ............................................2-1 
 

2.1.2 Additive and Reactive Flame Retardants................................................2-2 
 

2.1.3 Flame-Retardant Synergists....................................................................2-3 
 

2.2 Flame-Retardant Chemicals Currently Used in Foam .......................................... 2-4 
 

3.0 Exposure to Flame-Retardant Chemicals in Foam......................................................... 3-1 
 

3.1 Exposure Pathways and Routes (General) ............................................................ 3-1 
 

3.2 Industrial Releases and Exposures ........................................................................ 3-3 
 

3.2.1 Chemical Manufacturing ........................................................................3-5 
 

3.2.2 Foam Manufacturing...............................................................................3-7 
 

3.2.3 Furniture Manufacturing.......................................................................3-10 
 

3.3 Consumer and General Population Exposures .................................................... 3-12 
 

3.3.1 Physical and Chemical Properties Affecting Exposure ........................3-12 
 

3.3.2 Consumer Use and End-of-Life Analysis.............................................3-15 
 

4.0 Flame-Retardant Alternatives Evaluations..................................................................... 4-1 
 

4.1 Summary of Flame-Retardant Chemical Alternatives .......................................... 4-1 
 

4.1.1 Explanation of Toxicological and Environmental Endpoints Rating .....4-5 
 

4.1.2 Explanation of Exposure Route Rating...................................................4-9 
 

4.2 Chemical Summary Assessments........................................................................ 4-12 
 

4.2.1 Triphenyl Phosphate .............................................................................4-12 
 

4.2.2 Tribromoneopentyl alcohol...................................................................4-16 
 

4.2.3 Tris(1,3-dichloro-2-propyl) Phosphate .................................................4-20 
 

4.2.4 Proprietary A.........................................................................................4-25 
 

4.2.5 Proprietary B.........................................................................................4-30 
 

4.2.6 Proprietary C.........................................................................................4-35 
 

4.2.7 Proprietary D.........................................................................................4-40 
 

4.2.8 Proprietary E .........................................................................................4-44 
 

4.2.9 Proprietary F .........................................................................................4-48 
 

4.2.10 Proprietary G.........................................................................................4-52 
 

4.2.11 Proprietary H.........................................................................................4-57 
 

4.2.12 Proprietary I ..........................................................................................4-61 
 

4.2.13 Proprietary J..........................................................................................4-65 
 

4.2.14 Proprietary K.........................................................................................4-69 
 

4.2.15 Proprietary L .........................................................................................4-73 
 

5.0 Considerations for Selecting a Replacement for PentaBDE .......................................... 5-1 
 

5.1 Positive Environmental Attributes ........................................................................ 5-1 
 

iii 
5.2 Aesthetic and Performance Considerations........................................................... 5-3 
 

5.3 Process and Equipment Considerations ................................................................ 5-3 
 

5.4 Economic Viability................................................................................................ 5-4 
 

5.5 Alternatives Technologies (General).....................................................................5-4 
 

5.5.1 Barrier Technologies...............................................................................5-4 
 

5.5.2 Graphite Impregnated Foams..................................................................5-6 
 

5.5.3 Surface Treatments .................................................................................5-6 
 

5.6 Methods for Selecting Chemical Flame Retardants .............................................. 5-6 
 

6.0 References ...................................................................................................................... 6-1 
 

Appendix A PentaBDE Facts 

Appendix B Interpretive Guidance 

Appendix C Chemical Regulations List 

Volume 2 Chemical Hazard Reviews http://www.epa.gov/dfe/projects/flameret/index.htm 

LIST OF TABLES 

Table 1-1 Potential Flame-Retardant Chemical Formulations............................................. 1-4 
 

Table 4-1 Screening Level Toxicology and Exposure Summary......................................... 4-2 
 

Table 4-2 Definitions of Toxicological and Environmental Endpoints ............................... 4-5 
 

Table 4-3 Criteria Used to Assign Concern Levels.............................................................. 4-6
 

Table 4-4 Information for Estimating Half-Life .................................................................. 4-6 
 

LIST OF FIGURES 

Figure 1-1 Pentabromodiphenyl Ether (pentaBDE), Where m+n = 5................................... 1-2 
 

Figure 3-1 Simplified Life Cycle for a Flame-Retardant Chemical ...................................... 3-2 
 

Figure 3-2 Generic Chemical Manufacturing Process Flow Diagram .................................. 3-6 
 

Figure 3-3 Typical Slabstock Foam Production for Flexible Polyurethane Foam ................ 3-8 
 

Figure 3-4 Typical Molded Foam Production Line for Flexible Polyurethane Foam........... 3-9 
 

Figure 3-5 Process Flow Diagram: Furniture Manufacturing ............................................. 3-11 
 

iv 
LIST OF ACRONYMS 

ADDpot Potential Average Daily Dose 

ADRpot Potential Acute Dose Rate 

AFMA American Furniture Manufacturers Association 

AFSC American Fire Safety Council 

AHFA American Home Furnishings Alliance 

APP Ammonium Polyphosphate 

ATSDR Agency for Toxic Substances and Disease Registry 

BCF Bioconcentration Factor 

BIFMA The Business and Institutional Furniture Manufacturer’s Association 

BFR Brominated Flame Retardant 

CBI Confidential Business Information 

ChV Chronic Value 

CCRIS Chemical Carcinogenesis Research Information System 

CIS Chemical Information Systems 

COC Concentration of Concern 

CPA Clean Production Action 

CPSC Consumer Product Safety Commission 

DART Developmental and Reproductive Toxicology 

DecaBDE Decabromodiphenyl Ether 

DfE Design for the Environment 

ECDB Existing Chemicals Database 

ECOSAR Ecological Structure Activity Relationships 

EFED Environmental Fate and Effects Division 

ELISA Enzyme-Linked Immunosorbent Assay 

EMIC Environmental Mutagen Information Center 

EPA Environmental Protection Agency 

EPIWIN Estimations Program Interface for Windows 

ETIC Environmental Teratology Information Center 

EU European Union 

FDA Food and Drug Administration 

GIF Graphite Impregnated Foam 

HLC Henry’s Law Constant 

HMTC Hazardous Materials Technical Center 

HPV High Production Volume Chemicals 

HSDB Hazardous Substances Data Bank 

IARC International Agency for Research on Cancer 

IRIS Integrated Risk Information System 

KI Krueger International, Inc. 

Koc Soil Adsorption Coefficient 

Kow Octanol-Water Partition Coefficient 

LADDpot Lifetime Average Daily Dose 

LOAEC Lowest Observable Adverse Effect Concentration 

LOAEL Lowest-Observed Adverse-Effect-Level 

MA TURI Massachusetts Toxics Use Reduction 

MDI Methyl Diphenyl Diisocyanate 

MOE Margin of Exposure 

v 
NIOSH National Institute for Occupational Safety and Health 

NIST National Institute of Standards and Technology 

NOAEC No Observable Adverse Effect Concentration 

NOAEL No-Observed Adverse-Effect-Level 

NTE Neurotoxic Esterase 

NTP National Toxicology Program 

OctaBDE Octabromodiphenyl Ether 

OECD Organization for Economic Cooperation and Development 

OPPT Office of Pollution Prevention and Toxics 

PBDE Polybrominated Diphenyl Ether 

PEC Predicted Environmental Concentration 

PentaBDE Pentabromodiphenyl Ether 

PESTAB Pesticides Abstracts 

PFC Plaque-Forming Cell 

PPBIB Poisonous Plants Bibliography 

SIC Standard Industrial Classification 

SNUR Significant New Use Rule 

SWC Surface Water Concentration 

TCPP Tris (2-chloroisopropyl) Phosphate 

TDCPP Tris (1,3-dichloro-2-propyl) Phosphate 

TDI Toluene Diisocyanate 

TSCA Toxic Substances Control Act 

TSCATS Toxic Substances Control Act Test Submissions 

UFAC Upholstered Furniture Action Council 

USGS U.S. Geological Survey 

VCCEP Voluntary Children's Chemical Evaluation Program 

vi 
ABOUT THE PARTNERSHIP 
 

U.S. EPA’s Design for the Environment (DfE) Program is a results-oriented voluntary 

partnership program. It achieves risk reduction through pollution prevention and applying 

Agency expertise and technical tools. 

Designing for the environment is incorporating environmental considerations into business 

decision making. The EPA DfE Program collaborates with industry sectors to help businesses 

design or redesign products, processes and management systems that are cleaner, more costeffective and safer for the worker and the public. 

The Furniture Flame Retardancy Partnership is a joint effort among the U.S. EPA DfE Program, 

U.S. EPA Region IX, all segments of the furniture industry supply chain, government and nongovernment groups to identify environmentally safer solutions for meeting current and future 

furniture fire safety requirements. 

Steering Committee Members: 

American Home Furnishings Alliance (AHFA) (formerly AFMA) 
 

“AHFA understands and supports the long range nature of this project and encourages 

EPA to remain engaged with private sector stakeholders to develop environmentally sound 
 

solutions to fire safety." 
 

Business and Institutional Furniture Manufacturer’s Association (BIFMA) 

International 

"BIFMA is committed to promoting sustainable work environments and business practices 

based on sound economics, environmental protection, and social responsibility." 

American Fire Safety Council (AFSC) 

"AFSC is committed to improving fire safety standards and saving lives...We expect this 

partnership to lead to the implementation of safe and environmentally sound approaches 

to fire safety." 

GreenBlue 

"GreenBlue is attracted to this partnership because of the rare opportunity to 

reconceive design criteria for flame-retardant products." 

vii 
Partners:
 

FURNITURE MANUFACTURERS 

American Home Furnishings Alliance 

(AHFA) (formerly AFMA) 

Business and Institutional Furniture 

Manufacturer’s Association (BIFMA) 

International 

Berkline/Benchcraft 

Brayton International 

Herman Miller 

HNI Corporation (formerly Hon 

Industries) 

Krueger International, Inc. (KI) 

Steelcase 

FABRIC/BARRIER MANUFACTURERS 

Craftex Mills 

Culp 

Felters 

Glen Raven 

Microfibres 

National Textile Association 

Quaker 

CHEMICAL MANUFACTURERS 

American Fire Safety Council (AFSC) 

Albemarle Corporation 

Ameribrom, Inc. (ICL Industrial 

Products) 

Great Lakes Chemical Corporation 

Para Chem 

Supresta (formerly Akzo Nobel) 

NON-GOVERNMENTAL 

ORGANIZATIONS 

Clean Production Action (CPA) 
 

GreenBlue 
 

Massachusetts Toxics Use Reduction 
 

Institute (MA TURI) 
 

GOVERNMENTAL ORGANIZATIONS: 

U.S. Environmental Protection Agency (EPA) – Design for the Environment Program
 

Consumer Product Safety Commission (CPSC) 
 

National Institute of Standards and Technology (NIST) - Building and Fire Research Laboratory 
 

viii 
1.0 INTRODUCTION 

This volume contains the purpose and scope of the assessment, a description of the general 

characteristics of flame retardants, a general overview of exposure pathways and routes for flame 

retardants used in flexible polyurethane foam and the results of the assessments of 14 

formulations of flame-retardant products most likely to replace commercially available 

pentabromodiphenyl ether (pentaBDE). 

A second volume, subtitled, “Chemical Hazard Reviews,” consists of the complete data sets for 

each of the chemicals of the 14 formulations of flame-retardant products evaluated in this study. 

Volume 2 is available under a separate cover at 

http://www.epa.gov/dfe/projects/flameret/index.htm. 

1.1 Purpose of the PentaBDE Alternatives Analysis 

A significant quantity of the residential upholstered furniture sold in the United States contains 

low-density, flexible polyurethane foam. Without some form of fire protection, the foam is 

highly flammable. To address this safety issue, mandatory flammability standards and 

regulations have been enacted for residential upholstered furniture in California. California, 

Illinois, and Ohio have flammability standards for commercial furniture as well. The Upholstered 

Furniture Action Council (UFAC), an all-industry group, has also implemented voluntary 

standards for resistance to ignition from smoldering cigarettes. Most foam and furniture 

flammability standards and regulations (domestic and foreign) are performance based and do not 

specify particular chemicals or methods to achieve flame retardancy. Therefore, chemicals are 

not specifically required; rather, any method (chemical or product design) that achieves the 

standard is acceptable. Historically, halogenated flame-retardant chemicals, both brominated and 

chlorinated, have been used as a cost-effective method to meet standards without compromising 

product quality. 

Polybrominated diphenyl ethers (PBDEs) make up a category of structurally similar chemical 

flame retardants, which are used in a variety of applications. The application of the individual 

PBDE varies according to the number and location of bromine atoms attached to the diphenyl 

ether. There are ten possible sites for bromine to bind, decabromodiphenyl ether representing full 

saturation. The structure for pentaBDE contains five bromine atoms (C12H5Br5O). The bromine 

atoms can be bound to any of the carbon atoms, resulting in several possible isomers of 

pentaBDE (some of which are much more chemically stable than others). Figure 1-1 shows a 

generic figure for all PBDEs, where “m” and “n” refer to the number of bromine atoms bound to 

each aromatic ring. If m + n = 5, the resulting structure is a pentaBDE isomer. 

Commercially available pentaBDE is actually a mixture of PBDE congeners where the primary 

component is pentaBDE. The remaining congeners typically include triBDE (0 to 1 percent), 

tetraBDE (24 to 38 percent), and hexaBDE (4 to 12 percent) (European Chemicals Bureau, 

2001). For these congeners, m + n = 3, 4, and 6 respectively. Unless otherwise noted, all 

references in this report refer to the commercial pentaBDE mixture rather than the pure 

pentaBDE chemical. 

1-1
 
O 

Brn Brm 

Figure 1-1 Pentabromodiphenyl Ether (pentaBDE), where m+n = 5 

Brominated flame retardants (BFRs), such as pentaBDE, act by chemical interaction to prevent 

the spread of a fire. Combustion is typically propagated by a series of chemical reactions, where 

oxygen combines with chemicals in the burning product. BFRs interrupt some of these reactions 

by volatilizing halogen radicals to react with the product in place of oxygen, slowing 

combustion. 

PentaBDE has been the primary flame retardant for low-density, flexible polyurethane foam in 

residential furniture and mattresses for several years. About 8,500 metric tons (18.7 million 

pounds) of pentaBDE is used each year worldwide (Peltola and Ylä-Mononen, 2000) with 

approximately 98 percent of that being consumed in North America (Environ International 

Corp., 2003). Although pentaBDE saves lives by retarding fires, there is growing concern over 

the persistence and bioaccumulation of pentaBDE that may originate from foam manufactured 

with this chemical. Information on the presence of pentaBDE in the environment and biota, and 

its effects can be found in Appendix A of this report. More information on pentaBDE can be 

found in the Agency for Toxic Substances and Diseases Registry (ATSDR) Toxicological Profile 

for Polybrominated Biphenyls and Polybrominated Diphenyl Ethers (Update) (ATSDR, 2004) 

and the Voluntary Children’s Chemical Evaluation Program (VCCEP) Pentabromodiphenyl 

Ether Peer Consultation Meeting Report (TERA, 2004). 

The European Union (EU) banned the use and sale of pentaBDE as of August 2004. 

Subsequently, the sole U.S. manufacturer of pentaBDE voluntarily phased out its production on 

December 31, 2004. In addition to the voluntary phase-out, legislation has been passed to 

prohibit the manufacturing, processing, or sale of substances or articles containing more than 0.1 

percent by mass of pure pentaBDE in Hawaii and California in 2006 (January 1 and June 1, 

respectively). 

The phase-out of production presents the need for alternatives to pentaBDE that are 

environmentally safer, economically feasible, satisfy fire safety requirements and meet industry’s 

performance needs. In addition, the U.S. Consumer Product Safety Commission (CPSC) plans to 

implement new national fire safety standards regarding residential upholstered furniture that may 

lead to an increased need for flame-retardant furniture materials and an increased use of chemical 

flame retardants. The Furniture Flame Retardancy Partnership was formed as a result of this 

increased need to find practical alternatives that will suit the needs of all parties. 

1-2
 
1.2 Scope of the PentaBDE Alternatives Analysis 

Industry is actively exploring alternative methods to meet current and proposed fire safety 

standards. The Furniture Flame Retardancy Partnership is a project in which industry leaders 

have teamed with EPA and non-governmental environmental groups to evaluate each alternative 

based on human health, environmental, performance and cost considerations. The Furniture 

Flame Retardancy Partnership will identify the characteristics of the alternatives and anticipates 

that industry will choose flame retardants that perform well in each of these areas as full-scale 

replacements for pentaBDE. 

To date, the Furniture Flame Retardancy Partnership has evaluated available toxicological 

information for replacements for pentaBDE in low-density, flexible polyurethane foam. These 

are flame retardants that are viable options for meeting the performance requirements of 

California’s TB117 standard. This report includes information prepared for this short-term goal 

and presents it in a common format that will be directly useful to industry as replacement flame 

retardants are selected. 

The Furniture Flame Retardancy Partnership also has longer-term goals that are not included in 

this report. The next phase of this project will look at flame-retardant options for meeting the 

planned CPSC flammability standard for residential upholstered furniture. In the future, the 

Furniture Flame Retardancy Partnership intends to develop a process to identify additional 

toxicological data needed for adequately assessing the pentaBDE alternatives that attain a 

significant market share. This effort will help industry to develop a common level of 

toxicological information for such flexible foam flame retardants. The Partnership also intends to 

encourage development of safer flame retardants through high-level EPA recognition. 

Alternative flame retardants can be separated into two categories: alternative chemicals and 

alternative technologies. The ideal chemical alternative would be a drop-in replacement that has 

similar physical and chemical properties to pentaDBE formulations such that existing storage 

and transfer equipment as well as foam production equipment can be used without significant 

modification. Most pentaBDE formulations are liquid, so most U.S. foaming operations are 

currently equipped to use liquid streams in the production of foam. Any chemical substitute that 

is not a liquid or is extremely viscous will require most U.S. operations to alter existing 

equipment – at significant cost – to accommodate the new chemical. If the alternative is not 

compatible with existing process equipment at foam manufacturing facilities, the plants will be 

forced to modify their processes and potentially have to purchase new equipment. Holding cost 

and feasibility as significant considerations, this report has focused on evaluating several of these 

potential drop-in chemicals. 

Four chemical manufacturers have identified viable formulations for EPA review. These 

formulations are listed in Table 1-1. The chemicals in each formulation were screened for 

potential toxicological and environmental hazards as well as for potential exposure. A summary 

of the evaluations of this data is organized in Table 4-1 in Section 4. 

The data presented on the formulations provide a means for comparison and allow the reader to 

conduct a screening-level hazard evaluation for each chemical alternative. Chemical release 

points and associated exposure routes and pathways for flame-retardant chemical manufacturing 

1-3
 
facilities, foam manufacturing facilities and furniture manufacturing facilities are included in 

Section 3 of this report. 

Table 1-1 Potential Flame-Retardant Chemical Formulations 

Albemarle 

Corporation 

Ameribrom, Inc. (ICL 

Industrial Products) 

Great Lakes Chemical 

Corporation 

Supresta 

(Akzo Nobel) 

SAYTEX® RX-8500 FR 513 Firemaster® 550 Fyrol® FR-2 

SAYTEX® RZ-243 Firemaster® 552 AB053 

ANTIBLAZE® 195 AC003 

ANTIBLAZE® 205 AC073 

ANTIBLAZE® 180 

ANTIBLAZE® V-500 

ANTIBLAZE® 182 

Non-chemical alternatives that eliminate the need for pentaBDE are addressed in Section 5.5 of 

this report. Though these technologies may not be considered feasible for immediate 

implementation or application for flame retarding foam, these alternative technologies are being 

considered for further investigation by the Furniture Flame Retardancy Partnership. Three 

currently available, alternative technologies for flame retarding furniture include barrier 

technologies, graphite impregnated foam and surface treatment. There is considerable interest in 

future applications of these technologies for the furniture industry. 

This report is intended to provide information that will allow industry and other stakeholders to 

evaluate environmentally safer alternatives for flame retarding furniture. The report is organized 

as follows: 

• 	 Section 1 (Introduction): This section provides a background to the 

Furniture Flame Retardancy project including the purpose and scope of the 

Partnership and of this report. 

• 	 Section 2 (Chemical Flame Retardants): This section describes 

characteristics of the flame-retardant chemicals currently used in flexible 

polyurethane foam and the mechanisms by which they suppress fires. 

• 	 Section 3 (Exposure): This section provides a general discussion of 

exposure concerns that should be evaluated when conducting an 

environmental risk assessment and identifies exposure pathways and 

routes associated with flame-retardant chemicals used in furniture 

manufacturing. 

• 	 Section 4 (Alternatives Evaluations): This section contains EPA’s 

exposure and hazard assessments on a chemical-specific and formulationspecific basis for the flame-retardant formulations being evaluated. 

1-4
 
• 	 Section 5 (Considerations): This section addresses considerations for 

selecting a replacement for pentaBDE based on environmental and 

economic feasibility. It also includes alternative technologies that may 

serve as alternatives to chemical flame retardants. 

1-5
 
2.0 TYPES OF CHEMICAL FLAME RETARDANTS 

Publicly available scientific literature contains a wealth of information about various mechanisms of 

flame retardancy and characteristics of flame retardants. This section summarizes the general 

characteristics associated with flame retardants and associated mechanisms of flame retardancy. 

2.1 General Characteristics of Chemical Flame Retardants 

Some general characteristics of flame-retardant chemicals mandate how they interact with and flame 

retard the substrate in which they are used. This section defines some of these important characteristics, 

including: 

• 	 General mechanisms of flame retardancy; 

• 	 Additive and reactive flame-retardant chemicals; and 

• 	 Flame-retardant synergists. 

2.1.1 General Mechanisms of Flame Retardancy 

In general, flame retardants act in one of two ways; either by preventing ignition or preventing the 

spread of a fire. First, the ignition susceptibility of a product lowers when the flame retardant increases 

the net heat capacity of the product. Second, once a fire has already begun, flame retardants can reduce 

the tendency of the fire to spread by reacting with the product and forming a less flammable char or 

noncombustible gaseous layer along the boundary of the fire. 

Within these two general flame-retardant mechanisms, Kirk-Othmer’s Encyclopedia of Chemical 

Technology (Kirk-Othmer, 2001) provides a more detailed summary of five specific mechanisms by 

which flame retardancy may occur: physical dilution, chemical interaction, inert gas dilution, thermal 

quenching and protective coatings. 

• 	 Physical dilution: The flame retardant can act as a thermal sink, increasing the 

heat capacity of the product or reducing the fuel content to a level below the 

lower limit of flammability. Inert fillers such as glass fibers and microspheres and 

minerals such as talc act by this mechanism. 

• 	 Chemical interaction: The flame retardant dissociates into radical species that 

compete with chain propagating and branching steps in the combustion process. 

This is the general flame-retarding mechanism by which brominated flame 

retardants operate. 

• 	 Inert gas dilution: Flame-retardant additives produce large volumes of 

noncombustible gases when the product decomposes during combustion. The 

gases dilute the oxygen supply to the flame or dilute the fuel concentration below 

2-1
 
the flammability limit. Metal hydroxides, metal carbonates and some nitrogen 

producing compounds function in this way when used as flame retardants. 

• 	 Thermal quenching: Endothermic degradation of the flame retardant results in 

thermal quenching. Metal hydroxides and carbonates act in this way. 

• 	 Protective coatings: Some flame retardants function by forming a protective 

liquid or char barrier that acts as an insulating layer to reduce the heat transfer 

from the flame to the combusting product. Phosphorous compounds that 

decompose to give phosphoric acid and intumescent systems operate by this 

mechanism. 

BFRs such as pentaBDE react chemically to prevent the spread of a fire. In products without BFRs, 

combustion is propagated by a series of chemical reactions that occur in the gas phase, where oxygen 

combines with chemicals in the burning product. BFRs interrupt some of these reactions by introducing 

the volatilized halogens to react with the product in place of oxygen, slowing combustion. 

2.1.2 Additive and Reactive Flame Retardants 

Flame retardants are categorized as either additive or reactive. Additive flame-retardant chemicals can 

be added to a manufactured product without bonding or reacting with the product. They are incorporated 

and dispersed evenly throughout the product, but are not chemically bound to it. Reactive flameretardant chemicals may be incorporated into the product during manufacture of the plastic raw 

materials. They are chemically bound to the raw materials that are used to make the final product. 

The basic mechanisms of flame retardancy (discussed earlier) will vary depending on the specific flame 

retardant and substrate. Additive and reactive flame-retardant chemicals can function in the vapor or 

condensed phase. Depending on the specific chemical, any of the mechanisms previously discussed may 

be utilized. Due to specific physical and chemical properties of the flame retardant and its effects on the 

substrate, most are used exclusively as either reactive or additive. 

Additive Flame Retardants 

Most flame retardants are used as additive flame retardants. Commercial pentaBDE is added at the time 

the polymer is formed. In general, additive flame retardants react when heated and either (a) emit 

substances that displace the oxygen needed for a fire to burn, (b) form a protective coating on the 

surface of a flammable substrate, thereby limiting access of the fire to fuel sources, or (c) do a 

combination of both. Halogenated flame retardants act in the gas phase by releasing chlorine- and/or 

bromine-containing radicals. In contrast, other flame retardants quench the flame by forming an 

intumescent, resinous char on the surface of the polymer. This char insulates and protects the polymer 

from further decomposition. The flame retardant in the system then expands, helping to form an 

insulating barrier that limits further damage to the polymeric material. 

2-2
 
Additive flame retardants used in foam and other plastics are typically incorporated after manufacture of 

the polymer and during the manufacture of the end product (at the final product manufacturing facility). 

These additives are mixed into the polymer in common processing equipment concurrently with other 

ingredients such as stabilizers, pigments and processing aids. This is most likely to occur during a very 

preliminary stage at the end-product manufacturing facility (typically during the compounding step). 

Reactive Flame Retardants 

Reactive flame retardants are chemically bound to polymer products either by incorporating them into 

the polymer backbone during the polymerization reaction or by grafting them onto it. This is most likely 

to occur at the foam manufacturing facility. Therefore, reactive flame retardants are typically already 

incorporated in the raw materials that are purchased and received by the furniture manufacturers 

Note that because they are chemically bound to the substrate, reactive flame retardants tend to exert a 

much greater effect than additive flame retardants on the properties of the polymer they are incorporated 

into. 

2.1.3 Flame-Retardant Synergists 

Many flame-retardant synergists do not have significant flame-retardant properties by themselves; 

however, their use increases the overall effectiveness of the flame-retardant system. 

While char formation in the condensed phase and halogen interference in the vapor phase take place 

when flame retardants are used alone, the presence of a synergist can dramatically increase the flame 

retardant’s effectiveness, lowering the quantity of the flame retardant needed to meet the required 

standard. Since high levels of flame retardants often affect product quality, a synergist to reduce the 

amount of flame retardant is often used. Additionally, the cost of flame retardants can be significant; 

therefore, any method to decrease the quantity of flame retardants needed is advantageous. 

As an example of synergistic mechanisms, some synergists retard fire via two processes. In the 

condensed phase, a char layer is formed during the reaction with the synergistic compound, the flame 

retardant and the polymer. As discussed above, this char acts as a shield as it reduces the rate of 

decomposition of the polymer; therefore, less fuel is available for the flame. In the vapor phase, the 

chemical reaction is slowed down. This adds to the flame retardant’s inhibitory effects on combustion by 

allowing it to react more completely with free radicals of oxygen and hydrogen, which are necessary for 

combustion to occur (Kirk-Othmer, 2001). 

As an example of how synergists can be used, consider organophosphorous flame retardants. When used 

alone, organophosphorous flame-retardant concentrations may need to be extremely high. These 

concentrations of the flame retardant often adversely affect the properties of the product. Testing has 

shown that adding inorganic synergists can dramatically increase the flame-retardant efficiency. 

Therefore, a significantly smaller quantity of the flame retardant is required. The synergistic effect on 

flame retardancy, coupled by the reduction in adverse effects on the product from the flame retardant is 

attractive to flame-retardant and end-product manufacturers. 

2-3
 
2.2 Flame-Retardant Chemicals Currently Used in Foam 

A wide variety of flame-retardant chemicals are currently in use throughout the world to meet fire safety 

standards for various types of foam. Many of these chemicals could theoretically be used to meet U.S. 

fire safety standards for low-density, flexible polyurethane foam. However, their use will result in trade 

offs. Some, for example, require high loadings that result in an effect on foam quality. Others are cost 

prohibitive. Still others will require significant modifications in the handling and process equipment 

that is currently used in most U.S. foam manufacturing facilities. The environmental assessments 

presented in this report correspond to 14 specific formulations that chemical companies presented as the 

most viable large-scale substitutes for pentaBDE. However, other chemicals (besides these 14 

formulations) are currently used for other types of foam and in niche markets for low-density 

polyurethane foam. 

PentaBDE is an additive flame retardant that was used as a liquid formulation, typically blended with 

isopropylphenyl diphenyl phosphate/triphenyl phosphate and other additives. The commercial 

PentaBDE products have been used to flame retard low-density, flexible polyurethane foam (Weil and 

Levchik, 2004). Great Lakes Chemical Corporation was the sole manufacturer of pentaBDE in the 

United States, but Akzo Nobel and Great Lakes produced pentaBDE flame-retardant products prior to its 

phase-out. PentaBDE composition in products is proprietary. 

The remainder of this section briefly discusses three of the most commonly used chemicals that various 

reports have suggested may be viable alternatives to pentaBDE. The chemicals are used domestically 

and abroad to flame retard high-density, flexible polyurethane foam. Chemical companies and foam 

manufacturing facilities have experimented with their use in low-density flexible foams with moderate 

success. Generally the use of these chemicals either results in scorching of the foam (an aesthetic effect 

unless severe) or a negative effect on the physical properties of foam. Also, many formulations of these 

chemicals are available only as solids; making them less desirable as drop in substitutes for pentaBDE. 

Melamine 

There are numerous international manufacturers of melamine. Melamine and its derivatives are nonhalogenated flame retardants, typically used as a crystalline powder. Flame retardants based on 

melamine are currently used in flexible polyurethane foams, intumescent coatings, polyamides and 

thermoplastic polyurethanes (Special Chemicals, 2004). They are used effectively in Europe in highdensity flexible polyurethane foams but require 30 to 40 percent melamine per weight of the polyol. 

Tris (1,3-dichloro-2-propyl) phosphate (TDCPP) 

TDCPP is a chlorinated phosphate ester that is often used in polyurethane foam formulations. TDCPP 

comprises approximately 12 percent of the weight of the polyol in the final foam product (Weil and 

Levchik, 2004). It is used in high-density foam domestically and abroad and has been used domestically 

in low-density foams when light scorching (discoloration) is not a primary concern (Akzo Nobel, 2002). 

Note that TDCPP has been mistakenly referred to as tris (chloropropyl) phosphate (TCPP) in many 

reports. 

2-4
 
Ammonium Polyphosphate (APP) 

APP is an additive flame retardant containing nitrogen and phosphorus, typically used in a crystalline 

form. It is currently used to flame retard flexible and rigid polyurethane foams, as well as in intumescent 

laminations, molding resins, sealants and glues (Leisewitz et al., 2001). APP formulations comprise 

approximately 4 to 10 parts per hundred parts polyol in flexible foam, and 20 to 45 parts per hundred 

parts polyol in rigid foam. 

APP is included in this section because it has been listed in multiple sources as a flame retardant for 

several products, including flexible, polyurethane foam. However, chemical manufactures and foam 

manufacturing trade groups do not consider it to be an alternative for pentaBDE on a large scale. 

Reasons for this are that APP is typically incorporated as a solid, it has adverse effects on foam 

properties and processing and it is not considered to be as effective as a fire retardant compared to other 

alternatives (U.S. EPA, 2002). 

These chemicals have been used in the United States and around the world to flame retard flexible 

polyurethane foam. However, only pentaBDE is capable of achieving flame retardancy and nonscorching requirements in the low-density foam that is manufactured in the United States. While other 

flame retardants have historically been used and will continue to be used to flame retard higher-density 

foams, these flame retardants result in scorching in many low-density foam formulations. These 

chemicals are potential alternatives for pentaBDE, but scorching and other drawbacks must be addressed 

before large-scale use is feasible. 

Scorching results in foam that has a color gradient but unless severe, it will not adversely affect flame 

retardancy or foam performance. White foam has become the industry standard for flame-retarded, lowdensity foam in the mattress and bedding industries, and in many upholstered furniture applications in 

the United States. The color of the foam, however, is not a determinant of its flame retardancy. Greater 

acceptance of darkened foams would allow manufacturers to choose from a wider variety of alternative 

flame retardants. 

2-5
 
3.0 EXPOSURE TO FLAME-RETARDANT CHEMICALS IN FOAM 

To evaluate the risk to human health and the environment that is associated with any of the 

alternatives to pentaBDE, many factors must be considered. Risk is a function of two parameters, 

hazard and exposure. If there is very little exposure, then even the most hazardous chemicals 

pose minimal risk. However, if exposure is not well characterized, it cannot be assumed that 

there is no risk. The purpose of this section is to identify the highest priority routes of exposure 

to flame retardant chemicals used in foam that need to be further assessed and quantified. This 

section should be considered with the chemical-specific hazard analysis presented in Section 4. 

This section provides: general background regarding exposure pathways, discusses factors that 

affect exposure potential in an industrial setting, provides process descriptions for the industrial 

operations involved in the furniture manufacturing supply chain (identifying the primary release 

points and exposure pathways) and discusses consumer and environmental exposures. 

Exposures to specific chemicals are not discussed; rather, the purpose is to provide information 

such that the reader can identify and characterize potential exposures based on the physical and 

chemical properties of any pentaBDE alternative. 

Exposure can occur at many points in the life cycle of a flame-retardant chemical. There is a 

potential for occupational exposures during industrial operations; exposure to consumers while 

the flame-retarded product is being used; and exposure to the general population and 

environment when releases occur from product disposal or from manufacturing facilities. Figure 

3-1 presents a simplified life cycle for a flame-retardant chemical used in low-density 

polyurethane foam. 

3.1 Exposure Pathways and Routes (General) 

There are multiple ways people and the environment can be exposed to chemicals and the 

different types of exposures can impact the effect of the hazard. For instance, the toxicological 

effects from exposure to skin are different than those from exposures from swallowing or 

inhaling a chemical. Because of this, exposure is typically characterized by different pathways 

and routes. 

An exposure pathway is the physical course a chemical takes from the source of release to the 

organism that is exposed (how the chemical gets to the individual). The exposure route is a 

description of how the chemical gets into the organism. The three primary routes of exposure 

are: inhalation, dermal absorption and ingestion. 

3-1
 
Chemical 

Manufacturing 

Foam 

Manufacturing 

Furniture 

Manufacturing 

Residential 

Furniture Mattresses Carpet Cushion 

Carpet Cushion 

Manufacturing 

Landfill Incineration Recyc

Scrap Foam 

Off-Spec and Scrap Foam 

Industrial 

Manufacturing 

and Use 

Consumer Use 

Post Consumer Use 

(Product End-of-Life) 

Material Stream Recycle Stream Chemical Stream 

V

Migration to Surfacewater and Groundwater Combustion Byproduct Formation and Release Additional O

(Environmental and General Population Exposure) (Environmental and General Population Exposure) Exp

Figure 3-1 Simplified Life Cycle for a Flame-Retardant Chemical 

3-2 
3.2 

Expected environmental releases and potential occupational exposures are dependent upon the 

physical and chemical properties of the chemical of concern. For example, a highly volatile 

liquid will readily evaporate from mix tanks and open transfer operations, potentially resulting in 

significant fugitive air releases and occupational exposures to workers that breathe the vapors. 

Conversely, chemicals that are manufactured and formulated as solids do not typically result in 

exposure to vapors, but may result in inhalation exposure to fugitive dust. 

As noted above, risk is a function of the hazardous effects of an environmental toxicant and the 

level of exposure to it. Depending on the effects, exposure from only one or perhaps all three 

routes may result in significant risk. Therefore, each potential route should be evaluated 

independently along with an evaluation of appropriate endpoints. Endpoints are the specific 

toxicological effect, such as cancer, reproductive harm, organ/tissue damage or death. 

There are circumstances when a chemical has serious effects for endpoint; however, its physical 

and chemical properties as well as environmental fate minimize the potential for it to be 

transported from the release point through the environment. This may essentially eliminate a 

potential pathway and route of exposure and eliminate the associated risk. For example, some 

chemicals are only hazardous if they are inhaled. If the chemical is non-volatile, the likelihood of 

breathing vapors containing the chemical is very low. This only generally applies to inhalation 

exposure from volatilization of liquid chemicals. If the chemical is solid, there is potential 

inhalation exposure associated with breathing dust. In another example, if the primary concern is 

due to skin sensitization, then a requirement for workers to wear appropriate gloves may reduce 

or mitigate the risk. 

Industrial Releases and Exposures 

This section provides process descriptions and identifies the corresponding release and exposure 

points for the unit operations that are involved within the furniture manufacturing supply chain. 

It should be noted that many of the potential occupational exposures identified here could be 

reduced or eliminated by the use of engineering controls and personal protective equipment. 

Also, some releases will only result in exposure to workers, while other releases result in 

exposures to the environment and the general population. The level of exposure between workers 

and the general population will vary considerably. Therefore, a risk evaluation should address 

occupational exposures separately from environmental and general population exposure. 

Factors to consider when identifying and assessing potential pathways and routes of exposure are 

discussed below. Examples provided are occupational exposures. A more in-depth review of 

occupational exposures, consumer and general population exposures follows. 

Inhalation Exposures 

The physical state of the chemical during chemical manufacturing and downstream processing 

has a significant effect on the potential for inhalation exposure to workers. In particular, the 

physical state can result in three types of inhalation exposures that should be evaluated: 

Dust: Chemicals that are manufactured, processed and used as solids have the potential to result 

in occupational exposure to fugitive dusts. The potential for significant dust formation depends 

on whether the solid chemical is handled in the crystalline form, as an amorphous solid, or a fine 

3-3
 
powder. Formation and handling of crystals and amorphous solids results in significantly less 

dust than powders. If there is exposure to dust, the level of exposure is directly proportional to 

the concentration of chemical in the particulate form. Therefore, a flame retardant that is used at 

a lower concentration results in a decreased exposure from this pathway and route (assuming an 

equivalent amount of dust is inhaled). 

When assessing occupational exposures to pentaBDE alternatives, it is important to note the 

physical state of the chemical at the potential point of release and contact. The pure chemical 

may be manufactured as a solid powder, indicating a potential exposure to dust. However, it may 

be formulated into solution before any workers come in contact with it; thereby eliminating 

inhalation exposure to dust as a potential route. 

Vapor: Exposure to vapors can occur when liquid chemicals evaporate during manufacturing, 

processing and use. Most chemical manufacturing operations occur in closed systems such that 

vapors are contained. However, fugitive emissions are expected during open mixing operations, 

transfer operations and loading/unloading of raw materials. More volatile chemicals evaporate 

more quickly and result in greater fugitive releases and higher occupational exposures than less 

volatile chemicals. Therefore, vapor pressure is the best indicator of potential occupational 

exposures to vapors. Studies have indicated that in some situations there is a potential for 

chemicals to volatilize from foam during the use of the consumer product (Wilford et al., 2003). 

Mist: Non-volatile liquids can result in inhalation exposure if manufacturing or use operations 

result in the formation of mist. Therefore, risk assessors always address the potential for 

exposure from this pathway. It is unlikely that flame-retardant chemicals used as alternatives to 

pentaBDE on a large scale will be applied as a mist. However, some flame retardants that are 

applied as surface treatments can be spray applied. In these situations, exposure to mist will 

occur and should be evaluated. 

Dermal Exposures 

Occupational dermal exposure is also affected by the physical state of the chemical at the point 

of release and contact. For example, the likelihood of liquids being splashed or spilled during 

sampling and drumming operations is different than similar operations involving polymerized 

solids, powders, or pellets. 

Dermal exposure is also generally assumed to be proportional to the concentration of chemical in 

the formulation. For instance, the dermal exposure from contacting a pure chemical is greater 

than the exposure from contacting a solution that contains only 10 percent of the chemical. 

Screening-level evaluations of occupational dermal exposure can be based on the worker 

activities involving the chemical. For example, there may be significant exposure when workers 

handle bags of solid materials during loading and transfer operations. Maintenance and cleanup 

activities during shut down procedures, connecting transfer lines, and sampling activities also 

result in potential dermal exposures. 

3-4
 
Ingestion 

Occupational exposures via this route typically occur unintentionally when workers eat food or 

drink water that has become contaminated with chemicals. Two pathways should be considered. 

First, dust particles may spread throughout the facility and settle (or deposit) on tables, 

lunchroom surfaces, or even on food itself that is consumed. Vapors similarly spread throughout 

the facility and can adsorb into food and drinking water. 

Another potential pathway for ingestion occurs from dust particles that are too large to be 

absorbed through the lungs. These “non-respirable particles” are often swallowed, resulting in 

exposures from this route. 

While ingestion is considered to be a realistic route of exposure to workers, it is often considered 

less significant when compared to inhalation and dermal exposures, based on the relative 

exposure quantities. Ingestion during consumer use and to the general population is often as 

significant as or more important than the inhalation and dermal routes. If persistent and 

bioaccumulative compounds get into the environment and build up in the food chain, they can 

become a significant exposure concern. 

The unit operations associated with each industry sector of the furniture supply chain result in a 

unique set of potential release points and occupational exposures to flame retardant chemicals. 

Sections 3.2.1 through 3.2.3 present an overview of typical manufacturing processes for these 

industry sectors. Potential release points and associated exposure concerns are noted, as 

appropriate. 

3.2.1 Chemical Manufacturing 

The specific unit operations, operating conditions, transfer procedures and packaging operations 

vary with the manufacture of different flame-retardant chemicals. The expected releases and 

occupational exposures depend on these parameters, the chemical’s physical state upon release 

and its physical and chemical properties. While it is outside the scope of this report to identify 

and quantify the releases and exposures associated with individual chemicals, this section 

presents a description of a typical chemical manufacturing process, identifies the potential 

releases and notes those that are most variable based on the flame-retardant chemicals produced. 

Figure 3-2 presents a generic chemical manufacturing process flow diagram and identifies the 

primary release and occupational exposure points. 

The first step in most chemical manufacturing processes is to load or charge raw materials into 

some type of reactor or mix tank. Production volumes and batch sizes associated with flameretardant chemicals typically require the raw materials to be stored in large tanks or drums until 

use. Large-quantity liquids are typically pumped into the reactor, and solids are weighed and 

transferred via conveyorized, mechanical systems. Small-quantity raw materials may be 

manually introduced or carefully metered via automated systems. Releases and exposures are 

expected from these operations, but they are associated with the raw materials, not the finished 

flame-retardant product. 

3-5
 
Fugitive Air Emission 

Raw Materials 

Samples* Sample 

Equipment* 

Fugitive 

Air 

Emission 

Fugitive Dust 

Emissions 

Fugitive Air 

Emission 

Reactor 

Separation 

(Distillation 

Column or 

Filtration Unit) 

Drying Operations 

(e.g., drying oven 

or spray dryer) 

Temporary 

Storage and 

Filling Operations* 

Spent Filters 

Separation Waste 

and Filtrate 

*Occupational Exposure Expected 

Air Releases 

Liquid Releases 

Solid Releases

Miscellaneous: 

•Equipment 

Cleaning 

•Area Washdowns 

Figure 3-2 Generic Chemical Manufacturing Process Flow Diagram 

3-6
 
Crude or intermediate products may be transferred through a series of reactors, distillation 

columns, filtration systems, drying ovens, spray dryers and other unit operations. These 

processes typically occur in closed systems, with engineering controls that serve both to regulate 

operating parameters such as temperature and pressure as well as to minimize fugitive releases. 

However, there is potential for a variety of solid and liquid releases from these operations, from 

cleaning process equipment and from sampling activity. Additionally, crude or finished products 

may be stored on-site in drums, day-tanks, or more permanent storage vessels until the flameretardant formulation is packaged and shipped to customers (e.g., foam and textile 

manufacturers). The transfer and packaging operations are expected to result in releases of and 

exposures to the flame-retardant chemicals. Finally, miscellaneous operations, such as routine 

and unplanned maintenance activities, can result in considerable releases and exposures. 

After the flame retardant is manufactured, it may need to be formulated into a solution, slurry, or 

mixture prior to introduction into the commercial flame-retardant formulation. For example, fine 

powders of a chemical may be formulated into an agglomerated powder or into a solution. The 

formulation steps usually occur at the chemical manufacturing facility, but additional mixing 

steps can occur at the foam manufacturing plant. 

Release points from manufacturing and formulating can include: 

• Transfer and packaging operations involving handling a chemical product; 

• Routine and unplanned maintenance activities; 

• Leaks from pumps and pipelines; 

• Fugitive emissions from equipment; 

• Product sampling; and 

• Equipment and transport and storage vessel cleaning. 

3.2.2 Foam Manufacturing 

Flexible polyurethane foam is manufactured as slabstock foam or molded foam. The typical 

process used to manufacture each of these is described below. Rigid polyurethane foam is not 

discussed here because pentaBDE is used exclusively in flexible foam. 

Slabstock Foam 

The majority of flexible polyurethane foam is manufactured in slabstock operations. The 

slabstock manufacturing process is a continuous process that produces long, rectangular, 

continuous slabs of foam, called “buns”. Buns are cut into the desired configuration for an 

application, such as in furniture padding, bedding, automobile padding and seats, packaging 

materials and carpet padding. 

The typical commercial process for slabstock foam production consists of a single unit operation, 

operated in batches. Figure 3-3 presents a generic diagram for this process. The raw materials 

include diisocyanates, polyol, water, auxiliary blowing agents, filler, chain modifying agents and 

other additives (including flame retardants). 

3-7
 
Figure 3-3 Typical Slabstock Foam Production for Flexible Polyurethane Foam 

First, the raw materials and additives are metered into a single mix head, which dispenses the 

mixed materials to an enclosed conveyor system. Within a few minutes of leaving the mix head, 

the raw materials begin to create foam-producing reactions, producing the polyurethane foam on 

the conveyor. Most foam manufacturers have computerized controls at the mix head metering 

system that allow the raw materials mixture to be changed mechanically, without worker 

exposure to the chemicals. 

The foam mixture moves down the conveyor at approximately 15 feet per minute. The conveyor 

is housed in a tunnel that is ventilated to remove the gases that are given off in the foam reaction. 

The foam reaches its full height of 2 to 4 feet in approximately 1 to 2 minutes. After 5 to 10 

minutes, polymerization reactions are complete enough for the foam to be handled and cut. 

Workers typically enter the tunnel during startup and shutdown procedures or during upset 

conditions and usually wear appropriate personal protective equipment. Therefore, this potential 

occupational exposure point may be mitigated. Gases are often channeled away from the 

workplace and out the facility roof. Therefore, this is a potential environmental release point. 

The use of activated carbon filters or other organic vapor control devices on this stream can 

reduce releases from this exhaust stream. 

3-8
 
A “flying saw” is often used to cut foam on the production line. This is an overhead saw that 

moves at the same rate as the conveyor while cutting the foam, in order to produce a straight cut. 

Each cut of foam is removed from the conveyor and moved to a curing area. Typically, buns are 

cured for 24 hours before further fabrication or shipping. Off gassing may occur during this step. 

Therefore, there is potential for inhalation exposure to volatile chemicals from curing operations. 

Fabrication includes cutting and slicing the foam to meet the specifications of the customer. A 

machine called a slitter cuts large buns into a desired thickness. Vertical bandsaws or hand 

cutting tools are used to convert slabs of foam into smaller components for the desired end use 

(e.g., furniture). Dermal exposure and exposure to particulates may occur during this step. 

Molded Foam 

Molded flexible foam is produced when the foam polymerization reaction occurs in a closed 

mold resembling the final product. Molded foam is used in the transportation industry for seat 

cushions and interior trim, furniture, bedding, packaging materials, toys and novelty items. 

The typical commercial process for molded foam production consists of a circular production 

line containing multiple molds and process stations. Figure 3-4 presents a diagram of this 

process. 

Figure 3-4 Typical Molded Foam Production Line for Flexible Polyurethane Foam 

Raw materials include polyol, diisocyanates, water, catalyst, surfactant and other additives (e.g., 

flame-retardant formulation). The raw materials are pumped to a common mix head above the 

production line. Many ingredients are premixed to minimize the streams being fed to the head 

3-9
 
and to ensure precise measurement. The mix head dispenses a measured amount of the mixture 

into each mold and the molds are then heated to accelerate foam curing. Heating takes place 

either by passing the mold through a curing oven or passing heated water through tubes in the 

mold. Then, the mold is opened and emptied. The mold continues through the process line to be 

conditioned for the next product. 

Primary release points and corresponding occupational exposures occur from fugitive emissions 

during transfer operations and opening/closing the molds. Additional releases and exposures 

occur from frequent equipment cleaning operations. 

3.2.3 Furniture Manufacturing 

Upholstered furniture manufacturers typically receive foam on site, and do not directly handle 

flame-retardant chemical formulations. The primary modes of exposure and releases are due to 

worker contact with the treated foam. Primary activities where exposure and releases may occur 

are during receipt of the foam, cutting and trimming and the placement on the furniture. Figure 

3-5 presents a simplified process flow diagram for furniture manufacturing processes. A 

significant release may occur from flame-retarded scrap foam. Foam scrap from cutting and 

trimming operations is usually sold and utilized in the manufacture of carpet pad foaming. 

Otherwise the scrap is disposed of in landfills or by incineration. 

Occupational Exposures 

Occupational exposures during furniture manufacturing operations may occur due to inhalation 

of airborne fibers from handling operations and dust generated during cutting and dermal contact 

with treated foam. Workers will be directly exposed to foam that contains flame retardants on a 

regular basis as they handle the foam when it is received from suppliers, during incorporation 

into furniture and during cutting and cleanup activities. 

Releases to Water 

Furniture assembly is a dry process; therefore, there are no process water releases that are 

expected to contain flame retardants. Additionally, flame retardants are not expected to be 

formulated or applied at furniture manufacturing facilities unless the facility elects to use a postmanufacturing surface treatment alternative. Therefore, waste from container residue or 

equipment cleaning is not expected to contain flame retardants. 

3-10
 
3-11 

Figure 3-5 Process Flow Diagram: Furniture Manufacturing 

Receive and 

Unload 

Foam and 

Fabric* 

Cutting and 

Trimming 

Apply Foam 

and Fabric to 

Furniture* 

Finished 

Upholstery 

Product 

Fugitive Dust 

and Vapors 

Fugitive Dust and Vapors 

Fugitive Dust 

and Vapors 

Flame Retarded Foam and Fabric 

Scrap Foam 

Handling 

Carpet 

Padding 

Scrap Fabric 

Disposal 

(Landfill or 

Incineration) 

Air 

Solid 

Air

*Occupational Exposure 
Releases to Air 

It is possible that dust or vapors will be generated and emitted as stack or fugitive emissions as a 

result of cutting operations during furniture assembly. Although some air emissions of fugitive 

dust containing flame retardants from the facility are possible, the quantity of dust generated and 

released to workplace and ambient environments has not been reported. 

Releases to Land 

The primary potential source of flame-retardant releases to land is scrap from cutting and 

trimming operations and floor sweepings. The foam from this waste source is typically collected 

and recycled in carpet cushion manufacturing, but may be sent to a landfill. 

3.3 Consumer and General Population Exposures 

Exposures to consumers and the environment are different from exposures to workers and should 

be evaluated separately for a number of reasons. Occupational exposures typically result from 

direct contact with chemicals at relatively high concentrations while workers are conducting 

specific tasks. Conversely, consumers may be exposed over a much longer period, but to a much 

smaller level because the chemical is incorporated into the product. Also, the general population 

and the environment will be exposed via different pathways and routes than workers and 

consumers. For example, a person that does not own a flame-retarded furniture product may still 

be exposed if the chemical leaches from the disposed product into the drinking water supply. 

Once in the water supply, groundwater, or surface water, it can be ingested by people or 

consumed by fish and other animals. Similarly, if the chemical is released to the atmosphere 

during manufacture, use or disposal, it may settle out on food crops and be ingested directly by 

people, or by cattle or other livestock. If the chemical is bioaccumulative, it may concentrate in 

the animal and reach people through the food chain. For these reasons, exposure to the 

environment and the general population should be assessed independently from occupational 

exposure. 

A quantitative exposure assessment is outside the scope of this report. However, the primary 

pathways and routes from environmental, general population and consumer exposures are 

discussed in the following sections. Important chemical-specific factors that may help the reader 

compare exposure concerns between various pentaBDE alternatives are also discussed. 

3.3.1 Physical and Chemical Properties Affecting Exposure 

As previously discussed, the physical and chemical properties of a chemical often determine the 

potential (or at least the most likely) pathways and routes of exposure. In addition, the chemical 

properties dictate how the chemical will become distributed in the environment once it is 

released. These interactions in turn dictate the potential for the chemical to be transported from 

the release point to the receptor, and the availability for uptake into our bodies. 

3-12
 
Additive vs. Reactive Chemicals 

Regardless of the specific chemical composition, flame retardants are often categorized as either 

additive or reactive. Reactive flame retardants are chemically bound to the raw materials that are 

used to make the final product (i.e., bound to monomers and polymers that make up foam 

products). Additive flame retardants are incorporated and dispersed evenly throughout the foam, 

but are not chemically bound to it. 

Depending on the product and its end use, additive flame retardants can eventually wash off 

(e.g., from textiles that are frequently cleaned), volatilize (e.g., from some plastic and foam), or 

leach from furniture after it has been disposed of in a landfill. This results in potential exposures 

to consumers, the environment and the general population because the furniture itself can be a 

source of release. Each furniture article may release very small amounts of the chemical over a 

period of several years. However, the combined effect of millions of articles may be very 

significant. 

Reactive flame retardants are chemically bound to the foam either by incorporating them into the 

polymer backbone during the polymerization reaction or by grafting them onto it. This is most 

likely to occur at the foam manufacturing facility. Therefore, reactive flame retardants are 

typically already incorporated in the foam that is purchased and received by furniture 

manufacturers. 

Because reactive flame retardants are chemically bound to the foam, it is far less likely they will 

be released. It should be noted that even reactive chemicals or close analogues can be released 

from the finished article, either when they are liberated from the polymer backbone or because 

some of the chemical was not completely reacted during the polymerization process. Also, note 

that because they are chemically bound to the substrate, reactive flame retardants tend to exert a 

much greater effect than additive flame retardants on the properties of the polymer they are 

incorporated into. 

Properties Affecting Transport in the Environment (Vapor Pressure, Water Solubility) 

If a chemical is released into the environment, either from the finished foam article or directly 

from an industrial facility, there still may not be significant exposures unless there is a potential 

for it to travel from the source to the receptor. Primary mechanisms of transport include the 

water supply and air dispersion. Many factors affect movements of chemicals throughout these 

media. However, a few chemical properties can provide a good screening-level indication of 

which pathway(s) a chemical is likely to take. 

Water solubility is an indicator of the amount of chemical that will dissolve in aqueous solutions. 

Chemicals with high water solubility will readily dissolve. This indicates a potential for the 

chemical to be transported long distances in rain water and surface water runoff from the point of 

release. High water solubility also means the chemical is less likely to settle or precipitate as a 

solid at the bottom of a receiving stream; it may become dispersed throughout a drinking water 

supply that is eventually ingested by the general population. Water solubility is one of the criteria 

used in Section 4 to determine the potential for aquatic exposure and exposure to the general 

population via ingestion. 

3-13
 
The octanol-water partition coefficient (Log Kow) is a chemical-specific parameter that reflects 

the hydrophobicity of the chemical, meaning the tendency for the chemical to partition from 

water to organic phases (e.g. organic matter in soil or water, or lipids in organisms like fish). 

Some chemicals may initially be released on the ground; however, they are quickly absorbed by 

organic materials in the soil. In this instance, the chemical may never be transported to a water 

supply. Chemicals that readily dissolve in water are more likely to find their way to an 

underground water supply. The octanol-water partition coefficient is also used in Section 4 to 

evaluate aquatic exposure and general population exposure via ingestion. A high partition 

coefficient value means that the chemical is more soluble in octanol than in water while a low 

partition coefficient value means that the chemical is more soluble in water than in octanol. 

Vapor pressure can be used to assess the amount of chemical that vaporizes into the gas phase 

(from solution or from a finished article). Similarly, the Henry’s Law Constant indicates the 

amount of chemical that will volatilize from an aqueous solution. A high vapor pressure and 

Henry’s Law Constant indicates a higher potential for the chemical to enter the vapor phase and 

be transported long distances through ambient air. These parameters are used in Section 4 to 

evaluate potential general population exposure via inhalation. 

Persistence and Bioaccumulation 

If a chemical is released, there still may be little or no potential for environmental and general 

population exposures. This potential is affected by the fate of the chemical in the environment 

and its ability for uptake by the receptor organism. Two parameters affecting fate components of 

the exposure pathway are persistence and bioaccumulation. 

Persistence 

Many natural phenomena can degrade or destroy chemicals. Factors that can contribute to 

degradation include exposure to light, reactivity with air and water and microbial activity. The 

ability of a chemical to persist in the environment can be measured by its half-life. This is the 

amount of time required for half of the chemical to be degraded. The half-life can be measured 

(or estimated) for different media (e.g., half-life in air and half-life in water). Chemicals with a 

very long half-life are said to be persistent. Half-life is used in Section 4 to describe the 

persistence of pentaBDE alternatives, as well as their expected degradation products. 

Bioaccumulation 

The toxicological effects exhibited for some endpoints depend on the ability of the chemical to 

be absorbed in tissue, and remain for extended periods of time. This general concept is referred 

to as bioaccumulation. Chemicals that are highly bioaccumulative pose greater concerns. 

Bioaccumulation can be measured or estimated by analyzing a number of parameters, including 

the fish bioconcentration factor (BCF). BCFs are used in Section 4 to evaluate the 

bioaccumulation potential of each pentaBDE alternative. 

3-14
 
3.3.2 Consumer Use and End-of-Life Analysis 

Currently, there is uncertainty regarding the exposure pathways and routes associated with flame 

retardant chemicals such as pentaBDE. A significant amount of research is being conducted to 

assess their fate and transport from release points and consumer products to human and 

environmental receptors. The Furniture Flame Retardancy Partnership will evaluate the results of 

flame retardant exposure research as it is completed. This section very briefly discusses the 

potential pathways and routes of exposure associated with consumer uses and end-of-life 

(disposal) of flexible polyurethane foam. 

Primary Consumer Uses (Furniture, Carpet Cushion and Mattresses) 

In the United States today, pentaBDE is primarily used in flexible polyurethane foam for 

residential upholstered furniture and mattresses. A significant, secondary market for pentaBDE 

foam includes carpet cushion (rebond) manufacturing because large quantities of off-spec and 

recycled foam are used to manufacture this product. Millions of pounds of foam that is flame 

retarded with pentaBDE or an alternative have been, and will be, sold and used in homes 

throughout the United States as carpet cushions. Direct exposure to millions of consumers from 

these sources is possible. Recent studies have reported PBDE congeners in house dust (Rudel et. 

al., 2003; Stapleton et. al., 2004). 

Inhalation Exposure 

As discussed earlier, inhalation exposure can occur from dust, vapor and mist. Flame retardant 

chemicals that are incorporated into polyurethane foam will not result in consumer exposure to 

mist. However, recent studies of indoor air quality suggest that volatilization of PBDEs from 

treated furniture foam results in human exposure to PBDEs via inhalation (Wilford et. al., 2003; 

Harrad et.al., 2004). This poses a potential, long-term pathway for inhalation exposure. Reactive 

flame retardants may result in a lower potential for exposure than additive flame retardants 

because the flame retardant should be bound within the foam matrix and is expected to be less 

available for release and subsequent exposure. 

Dermal Exposure 

Dermal exposure is also possible from direct contact with furniture, carpet padding and 

mattresses that have been treated with flame retardant chemicals. This pathway and route for 

flame retardants in foam is difficult to assess or quantify because foam is typically covered by 

textiles or carpet. Still, there is potential for direct contact if the foam is exposed. Additionally, it 

is expected that as carpet padding ages, foam dust will be generated and become airborne with 

traffic on carpet. This presents a particular exposure potential for children, who spend time on 

the floor. Dermal exposure is also possible when volatile chemicals deposit onto dust that 

subsequently settles on household surfaces. This potential pathway is expected to be greater for 

additive chemicals than for reactives. 

3-15
 
Ingestion 

Ingestion is another route of exposure to consumers that should be considered during a risk 

evaluation. As for dermal exposure, young children can be similarly exposed to household dust 

containing flame retardants: children are known to ingest larger amounts of household dust than 

adults. Mouthing of furniture, bedding and other materials are also possible routes of exposure 

for young children. 

Miscellaneous and Historical Consumer Uses (Automobiles) 

PentaBDE and other flame retardants have been used in flexible and rigid foam seating and other 

components of automobile interiors. Industry has been shifting from pentaBDE in this 

application over the past several years. However, the foam in automobile seats must still meet 

applicable fire safety standards. Therefore, flame retardants are still used. There is one additional 

pathway and route of exposure associated with foam in automobile seating that has not been 

previously discussed. Studies have shown that a phenomenon known as “fogging” occurs inside 

vehicles when components of plastics and foam volatilize during use and deposit on windshields, 

creating a film. This typically occurs due to the elevated temperatures in closed autos that are left 

in direct sunshine during summer months. Additive chemicals vaporize from foam at these high 

temperatures. Fogging is generally associated with plasticizers, but flame retardants and other 

additives can also volatilize and contribute to this effect (Bradford et al., 1996). 

3-16
 
4.0 FLAME-RETARDANT ALTERNATIVES EVALUATIONS 

In order to evaluate chemical alternatives for flame retarding furniture foam, all of the factors 

discussed in prior sections of this report must be considered, including toxicology, exposure, 

type of flame-retardant chemical, efficacy of use within existing manufacturing systems, 

availability and viability of non-chemical alternatives, cost and performance. This report does 

not include information on performance testing or cost. 

This section summarizes the toxicological and exposure characteristics of each chemical in 

alternative flame-retardant formulations that are considered viable substitutes for pentaBDE use 

in flexible polyurethane foam. Chemical components less than 1 percent by weight were not 

considered in this assessment. The characteristics of the chemicals in each formulation are 

summarized qualitatively in Section 4.1 using a relative ranking scheme and more detailed 

characteristics of the chemicals in each formulation are presented in Section 4.2. 

These evaluations of flame-retardants are not full risk assessments, but do provide screeninglevel information on the hazard concerns and potential routes of exposure associated with the 

chemical components. Chemical risk is composed of two parts: hazard and exposure. The 

hazards evaluated in this report were the potential for human health effects and ecotoxicity. 

Exposure refers to the amount of material to which workers, the community or the environment 

come into contact. The toxicological information summarized in these evaluations is based on 

existing information and will provide the basis for identifying unmet data needs. The exposure 

potential is derived from simple criteria applied to the physical, chemical, and environmental fate 

properties of the chemicals. A full exposure assessment would consider the quantity, frequency, 

duration and route of exposure. Understanding the exposure routes and pathways is critical to 

conducting an exposure assessment. The concentration of a chemical in the mixture would factor 

into the overall exposure assessment and, therefore, the potential risk associated with the 

commercial formulations of the flame retardant alternatives. 

4.1 Summary of Flame-Retardant Chemical Alternatives 

Table 4-1 presents a qualitative summary of toxicological and exposure characteristics of the 

chemicals in each formulation considered in the alternatives analysis. The table qualitatively 

summarizes toxicological endpoints and exposure routes for each chemical, including seven 

human health effects, two ecotoxicity effects and two environmental endpoints and six routes of 

occupational, general population and aquatic exposure. Each of these endpoints is explained in 

Table 4-2. 

Each toxicological endpoint in Table 4-1 is assigned a rating of L, M, or H to indicate whether 

the chemical has a low (L), medium (M), or high (H) hazard concern. If the L, M, or H indicator 

is bold or colored, then the assignment was made using experimental data on the chemical. If the 

L, M, or H indicator is italicized, then experimental data were not available for that chemical and 

the assignment was estimated using structure activity relationships (SAR) analysis involving 

modeling techniques and professional judgment. Similarly, each exposure route is assigned a 

rating of Y (yes) or N (no) to indicate whether that exposure route may occur for each chemical. 

4-1
 
Table 4-1 Screening Level Toxicology and Exposure Summary 

L = Low hazard concern N = No *Ongoing studies may result in a change 

M1 = Moderate hazard concern Y = Yes ▲Persistent degradation products expect

H = High hazard concern P = Yes for pure chemical L, 

M1 , or H = Endpoint assigned using estimated values and professional judgment (Structure Activity Relationships) 

Company Chemical` 

% in Formulation3 

Human Health Effects Ecotoxicity Environmental Potential Ro

Cancer Hazard 

Skin Sensitizer

Reproductive

Developmental 

Neurological

Systemic

Genotoxicity

Acute

Chronic

Persistence 

BioaccumulationWorker 

Inhalation 

Dermal

Ingestion 

Albemarle ANTIBLAZE 180 and 

ANTIBLAZE 195 

Albemarle  Tris(1,3-dichloro-2-propyl)Phosphate 

CAS # 13674-87-8 ANTIBLAZE 182 and ANTIBLAZE 205 

95% M L M M L M M M M M L N Y Y 

Proprietary A Chloroalkyl phosphate (1) M L M M L M M M M M L N Y Y 

Proprietary B Aryl phosphate L L 

M* M* M 

M* L H H L M N Y Y 

Albemarle 

Triphenyl Phosphate CAS # 115-86-6 ANTIBLAZE V500 Proprietary C Chloroalkyl phosphate (2) 

L 

M 

L 

M 

L 

M* 

L 

M* 

L L 

M M 

L L 

H 

M 

H 

M 

L 

M 

L 

L 

Y 

N 

Y 

Y 

Y 

Y 

Albemarle 

Proprietary B Aryl phosphate L L 

M* M* M 

M* L H H L M N Y Y 

Triphenyl Phosphate CAS # 115-86-6 SAYTEX RX-8500 Proprietary D Reactive brominated flame retardant 

L L L L L M L H H L L Y Y Y 

L M L L M M L M M 

L▲ L N Y Y 

Proprietary B Aryl phosphate L L 

M* M* M 

M* L H H L M N Y Y 

Triphenyl Phosphate CAS # 115-86-6 L L L L L M L H H L L Y Y Y 

1 The moderate designation captures a broad range of concerns for hazard. 2 More information on degradation products can be found in sections 4.1.1 and 5.1. 3 Chemical concentrations are listed in descending order; only chemicals with concentrations greater than one percent in the formulation were eva

4-2 
Table 4-1 Screening Level Toxicology and Exposure Summary 

L = Low hazard concern N = N o *Ongoing studies may result in a change 

M4 = Moderate hazard concern Y = Yes ▲Persistent degradation products expect

H = High hazard concern P = Yes for pure chemical L,

M1, or

H = Endpoint assigned using estimated values and professional judgment (Structure Activity Relationships)

Human Health Effects Ecotoxicity Environmental Potential Ro

Worker 

Company Chemical 

% in Formulation6

Cancer Hazard 

Skin Sensitizer 

Reproductive 

Developmental 

Neurological 

Systemic 

Genotoxicity 

Acute 

Chronic 

Persistence 

Bioaccumulation 

Inhalation 

Dermal 

Ingestion 

Albemarle SAYTEX RZ-243 

Proprietary E Tetrabromophthalate diol diester L 

L

L* L* L

M* L

L H 

L▲ L N Y Y 

Proprietary B Aryl phosphate 

L

L

M* M* M

M* L H 

H

L

M N Y Y 

Triphenyl Phosphate CAS # 115-86-6 

L

L

L

L

L

M

L H 

H

L

L Y Y Y 

Ameribrom FR513 

Tribromoneopentyl Alcohol CAS # 36483-57-5 

M

L

M

M

M

M

M

M M 

L L Y Y Y 

Great Lakes 

Firemaster 550 Proprietary F Halogenated aryl ester

L

L

M

M

L

M

L

H H 

L▲ L N Y Y 

Proprietary G Triaryl phosphate, isopropylated

L

L

M* M* M

M* L H 

H

L

M N Y Y 

Triphenyl Phosphate CAS # 115-86-6 

L

L

L

L

L

M

L H 

H

L

L Y Y Y 

Proprietary H Halogenated aryl ester

L

L

M

M

L

M

L

H H 

L▲ L N Y Y 

Great Lakes 

Firemaster 552 

Proprietary F Halogenated aryl ester

L

L

M

M

L

M

L

H H 

L▲ L N Y Y 

Proprietary G Triaryl phosphate, isopropylated

L

L

M* M* M

M* L H 

H

L

M N Y Y 

Triphenyl Phosphate 

CAS # 115-86-6 

L

L

L

L

L

M

L H 

H

L

L Y Y Y 

Proprietary H Halogenated aryl ester

L

L

M

M

L

M

L

H H 

L▲ L N Y Y 

4 The moderate designation captures a broad range of concerns for hazard. 5 More information on degradation products can be found in sections 4.1.1 and 5.1. 6 Chemical concentrations are listed in descending order; only chemicals with concentrations greater than one percent in the formulation were eva
Table 4-1 Screening Level Toxicology and Exposure Summary 

L = Low hazard concern N = N o *Ongoing studies may result in a change 

M1 = Moderate hazard concern Y = Yes ▲Persistent degradation products expect

H = High hazard concern P = Yes for pure chemical L,

M1, or

H = Endpoint assigned using estimated values and professional judgment (Structure Activity Relationships)

Human Health Effects Ecotoxicity Environmental Potential Ro

Worker 

Company Chemical 

% in Formulation3

Cancer Hazard 

Skin Sensitizer 

Reproductive 

Developmental 

Neurological 

Systemic 

Genotoxicity 

Acute 

Chronic 

Persistence 

Bioaccumulation 

Inhalation 

Dermal 

Ingestion 

Supresta AB053 

Tris(1,3-dichloro-2-propyl)Phosphate 

CAS # 13674-87-8 

M

L

M

M

L

M

M

M

M

M

L N Y Y 

Supresta AC003 

Proprietary I Organic phosphate ester 92-99% L 

L

L

L

L

M

L H 

H

H

L P Y Y 

Triphenyl Phosphate CAS # 115-86-6 1-8% 

L

L

L

L

L

M

L H 

H

L

L Y Y Y 

Supresta AC073 

Triphenyl Phosphate CAS # 115-86-6 38-48% 

L

L

L

L

L

M

L H 

H

L

L Y Y Y 

Proprietary J Aryl phosphate 40-46% 

L

L

L

L

L

M

M* L

H

L

L Y Y Y 

Proprietary K Aryl phosphate 12-18% 

L

L

L

L

L

M

L

L

L

L

L P Y Y 

Proprietary L Aryl phosphate 1-3% 

L

L

L

L

L

M

L

L

L

L

L P Y Y 

Supresta Fyrol FR-2 

Tris(1,3-dichloro-2-propyl)phosphate 

CAS # 13674-87-8 99% 

M

L

M

M

L

M

M

M

M

M

L N Y Y 

1 The moderate designation captures a broad range of concerns for hazard. 2 More information on degradation products can be found in sections 4.1.1 and 5.1. 3 Chemical concentrations are listed in descending order; only chemicals with concentrations greater than one percent in the formulation were eva
Table 4-2 Definitions of Toxicological and Environmental Endpoints 

Toxicological 

Category 

Toxicological 

Endpoint Definition 

Human Health Effects Cancer Hazard Any growth or tumor caused by abnormal and uncontrolled cell division. 

Skin Sensitizer Chemical that causes an allergic skin reaction characterized by the presence of 

inflammation; may result in cell death. 

Reproductive Adverse effects on the reproductive systems of females or males, including 

structural/functional alterations to the reproductive organs/system, the related 

endocrine system, mating, or fertility/reproductive success. 

Developmental* Adverse effects on the developing organism (including structural abnormality, 

altered growth, or functional deficiency or death) resulting from exposure prior 

to conception (in either parent), during prenatal development, or postnatally up 

to the time of sexual maturation. 

Neurological Adverse effects on the central or peripheral nervous system. 

Systemic Adverse effect (other than those listed separately) that is of either a generalized 

nature or that occurs at a site distant from the point of entry of a substance: a 

systemic effect requires absorption and distribution of the substance in the 

body. 

Genotoxicity Induction of genetic changes in a cell as a consequence of gene sequence 

changes (mutagenicity), or chromosome number/structure alterations. 

Ecotoxicity Adverse effects observed in living organisms that typically inhabit the wild. The assessment focused 

on effects in aquatic organisms (fish, invertebrates, algae). 

Acute Short-term, in relation to exposure or effect. Exposures are typically less than 

96 hours. 

Chronic Effects observed after repeated exposures. 

Environmental Persistence Attribute of a substance that describes the length of time that the substance 

remains in the environment before it is physically removed by chemical or 

biological transformations. 

Bioaccumulation* Ability of living organisms to concentrate a substance obtained either directly 

from the environment or indirectly through its food. 

*REFERENCE: International Union of Pure and Applied Chemistry, Clinical Chemistry Division Commission on 

Toxicology. Glossary for Chemists of Terms Used in Toxicology (IUPAC Recommendations, 1993). 

4.1.1 Explanation of Toxicological and Environmental Endpoints Rating 

The assessments combine data on flame-retardant alternatives from four sources: (1) publicly 

available measured (experimental) data obtained from a comprehensive literature review; (2) 

measured confidential data from EPA OPPT Confidential Business Information (CBI) databases; 

(3) SAR-based estimations from EPA’s New Chemical Program’s P2 Framework and 

Sustainable Futures predictive methods; (4) professional judgment of EPA staff who identified 

experimental data on closely related analogs; and (5) confidential studies submitted by chemical 

manufacturers. When experimental data were lacking, the expert judgment of scientists from 

EPA’s New Chemical Program was used to assess physical/chemical property, environmental 

fate, aquatic toxicity and human health endpoints. The following abbreviations are used to 

indicate sources of data presented in this assessment: 

• 	 M = Measured/experimental data contained in the open literature; 

• 	 MC = Measured/experimental confidential data contained in EPA OPPT 

CBI databases or submitted by industry; 

4-5
 
• E = Estimations obtained using predictive methodology; and 

• P = Professional judgment of subject matter experts. 

Table 4-3 lists the criteria that were used to interpret the data collected in this document. These 

criteria are used by the EPA New Chemicals Program to assign concern levels to new chemicals 

submitted under the Toxic Substances Control Act (TSCA). EPA has published these criteria in 

several sources including USEPA 1992, USEPA 1994, and USEPA 1995. EPA New Chemicals 

Program persistence criteria have been published in the Federal Register (USEPA 1999). 

Table 4-3 Criteria Used to Assign Concern Levels 

Concern Level Persistence Criteria 

High Half-life in water, soil, or sediment > 180 days 

Moderate Half-life in water, soil, or sediment between 60 and 180 days 

Low Half-life in water, soil, or sediment < 60 days 

Concern Level Bioaccumulation Criteria 

High Bioconcentration factor (BCF) > 5000 

Moderate BCF between 1,000 and 5,000 

Low BCF < 1,000 

Concern Level * Aquatic Toxicity Criteria 

High Value is ≤ 1 mg/L (chronic value <0.1 mg/L) 

Moderate Value is between 1 and 100 mg/L (chronic value 0.1 and 10 mg/L) 

Low Value is >100 mg/L (chronic value >10 mg/L) or log Kow is greater 

than 8 

Concern Level Human Health Criteria 

High Evidence of adverse effects in human populations or conclusive 

evidence of severe effects in animal studies 

Moderate Suggestive animal studies, analog data, or chemical class known to 

produce toxicity 

Low No basis for concern identified 

*If the water solubility is estimated, the chemical will not be considered to have “no effects at saturation” if the 

estimated value is within a factor of 10 percent of the cutoff value. The concern level will be considered low if “no 

effects at saturation” (below the solubility limit). 

More information on the EPA New Chemicals Program criteria used to assign concern levels can 

be found in the Sustainable Futures Pilot Project Interpretive Guidance Document (attached as 

Appendix B to this document) or visit: 

http://www.epa.gov/oppt/newchems/sustainablefutures.htm. 

There are many other hazard classification systems which can be applied to the experimental 

data listed in Section 4.2 and Volume II of this report. Examples of these systems include. 

4-6
 
• 	 Globally Harmonized System of Classification and Labelling of 

Chemicals (GHS) 

http://www.unece.org/trans/danger/publi/ghs/ghs_rev00/00files_e.html 

• 	 EPA's Office of Pesticide Programs (OPP) 

A comparison of the OPP criteria and GHS criteria: 

http://www.epa.gov/oppfead1/international/global/ghscriteriasummary.pdf 

• 	 EU Dangerous Substance Directive (EU) 

Links to the directive, annexes and all amendments can be found here: 

http://europa.eu.int/comm/environment/dansub/main67_548/index_en.htm 

• 	 Annex 6 lists the general labeling and classification requirements for 

dangerous substances and preparations: 

http://europa.eu.int/comm/environment/dansub/pdfs/annex6_en.pdf 

• 	 Canadian Hazardous Products Act (Canada) 

The Consumer Chemical Container Regulations: 

http://laws.justice.gc.ca/en/H-3/SOR-2001-269/text.html 

• 	 The Controlled Products Regulations: 

http://laws.justice.gc.ca/en/H-3/SOR-88-66/text.html 

If measured data pertaining to these criteria are not available, they can be estimated based on use 

of Structure Activity Relationships (SAR) analysis. SAR is the relationship of the molecular 

structure of a chemical with a physicochemical property, environmental fate attribute, and/or 

specific effect on human health or an environmental species. These correlations may be 

qualitative (simple SAR) or quantitative (quantitative SAR, or QSAR). Information on EPA’s 

use of SAR analysis has been published in USEPA 1994. 

SAR estimations for several physical and chemical properties were obtained using the models of 

EPA’s P2 Framework. The P2 Framework is an approach to risk-screening that incorporates 

pollution prevention principles in the design and development of chemicals. These models are 

screening level methods and are intended to be used when data are unavailable or to supplement 

available data. They are not intended to replace data from well-designed studies. For 

physical/chemical properties and environmental fate parameters, estimates were obtained from 

the Estimations Program Interface for Windows (EPIWIN) suite methodology. These methods 

were used to obtain melting point, boiling point, vapor pressure, octanol/water partition 

coefficient, water solubility, Henry’s Law constant, atmospheric oxidation rate, biodegradation 

potential, soil adsorption coefficient, bioconcentration factor, hydrolysis rate, volatilization rates 

and removal in a sewage treatment plant as applicable. For aquatic toxicity potential, EPA’s 

Ecological Structure Activity Relationships (ECOSAR) estimation program was used. This 

methodology uses chemical structure to estimate toxicity of an industrial chemical to fish, 

invertebrates, and algae in the surface water to which the chemical has been discharged. The 

program determines both acute (short-term) toxicity and, when available, chronic (long-term or 

delayed) toxicity. The potential for a chemical to cause cancer in humans was estimated using 

OncoLogic. This program uses a decision tree based on the known carcinogenicity of chemicals 

4-7
 
with similar chemical structures, information on mechanisms of action, short-term predictive 

tests, epidemiological studies, and expert judgment. All estimates obtained in this project were 

reviewed by EPA scientists with expertise in the appropriate field. 

The persistence of a chemical substance in a screening assessment is based on determining the 

importance of removal processes that may occur once a chemical enters the environment. As 

noted above, chemicals with a half-life of less than 60 days are expected to be of low concern for 

persistence based on the criteria that were used to interpret the data collected in this document. 

The persistence screening assessment does not directly address the pathways that a flame 

retardant might enter the environment (e.g., volatilization or disposal in a land fill) and focuses 

instead on the removal processes that are expected to occur once it is released to air, water, soil, 

or sediment. Determining how a chemical enters the environment is typically a component of a 

complete exposure assessment or life cycle analysis and is discussed in Section 3. Similarly, the 

persistence screening assessment does not address what might happen to a chemical substance 

throughout its life cycle, such as disposal during incineration of consumer or commercial 

products (incineration is discussed briefly in Section 5.1). 

Environmental removal processes are generally divided into two categories: chemical and 

biological. One of the most important chemical degradation processes is hydrolysis. The 

importance of hydrolysis can be determined from experimental data (on both the compound of 

interest and closely related analogs) and by using the half-life obtained from the models within 

EPIWIN. Photolysis may also be an important environmental removal process and was 

considered in this assessment when experimental data were available. Estimation methods for 

photolysis are not available within EPA’s Sustainable Future pilot project. 

Biodegradation is also considered in determining the persistence of a chemical substance in the 

environment. If experimental data on the biodegradation of a chemical substance are not 

available, then the potential of the chemical to undergo this process can be assessed from the 

results of the EPIWIN models. These models fall into three classes: 

1. 	 Probability of rapid biodegradation models based on linear and non-linear 

regressions that estimate the probability that a chemical substance will 

degrade fast; 

2. 	 Expert survey models – semi-quantitative models that determine the rate 

of ultimate and primary biodegradation; and 

3. 	 Probability of ready biodegradability. 

The first set of models are useful for determining if a chemical substance has the potential to 

biodegrade quickly in the environment, but do not provide a quantitative indication of its halflife. If a chemical is likely to biodegrade quickly its half-life is expected to be less than 60 days 

and, therefore, it is expected to have a low concern for persistence. The results of the estimates 

from the first set of models are used in concert with the semi-quantitative output from the second 

set of models, which include an ultimate and primary survey model for evaluating persistence. 

These models provide a numeric result, ranging from 1 to 5, to provide an indication of the 

amount of time required for complete mineralization (ultimate degradation) and removal of the 

parent substance (primary degradation) of the test compound. The numeric result is converted to 

4-8
 
a more meaningful time frame for removal for the user based on the scheme presented in the 

following table. The results from the ultimate degradation model can also be used to estimate 

the half-life for a chemical, which is also provided in Table 4-4. 

Table 4-4 Information for Estimating Half-Life 

Model Results for Primary 

and Ultimate Time for Removal 

Approximate Half-Life (Days, 

Based on ultimate) 

>4.75 Hours 0.17 

4.75 to >4.25 Hours to Days 1.25 

4.25 to >3.75 Days 2.33 

3.75 to >3.25 Days to Weeks 8.67 

3.25 to >2.75 Weeks 15 

2.75 to >2.25 Weeks to Months 37.5 

2.25 to >1.75 Months 60 

#1.75 Recalcitrant 180 

The third set of models (also known as MITI models), and the ready biodegradability test that 

they correspond to, are more applicable to determining a chemical’s potential for removal in a 

sewage treatment plant than its persistence in the environment. 

When determining environmental persistence, screening assessments also consider the potential 

persistence of breakdown products resulting from biodegradation and chemical removal 

processes. This assessment is performed because of the potential for human and environmental 

exposure to persistent breakdown products. Breakdown products resulting from hydrolysis can 

be determined experimentally or by using professional judgment based on analogs with similar 

functional groups. Breakdown products may also be reported in experimental biodegradation 

tests or can be determined using professional judgment. When the rate for ultimate degradation is 

much slower than that for primary degradation, the potential for persistent breakdown products 

exists. 

4.1.2 Explanation of Exposure Route Rating 

Six exposure routes are presented for each chemical, including two occupational exposure routes, 

three general population exposure routes and one aquatic exposure route. Each of these potential 

routes is assigned a Y (yes, exposure may occur) or an N (no, exposure is not likely to occur). 

The potential for occupational exposure is determined by the physicochemical properties of the 

pure material. If the flame retardant is commonly manufactured or formulated as a liquid and the 

vapor pressure indicates that it is not expected to volatilize, then a “P” indicates that the potential 

for worker inhalation exposure is expected to be limited to those situations when the material is 

in a purified form that could contribute to dust-related exposure. The exposure routes are based 

on the state of the pure compound or representative pure compound unless further use 

information has been provided. The thresholds for each exposure route were adapted from EPA’s 

New Chemicals Program, except as noted. 

4-9
 
Occupational Exposure 

Inhalation 

Liquids4

: If a liquid has a vapor pressure amenable to volatilization, then the liquid will 

evaporate and present the potential for a person to inhale the vapor. Occupational exposure may 

occur when the vapor pressure is greater than 1 x 10-06 mm Hg at 25 degrees Celsius. Liquids 

may also be inhaled as a mist if the liquid chemical is sprayed during transfer or application 

operations. 

Solids5: Occupational exposure may occur in all cases when processing or handling solids. 

Solid-state chemicals may be used in a crystalline, packed, or powder form. In all cases, a solid 

chemical may produce particulate dust as a byproduct of manufacturing or use operations. When 

this occurs, a worker may inhale the dust particles while working with the chemical. 

Gases6

: Occupational exposure may occur in all cases when processing or handling gases. 

Gaseous chemicals should always be contained in cylinders to enable their use; however, if they 

are uncontained, gaseous chemicals result in exposure to workers. Routine exposure to gaseous 

chemicals is not expected unless there is an accident. However, fugitive releases may occur when 

connecting transfer lines. 

Dermal 

Dermal exposures may occur to workers while handling liquid or solid flame-retardant 

chemicals. In general, workers handling liquid chemicals may be exposed to the chemical by full 

hand immersion, splashing, or spraying depending upon the manufacturing processes utilized at a 

facility. Workers handling solid chemicals can be exposed on the surface of their hands as well 

as from particulate dust that may settle onto their skin. All chemicals are expected to present a 

dermal exposure to workers in this report. The use of personal protective equipment may 

mitigate these exposures. 

Ingestion 

Exposures associated with ingestion are not included for the purposes of this screening level 

assessment; however, workers may incidentally ingest flame-retardant chemicals through 

ingestion of contaminated food and water. Ingestion may occur if the chemical is suspended in 

air as a particulate or a mist as part of manufacturing, and then recondenses or flocculates into 

food or drinking sources. Alternatively, secondary ingestion may occur as a result of inhaling the 

mist or dust form of the chemical, and then swallowing residual chemical in the nasal or 

esophageal passageways. 

4

 Liquids are substances that have a melting point less than 25 degrees Celsius and a boiling point greater than 25 
 

degrees Celsius. 
 5

 Solids are substances that have a melting point of greater than 25 degrees Celsius. 
 6

 Gases are substances that have a boiling point less than 25 degrees Celsius. 
 

4-10
 
General Population Exposure 

Inhalation 

Liquids7: If the liquid has a vapor pressure amenable to volatilization from the product in which 

the chemical is carried, a person may inhale the liquid as a vapor while in contact with the 

product or substance carrying the chemical. For this report, general population exposure may 

occur if the chemical vapor pressure is greater than 1 x 10-06 mm Hg at 25 degrees Celsius and if 

the chemical is additive, not reactive8. 

Solids9

: General population exposure may occur if the vapor pressure is greater than 1 x 10-06 

mm Hg at 25 degrees Celsius and if the chemical is not reactive. Although not included in this 

screening level assessment, as foam products age and break down, particulate (matter) may be 

released from the foam products which may contain flame-retardant chemicals. This flameretardant foam dust may be present in carpets or in flame-retardant furniture and could represent 

an exposure to the general population. 

Gases10: General population exposure is not expected to occur if the chemical is a gas, since 

gases would not be intentionally contained outside of the manufacturing arena (excluding 

accidental releases). 

Dermal 

Dermal exposures may occur to the general population while handling products or substances 

containing the flame-retardant chemical, if the flame-retardant chemical is not reactive. 

Ingestion 

The general population may be exposed to a flame-retardant chemical if the chemical has water 

solubility greater than 1 x 10-06 grams/liter, is dispersible, or has the potential to leach. These 

would indicate that the chemical is easily absorbed in water and may be found in surface and 

groundwater sources as a result of disposal and environmental releases of the chemical. 

Aquatic Exposure 

The flame-retardant chemical may present an aquatic exposure if the water solubility of the 

compound is greater than 1 x 10-06 grams/liter or the compound is dispersible in water. 

7

 Liquids are substances that have a melting point less than 25 degrees Celsius and a boiling point greater than 25 
 

degrees Celsius. 
 8

 Reactive chemicals (as opposed to additive chemicals) are those that are incorporated into the foam by new 
 

chemical bonds that are formed between the substrate and the flame retardant. Therefore, they are not assumed to be 
 

available for exposure. 
 9

 Solids are substances that have a melting point of greater than 25 degrees Celsius. 
 10 Gases are substances that have a boiling point less than 25 degrees Celsius. 
 

4-11
 
4.2 Chemical Summary Assessments 

The following subsections (4.2.1 through 4.2.19) contain summaries of the toxicity and exposure 

data for 15 chemicals that are components of the flame retardant formulations assessed in this 

report. These summary data were used to develop the hazard concern and exposure conclusions 

that are presented in Table 4-1. The studies from which these data were derived are summarized 

in Volume 2 of this report, entitled Chemical Hazard Reviews. 

4.2.1 Triphenyl Phosphate 

Record ID: Triphenyl Phosphate CAS No. 115-86-6 

P 

O 

O 

OO 

MW: 326.29 

MF: C18H15O4P 

Physical Forms: 

Neat: Solid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: c1ccccc1OP(=O)(Oc2ccccc2)Oc3ccccc3 

Name: Phosphoric acid, triphenyl ester 

Synonyms: Triphenyl phosphate; TPP 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: High 

° Based on systemic effects and eye irritation. 

4-12 
Record ID: Triphenyl Phosphate CAS No. 115-86-6 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) 50.5 (M) 

Boiling Point (deg C) 245 @ 11 mm Hg (M); 389 (E) 

Vapor Pressure (mm Hg) 6.3x10-6 (M) 

Water Solubility (g/L) 1.9x10-3 (M) 

Log Kow 4.59 (M) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC (atmm3

/mole) 1.2 × 10-5 (M) 

Soil Adsorption Coefficient – Koc 2514-3561 (M) 

Bioconcentration Factor – BCF 132-264 (Rainbow Trout); 218-1743 (Fathead 

Minnow) (M) 

Persistence 

Experimental Biodeg Tests 

93.8% removal as DOC in OECD 303A over 20 

days; 50-100% removal within 8 days in river 

die-away; 83-84% over 28 days using MITI II; 

10.3% removal in 40 days under anaerobic 

conditions in river sediment 

Ultimate Biodeg Model Weeks-months (E) 

Primary Biodeg Model Days (E) 

BOD or COD 

Atmospheric Half-life 12 hours (E) 

Hydrolysis Half-life Half-life at 20 degrees C: 366 days@ pH 3; 406 

days @ pH 7, <5 days @ pH 9 (M) 

Volatilization Half-life for Model River 13 days (E) 

Volatilization Half-life for Model Lake 152 days (E) 

Removal in Sewage Treatment Plant 61% (E) 

Ready Biodegradability Ready biodegradable (M) 

Byproducts 

Degradation Products Diphenyl phosphate, phenol (M) 

Metabolites 

4-13
 
Record ID: Triphenyl Phosphate CAS No. 115-86-6 

ECOTOXICITY: 

ECOSAR Class Esters-phosphate 

Comments * = based on geometric mean of experimental 

values 

Acute Toxicity 

Fish LC5O 96-h LC50, 0.870 mg/L (M) 

Daphnid LC5O 

48-h LC50, 1.2 mg/L (MC) 

48-h LC50, 1.1 mg/L* (M) 

Green Algae EC5O 96-h EC50, 2.0 mg/L (M) 

Chronic Toxicity 

Fish ChV 0.140 mg/L (MC); 0.09 (F96/ACR10)(E) 

Daphnid ChV 0.1 mg/L (D48/ACR10) (E) 

Green Algae ChV 

≥0.140 mg/L (E) 

< 0.600 mg/L (M) 

0.5 mg/L (A96/ACR4) (E) 

Overall Hazard Concern for Aquatic 

Toxicity HIGH 

HEALTH EFFECTS: 

Absorption 

Poor thru skin as neat solid, moderate thru skin in 

solution; moderate thru lungs and GI tract based 

on closely related analogs (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern for 

Carcinogenicity LOW 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low; Rat, mouse, rabbit, oral, LD50 > 5000 

mg/kg (M); Mammal, dermal, LD50 > 8000 

mg/kg (MC); rabbit, dermal, LD50 > 7900 mg/kg 

(M) 

Eye Irritation Moderate; Mild eye irritation, rabbits (M, MC) 

Skin Irritation Low; Negative, rabbits (M) 

Skin Sensitizer Low; negative in guinea pigs (MC), very low 

incidence in humans (M) 

4-14
 
Record ID: Triphenyl Phosphate CAS No. 115-86-6 

Reproductive Effects 

Low; 91-112-d reproductive 

(incomplete)/developmental study, rats, diet, no 

reproductive effects, NOAEL = 690 mg/kg/day 

(1%) (M) 

Developmental Effects 

Low; 91-112-d reproductive/developmental 

study, rats, diet, no developmental effects, 

NOAEL = 690 mg/kg/day, maternal LOAEL = 

690 mg/kg/day (1%) (M) 

Immune System Effects 

Low; 120-d repeated-dose study, rats, diet, no 

immune system effects, NOAEL = 700 

mg/kg/day (1%) (M) 

Neurotoxicity 

Low; negative in delayed neurotoxicity studies in 

the hen at up to 10,000 mg/kg/day (oral, 6 dosing 

days) and in the cat at 700 mg/kg (subcutaneous, 

single dose) (M); 120-d repeated-dose 

neurotoxicity screening study, rats, diet, no 

neurobehavioral effects, NOAEL = 711 

mg/kg/day (1.0%) (M) 

Genotoxicity/Mutagenicity 

Low; Negative in Ames assay and Negative in 

forward mutation assay, mouse lymphoma cells 

in vitro, with and without metabolic activation 

(M); Negative in mitotic gene conversion assay 

in Saccharomyces cerevisiae with and without 

activation (M) 

Systemic Effects 

Moderate; 35-d repeated-dose study (inadequate), 

rats, diet, increased relative liver weight at 0.5%, 

NOAEL = 0.1%; 120-d repeated-dose 

(neurotoxicity screening) study, rats, diet, 

decreased body weight gain without decreased 

food consumption, NOAEL = 161 mg/kg/day 

(0.25%), LOAEL = 345 mg/kg/day (1%); 21-d 

repeated-dose study (inadequate), rabbits, dermal, 

systemic effects (M) 

Overall Hazard Concern for Non-Cancer 

Health Effects MODERATE 

4-15
 
4.2.2 Tribromoneopentyl alcohol 

Record ID: Tribromoneopentyl alcohol CAS No. 36483-57-5 

O Br

Br 

Br 

MW: 324.84 

MF: C5H9Br3O 

Physical Forms: 

Neat: Solid 

As Formulated: 

Use: Flame retardant, 

reactive 

SMILES: OCC(CBr)(CBr)CBr 

Name: 1-Propanol, 2,2-dimethyl-, tribromo derivative (FRA-12) 

Synonyms: Tribromoneopentyl alcohol 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Moderate 

° Based on reproductive effects, developmental effects, neurotoxicity, genotoxicity/mutagenicity, 

systemic effects, eye irritation, and skin irritation. 

4-16
 
Record ID: Tribromoneopentyl alcohol CAS No. 36483-57-5 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) 62-67 (M) 

Boiling Point (deg C) 300 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) 6.2x10-5 (E) 

Water Solubility (g/L) 2 (M) 

1.9 at 20.1 degrees C (MC) 

Log Kow 2.6 (MC) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 1.14 x10-10 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 22.9 (E) 

Bioconcentration Factor – BCF 10.8 (E) 

Persistence 

Experimental Biodeg Tests 

2.5% CO2 evolution over 28 days in OECD 310 

test (MC); 77% removal as DOC using OECD 

302B in 36 days after a 10-day lag period (MC) 

Ultimate Biodeg Model Weeks-months (E) 

Primary Biodeg Model Days-weeks (E) 

BOD or COD 

Atmospheric Half-life 25 hours (E) 

Hydrolysis Half-life 

Volatilization Half-life for Model River Negligible (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 2.55% (E) 

Ready Biodegradability Not ready biodegradable (MC) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-17
 
Record ID: Tribromoneopentyl alcohol CAS No. 36483-57-5 

ECOTOXICITY: 

ECOSAR Class Haloalcohols 

Acute Toxicity 

Fish LC5O 96-h LC50=32 mg/L (MC) 

Daphnid LC5O 48-h EC50=64 mg/L (MC) 

Green Algae EC5O 72-h EC50=28 mg/L (MC) 

Chronic Toxicity 

Fish ChV 3.2 mg/L (F96/ACR 10) (E) 

Daphnid ChV 6.4 mg/L (D48/ACR10) (E) 

Green Algae ChV 7 mg/L (GA72/ACR4) (E) 

Overall Hazard Concern for 

Aquatic Toxicity MODERATE 

HEALTH EFFECTS: 

Absorption Nil thru skin as neat material; moderate thru skin when in 

solution; good absorption expected thru lungs and GI tract (P) 

CANCER HEALTH EFFECTS: 

Experimental data Moderate by analogy to a closely related compound; 2-yr study, 

male/female, rats, mice, neoplasms in multiple organs (P) 

OncoLogic Results Moderate 

Overall Hazard Concern for 

Carcinogenicity MODERATE 

4-18
 
Record ID: Tribromoneopentyl alcohol CAS No. 36483-57-5 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low; Rat oral LD50 = 1630 to >2000 mg/kg (M,MC), effects on 

bladder (M); Rat dermal LD50 >2000 mg/kg (MC); Rat 7-h 

inhalation LC50 > 714 mg/m3 (mixture, inadequate study) (M) 

Eye Irritation Moderate; Mild eye irritant in rabbits (M); 

moderate eye irritant in rabbits (MC) 

Skin Irritation Moderate; Mild skin irritant in rabbits 24 hr exposure (M) but 

not 4 hour exposure (MC) 

Skin Sensitizer Low; negative in mouse local lymph node assay (MC) 

Reproductive Effects 

Moderate by analogy to a closely related compound; 

repro/fertility study, mice, diet, 141, 274, 589 mg/kg/day, 

decreased fertility and litter size, increased gestation length, 

LOAEL = 141 mg/kg/day (P) 

Developmental Effects 

Moderate by analogy to a closely related compound; 

repro/fertility study, mice, diet, 141, 274, 589 mg/kg/day, 

decreased pup weight, NOAEL = 141 mg/kg/day (P) 

Immune System Effects 

Neurotoxicity Moderate based on bromo substituents (P) 

Genotoxicity/Mutagenicity 

Moderate; Positive, mutagenic in L5178Y mouse lymphoma 

cells with activation by rat S9 (MC); Positive, chromosomal 

aberrations, in vitro (MC); Positive, mouse micronucleus assay, 

females (MC); Positive, Salmonella with activation from 

hamster S9 (M, MC); Negative, Salmonella without activation or 

with activation by rat S9 (M, MC); Negative, yeast, mitotic gene 

conversion assay with or without activation (M) 

Systemic Effects 

Moderate; 30-d repeated-dose study, rats, oral, diet, 10, 30, 100, 

300 mg/kg/day, kidney, ureter, bladder, blood changes, 

NOAEL = 30 mg/kg/day (M,P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-19
 
4.2.3 Tris(1,3-dichloro-2-propyl) Phosphate 

Record ID: Tris(1,3-dichloro-2-propyl) Phosphate CAS No. 13674-87-8 

P 

O 

O 

OO 

Cl 

Cl 

Cl 

Cl 

Cl 

Cl 

MW: 430.91 

MF: C9H15Cl6O4P 

Physical Forms: 

Neat: Liquid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: ClCC(CCl)OP(=O)(OC(CCl)CCl)OC(CCl)CCl 

Name: 2-Propanol, 1,3-dichloro-, phosphate (3:1) 

Synonyms: Tris(1,3-dichloro-2-propyl) Phosphate, TDCPP; TDCP 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Moderate 

° Based on reproductive effects, developmental effects, genotoxicity/mutagenicity, systemic 

effects, eye irritation, and skin irritation. 

4-20
 
Record ID: Tris(1,3-dichloro-2-propyl) Phosphate CAS No. 13674-87-8 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) -58 (M) 

Boiling Point (deg C) 236-237 @ 5 mm Hg (M); Slowly decomposes 

>200 (M) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) 0.042 (M) 

0.018 (MC) 

Log Kow 

2.40 (M) 

3.69 (MC) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC (atm-m3

/mol) 2.61x10-9 (E) 

Soil Adsorption Coefficient – Koc 9222 (E) 

Bioconcentration Factor – BCF 3-5 (Goldfish); 3-113 (Killifish) (M) 

Persistence 

Experimental Biodeg Tests 

0% CO2 uptake over 28 days in OECD 301B test; 

1% by BOD over 28 days in MITI test; 0% by 02 

uptake over 28 days in OECD 302C test; 0­

18.5% 02 uptake over 7-14 days in river die-away 

(M) 

Ultimate Biodeg Model Recalcitrant (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 7.1 hours (E) 

Hydrolysis Half-life >1 year @ pH 7 

Volatilization Half-life for Model River Negligible (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 3% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-21
 
Record ID: Tris(1,3-dichloro-2-propyl) Phosphate CAS No. 13674-87-8 

ECOTOXICITY: 

ECOSAR Class Esters - phosphate 

Comments * = based on geometric mean of experimental values 

Acute Toxicity 

Fish LC5O 96-h LC50, 1.9 mg/L* (M,MC) 

Daphnid LC5O 48-h LC50, 3.8 mg/L (E) 

Green Algae EC5O 96-h EC50, 12.0 mg/L (M) 

Chronic Toxicity 

Fish ChV 0.200 mg/L* (F96/ACR10) (E) 

Daphnid ChV 0.400 mg/L (D48/ACR10) (E) 

Green Algae ChV 6.0 mg/L (M) 

Overall Hazard Concern for 

Aquatic Toxicity MODERATE 

HEALTH EFFECTS: 

Absorption Good absorption and reaction, all routes 

CANCER HEALTH EFFECTS: 

Experimental data 

2-yr chronic toxicity/carcinogenicity study, rats, diet, 5, 20, 80 

mg/kg/day, increased benign adrenal cortex tumors, testicular 

interstitial cell tumors, and hepatocellular adenomas at 20 and 80 

mg/kg/day (M) 

OncoLogic Results Moderate 

Overall Hazard Concern for 

Carcinogenicity MODERATE 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low; Mouse oral LD50= (male) 2670 & (female) 2250 mg/kg; 

Rat oral LD50 = 3160 mg/kg; 

Rabbit oral LD50 = 6800 mg/kg; 

Rabbit dermal (24-hr) LD50 >4640 mg/kg (no death, clinical signs 

or gross necropsy lesions)(M) 

Eye Irritation Moderate; Mild reversible conjunctival irritant or negative, rabbits 

(M) 

Skin Irritation Moderate; 4 Hrs: non-irritant; 24 hrs: mild skin irritant, rabbits (M) 

Skin Sensitizer Low; Negative in guinea pigs (MC); Uncertain concern for 

sensitization as substance is a potential alkylating agent (P) 

4-22
 
Record ID: Tris(1,3-dichloro-2-propyl) Phosphate CAS No. 13674-87-8 

Reproductive Effects 

Moderate; Male reproduction study, rabbits, gavage, 12-wk 

exposure, no effects on male fertility or spermatogenesis, NOAEL 

= 200 mg/kg/day (M); 2-yr chronic toxicity/carcinogenicity study, 

rats, diet, 5, 20, 80 mg/kg/day, anomalies of the testes and seminal 

vesicles, NOAEL = 5 mg/kg/day (M) 

Developmental Effects 

Moderate; Developmental toxicity study, gavage, rats, gd 6-15, 25, 

100, 400 mg/kg/day, increased resorptions, decreased fetal 

viability, weight, and length, NOAEL = 100 mg/kg/day. 

Developmental toxicity study, gavage, rats, gd 7-19, 25, 50, 100, 

200, 400 mg/kg/day, decreased fetal viability, NOAEL = 200 

mg/kg/kday (M). 

Immune System Effects 

Low; Uncertain concern for immunotoxicity because substance is 

potentially an alkylating agent; 

Immunotoxicity assay, subcutaneous, mouse, 4 consecutive days, 

0.25, 2.5, 25 mg/kg/day; lymphoid depletion of thymus, reduced 

responses to T-cell & B-cell antigens, NOAEL 0.25 mg/kg/day 

(M) 

Neurotoxicity 

Low; Acute delayed neurotoxicity study, hens, gavage, no 

significant inhibition of brain neurotoxic esterase (NTE) activity at 

10,000 mg/kg; 90-d study, hens, gavage, no behavioral effects or 

histopathological changes indicative of neurotoxicity, NOAEL = 

100 mg/kg/day; 

In developmental toxicity assay, rats, gavage gd 7-19, no adverse 

effect on postnatal neurobehavioral tests of sensory and motor 

function, NOAEL = 200 mg/kg/day (M) 

Genotoxicity/ Mutagenicity 

Moderate; Positive, mutagenicity, Salmonella, with metabolic 

activation; Negative, mutagenicity, mouse lymphoma cells with or 

without activation & hamster lung cells with activation, in vitro; 

Negative, sex-linked recessive lethal, Drosophila in vivo (M) 

Positive only with activation, chromosomal aberrations, in vitro, 

human lymphocytes (MC) & mouse lymphoma cells (M); 

Negative, chromosomal aberrations, in vitro, Chinese hamster 

ovary cells (MC); Negative, sister chromatid exchange, in vitro, 

cell line not reported (MC); Positive with or without activation, 

sister chromatid exchange, in vitro, mouse lymphoma cell; 

Negative, unscheduled DNA synthesis, in vivo, in rat hepatocytes 

(M, MC); Negative, chromosomal aberrations, in vivo, mice (M); 

Negative, micronucleus assay in vivo, mice (MC) 

4-23
 
Record ID: Tris(1,3-dichloro-2-propyl) Phosphate CAS No. 13674-87-8 

Systemic Effects 

Moderate; 2-yr chronic toxicity/carcinogenicity study, rats, diet, 5, 

20, 80 mg/kg/day, increased mortality, decreased body weight, 

anemia, anomalies of the liver, kidneys, testes, seminal vesicles, 

renal cortex, and adrenal cortex, LOAEL = 5 mg/kg/day. 

Inadequate 90-day dietary study, mice, 0.01, 0.04, 0.13, 0.42 and 

1.33% in diet; increased mortality, decreased body weight, 

anemia, increased liver & kidney weight, liver histopathology; 

NOAEL= 0.01% dietary level (M) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-24
 
4.2.4 Proprietary A 

Record ID: Proprietary A: Chloroalkyl phosphate (1) CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Liquid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Chloroalkyl phosphate (1) 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Moderate 

° Based on reproductive effects, developmental effects, genotoxicity/mutagenicity, systemic 

effects, eye irritation, and skin irritation. 

4-25
 
Record ID: Proprietary A: Chloroalkyl phosphate (1) CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) -58 (M) 

Boiling Point (deg C) 236-237 @ 5 mm Hg (M); Slowly decomposes 

>200 (M) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) 0.042 (M) 

0.018 (MC) 

Log Kow 

2.40 (M) 

3.69 (MC) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC (atm-m3

/mol) 2.61x10-9 (E) 

Soil Adsorption Coefficient – Koc 9222 (E) 

Bioconcentration Factor – BCF 3-5 (Goldfish); 3-113 (Killifish) (M) 

Persistence 

Experimental Biodeg Tests 

0% CO2 uptake over 28 days in OECD 301B test; 

1% by BOD over 28 days in MITI test; 0% by 02 

uptake over 28 days in OECD 302C test; 0­

18.5% 02 uptake over 7-14 days in river die-away 

(M) 

Ultimate Biodeg Model Recalcitrant (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 7.1 hours (E) 

Hydrolysis Half-life >1 year @ pH 7 

Volatilization Half-life for Model River Negligible (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 3% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-26
 
Record ID: Proprietary A: Chloroalkyl phosphate (1) CAS No. 

ECOTOXICITY: 

ECOSAR Class Esters - phosphate 

Comments * = based on geometric mean of experimental values 

Acute Toxicity 

Fish LC5O 96-h LC50, 1.9 mg/L* (M,MC) 

Daphnid LC5O 48-h LC50, 3.8 mg/L (E) 

Green Algae EC5O 96-h EC50, 12.0 mg/L (M) 

Chronic Toxicity 

Fish ChV 0.200 mg/L* (F96/ACR10) (E) 

Daphnid ChV 0.400 mg/L (D48/ACR10) (E) 

Green Algae ChV 6.0 mg/L (M) 

Overall Hazard Concern for 

Aquatic Toxicity MODERATE 

HEALTH EFFECTS: 

Absorption Good absorption and reaction, all routes 

CANCER HEALTH EFFECTS: 

Experimental data 

2-yr chronic toxicity/carcinogenicity study, rats, diet, 5, 20, 80 

mg/kg/day, increased benign adrenal cortex tumors, testicular 

interstitial cell tumors, and hepatocellular adenomas at 20 and 80 

mg/kg/day (M) 

OncoLogic Results Moderate 

Overall Hazard Concern for 

Carcinogenicity MODERATE 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low; Mouse oral LD50= (male) 2670 & (female) 2250 mg/kg; 

Rat oral LD50 = 3160 mg/kg; 

Rabbit oral LD50 = 6800 mg/kg; 

Rabbit dermal (24-hr) LD50 >4640 mg/kg (no death, clinical signs 

or gross necropsy lesions)(M) 

Eye Irritation Moderate; Mild reversible conjunctival irritant or negative, rabbits 

(M) 

Skin Irritation Moderate; 4 Hrs: non-irritant; 24 hrs: mild skin irritant, rabbits (M) 

Skin Sensitizer Low; Negative in guinea pigs (MC); Uncertain concern for 

sensitization as substance is a potential alkylating agent (P) 

4-27
 
Record ID: Proprietary A: Chloroalkyl phosphate (1) CAS No. 

Reproductive Effects 

Moderate; Male reproduction study, rabbits, gavage, 12-wk 

exposure, no effects on male fertility or spermatogenesis, NOAEL 

= 200 mg/kg/day (M); 2-yr chronic toxicity/carcinogenicity study, 

rats, diet, 5, 20, 80 mg/kg/day, anomalies of the testes and seminal 

vesicles, NOAEL = 5 mg/kg/day (M) 

Developmental Effects 

Moderate; Developmental toxicity study, gavage, rats, gd 6-15, 25, 

100, 400 mg/kg/day, increased resorptions, decreased fetal 

viability, weight, and length, NOAEL = 100 mg/kg/day. 

Developmental toxicity study, gavage, rats, gd 7-19, 25, 50, 100, 

200, 400 mg/kg/day, decreased fetal viability, NOAEL = 200 

mg/kg/kday (M). 

Immune System Effects 

Low; Uncertain concern for immunotoxicity because substance is 

potentially an alkylating agent; 

Immunotoxicity assay, subcutaneous, mouse, 4 consecutive days, 

0.25, 2.5, 25 mg/kg/day; lymphoid depletion of thymus, reduced 

responses to T-cell & B-cell antigens, NOAEL 0.25 mg/kg/day 

(M) 

Neurotoxicity 

Low; Acute delayed neurotoxicity study, hens, gavage, no 

significant inhibition of brain neurotoxic esterase (NTE) activity at 

10,000 mg/kg; 90-d study, hens, gavage, no behavioral effects or 

histopathological changes indicative of neurotoxicity, NOAEL = 

100 mg/kg/day; 

In developmental toxicity assay, rats, gavage gd 7-19, no adverse 

effect on postnatal neurobehavioral tests of sensory and motor 

function, NOAEL = 200 mg/kg/day (M) 

Genotoxicity/ Mutagenicity 

Moderate; Positive, mutagenicity, Salmonella, with metabolic 

activation; Negative, mutagenicity, mouse lymphoma cells with or 

without activation & hamster lung cells with activation, in vitro; 

Negative, sex-linked recessive lethal, Drosophila in vivo (M) 

Positive only with activation, chromosomal aberrations, in vitro, 

human lymphocytes (MC) & mouse lymphoma cells (M); 

Negative, chromosomal aberrations, in vitro, Chinese hamster 

ovary cells (MC); Negative, sister chromatid exchange, in vitro, 

cell line not reported (MC); Positive with or without activation, 

sister chromatid exchange, in vitro, mouse lymphoma cell; 

Negative, unscheduled DNA synthesis, in vivo, in rat hepatocytes 

(M, MC); Negative, chromosomal aberrations, in vivo, mice (M); 

Negative, micronucleus assay in vivo, mice (MC) 

4-28
 
Record ID: Proprietary A: Chloroalkyl phosphate (1) CAS No. 

Systemic Effects 

Moderate; 2-yr chronic toxicity/carcinogenicity study, rats, diet, 5, 

20, 80 mg/kg/day, increased mortality, decreased body weight, 

anemia, anomalies of the liver, kidneys, testes, seminal vesicles, 

renal cortex, and adrenal cortex, LOAEL = 5 mg/kg/day. 

Inadequate 90-day dietary study, mice, 0.01, 0.04, 0.13, 0.42 and 

1.33% in diet; increased mortality, decreased body weight, 

anemia, increased liver & kidney weight, liver histopathology; 

NOAEL= 0.01% dietary level (M) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-29
 
4.2.5 Proprietary B 

Record ID: Proprietary B: Aryl phosphate CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: Liquid 

Use: Flame retardant, 

additive 

SMILES: 

Name: Aryl phosphate 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: High 

° Based on reproductive effects, developmental effects, neurotoxicity, systemic effects, and eye 

irritation. 

4-30
 
Record ID: Proprietary B: Aryl phosphate CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) 90 (E) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) <10-6 (E) 

Log Kow 6.16 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 7.74x10-8 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 2.6x104

 (E) 

Bioconcentration Factor – BCF 1820 (E) 

Persistence 

Experimental Biodeg Tests 46% ThOD after 28 days in OECD 301F (MC) 

Ultimate Biodeg Model Weeks -months (E) 

Primary Biodeg Model Days-weeks (E) 

BOD or COD 

Atmospheric Half-life 9.3 hours (E) 

Hydrolysis Half-life 

Volatilization Half-life for Model River 605 days (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 93% (E) 

Ready Biodegradability Not ready biodegradable (MC) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-31
 
Record ID: Proprietary B: Aryl phosphate CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phosphate 

Acute Toxicity 

Fish LC5O 96-h LC50, NES (No effects at saturation) (E) 

Daphnid LC5O 48-h LC50, NES (E) 

Green Algae EC5O 96-h EC50, NES (E) 

Chronic Toxicity 

Fish ChV NES (E) 

Daphnid ChV NES (E) 

Green Algae ChV NES (E) 

Overall Hazard Concern 

for Aquatic Toxicity 

HIGH (chronic toxicity and only when 1 or 2 isopropyls are 

present) 

HEALTH EFFECTS: 

Absorption 

Nil thru skin as neat solid; poor thru skin when in solution; poor 

thru lungs and GI tract by analogy to closely related compounds 

(P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern 

for Carcinogenicity LOW 

4-32
 
Record ID: Proprietary B: Aryl phosphate CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low in mixtures; Rat oral LD50 >5000 mg/kg (no deaths), 

>20,000 mg/kg (4/10 deaths); Rat 1-hr inhalation LC50 > 200 

mg/L; Rat dermal LD0 > 2000 mg/kg (no deaths)(M) 

Eye Irritation Moderate in mixtures; Rabbits, very slight eye irritation (M) 

Skin Irritation Low in mixtures; Not irritating to intact or abraded skin in rabbits 

(M) 

Skin Sensitizer Low by analogy to a closely related compound (P) 

Reproductive Effects 

Preliminary results of an unfinished 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening 

test suggest that the reproductive hazard may be moderate, rat, 

oral gavage, ovarian weight effect at ≥25 mg/kg/day, epididymal 

weight effect and reduced fertility at 100 and 400 mg/kg/day 

(MC) 

Developmental Effects 

Preliminary results of an unfinished 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening 

test suggests the developmental hazard may be moderate; rat, oral 

gavage, reduced pre- and post-natal survival at 400 mg/kg/day 

(MC) 

Immune System Effects 

Neurotoxicity 

Moderate in mixtures; acute delayed neurotoxicity assay, hens, 

oral gavage, NOAEL = 12 mg/kg/day for neurotoxic esterase 

(NTE) inhibition, LOAEL = 1000 mg/kg/day; delayed oral 

neurotoxicity, hens, 2 oral treatments 3 weeks apart, transient 

dose-related gait impairment (LOAEL = 12 mg/kg/day), but no 

neurohistopathology at doses as high as 11,700 mg/kg/day (M); 

Also by analogy to closely related compounds and professional 

judgment; neurotoxicity study, hens, oral gavage, 3, 5, 7, 9 g/kg, 

ataxia, neuropathological lesions, LOAEL = 3000 mg/kg; 

neurotoxicity study, hens, oral gavage, 10, 20, 90, 270 

mg/kg/day, ataxia, nerve degeneration, NOAEL = 20 mg/kg/day; 

NTE inhibition (M,P) 

Genotoxicity/Mutagenicity Low by analogy to a closely related compound; Negative, Ames 

assay (P) 

Systemic Effects 

Moderate in mixture (liver effects); 28-d repeated-dose study 

(inadequate), rats, diet, 0.1%, 0.5%, 1.0%, liver effects all doses, 

LOAEL = 0.1% (M); 

Preliminary results of an unfinished a 39-41-day combined 

subchronic toxicity with reproductive/developmental screening 

test suggest that there may be a moderate hazard for subchronic 

toxicity (adrenal and liver effects), rat, oral gavage, adrenal 

weight effect in females, LOAEL = 25 mg/kg/day (MC) 

4-33
 
Record ID: Proprietary B: Aryl phosphate CAS No. 

Overall Hazard Concern 

for Non-Cancer Health 

Effects 

MODERATE

4-34
 
4.2.6 Proprietary C 

Record ID: Proprietary C: Chloroalkyl phosphate (2) CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: Liquid 

Use: Flame retardant, 

additive 

SMILES: 

Name: Chloroalkyl phosphate (2) 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Moderate 

° Based on reproductive effects, developmental effects, systemic effects, eye irritation, skin 

irritation, and skin sensitizer. 

4-35
 
Record ID: Proprietary C: Chloroalkyl phosphate (2) CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) < 20 (P) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <10-6 (MC) 

Water Solubility (g/L) 0.23 (MC) 

Log Kow 2.83 (MC) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 2.74x10-14 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 1.1x104

 (MC); 6.07x106 (E) 

Bioconcentration Factor – BCF 6.64 (E) 

Persistence 

Experimental Biodeg Tests 

37% oxygen uptake after 28 days in OECD 302C 

(MC); 5% degradation in modified Sturm test, 

28 days (MC); 8-15% inhibition to activated 

sludge (MC) 

Ultimate Biodeg Model Recalcitrant (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 1.6 hours (E) 

Hydrolysis Half-life Half-life is greater than 1 year (MC) 

Volatilization Half-life for Model River Negligible (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 44.7% (E) 

Ready Biodegradability Not ready biodegradable (MC) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-36
 
Record ID: Proprietary C: Chloroalkyl phosphate (2) CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phosphate 

Acute Toxicity 

Fish LC5O 

96-h LC50, 9.6 mg/L (E) 

96-h LC50, 52.2 mg/L (MC) 

Daphnid LC5O 

48-h EC50, 30.0 mg/L (E) 

48-h EC50, 41.9 mg/L (MC) 

Green Algae EC5O 

96-h EC50, 1.5 mg/L (E) 

96-h EC50 (growth rate inhibition), 38.5 mg/L (MC) 

96-h EC50 (growth inhibition), 20.1 mg/L (MC) 

Chronic Toxicity 

Fish ChV 1.0 mg/L (E) 

Daphnid ChV 

3.0 mg/L, (E) 

23-d EC50 (parental mortality), 7.31 mg/L (MC) 

LOEC (impaired reproduction), > 3.68 mg/L (MC) 

NOEC (impaired reproduction), ≥ 3.68 mg/L (MC) 

Green Algae ChV 1.2 mg/L (E) 

Overall Hazard Concern for 

Aquatic Toxicity MODERATE 

HEALTH EFFECTS: 

Absorption Poor absorption via all routes (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

Moderate by analogy to a closely related compound; 2-yr chronic 

toxicity/carcinogenicity study, rats, diet, 5, 20, 80 mg/kg/day, 

increased benign adrenal cortex tumors and hepatocellular 

adenomas at 20 and 80 mg/kg/day (P) 

OncoLogic Results Low-moderate (E) 

Overall Hazard Concern for 

Carcinogenicity MODERATE 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low; Rat oral LD50 between 2000 and 5000 mg/kg (M), >2000 

mg/kg (MC); Rat inhalation LC50 >1.65 mg/L (no death) (MC); 

Rat dermal LD50 > 2000 mg/kg (no deaths or clinical signs)(M, 

MC) 

Eye Irritation Moderate; Slight eye (conjunctival) irritation (M, MC) 

Skin Irritation Moderate, rabbits; No skin irritation (M); slight irritation 

(erythema) (MC); mild irritation (erythema, edema) (MC) 

4-37
 
Record ID: Proprietary C: Chloroalkyl phosphate (2) CAS No. 

Skin Sensitizer Moderate; guinea pig, no sensitization (M), mild sensitization 

(MC) 

Reproductive Effects 

A 4-wk oral gavage study in rats reported no histopathology of 

reproductive organs in either sex at a NOAEL of 600 mg/kg/day, 

but the study duration was short (MC); 

Moderate by analogy to a closely related compound; 12-wk male 

reproduction study, rabbits, gavage, no effects on male fertility or 

spermatogenesis, NOAEL = 200 mg/kg/day; 2-yr chronic 

toxicity/carcinogenicity study, rats, diet, 5, 20, 80 mg/kg/day, 

anomalies of the testes and seminal vesicles, NOAEL = 5 

mg/kg/day (P) 

Developmental Effects 

Moderate by analogy to closely related compound; 

Developmental toxicity study on one analog, gavage, rats, gd 6­

15, 25, 100, 400 mg/kg/day, increased resorptions, decreased 

fetal viability, weight, and length, fetal NOAEL = 100 mg/kg/day 

(P); 

Developmental toxicity study on another analog, gavage, rats, 15, 

50, 150, 500 mg/kg/day, maternal deaths at 150 mg/kg/day, 

maternal NOAEL = 50 mg/kg/day, fetal NOAEL = 15 mg/kg/day 

(P) 

Immune System Effects 

Neurotoxicity 

Low, neurotoxicity screening battery after 4-week oral gavage, 

rats, no behavioral effects or neurohistopathology, NOAEL = 600 

mg/kg/day (MC). 

Also by analogy to a closely related compound; Acute study, 

hens, gavage, delayed neurotoxicity, no inhibition of brain 

neurotoxic esterase (NTE) activity, NOAEL = 10,000 mg/kg; 90­

d study, hens, gavage, no behavioral effects or histopathological 

changes indicative of neurotoxicity, NOAEL = 100 mg/kg/day 

(P) 

Genotoxicity/Mutagenicity 

Low, Negative, mutagenicity in mouse lymphoma (M, MC) and 

Ames test (MC); Negative, chromosomal aberrations in vitro 

(human lymphocytes) (MC); Negative, bone marrow 

micronucleus assay in mice (oral gavage) (MC) 

Moderate for genotoxic effects other than mutagenicity by 

analogy to closely related compounds: Positive, chromosomal 

aberrations, in vitro, human lymphocytes; Positive, rat dominant 

lethal assay (P); 

4-38
 
Record ID: Proprietary C: Chloroalkyl phosphate (2) CAS No. 

Systemic Effects 

Moderate, 4-week oral gavage study, rats (liver effects), 

NOAEL = 15 mg/kg,day, LOAEL = 150 mg/kg/day (MC); 

Also by analogy to a closely related compound; 2-yr chronic 

toxicity/carcinogenicity study, rats, diet, 5, 20, 80 mg/kg/day, 

increased mortality, decreased body weight, anomalies of the 

liver, kidneys, testes, seminal vesicles, renal cortex, and adrenal 

cortex, NOAEL = 5 mg/kg/day (P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-39
 
4.2.7 Proprietary D 

Record ID: Proprietary D: Reactive brominated flame retardant CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: Liquid 

Use: Flame retardant, 

reactive 

SMILES: 

Name: Reactive brominated flame retardant 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence XU

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Moderate 

U Likely brominated hydrolysis product is expected to be persistent. 

° Based on neurotoxicity, systemic effects, eye irritation, and skin sensitizer. 

4-40
 
Record ID: Proprietary D: Reactive brominated flame retardant CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) < 20 (P) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) 0.007 to 0.15 (E) 

Log Kow 3.83 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 2.23x10-21 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 10 (E) 

Bioconcentration Factor – BCF 39 (E) 

Persistence 

Experimental Biodeg Tests 

Ultimate Biodeg Model Months (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 4.2 hours (E) 

Hydrolysis Half-life 19 hrs @ pH 8; 7 days @ pH 7 (E) 

Volatilization Half-life for Model River Negligible (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 23% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Brominated hydrolysis product (P) 

Metabolites 

4-41
 
Record ID: Proprietary D: Reactive brominated flame retardant CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phthalate 

Acute Toxicity 

Fish LC5O 96-h LC50, ≤ 67.0 mg/L (E) 

Daphnid LC5O 48-h LC50, ≤ 280.0 mg/L (E) 

Green Algae EC5O 96-h EC50, ≤ 5.4 mg/L (E) 

Chronic Toxicity 

Fish ChV ≤ 7.0 mg/L (E) 

Daphnid ChV ≤ 30.0 mg/L (E) 

Green Algae ChV ≤ 4.2 mg/L (E) 

Overall Hazard Concern for Aquatic 

Toxicity MODERATE 

HEALTH EFFECTS: 

Absorption Poor all routes (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-42
 
Record ID: Proprietary D: Reactive brominated flame retardant CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low; Rat oral LD50 >10,000 mg/kg (no deaths); 

Rabbit dermal LD50 >20,000 mg/kg (no deaths); 

Rat 1-hr inhalation LC50 >0.008 mg/L (no 

deaths) (M); Low by analogy to a closely related 

compound; Rat oral LD50 = 2874 (P) 

Eye Irritation Moderate, mild reversible conjunctival irritant or 

not an eye irritant in rabbits (M) 

Skin Irritation Low, not an irritant to intact skin, mild reversible 

irritation of abraded skin in rabbits (M) 

Skin Sensitizer Moderate by analogy to a closely related 

compound (P) 

Reproductive Effects 

Developmental Effects 

Immune System Effects 

Neurotoxicity 

Moderate by analogy to a closely related 

compound: Acute oral study, rats, brain 

hemorrhages (P) 

Genotoxicity/Mutagenicity 

Low, Negative in Ames assay with or without 

metabolic activation (M); Low also by analogy 

to a closely related compound; Negative in Ames 

assay (P) 

Systemic Effects 

Moderate by analogy to closely related 

compounds: 28-d, rats, oral, 160, 400, 1000 

mg/kg/day, renal effects at all doses; 21-d 

repeated-dose study, rats, inhalation, 2-8 mg/L, 

adrenal, thyroid, lung, and liver effects; 28-d 

repeated-dose study, rabbits, dermal, 5000 

mg/kg, kidney, liver, blood effects (P) 

Overall Hazard Concern for Non-Cancer 

Health Effects MODERATE 

4-43
 
4.2.8 Proprietary E 

Record ID: Proprietary E: Tetrabromophthalate diol diester CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: Liquid 

Use: Flame retardant, 

additive 

SMILES: 

Name: Tetrabromophthalate diol diester 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence XU

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: 

U Likely brominated hydrolysis product is expected to be persistent. 

° Based on systemic effects. 

4-44
 
Record ID: Proprietary E: Tetrabromophthalate diol diester CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) < 20 (P) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) 0.002 (E) 

Log Kow 5.57 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC <10-8 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 27,000 (E) 

Bioconcentration Factor – BCF 3,903 (E); Low, hydrolyzes 

Persistence 

Experimental Biodeg Tests 

Ultimate Biodeg Model Recalcitrant (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 3.2 hours (E) 

Hydrolysis Half-life 8 days @ p-H 7; 19 hours @ pH 8 (E) 

Volatilization Half-life for Model River Negligible (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 89% (E) 

Ready Biodegradability Not Ready Biodegradable (E) 

Byproducts 

Degradation Products Tetrabromophthalate by hydrolysis (P) 

Metabolites 

4-45
 
Record ID: Proprietary E: Tetrabromophthalate diol diester CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phthalate 

Acute Toxicity 

Fish LC5O 96-h LC50, NES (No effects at saturation) (E) 

Daphnid LC5O 48-h LC50, NES (E) 

Green Algae EC5O 96-h EC50, NES (E) 

Chronic Toxicity 

Fish ChV 0.040 or NES (E) 

Daphnid ChV 0.030 or NES (E) 

Green Algae ChV 0.100 or NES (E) 

Overall Hazard Concern for 

Aquatic Toxicity HIGH (chronic toxicity only) 

HEALTH EFFECTS: 

Absorption Absorption of LMW fraction is expected to be poor by all 

routes based on physicochemical properties (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Cannot be run in OncoLogic 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-46
 
Record ID: Proprietary E: Tetrabromophthalate diol diester CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Eye/Skin Irritation 

Skin Sensitizer 

Reproductive Effects 

Developmental Effects 

Immune System Effects 

Neurotoxicity 

Genotoxicity/Mutagenicity 

Systemic Effects 

Moderate by analogy to closely related compounds; kidney 

toxicity, NOAEL = 400 mg/kg (M); liver toxicity based on 

brominated phenyl moiety (P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-47
 
4.2.9 Proprietary F 

Record ID: Proprietary F: Halogenated aryl ester CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Liquid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Halogenated aryl ester 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence XU

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Low 

U Likely halogenated degradation product is expected to be persistent. 

° Based on reproductive effects, developmental effects, and systemic effects. 

4-48
 
Record ID: Proprietary F: Halogenated aryl ester CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) < 20 (P) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <1x10-6 (E) 

Water Solubility (g/L) 0.002 (MC) 

Log Kow 8.75 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 7.05 x10-6 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc >28,840 (MC) 

Bioconcentration Factor – BCF 1.7-6.2 (MC) 

Persistence 

Experimental Biodeg Tests 

Half-life of 3.5 days in water shake flask dieaway test, 8.5 days in sediment (MC); 

6% biodegradation after 28 days in closed bottle 

test (MC) 

Ultimate Biodeg Model Months (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 12 hours (E) 

Hydrolysis Half-life >1 year @ pH 4, 7, and 9 (MC) 

Volatilization Half-life for Model River 8 days (E) 

Volatilization Half-life for Model Lake 98 days (E) 

Removal in Sewage Treatment Plant 90% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Halogenated aryl acid 

Metabolites 

4-49
 
Record ID: Proprietary F: Halogenated aryl ester CAS No. 

ECOTOXICITY: 

ECOSAR Class Esters 

Acute Toxicity 

Fish LC5O 96 hr NOEC, NES (No effects at saturation) (MC) 

Daphnid LC5O 24 hr EC50, 1.2 mg/L; 48 hr EC50, 0.42 mg/L (MC) 

Green Algae EC5O 96 hr EC50, NES (MC) 

Chronic Toxicity 

Fish ChV NES (E) 

Daphnid ChV 0.04 (D48/ACR10) (E) 

Green Algae ChV NES (E) 

Overall Hazard Concern for 

Aquatic Toxicity HIGH 

HEALTH EFFECTS: 

Absorption Poor absorption via all routes (P) 

CANCER HEALTH EFFECTS: 

Experimental data Uncertain by analogy to a closely related chemical classes (P) 

OncoLogic Results 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-50
 
Record ID: Proprietary F: Halogenated aryl ester CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity Low; Rat oral LD50 >2000 mg/kg (M) 

Eye Irritation 

Skin Irritation 

Skin Sensitizer 

Reproductive Effects Moderate by analogy to a closely related compound (P) 

Developmental Effects Moderate by analogy to a closely related compound (P) 

Immune System Effects 

Neurotoxicity 

Genotoxicity/Mutagenicity 

Systemic Effects Moderate concern for liver effects by analogy to a closely 

related compound (P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-51
 
4.2.10 Proprietary G 

Record ID: Proprietary G: Triaryl phosphate, isopropylated CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: Liquid 

Use: Flame retardant, 

additive 

SMILES: 

Name: Triaryl phosphate, isopropylated 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: High 

° Based on reproductive effects, developmental effects, neurotoxicity, systemic effects, and eye 

irritation. 

4-52
 
Record ID: Proprietary G: Triaryl phosphate, isopropylated CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) 90 (E) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) <10-6 (E) 

Log Kow 6.16 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 7.74x10-8 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 2.6x104

 (E) 

Bioconcentration Factor – BCF 1820 (E) 

Persistence 

Experimental Biodeg Tests 46% ThOD after 28 days in OECD 301F (MC) 

Ultimate Biodeg Model Weeks -months (E) 

Primary Biodeg Model Days-weeks (E) 

BOD or COD 

Atmospheric Half-life 9.3 hours (E) 

Hydrolysis Half-life 

Volatilization Half-life for Model River 605 days (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 93% (E) 

Ready Biodegradability Not ready biodegradable (MC) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-53
 
Record ID: Proprietary G: Triaryl phosphate, isopropylated CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phosphate 

Acute Toxicity 

Fish LC5O 96-h LC50, NES (No effects at saturation) (E) 

Daphnid LC5O 48-h LC50, NES (E) 

Green Algae EC5O 96-h EC50, NES (E) 

Chronic Toxicity 

Fish ChV NES (E) 

Daphnid ChV NES (E) 

Green Algae ChV NES (E) 

Overall Hazard Concern 

for Aquatic Toxicity 

HIGH (chronic toxicity and only when 1 or 2 isopropyls are 

present) 

HEALTH EFFECTS: 

Absorption 

Nil thru skin as neat solid; poor thru skin when in solution; poor 

thru lungs and GI tract by analogy to closely related compounds 

(P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern 

for Carcinogenicity LOW 

4-54
 
Record ID: Proprietary G: Triaryl phosphate, isopropylated CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Low in mixtures; Rat oral LD50 >5000 mg/kg (no deaths), 

>20,000 mg/kg (4/10 deaths); Rat 1-hr inhalation LC50 > 200 

mg/L; Rat dermal LD0 > 2000 mg/kg (no deaths)(M) 

Eye Irritation Moderate in mixtures; Rabbits, very slight eye irritation (M) 

Skin Irritation Low in mixtures; Not irritating to intact or abraded skin in rabbits 

(M) 

Skin Sensitizer Low by analogy to a closely related compound (P) 

Reproductive Effects 

Preliminary results of an unfinished 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening 

test suggest that the reproductive hazard may be moderate, rat, 

oral gavage, ovarian weight effect at ≥25 mg/kg/day, epididymal 

weight effect and reduced fertility at 100 and 400 mg/kg/day 

(MC) 

Developmental Effects 

Preliminary results of an unfinished 39-41-day combined 

subchronic plus reproductive/developmental toxicity screening 

test suggests the developmental hazard may be moderate; rat, oral 

gavage, reduced pre- and post-natal survival at 400 mg/kg/day 

(MC) 

Immune System Effects 

Neurotoxicity 

Moderate in mixtures; acute delayed neurotoxicity assay, hens, 

oral gavage, NOAEL = 12 mg/kg/day for neurotoxic esterase 

(NTE) inhibition, LOAEL = 1000 mg/kg/day; delayed oral 

neurotoxicity, hens, 2 oral treatments 3 weeks apart, transient 

dose-related gait impairment (LOAEL = 12 mg/kg/day), but no 

neurohistopathology at doses as high as 11,700 mg/kg/day (M); 

Also by analogy to closely related compounds and professional 

judgment; neurotoxicity study, hens, oral gavage, 3, 5, 7, 9 g/kg, 

ataxia, neuropathological lesions, LOAEL = 3000 mg/kg; 

neurotoxicity study, hens, oral gavage, 10, 20, 90, 270 

mg/kg/day, ataxia, nerve degeneration, NOAEL = 20 mg/kg/day; 

NTE inhibition (M,P) 

Genotoxicity/Mutagenicity Low by analogy to a closely related compound; Negative, Ames 

assay (P) 

Systemic Effects 

Moderate in mixture (liver effects); 28-d repeated-dose study 

(inadequate), rats, diet, 0.1%, 0.5%, 1.0%, liver effects all doses, 

LOAEL = 0.1% (M); 

Preliminary results of an unfinished a 39-41-day combined 

subchronic toxicity with reproductive/developmental screening 

test suggest that there may be a moderate hazard for subchronic 

toxicity (adrenal and liver effects), rat, oral gavage, adrenal 

weight effect in females, LOAEL = 25 mg/kg/day (MC) 

4-55
 
Record ID: Proprietary G: Triaryl phosphate, isopropylated CAS No. 

Overall Hazard Concern 

for Non-Cancer Health 

Effects 

MODERATE 

4-56
 
4.2.11 Proprietary H 

Record ID: Proprietary H: Halogenated aryl ester CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Liquid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Halogenated aryl ester 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence XU

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard- X 

Is the chemical predicted to be a PBT 

by PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Low 

U Likely halogenated degradation product is expected to be persistent. 

° Based on reproductive effects, developmental effects, and systemic effects. 

4-57
 
Record ID: Proprietary H: Halogenated aryl ester CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) < 20 (P) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <1x10-6 (E) 

Water Solubility (g/L) 0.002 (MC) 

Log Kow 12.0 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 3.08x10-7 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc >28,840 (MC) 

Bioconcentration Factor – BCF 1.7-6.2 (MC) 

Persistence 

Experimental Biodeg Tests 

Half-life of 3.5 days in water shake flask dieaway test, 8.5 days in sediment (MC); 

6% biodegradation after 28 days in closed bottle 

test (MC) 

Ultimate Biodeg Model Months (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 6 hours (E) 

Hydrolysis Half-life >1 year @ pH 4, 7, and 9 (MC) 

Volatilization Half-life for Model River 211 days (E) 

Volatilization Half-life for Model Lake 2310 days (E) 

Removal in Sewage Treatment Plant 90% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Halogenated aryl acid 

Metabolites 

4-58
 
Record ID: Proprietary H: Halogenated aryl ester CAS No. 

ECOTOXICITY: 

ECOSAR Class Esters 

Acute Toxicity 

Fish LC5O 96 hr NOEC, NES (No effects at saturation) (MC) 

Daphnid LC5O 

24 hr EC50, 1.2 mg/L; 48 hr EC50, 0.42 mg/L 

(MC) 

Green Algae EC5O 96 hr EC50, NES (MC) 

Chronic Toxicity 

Fish ChV NES (E) 

Daphnid ChV 0.04 (D48/ACR10) (E) 

Green Algae ChV NES (E) 

Overall Hazard Concern for Aquatic 

Toxicity HIGH 

HEALTH EFFECTS: 

Absorption Poor absorption via all routes (P) 

CANCER HEALTH EFFECTS: 

Experimental data Uncertain by analogy to a closely related chemical 

classes (P) 

OncoLogic Results 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-59
 
Record ID: Proprietary H: Halogenated aryl ester CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity Low; Rat oral LD50 >2000 mg/kg (M) 

Eye Irritation 

Skin Irritation 

Skin Sensitizer 

Reproductive Effects Moderate by analogy to a closely related 

compound (P) 

Developmental Effects Moderate by analogy to a closely related 

compound (P) 

Immune System Effects 

Neurotoxicity 

Genotoxicity/Mutagenicity 

Systemic Effects Moderate concern for liver effects by analogy to a 

closely related compound (P) 

Overall Hazard Concern for Non-Cancer 

Health Effects MODERATE 

4-60
 
4.2.12 Proprietary I 

Record ID: Proprietary I: Organic phosphate ester CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Organic phosphate ester 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? Yes 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: High 

° Based on systemic effects and eye irritation. 

4-61
 
Record ID: Proprietary I: Organic phosphate ester CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) < 20 (P) 

Boiling Point (deg C) >300 (MC) 

Boiling Point Pressure (mm 

Hg) 760 (MC) 

Vapor Pressure (mm Hg) <10-6 (MC) 

Water Solubility (g/L) 8x10-4 (MC,P) 

Log Kow 6.89 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 4.89x10-14 atm-m3

/mole (E) 

Soil Adsorption Coefficient – 

Koc 

5.0x107 (E) 

Bioconcentration Factor – 

BCF 245 (MC) 

Persistence 

Experimental Biodeg Tests 2.3% degradation after 28 days MITI-II (MC); 30% in 28 

days and 52% in 140 days - closed bottle test (MC) 

Ultimate Biodeg Model Months (E) 

Primary Biodeg Model Days (E) 

BOD or COD 

Atmospheric Half-life 2.1 hours (E) 

Hydrolysis Half-life Half-life of 20 days at pH 9 and 25 deg C (MC) 

Volatilization Half-life for 

Model River Negligible (E) 

Volatilization Half-life for 

Model Lake Negligible (E) 

Removal in Sewage Treatment 

Plant 94% (E) 

Ready Biodegradability Not Ready Biodegradable (MC) 

Byproducts 

Degradation Products Degradation products are expected to be less persistent than 

the parent compound 

4-62
 
Record ID: Proprietary I: Organic phosphate ester CAS No. 

Metabolites 

ECOTOXICITY: 

ECOSAR Class Ester-phosphate 

Acute Toxicity 

Fish LC5O 

96-h LC50, NES (No effects at saturation) (E) 

96-h LC50, 0.205 mg/L (MC) 

Daphnid LC5O 

48-h LC50, NES (E) 

48-h LC50, > 0.846 mg/L (MC) 

Green Algae EC5O 96-h EC50, NES (E) 

Chronic Toxicity 

Fish ChV 0.200 or NES (E) 

LOEC (reduced larval survival and growth), 0.088 mg/L (MC) 

Daphnid ChV 0.070 or NES (E) 

LOEC (reduced reproduction and growth), 0.147 mg/L (MC) 

Green Algae ChV 0.140 or NES (E) 

Overall Hazard Concern for 

Aquatic Toxicity HIGH (chronic toxicity only) 

HEALTH EFFECTS: 

Absorption Poor all routes by analogy to closely related compounds and 

physicochemical properties (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-63
 
Record ID: Proprietary I: Organic phosphate ester CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity Low; rat oral LD50 > 5 g/kg; rabbit dermal LD50 > 5 g/kg; 

LC50>1.55 mg/L (MC) 

Eye Irritation Moderate; mild and transient eye irritation, rabbits; no eye 

irritation, rabbits (MC) 

Skin Irritation Low; no skin irritation in rabbits (MC) 

Skin Sensitizer Low; no skin sensitization in guinea pigs (MC) 

Reproductive Effects Low; NOAEL>1000 mg/kg/day in reproductive/developmental 

screening test in rats (MC) 

Developmental Effects Low; NOAEL>1000 mg/kg/day in reproductive/developmental 

screening test in rats (MC) 

Immune System Effects 

Neurotoxicity Low by analogy to a closely related compound; 42-d 

neurotoxicity test, hens, NOAEL = 5 g/kg/day (P) 

Genotoxicity/Mutagenicity 

Low; Negative, mouse micronucleus assay, in vivo, i.p.; 

Negative, chromosomal aberrations in vitro; Negative Ames 

assay, Salmonella and E. coli; Negative mouse lymphoma assay 

(MC) 

Systemic Effects 

Moderate by analogy to a closely related compound; 28-d 

repeated-dose study, rat, oral gavage, slight liver toxicity, 

NOAEL = 300 mg/kg/day, LOAEL = 1000 mg/kg/day (P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-64
 
4.2.13 Proprietary J 

Record ID: Proprietary J: Aryl phosphate CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Liquid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Aryl phosphate 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: High 

° Based on systemic effects and eye irritation. 

4-65
 
Record ID: Proprietary J: Aryl phosphate CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) -21 (M) 

Boiling Point (deg C) 425 (M) 

Boiling Point Pressure (mm Hg) 760 (M) 

Vapor Pressure (mm Hg) 1.4x10-6 (M) 

Water Solubility (g/L) 0.0032 (M) 

Log Kow 5.12 (M) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 8.48x10-7 atm-m3

/mole (M) 

Soil Adsorption Coefficient – Koc 3.7x104

 (E) 

Bioconcentration Factor – BCF 290 (E) 

Persistence 

Experimental Biodeg Tests 

43-90% CO2 evolution in 28 days with activated 

sludge inoculum; 50% removal in 11 days in 

river die away; half life of 0.44 days in pond 

water and 39 days in pond sediment 

Ultimate Biodeg Model Weeks-months (E) 

Primary Biodeg Model Days-weeks (E) 

BOD or COD 

Atmospheric Half-life 8.2 hours (E) 

Hydrolysis Half-life 

Volatilization Half-life for Model River 54 days (E) 

Volatilization Half-life for Model Lake 594 days (E) 

Removal in Sewage Treatment Plant 81.2% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-66
 
Record ID: Proprietary J: Aryl phosphate CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phosphate 

Acute Toxicity 

Fish LC5O 96-h LC50, NES (No effects at saturation) (E) 

Daphnid LC5O 48-h LC50, NES (E) 

Green Algae EC5O 96-h EC50, 0.020 mg/L or NES (E) 

Chronic Toxicity 

Fish ChV 0.003 mg/L (E) 

Daphnid ChV 0.002 mg/L (E) 

Green Algae ChV 0.020 mg/L (E) 

Overall Hazard Concern for 

Aquatic Toxicity HIGH (chronic toxicity only) 

HEALTH EFFECTS: 

Absorption 

Nil thru skin as neat solid; poor thru skin when in solution; 

poor thru lungs and GI tract by analogy to closely related 

compounds (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-67
 
Record ID: Proprietary J: Aryl phosphate CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity Low; Rat oral LD50 > 5000 mg/kg; Rat dermal LD50 > 2000 

mg/kg (M) 

Eye Irritation Low; Rabbits, no eye irritation (M) 

Skin Irritation Moderate; Rabbits, mild skin irritation (M) 

Skin Sensitizer Low by analogy to a closely related compound (P) 

Reproductive Effects 

Low, 90-day oral toxicity (diet), rats, no effect on 

histopathology or weights of reproductive organs in males or 

females, NOAEL = 1600 ppm (M) 

Developmental Effects 

Immune System Effects 

Neurotoxicity 

Low, delayed neurotoxicity; 5-d study, hens, oral gavage, 

5000 mg/kg/day, no evidence of delayed neurotoxicity; 90-day 

oral toxicity (diet), rats, no neurohistopathology in males or 

females, NOAEL = 1600 ppm (M); 

Also by analogy to a closely related compound (P) 

Genotoxicity/Mutagenicity 

Studies on poorly defined mixtures suggest negative results for 

mutagenicity (Salmonella typhimurium, Saccharomyces 

cerevisiae, mouse lymphoma cells), chromosomal aberration in 

vitro (mouse lymphoma cells) and sister chromatid exchange in 

vitro (mouse lymphoma cells) (M) 

Systemic Effects 

Moderate, based on studies identifying liver as potential target 

organ. 90-day oral toxicity (diet), rats, at 1600 ppm (125 

mg/kg/day), increased absolute and relative liver weights (both 

sexes) and adrenal weights (females), no histopathological 

lesions, but not tested at limit dose, NOAEL = 400 ppm, 

LOAEL = 1600 ppm (M); Also by analogy to closely related 

compounds (liver effects); 28-d repeated-dose study 

(inadequate), rats, diet, increased relative liver weight (no 

histopathology data available) at 0.5%, NOAEL = 0.1% (P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-68
 
4.2.14 Proprietary K 

Record ID: Proprietary K: Aryl phosphate CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Aryl phosphate 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Low 

° Based on systemic effects. 

4-69
 
Record ID: Proprietary K: Aryl phosphate CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) 90 (E) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) <10-6 (E) 

Log Kow 8.52 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 2.65x10-7 atm-m3

/mole (E) 

Soil Adsorption Coefficient – Koc 2.7x105

 (E) 

Bioconcentration Factor – BCF 89 (E) 

Persistence 

Experimental Biodeg Tests 

Ultimate Biodeg Model Months (E) 

Primary Biodeg Model Days-weeks (E) 

BOD or COD 

Atmospheric Half-life 9.7 hours (E) 

Hydrolysis Half-life 

Volatilization Half-life for Model River 193 days (E) 

Volatilization Half-life for Model Lake Negligible (E) 

Removal in Sewage Treatment Plant 94% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products Degradation products are expected to be less 

persistent than the parent compound 

Metabolites 

4-70
 
Record ID: Proprietary K: Aryl phosphate CAS No. 

ECOTOXICITY: 

ECOSAR Class Ester-phosphate 

Acute Toxicity 

Fish LC5O 96-h LC50, NES (No effects at saturation) (E) 

Daphnid LC5O 48-h LC50, NES (E) 

Green Algae EC5O 96-h EC50, NES (E) 

Chronic Toxicity 

Fish ChV NES (E) 

Daphnid ChV NES (E) 

Green Algae ChV NES (E) 

Overall Hazard Concern for 

Aquatic Toxicity LOW 

HEALTH EFFECTS: 

Absorption 

Nil thru skin as neat solid; poor thru skin when in solution; 

poor thru lungs and GI tract by analogy to closely related 

compounds (P) 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal (E) 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-71
 
Record ID: Proprietary K: Aryl phosphate CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Eye/Skin Irritation 

Skin Sensitizer Low by analogy to a closely related compound (P) 

Reproductive Effects 

Developmental Effects 

Immune System Effects 

Neurotoxicity Low by analogy to a closely related compound (P) 

Genotoxicity/Mutagenicity 

Systemic Effects 

Moderate by analogy to closely related compounds (liver 

effects); 28-d repeated-dose study (inadequate), rats, diet, 

liver effects at 0.5%, NOAEL = 0.1% (P) 

Overall Hazard Concern for 

Non-Cancer Health Effects MODERATE 

4-72
 
4.2.15 Proprietary L 

Record ID: Proprietary L: Aryl phosphate CAS No. 

MW: 

MF: 

Physical Forms: 

Neat: Solid 

As Formulated: 

Use: Flame retardant, 

additive 

SMILES: 

Name: Aryl phosphate 

Synonyms: 

ASSESSMENT SUMMARY: 

Concern Level 

HIGH MODERATE LOW 

Persistence X 

Bioconcentration X 

Cancer Health Hazard X 

Non-Cancer Health Hazard X° 

Aquatic Toxicity Hazard X 

Is the chemical predicted to be a PBT by 

PBT Profiler? No 

Overall Hazard Concern Human Health Hazard: Moderate 

Aquatic Hazard: Low 

° Based on systemic effects. 

4-73
 
Record ID: Proprietary L: Aryl phosphate CAS No. 

PHYSICAL/CHEMICAL PROPERTIES 

Melting Point (deg C) 90 (E) 

Boiling Point (deg C) >400 (E) 

Boiling Point Pressure (mm Hg) 760 (E) 

Vapor Pressure (mm Hg) <10-6 (E) 

Water Solubility (g/L) <10-6 (E) 

Log Kow 10.43 (E) 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC 

(atm-m3/mole) 6.85x10-7 (E) 

Soil Adsorption Coefficient – Koc 1.9x106

 (E) 

Bioconcentration Factor – BCF 3.1 (E) 

Persistence 

Experimental Biodeg Tests 

Ultimate Biodeg Model Recalcitrant (E) 

Primary Biodeg Model Weeks (E) 

BOD or COD 

Atmospheric Half-life 8.8 hours (E) 

Hydrolysis Half-life 

Volatilization Half-life for Model 

River 79 days (E) 

Volatilization Half-life for Model 

Lake Negligible (E) 

Removal in Sewage Treatment 

Plant 94% (E) 

Ready Biodegradability Not ready biodegradable (E) 

Byproducts 

Degradation Products 

Metabolites 

4-74
 
Record ID: Proprietary L: Aryl phosphate CAS No. 

ECOTOXICITY: 

ECOSAR Class Esters-phosphate 

Acute Toxicity 

Fish LC5O 96-h LC50, NES (No effects at saturation) (E) 

Daphnid LC5O 48-h LC50, NES (E) 

Green Algae EC5O 96-h EC50, NES (E) 

Chronic Toxicity 

Fish ChV NES (E) 

Daphnid ChV NES (E) 

Green Algae ChV NES (E) 

Overall Hazard Concern for 

Aquatic Toxicity LOW 

HEALTH EFFECTS: 

Absorption Nil thru skin as neat solid, poor thru skin in solution; poor 

thru lungs and GI tract, based on closely related analogs 

CANCER HEALTH EFFECTS: 

Experimental data 

OncoLogic Results Marginal 

Overall Hazard Concern for 

Carcinogenicity LOW 

4-75
 
Record ID: Proprietary L: Aryl phosphate CAS No. 

NON-CANCER HEALTH EFFECTS: 

Acute Toxicity 

Eye Irritation 

Skin Irritation 

Skin Sensitizer Low, concern for sensitization by analogy to closely 

related compounds (P) 

Reproductive Effects 

Developmental Effects 

Immune System Effects 

Neurotoxicity 

Low; Not neurotoxic by analogy to a closely related 

compound which yielded negative results in all reliable 

oral assays for delayed acute neurotoxicity in hens and 

subchronic neurobehavioral assays in rats (M); 

Proprietary L lacks structural motifs associated with 

neurotoxicity (P) 

Genotoxicity/ Mutagenicity 

Systemic Effects 

Moderate, systemic effects by analogy to closely related 

compounds, including 28-d repeated-dose study 

(inadequate), rats, diet, liver effects at 0.5%, NOAEL = 

0.1% (P) 

Overall Hazard Concern for NonCancer Health Effects MODERATE 

4-76
 
5.0 CONSIDERATIONS FOR SELECTING A REPLACEMENT FOR PENTABDE 

Multiple factors must be considered when selecting an appropriate chemical flame retardant. In 

addition to flame retardancy properties and health and environmental considerations, the flame 

retardant’s use cannot negatively affect the quality of the foam (either physical characteristics or 

aesthetics that would reduce its desirability in the market place). This is a concern because the 

chemical will be incorporated in large amounts that may have effects on the foam product (e.g., 

pentaBDE formulations can make up as much as 8 percent by weight of the final foam product 

and other flame-retardant formulations have been used at concentrations above 10 percent). 

Additionally, it must be practical to use the chemical during production and processing of the 

foam and furniture with existing equipment. Finally, the chemical cannot be cost prohibitive. 

The Furniture Flame Retardancy Partnership recognizes the significance of considering practical 

alternatives. The information in this report is focused on environmental attributes and can be 

weighed with cost and performance information when selecting alternatives. 

5.1 Positive Environmental Attributes 

This section identifies a set of positive attributes that companies should consider when 

formulating or selecting a flame retardant, or flame-retarded raw materials (e.g., foam and 

textiles) that will meet or exceed existing flammability standards. These attributes are linked to 

different aspects of what might happen to a chemical substance during its life cycle. While 

ensuring that fire-safety standards are met, the following environmentally desirable chemical 

characteristics and attributes, relevant to many flame-retardant chemicals, should be considered 

general "rules of thumb". 

Aerobic Degradation 

Biodegradation and incineration are both forms of aerobic degradation or aerobic oxidation of 

the chemical. Biodegradation is mediated by living organisms and generally slow compared to 

incineration which is abiotic on a rapid time line. Environmental oxidation can be an abiotic 

form of aerobic degradation which is generally very slow for most chemicals. Abiotic oxidative 

processes addressed here occur in the absence of light. For the purposes of this report, two 

categories of aerobic degradation are being discussed: biodegradation and incineration. 

Attributes and considerations associated with these categories are discussed in more detail 

below. 

Readily Biodegradable: Low Persistence 

Typically, the environmental profile of a chemical improves with its rate of 

biodegradation. According to the Organization for Economic Cooperation and 

Development (OECD), a chemical is readily biodegradable if, in a 28-day test, it 

biodegrades 60 percent or more within 10 days of the time when degradation first reaches 

10 percent (70% for DOC-based tests). There are two main features of readily 

biodegradable substances. Hydrophobic components composed of unsaturated linear 

alkyl chains (straight chain carbon molecules) biodegrade more rapidly under aerobic 

conditions in sewage treatment plants and the environment than highly branched chains. 

5-1
 
Also, hydrophobic and hydrophilic components that are linked by an easily biodegradable 

group like a carboxylic acid ester will separate the hydrophobe from the hydrophile 

during the first step through aerobic biodegradation (i.e., ester hydrolysis). 

Keep in mind that while the rate of biodegradation is important, it is equally important to 

be aware of the byproducts formed through the degradation process. In some cases, the 

products of biodegradation might be more toxic and persistent than the parent compound. 

Incineration: Consideration of Combustion Byproducts 

A concern with chemicals introduced into foam products is the formation of hazardous 

combustion byproducts either during a residential fire or if the consumer product is 

ultimately disposed to an incinerator. For example, halogenated flame retardants have the 

potential to combine with other organic compounds during combustion and form 

halogenated dioxins and furans. The formation of other hazardous combustion 

byproducts should also be considered. 

Low Bioaccumulation Potential and Low Bioavailability: High log Kow (>8); Large 

Molecule 

The ability of a chemical to accumulate is often measured by the bioconcentration factor (BCF). 

A high BCF indicates a high potential to bioaccumulate. Quantified, chemical-specific BCFs are 

often not available; however, this property can be estimated by correlating it with another 

readily-available parameter - the octanol-water partition coefficient (Kow). In general, a log Kow 

of 3.5 to 5 corresponds to BCFs of approximately 1,000 to 5,000. Both ranges represent a 

moderate to high bioaccumulation potential. Note that as the log Kow increases above 8, the 

bioaccumulation potential decreases. 

The potential for a molecule to be absorbed and harm an organism is less when the molecule is 

larger than a certain size. Molecules with the following characteristics are not available for 

passive uptake through the respiratory membranes of aquatic organisms: (a) molecules with 

hydrophilic components having large cross-sectional diameters, at least twice as large as 

hexabromobenzene (i.e., greater than 10 Å), or (b) neutral and anionic surfactants with molecular 

weights greater than 1,000 daltons. (Large diameters or high molecular weights will limit 

toxicity to surface effects only and will prevent systemic effects.) 

In addition, high molecular weight molecules (greater than 1,000 daltons) tend to be less volatile 

and therefore, may exhibit less of a potential for inhalation exposure to vapors during 

manufacturing and processing of foam and textiles. If exposure occurs high molecular weight 

molecules are less likely to be absorbed, therefore limiting potential for adverse effects to be 

expressed. 

Reactive Flame Retardants: Even if a chemical has the potential to bioaccumulate, the 

environmental concerns may be reduced or mitigated if the chemical is permanently incorporated 

into a commercial product. In this case, the potential for exposure to the chemical is greatly 

decreased. Reactive flame retardants are generally incorporated into the product (e.g., foam or 

textile) during the early stages of manufacturing. Additives are mixed throughout the 

5-2
 
formulation, but are not chemically bound. Therefore, these additives have a much higher 

potential to migrate, or leach, from the product into the environment under normal conditions. 

Low Toxicity: Effects on several human health endpoints should be minimized. These effects 

include: cancer hazard, skin sensitization, reproductive effects, developmental effects, 

neurological effects, systemic effects and mutagenicity. Section 4 discusses methods to 

characterize these effects and presents results of the screening level evaluations for the 14 

formulations assessed in this report. 

5.2 Aesthetic and Performance Considerations 

Scorching is a primary concern in the manufacture of flexible polyurethane foam in general, and 

is a particular concern for low-density foams. Light scorching results in discoloration or 

yellowing of the foam, while severe scorching can cause decomposition resulting in permanent 

damage to the foam. This phenomenon occurs because of the high temperatures that are 

generated during production of the foam bun. 

Scorching is more prevalent in low-density foams because of the necessity to use toluene 

diisocyanate (TDI), which enables the foam to achieve low densities, better firmness and better 

support. Methyl diphenyl diisocyanate (MDI) is used to manufacture higher density foams as 

well as memory foams. The use of TDI causes a more exothermic (heat generating) reaction than 

the use of MDI. Therefore, a higher thermally resistant flame retardant is required for 

manufacturing low-density foams. 

PentaBDE allows for the manufacture of low-density flame-retarded foam that is “snow white” 

in color. Because of its aesthetic desirability, it became the industry standard in mattresses and 

bedding products, as well as in many upholstered furniture applications. Greater acceptance of 

off-white foams could allow manufacturers to choose from a wider variety of alternative flame 

retardants. Barrier fabrics are allowing mattress manufacturers to mask the color of foam so that 

it will not be visible to the consumer. Other characteristics of foam that can be affected by the 

choice of flame retardants include firmness, durability and flexibility. 

5.3 Process and Equipment Considerations 

Another important consideration when selecting an alternative for pentaBDE is the feasibility of 

using the new chemical in an industrial setting. Ideally the alternative should be compatible with 

existing process equipment at foam manufacturing facilities. If it is not, the plants will be forced 

to modify their processes and potentially to purchase new equipment. The ideal alternative would 

be a drop-in replacement that has similar physical and chemical properties such that existing 

storage and transfer equipment as well as foam production equipment can be used without 

significant modifications. 

For example, most U.S. foam facilities are equipped to store and process liquid flame-retardant 

formulations through pipes, metering systems and pumps. A solid alternative may require foam 

plants to make significant investments for conveyorized transfer, dust control systems and solid 

weighing apparatus. These modifications are feasible, from an engineering point of view, but 

may be cost prohibitive in certain circumstances. 

5-3
 
Similarly, many foam “recipes” and manufacturing procedures are based on the addition of 

liquid flame-retardant chemicals. Addition of a solid flame retardant may require changes such 

as additional mixing steps and alteration of the process times. In some cases, these changes can 

have significant effects on foam quality or cost-effectiveness of manufacture. 

5.4 Economic Viability 

Foam manufacturing is a very competitive market in the United States and around the world. A 

flame-retardant alternative that is either more expensive per pound, or requires more flame 

retardant per linear foot to meet the fire safety standards will increase the foamer’s raw material 

costs. In this situation, a foam manufacturer will attempt to pass the cost on to their customers 

(e.g., the furniture manufacturer), who will subsequently pass the cost to consumers. If this 

increase causes a significant market share loss, the foam manufacturer may not be able to 

compete and may be forced to discontinue use of the alternative, making the alternative 

economically unfeasible. 

5.5 Alternatives Technologies (General) 

Potential alternatives for pentaBDE can be separated into two categories: (1) alternative 

chemicals, and (2) alternative technologies. Chemical alternatives are the focus of this report; 

however this section provides a brief discussion of three currently-available alternative 

technologies being considered for further investigation by the Furniture Flame Retardancy 

Partnership: barrier technologies, graphite impregnated foam and surface treatment. Graphite 

impregnated foam and surface treatments have limited commercial uses; therefore, they are only 

briefly discussed. Barrier technologies are predominantly used in mattress manufacturing rather 

than residential upholstered furniture. However, there is considerable interest in future 

applications for furniture. Future partnership activities may focus on barrier technologies if 

appropriate. 

In addition to the following technologies, it should be noted that some furniture designs exclude 

the use of filling materials, and even fabric altogether. Design therefore, should be considered 

when evaluating alternative means for achieving flame retardancy in furniture. 

5.5.1 Barrier Technologies 

Flame-retardant barrier materials can be a primary defense in protecting padding for furniture 

and mattresses. Manufacturers can layer barrier materials to improve the flame retardancy of 

their products. This layering approach allows a product to maintain its fire resistance even if one 

layer is compromised. 

There are many types of barrier materials available. Fabrics composed of natural fibers such as 

cotton that are chemically treated to make them flame retardant are flame-retardant barrier 

materials. The hazards of these chemical treatments have not been assessed in this report. Fabrics 

composed of synthetic fibers that are inherently flame retardant are also flame-retardant barrier 

materials. Plastic films derived from flame-retardant resins are also flame-retardant barrier 

materials. These materials are designed and manufactured to meet specific flammability 

standards. This also explains the large number of flame-retardant barrier materials that are 

5-4
 
available. Flame-retardant barrier materials can be characterized by cost, resulting in three 

primary groups. 

The first group of flame-retardant materials is the chemically treated, primarily boric acid 

treated, cotton-based materials. These materials are the least expensive flame-retardant barrier 

materials available. Mattress manufacturers that base their material decisions predominantly on 

cost prefer these flame retardants. 

The second group of flame-retardant materials is a blend of inexpensive natural fibers and 

expensive synthetic fibers. Synthetic fibers used in these blends include VISIL, Basofil, 

Polybenzimidazole, KEVLAR, NOMEX and fiberglass. Smaller manufacturers of furniture and 

mattresses in niche markets use these materials. These blends are commonly used in bus and 

airplane seating. 

The third group of flame-retardant materials is composed solely of expensive, high-performance 

synthetic fibers. They are generally used in industrial or high-performance applications such as 

firemen’s coats and astronaut space suits. 

Barrier materials can also be divided into woven or nonwoven fabrics. Woven fabrics tend to use 

general weaving technology to manufacture the fabrics. Manufacturers can customize fabrics to 

meet specific customer needs. Nonwoven fabrics are created using quite different technologies. 

Thermally bonded fabrics are a type of nonwoven fabrics. These materials consist of a core, 

typically cotton, which is fed with one or two outer layers of melt blown and/or spunbond 

polypropylene webs. The polypropylene web serves as the binder in this process. The core and 

the web pass between a smooth and a patterned calendar. The calendars are heated and thermally 

bind the core to the web. This process creates thermally bonded laminates. Another type of 

nonwoven fabrics is needle-punched nonwovens. In this process, a spun bonded or carded web 

passes under a needle board that contains thousands of needles. As the needle passes into the 

web, a barb catches a fiber and passes it through the web, interlocking the fibers. 

One unique group of barrier materials is flame-retardant films. The films do not have the strength 

or texture to be used as an external barrier. The film can be used to wrap the foam cushions or it 

can be quilted with flame-retardant fabrics for added support and an extra layer of fire protection. 

Neoprene film is a common flame-retardant film. One type of material that competes with 

neoprene film is fiberglass fabric. 

Mattress manufacturers are now using barrier technology to meet new fire safety standards in the 

state of California (California Technical Bulletin 603). 

More information on barrier fabrics can be found in the following sources: 

Decabromodiphenylether: An Investigation of Non-Halogen Substitutes in Electronic Enclosure 

and Textile Applications (Lowell, 2005) 

Survey and Technical Assessment of Alternatives to Decabromodiphenyl Ether (decaBDE) in 

Textile Applications (Posner, 2004) 

5-5
 
5.5.2 Graphite Impregnated Foams 

Graphite impregnated foam (GIF) can be considered an “inherently flame-resistant foam” that is 

self-extinguishing and highly resistant to combustion. It is a relatively new technology and is 

largely used in niche markets such as for general aircraft seating. GIF technology produces foam 

that can meet airline fire safety standards for the seats with a reduced dependency on flameretarded fabric. By minimizing the expense associated with flame-retardant fabric, GIF modified 

foams can be priced competitively. 

GIF technology reportedly allows the design and fabrication of complex, comfortable and 

aesthetically pleasing seating for private aircraft. While GIF foam seating promises the 

possibility of eliminating the need for barrier fabrics, there are tradeoffs. When the barrier is 

removed, comprehensive composite flammability testing will be required on each new seat 

design to meet current fire safety standards (Federal Airways Regulation Part 25 Appendix F). 

5.5.3 Surface Treatments 

Surface treatments are also used in some applications and niche markets and may be appropriate 

for some textile manufacturing and furniture manufacturing readers of this document. However, 

surface treatments may not be viable as industry-wide replacements for pentaBDE for use in 

low-density foam for the following reasons: 

There have been many proposals to achieve good resistance to ignition by post impregnation of 

foam with a variety of additives including borates, phosphates, various ammonium salts, etc. 

In addition to durability concerns (many surface treatments wash off or degrade over time), there 

are other considerations that limit their use. 

The main concern is difficulty in achieving uniform impregnation of a foam cushion, which may 

be 5 or 6 inches thick. In addition, many of these systems are water-based and the impregnated 

pieces then have to be dried, which is a slow and expensive process. The drying process also 

tends to produce a thin crust of the additive on the surface of the flexible polyurethane foam 

cushion. A variation of this approach has been to surface treat the finished upholstered cushion. 

This process must occur at the furniture assembly plants, which are not typically equipped for 

chemical processing. Some surface treatments can also leave an undesirable coating on the fabric 

cover or the cushion that is subject to disruption by friction during use. 

5.6 Methods for Selecting Chemical Flame Retardants 

The Partnership designed this report to provide stakeholders with the ability to impose their own 

values on which chemicals to select and weigh information based on multiple considerations, 

focusing on environmental and human health attributes. Various governmental, commercial and 

non-governmental organizations have developed tools and methods to assist with complex 

decision-making, some of it specific to creating chemical rankings. 

The Analytic Hierarchy Process (AHP) is a widely used technique for multi-attribute decision 

making. The process was developed by TL Saaty (The Analytical Hierarchy Process, McGrawHill, 1980), and uses a complex weighting system for comparing pairwise criteria, which can be 

further broken down into sub-criteria. A useful guide for investigating MCA tools is OECD's 

5-6
 
Technical Guidance Document on the Use of Socio-Economic Analysis in Chemical RiskManagement Decision Making. Another useful guide is found at 

http://farmweb.jrc.cec.eu.int/ci/S6_weighting.htm. 

Due to the complexity of the calculations, commercial software has been developed to assist 

analysts (www.expertchoice.com), though the calculations can be done without specialized 

software (http://mdm.gwu.edu/forman/Reproducing%20AHP%20calculations.pdf). 

Two resources specific to creating chemical rankings, and which are applicable to the data 

generated from this report are: 

1. 	 CARS – Chemical Assessment and Ranking System found at: 

http://www.zerowaste.org/cars/ 

2. 	 Substitution of PBT (persistent, bioaccumulative, toxic) substances in products and 

processed. Guidance for the use of environmentally sound substances. 

A. 	 www.umweltdaten.de/umweltvertraegliche-stoffe-e/part1.pdf 

B. 	 www.umweltdaten.de/umweltvertraegliche-stoffe-e/part2.pdf 

The methodology in the second web site is particularly relevant. While it is written to address 

chemicals relevant to the aquatic environment, it could be modified to add concerns for releases 

to air as well. 

Regulations that restrict the use of particular chemicals may also be useful to stakeholders when 

making decisions about flame retardancy methods. Appendix C provides a list of regulations that 

readers may reference to locate sources of information. 

The information in this report is intended to aid industry in incorporating environmental 

information into their decision-making processes. Consumer groups may also find this 

information useful. While the information in this report is static, the Partnership will continue to 

work together to update this information and identify environmentally preferable options for both 

furniture and mattress fire safety. Current information on the Partnership is available on the web 

at http://www.epa.gov/dfe/projects/flameret/index.htm. 

5-7
 
6.0 REFERENCES 

1. 	 Agency for Toxic Substances and Disease Registry (ATSDR). 2004. Toxicological 

profile for polybrominated biphenyls and polybrominated diphenyl ethers - draft for 

public comment. U.S. Department of Health and Human Services, Public Health Service. 

Atlanta, GA. http://www.atsdr.cdc.gov/toxprofiles/tp68.html 

2. 	 Birnbaum, L.S., and D.F. Staskal. 2004. “Brominated Flame Retardants: Cause for 

Concern?” Environmental Health Perspectives. 112(1): 9-17. 

3. 	 Bonaddio, V. 2002. Polyurethane Foam Association. Telephone communication to 

A.Brazy, Eastern Research Group, Inc. July 31. 

4. 	 Borgnes, D., and B. Rikheim. 2004. “Decomposition of BFRs and emission of dioxins 

from co-incineration of MSW and electrical and electronic plastics waste.” 

Organohalogen Compounds. 66: 890-898. 

5. 	 Borms, R., R. Wilmer, S. Bron, Y. Zilberman, and P. Georlette. 2004. “Efficient Reactive 

Flame Retardant Systems for Production of Flexible and Rigid Polyurethane Foams.” 

Proceedings of the Flame Retardants 2004 Conference. London, England. 

6. 	 Bradford, L., E. Pinzoni, and J. Wuestenenk. 1996. “The Effect of Fogging of Common 

FR Additives in Flexible Foam.” Proceedings of the Polyurethane Foam Association. 

October 17-18. 

7. 	 Butt, C.M., M.L. Diamond, J. Truong, M.G. Ikonomou, and A.F.H. ter Schure. 2004. 

"Spatial Distribution of Polybrominated Diphenyl Ethers in Southern Ontario As 

Measured in Indoor and Outdoor Window Organic Films." Environmental Science & 

Technology. 38(3): 724-731. 

8. 	 Consumer Product Safety Commission. 2004. “Public Meeting on the CPSC Staff’s 

Revised Draft Standard for Upholstered Furniture Flammability.” Presentation slides. 

October 28. 

9. 	 de Wit, C.A. 2000. Brominated Flame Retardants. Report 5065. Swedish Environmental 

Protection Agency. 

10. 	 Dezignare Interior Design Collective. 2003. “Great Lakes Develops Flame Retardants 

That Meet Changing Demands of the Polyurethane Market.” 

http://www.dezignare.com/whatshot/July2003/1.Chicago.html. 

11. 	 Environ International Corporation. 2003. “Tier 1 Assessment of the Potential Health 

Risks to Children Associated with Exposure to the Commercial Pentabromodiphenyl 

Ether Product.” Prepared for Great Lakes Chemical Corporation as the sponsor to EPA’s 

Voluntary Children’s Chemical Exposure Program. 

6-1
 
12. 	 European Chemicals Bureau. 2001. European Union Risk Assessment Report: diphenyl 

ether, pentabromo deriv. EUR 19730 EN. Joint Research Centre. 

http://ecb.jrc.it/DOCUMENTS/ExistingChemicals/RISK_ASSESSMENT/REPORT/penta_bdpereport015.pdf 

13. 	 Fisk, P.R., A.E. Girling, and R.J. Wildey. 2003. Prioritisation of Flame Retardants for 

Environmental Risk Assessment. Prepared by Peter Fisk Associates for the Environment 

Agency (United Kingdom). 

14. 	 Harrad, S., R. Wijesekera, S. Hunter, C. Halliwell, and R. Baker. 2004. “Preliminary 

Assessment of U.K. Human Dietary and Inhalation Exposure to Polybrominated 

Diphenyl Ethers.” Environmental Science and Technology. 38(8): 2345-2350. 

15. 	 Kirk Othmer. 2001. Kirk Othmer Encyclopedia of Chemical Technology. John Wiley & 

Sons, New York, NY. 

16. 	 Leisewitz, A., H. Kruse, E. Schramm. 2001. “Substituting Environmentally Relevant 

Flame Retardants: Assessment Fundamentals.” Research Report 204 08 542 UBA-FB 

000171/le. Federal Ministry of the Environment, Nature Conservation, and Nuclear 

Safety (Germany). 

17. 	 Lindberg, P., U. Sellström, L. Häggberg, and C.A. de Wit. 2004. “Higher Brominated 

Diphenyl Ethers and Hexabromocyclododecane Found in Eggs of Peregrine Falcons 

(Falco peregrinus) Breeding in Sweden.” Environmental Science & Technology. 38(1): 

93-96. 

18. 	 Lowell Center for Sustainable Production. 2005. Decabromodiphenylether: An 

Investigation of Non-Halogen Substitutes in Electronic Enclosure and Textile 

Applications. University of Massachusetts Lowell. 

http://sustainableproduction.org/downloads/DecaBDESubstitutesFinal4-15-05.pdf 

19. 	 Luedeka, R. 2002. Polyurethane Foam Association. Telephone communication to 

A.Brazy, Eastern Research Group, Inc. July 3. 

20. 	 North, K. 2004. “Tracking Polybrominated Diphenyl Ether Releases in a Wastewater 

Treatment Plant Effluent, Palo Alto, California.” Environmental Science & Technology. 

38(17):4484-4488. 

21. 	 Official Journal of the European Union. 2003. Directive 2003/11/EC. OJ L42/45. 

February 15. http://europa.eu.int/eurlex/pri/en/oj/dat/2003/l_042/l_04220030215en00450046.pdf 

22. 	 Organisation for Economic Co-operation and Development. 1995. Risk Reduction 

Monograph No.3: Selected Brominated Flame Retardants. OCDE/GD(94)96. Paris, 

France. http://www.olis.oecd.org/olis/1994doc.nsf/LinkTo/ocde-gd(94)96 

6-2
 
23. 	 Peltola, J., and L. Ylä-Mononen. 2000. Pentabromodiphenyl ether as a global POP. 

Finnish Environment Institute, Chemicals Division. 

http://www.unece.org/env/popsxg/docs/2000-2003/pentabromodiphenyl_ether.pdf 

24. 	 Posner, S. 2004. Survey and Technical Assessment of Alternatives to Decabromodiphenyl 

Ether (decaBDE) in Textile Applications. Prepared by IFP Research for the Swedish 

Chemicals Inspectorate. http://www.kemi.se/upload/Trycksaker/Pdf/PM/PM5_04.pdf 

25. 	 Risk & Policy Analysts Limited. 2000. Risk Reduction Strategy and Analysis of 

Advantages and Disadvantages for Pentabromodiphenyl Ether. J285/PeBDPE. Prepared 

for the Department of the Environment, Transport and the Regions (United Kingdom). 

26. 	 Rudel, R.A., D.E. Camann, J.D. Spengler, L.R. Korn, J.G. Brody. 2003. “Phthalates, 

Alkylphenols, Pesticides, Polybrominated Diphenyl Ethers, and Other EndocrineDisrupting Compounds in Indoor Air and Dust.” Environmental Science & Technology. 

37(20): 4543-4553. 

27. 	 Sjödin, A., L. Hagmar, E. Klasson-Wehler, K. Kronholm-Diab, E. Jakobsson, and Å. 

Bergman. 1999. “Flame Retardant Exposure: Polybrominated Diphenyl Ethers in Blood 

from Swedish Workers.” Environmental Health Perspectives. 107(8): 643-648. 

28. 	 Sjödin, A., H. Carlsson, K. Thuresson, S. Sjölin, Å. Bergman, and C. Östman. 2001. 

“Flame Retardants in Indoor Air at an Electronics Recycling Plant and at Other Work 

Environments.” Environmental Science & Technology. 35(3): 448-454. 

29. 	 Stapleton, H.M., R.J. Letcher, and J.E. Baker. 2004. “Debromination of Polybrominated 

Diphenyl Ether Congeners BDE 99 and BDE 183 in the Intestinal Tract of the Common 

Carp (Cyprinus carpio).” Environmental Science & Technology. 38(4): 1054-1061. 

30. 	 Stapleton, H.M., N.G. Dodder, J.H. Offenberg, M.M. Schantz, S.A. Wise. 2005. 

“Polybrominated Diphenyl Ethers in House Dust and Clothes Dryer Lint.” Environmental 

Science & Technology. 39(4): 925-931. 

31. 	 State of California. 2004. Assembly Bill No. 2587. September 21. 

http://www.leginfo.ca.gov/pub/03-04/bill/asm/ab_2551­

2600/ab_2587_bill_20040921_chaptered.pdf 

32. 	 State of Hawai’i. 2004. House Bill No. 2013. June 24. 

http://www.capitol.hawaii.gov/session2004/bills/hb2013_cd1_.htm 

33. 	 Toxicology Excellence for Risk Assessment (TERA). 2004. Report of the Peer 

Consultation Meeting on Pentabromodiphenyl Ether. Voluntary Children's Chemical 

Evaluation Program (VCCEP) Peer Consultation Meeting on Octabromodiphenyl Ether 

and Pentabromodiphenyl Ether, June 3-5, 2003, Cincinnati, OH. 

http://www.tera.org/peer/VCCEP/OctaPenta/OctaPentaWelcome.html 

6-3
 
34. 	 U.S. EPA. 1992. Classification Criteria for Environmental Toxicity and Fate of 

Industrial Chemicals. Office of Prevention, Pesticides and Toxics, Chemical Control 

Division. Washington, DC. 

35. 	 U.S. EPA. 1994. US EPA/EC Joint Project on the Evaluation of (Quantitative) Structure 

Activity Relationships. Office of Prevention, Pesticides and Toxic Substances. EPA 743­

R-94-001. Washington, DC. http://www.epa.gov/oppt/newchems/21ecosar.htm 

36. 	 U.S. EPA. 1999. “Category for Persistent, Bioaccumulative, and Toxic New Chemical 

Substances.” Federal Register. 64(213): 60194-60204. November 4. 

http://www.epa.gov/fedrgstr/EPA-TOX/1999/November/Day-04/t28888.htm 

37. 	 U.S. EPA. 2000. “Revision to CEB’s Method for Screening-Level Assessments of 

Dermal Exposure.” Memorandum to CEB staff and contractors. Office of Prevention, 

Pesticides and Toxics, Economics, Exposure and Technology Division, Chemical 

Engineering Branch. Washington, DC. 

38. 	 Wagner, P.M., J.V. Nabholz, R.J. Kent. 1995. “The New Chemicals Process at the 

Environmental Protection Agency (EPA): Structure-Activity Relationships for Hazard 

Identification and Risk Assessment.” Toxicology Letters. 79: 67-73. 

39. 	 Watanabe, I., and S. Sakai. 2003. “Environmental release and behavior of brominated 

flame retardants.” Environment International. 29: 665-682. 

40. 	 Weil, E., and S. Levchik. 2004. “Commercial Flame Retardancy of Polyurethanes.” 

Journal of Fire Sciences. 22(3): 183-210. 

41. 	 Wilford, B.H., G.O. Thomas, R.E. Alcock, K.C. Jones, and D.R. Anderson. 2003. 

“Polyurethane Foam as a Source of PBDEs to the Environment.” Organohalogen 

Compounds. 61:219-222. 

42. 	 Wilford, B.H., T. Harner, J. Zhu, M. Shoeib, and K.C. Jones. 2004. “Passive Sampling 

Survey of Polybrominated Diphenyl Ether Flame Retardants in Indoor and Outdoor Air 

in Ottawa, Canada: Implications for Sources and Exposure.” Environmental Science & 

Technology. 38(20): 5312-5318. 

6-4
 
Appendix A 
 

PentaBDE Facts 
 
Summary of USEPA’s Understanding of PBDEs 

Polybrominated diphenylethers (PBDEs) are members of a broader class of brominated 

chemicals used as flame retardants; these are called brominated flame retardants, or BFRs. There 

are commercial mixtures of PBDEs with different average amounts of bromination: penta-, octa-, 

and decaBDE. These chemicals are major components of commercial formulations often used as 

fire retardants in furniture foam (pentaBDE), plastics for TV cabinets, consumer electronics, 

wire insulation, backcoatings for draperies and upholstery (decaBDE) and plastics for personal 

computers and small appliances (octaBDE). The value of these chemicals is their ability to slow 

ignition and rate of fire growth, and as a result increase available escape time in the event of a 

fire involving the above consumer products. 

Although use of these chemicals is intended to save lives and property, there have been 

unintended consequences. Environmental monitoring programs in Europe, Asia, North America, 

and the Arctic have detected several PBDEs in human breast milk, fish, aquatic birds and 

elsewhere in the environment. Tetra- to hexabrominated diphenyl ethers are the PBDEs most 

frequently detected in wildlife and humans. The exact mechanisms or pathways by which the 

PBDEs end up in the environment and humans are not known yet, but would include releases 

from manufacturing or processing of the chemicals into products like plastics or textiles, aging 

and wear of the end consumer products and direct exposure during use (e.g., from furniture). 

EPA is not only interested in responding to monitoring data, however. The Agency 

continually looks for pollution prevention opportunities; the Pollution Prevention Act of 1990 

and EPA's Pollution Prevention Strategy establish that pollution should be prevented or reduced 

at the source whenever feasible. The Agency has also made protection of children's health a 

fundamental goal of public health and environmental protection in the United States. 

In general, the human health and environmental concerns are higher for the lower 

brominated mixtures (i.e., pentaBDE and octaBDE), and data suggest that higher brominated 

forms such as decaBDE can be altered to form more toxicologically active lower brominated 

forms. The limited toxicity test data that is currently available indicate the potential for adverse 

effects to humans and environmental organisms, especially for lower brominated mixtures, but 

existing hazard and exposure information on PBDEs is incomplete. More needs to be understood 

about the environmental fate and the exposure pathways that lead to PBDE presence in wildlife 

and people. PBDEs appear to be persistent and bioaccumulative in the environment. EPA 

believes an improved understanding of potential risks posed by the different PBDE mixtures in 

their various use applications is needed. EPA is addressing PBDE information needs with a 

three-pronged approach, which includes: 

• 	 Efforts to better understand the environmental properties, exposure pathways and how 

these chemicals are getting into human tissue; 

• 	 Research and detailed testing to determine health and environmental effects; and 

• 	 Evaluation of potential substitutes, which includes the analysis of technical performance, 

cost-effectiveness and risk-risk trade-offs related to fire prevention and toxicity. 

A-1
 
EPA offices and regions are working with fire safety advocates, industry, environmental 

and public health groups, other federal agencies, state governments and other national 

governments to answer the key questions and provide a basis for informed risk reduction 

decisions, including potential regulatory and voluntary actions. In November 2003, Great Lakes 

Chemical Corp., the only U.S. manufacturer of pentaBDE and octaBDE, announced a voluntary 

phase out of both those chemicals by the end of 2004. 

Toxicity 

There are commercial mixtures of PBDEs with different average amounts of 

bromination: penta-, octa- and decaBDE. In general, the human health and environmental 

concerns are greater for the lower brominated mixtures. 

Penta- and OctaBDE 

Effects on induction of hepatic enzymes were the basis of the EPA Integrated Risk Information 

System (IRIS) assessments of commercial pentaBDE and octaBDE mixtures which were 

completed in 1990. However, although liver enzyme induction was used as the basis for the RfD 

then, based on current methodology, this endpoint would not now be used as the basis of an RfD 

given the absence of other negative liver effects or histopathology. An update of the IRIS 

assessment for PBDE's is in progress. Several recent studies in young laboratory animals (rats 

and mice) exposed to commercial pentaBDE or to several individual congeners during gestation 

have shown some evidence of alterations in several behavioral parameters, deficits in learning 

and memory, and delays in the onset of puberty. Prenatal exposure to octaBDE mixtures in 

laboratory animals has resulted in reductions in fetal body weight, and delays in ossification - a 

longer than normal period before hardening of the bones. PentaBDE and octaBDE mixtures and 

individual congeners have also been shown to disrupt normal thyroid hormone levels in adult 

rats and mice. This could have possible concerns for developmental neurotoxic effects since it is 

well-established that disruption of thyroid hormone levels in the pregnant female may affect 

brain development in the fetus. The National Toxicology Program (an interagency program 

consisting of relevant toxicology activities of the Centers for Disease Control, Food and Drug 

Administration and National Institutes of Health) plans to conduct both chronic and subchronic 

toxicity studies on the commercial pentaBDE mixture, as well as the individual congeners 

appearing in greatest concentration in the mixture. 

DecaBDE 

Less is known about the potential toxicity of decaBDE. However, in contrast to penta- and 

octaBDE, decaBDE is poorly absorbed which may limit its potential toxicity. Some studies have 

shown thyroid and liver toxicity. Prenatal developmental toxicity studies in animals have been 

equivocal. A recent study in mice has provided some evidence of behavioral alterations. The 

European Commission will be requiring a more complete developmental neurotoxicity study in 

rodents to help clarify the potential for decaBDE exposure to result in developmental 

neurotoxicity. In addition, exposure to very high doses of decaBDE has been shown to cause 

tumors in laboratory animals. 

A-2
 
Exposure 

PBDEs have been measured in breast milk, adipose tissue and blood serum from human 

populations in Sweden, Finland, Germany, Japan, Spain, Canada and the United States. PBDE 

concentrations have steadily increased over 20 years of monitoring conducted in Sweden and 

Germany. In Sweden, PBDE levels in breast milk had doubled every 5 years between 1972 and 

1997, with a decreasing trend since 1997. North American data are limited and additional 

studies are ongoing to determine relative levels in breast milk and blood serum compared to 

those found in Europe. However, average levels as measured in 23 human adipose tissue samples 

and 32 serum samples from among California women and 50 breast milk samples from Canada 

were higher than PBDE levels measured in Sweden. 

Limited monitoring studies have found PBDEs in air, water, sediment, biota and sewage 

sludge throughout North America. The highest concentrations are generally associated with 

locations near facilities manufacturing or processing PBDEs. Concentrations of PBDEs are 

higher in municipal sewage sludge than in other environmental media. Recently reported PBDE 

concentrations in the United States and Canada are greater than those reported in Europe and 

Asia. 

Different congeners are found at different levels in environmental media and wildlife. 

Generally the highest measured concentrations are for the tetra (>50%), penta (20-30%), hexa 

(15-20%) and hepta and octa brominated (< 20%) congeners. Which congeners are found and 

their relative and absolute concentrations vary from site to site. 

A-3
 
Questions and Answers on PBDEs 

1. What are PBDEs? 

Polybrominated diphenylethers (PBDEs) are members of a broader class of brominated 

chemicals used as flame retardants; these are called brominated flame retardants, or BFRs. There 

are three commercial mixtures of PBDEs with differing average amounts of bromination: penta-, 

octa-, and decaBDE. 

2. What are PBDEs used for? 

These chemicals are major components of commercial formulations often used as flame 

retardants in furniture foam (pentaBDE), plastics for TV cabinets, consumer electronics, wire 

insulation, and backcoatings for draperies and upholstery (decaBDE), and plastics for personal 

computers and small appliances (octaBDE). The benefit of these chemicals is their ability to 

slow ignition and rate of fire growth, and as a result increase available escape time in the event 

of a fire. 

3. What are concerns associated with PBDEs? 

Although use of flame retardants saves lives and property, there have been unintended 

consequences. There is growing evidence that PBDEs persist in the environment and accumulate 

in living organisms, as well as toxicological testing that indicates these chemicals may cause 

liver toxicity, thyroid toxicity, and neurodevelopmental toxicity. Environmental monitoring 

programs in Europe, Asia, North America, and the Arctic have found traces of several PBDEs in 

human breast milk, fish, aquatic birds, and elsewhere in the environment. Particular congeners , 

tetra- to hexabrominated diphenyl ethers, are the forms most frequently detected in wildlife and 

humans. The mechanisms or pathways through which PBDEs get into the environment and 

humans are not known yet, but could include releases from manufacturing or processing of the 

chemicals into products like plastics or textiles, aging and wear of the end consumer products, 

and direct exposure during use (e.g., from furniture). 

4. What is the Agency doing to better understand the possible risks from exposure to 

PBDEs? 

EPA is currently evaluating a risk assessment and data needs analysis on PBDEs that was 

developed by industry for the Voluntary Children’s Chemical Evaluation Program (VCCEP). 

This assessment evaluates the potential risks to children and prospective parents from all 

potential exposure scenarios. EPA will be releasing its views of the assessment, including any 

further VCCEP data needs, in the next few months. 

Directly or through grant mechanisms, EPA has been supporting research aimed at a range of 

topics related to PBDEs, including measuring PBDE levels in umbilical cord blood from 

newborn U.S. infants, mothers’ blood, house dust, food, breast milk, and children; potential 

thyroid toxicity and developmental neurotoxicity; and the environmental fate of the PBDEs upon 

their release during production or after disposal of products that contain these chemicals. 

EPA’s Office of Research and Development, National Center for Environmental Assessment, is 

enhancing its Integrated Risk Information System (IRIS) database on the PBDEs. IRIS is a 

database of human health effects that may result from exposure to substances found in the 

A-4
 
environment. The Agency developed IRIS to provide consistent information on chemical 

substances for use in risk assessments, decision-making and regulatory activities. The 

information in IRIS is intended for those without extensive training in toxicology, but with some 

knowledge of health sciences. 

5. How does this action complement the decision by the sole US manufacturer to phase out 

production by December 31, 2004? 

This action builds on the November 3, 2003, announcement by the Great Lakes Chemical 

Corporation, the only U.S. manufacturer of these chemicals, who agreed to voluntarily phase-out 

production by December 31, 2004. In 2003, EPA commended Great Lakes Chemical 

Corporation for taking this responsible action. EPA is concerned that manufacture or import 

could be reinstated in the future, and thus believes it is necessary to have the opportunity to 

evaluate any new manufacture or import associated with these chemicals. 

6. Why are these chemical important and are there substitutes? 

These chemicals provide a very important benefit because of their ability to save lives and 

property by slowing ignition and rate of fire growth, and therefore increase available escape time 

in the event of a fire. However, EPA also believes both the phase out and the Significant New 

Use rule will further spur the development of safer alternatives. 

EPA has been working to ensure that following the phasing out of these two chemicals, 

acceptable alternatives are available to industry. Such alternatives would need to meet 

technological requirements of industry users, flame retardancy requirements in US standards, 

and present lower hazards than the chemicals for which they are substituting. To promote these 

goals and to explore the safety of alternative flame retardant chemicals, EPA has convened a 

group of stakeholders in its Furniture Flame Retardancy Partnership, including chemical 

manufacturers and users, the furniture industry, government agencies, and consumer groups, who 

will work together to evaluate possible alternatives to PentaBDE. 

7. Should consumers discard any products that might contain PentaBDE or Octa? 

No, the EPA does not believe that there is a need to remove or replace products that may contain 

these chemicals. EPA has not concluded that PBDEs pose an unreasonable risk to human health 

or the environment. However, due to growing concerns, EPA believes that the phase out and the 

regulatory action taken in this announcement are useful steps to minimize and ultimately help 

prevent further exposure to these chemicals. 

8. What are PBDEs commonly used for? 

The PBDEs are major components of commercial formulations often used as fire retardants in 

furniture foam, plastics for TV cabinets, consumer electronics, wire insulation, and backcoatings for draperies and upholstery, and plastics for personal computers and small appliances. 

These chemicals slow ignition and rate of fire growth, and, as a result, increase available escape 

time in the event of a fire involving the above consumer products. 

9. How are people exposed to PBDEs? 

PBDEs are not chemically bound to plastics, foam, fabrics, or other products in which they are 

used, making them more likely to leach out of these products. PBDEs may enter the air, water 

A-5
 
and soil during their manufacture and use in consumer products. The primary route of human 

exposure is currently unclear. 

10. What is the Agency doing to better understand the occurrence of PBDEs in the 

environment? 

EPA is addressing PBDE information needs with a three-pronged approach which includes: 1) 

efforts to better understand the environmental properties, exposure pathways, and how these 

chemicals are getting into human tissue; 2) research and detailed testing to determine health and 

environmental effects from exposure to PBDEs; and 3) evaluation of potential PBDE substitutes, 

which includes the analysis of technical performance, cost-effectiveness, and risk-risk trade-offs 

related to fire prevention and toxicity. 

11. What efforts are underway to discourage continued use of the PBDEs? 

In November 2003, the Great Lakes Chemical Corporation announced a voluntary phase out of 

PentaBDE and OctaBDE by the end of 2004. Great Lakes is the only U.S. manufacturer of these 

PBDEs. To follow up on this voluntary action, EPA is working with chemical manufacturers and 

end users to facilitate an orderly transition to safer substitutes. The State of California has 

enacted a law banning use of PentaBDE and OctaBDE by January 2008 (recently changed to 

June 1, 2006) and other states (including Maine, Hawaii, Washington, and New York) are also 

considering or have passed similar legislation. In Europe, the European Union enacted a ban on 

PentaBDE and OctaBDE in all products which took effect on August 15, 2004. 

EPA is also working with the fire safety advocates, chemical manufacturers, manufacturers of 

end products such as furniture or plastics for electronics, environmental and public health 

groups, other federal agencies, state governments, and other nations to answer key questions and 

help people make informed decisions based on risk. EPA is considering both regulatory and 

voluntary actions. 

A-6
 
Appendix B 
 

Interpretive Guidance 
 
Interpretive Guidance Document for Sustainable Futures Summary Assessment 
 

Updated September 2004
 

This document was developed to help interpret results from the Sustainable Futures / P2 Framework 

models. Information is also included here which helps assign concern levels to results based on 

criteria from U.S. EPA OPPT’s New Chemicals Program 

http://www.epa.gov/oppt/newchems/index.htm. Information contained in this document is presented 

in greater detail in the P2 Framework Manual. For more information on the models, estimations 

provided, and interpretation of results, please check the manual, which can be downloaded from 

http://www.epa.gov/oppt/p2framework/docs/p2manua.htm. 

Physical/Chemical Properties and Environmental Fate Estimations 2 

EPISuiteJ - Entering Data .............................................................................................. 2 
 

Interpreting Results from EPISuiteJ............................................................................. 2 
 

Hazard Estimations 5 

Aquatic Toxicity Hazard - ECOSAR............................................................................. 5 
 

Human Health Hazard - Cancer - OncoLogic.............................................................. 6 
 

Human Health Hazard - Non-Cancer ........................................................................... 7 
 

PBT Potential Estimation 7 

Exposure Estimations 8 

Aquatic Exposure - E-FAST........................................................................................... 8 
 

Human Exposure - ChemSTEER and E-FAST............................................................ 8 
 

Risk Estimations 9 
 

Estimating Aquatic Risk ................................................................................................. 9 
 

Aquatic Risk Summary................................................................................................. 11 
 

Estimating Human Health Non-Cancer Risk ............................................................. 11 
 

Human Health Risk Summary..................................................................................... 13 
 

Occupational Risk Summary ....................................................................................... 14 
 

Estimating Human Health Cancer Risk...................................................................... 14 
 

References Cited 15 

Model Availability 
 

C EPISuiteTM - download at no cost from http://www.epa.gov/opptintr/exposure/docs/episuite.htm 

C ECOSAR - download at no cost from http://www.epa.gov/oppt/newchems/21ecosar.htm 

C PBT Profiler - use on-line at no cost at www.pbtprofiler.net 

C Cancer Expert System / OncoLogic - contact Bill Waugh, waugh.bill@epa.gov for information. 

U.S. EPA has purchased the commercial rights to OncoLogic and plans to make the model 

publicly available. 

C E-FAST - download at no cost from http://www.epa.gov/opptintr/exposure/docs/efast.htm 

C ChemSTEER - download at no cost from 

http://www.epa.gov/opptintr/exposure/docs/chemsteer.htm 

B-1
 
Physical/Chemical Properties and Environmental Fate Estimations 

EPISuiteTM - Entering Data 

The chemical structure can be entered using SMILES notation - or - if the chemical has a CAS 

Registry Number, the CAS numbers may be entered and the structure will be retrieved from the 

EPISuiteTM built-in database if available. There is also a name lookup function that allows the user 

to retrieve chemical information without knowing the chemical structure or CAS number. 

If any experimental data are available for the chemical, then all data should be entered into the input 

screen for EPISuiteTM. 

For chemicals that are known liquids with no experimental MP data, enter 20 deg C as an 

experimental MP into the input screen for all EPISuiteTM predictions. 

Interpreting Results from EPISuiteTM 

Melting Point and Boiling Point - Estimated by MPBPWIN 

MP < 25 deg C = Liquid MP > 25 deg C = Solid BP < 25 deg C = Gas 

Vapor Pressure - Estimated by MPBPWIN 

> 10-4 = Vapor (gas) phase 10-5 - 10-7 = Vapor and particulate phase < 10-8 = Solid phase 

For chemicals with a VP < 10-6, there is low concern for inhalation exposure. 

Water Solubility (mg/L) - Estimated by WSKOWWIN 

> 10,000 Very soluble 

> 1,000 - 10,000 Soluble 

> 100 - 1,000 Moderate solubility 

> 0.1 - 100 Slightly soluble 

< 0.1 Insoluble 

Log Kow (Log P) - Estimated by KOWWIN 

< 1 Highly soluble in water (hydrophilic) 
 

> 4 Not very soluble in water (hydrophobic) 
 

> 8 Not readily bioavailable 
 

> 10 Not bioavailable - difficult to measure experimentally 
 

Henry’s Law Constant (atm-m3/mole) - Estimated by HENRYWIN 

> 10-1 Very volatile from water 

10-1 - 10-3 Volatile from water 

10-3 - 10-5 Moderately volatile from water 

10-5 - 10-7 Slightly volatile from water 

< 10-7 Nonvolatile 

If experimental vapor pressure and water solubility data are available and entered as input data into 

EPISuiteTM, then the VP/Wsol estimate (instead of the bond or group estimation method) should be 

used. 

B-2
 
Atmospheric Oxidation Half-life - Estimated by AOPWIN 

< 2 hours Rapid 

2 hrs - < 1 day Moderate 

> 1 day - < 10 days Slow 

>10 days Negligible 

>2 days Has potential for long range transport in air 

Hydrolysis Rates - Estimated by HYDROWIN 

- Only Esters, Carbamates, Epoxides, Halomethanes, and certain Alkyl Halides are estimated in 

HYDROWIN. 

Biodegradation - Estimated by BIOWIN: 3 Models available in EPISuiteTM 

1. Probability of Rapid Biodegradation (BIOWIN): 

BIOWIN Linear and BIOWIN Nonlinear 

> 0.50 Likely to biodegrade fast < 0.50 Not likely to biodegrade fast 

2. Expert Survey Biodegradation (Primary/Ultimate): 

Calculated Time Required Predicted Time Required 

Rating for Biodegradation Rating for Biodegradation 

5.0 	 Hours 5.0 Hours 

4.5 	 Hours - days 4.0 Days 

4.0 	 Days 3.0 Weeks 

3.5 	 Days - weeks 2.5 Weeks - months 

2.0 	 Months 

1.0 	 Longer 

3. Ready Biodegradability Model (MITI): 

MITI Linear and MITI Nonlinear 

> 0.50 Ready Biodegradable < 0.50 Not Ready Biodegradable 

Soil Adsorption Coefficient (Log Koc) - Estimated by PCKOCWIN 

> 4.5 	 Very strong sorption to soil and sediment, negligible migration potential to groundwater 

3.5 - 4.4 	 Strong sorption to soil and sediment, negligible to slow migration potential to 

groundwater 

2.5 - 3.4 	 Moderate sorption to soil and sediment, slow migration potential to groundwater 

1.5 - 2.4 	 Low sorption to soil and sediment, moderate migration potential to groundwater 

< 1.5 	 Negligible sorption to soil and sediment, rapid migration potential to groundwater 

Bioconcentration Factors - Estimated by BCFWIN 

> 5000 High bioconcentration potential 

1000 - 5000 Moderate bioconcentration potential 

< 1000 Low bioconcentration potential 

B-3
 
STPWIN - Percent Removal in Sewage Treatment Plants 

S 	 Gives an indication of the percent removed from biodegradation (Bio P), sludge adsorption (Bio 

S), and aeration (Bio A) in a POTW or Sewage Treatment Plant. 

S 	 Negligible biodegradation (half-life = 10,000 hours) is the default value for the primary clarifier 

(P), aeration vessel (A), and final settling tank (S) unless otherwise specified in the input screen 

for EPISuiteTM. If data are available for the chemical, these half-lives can be changed in the 

input screen using the following guidance: 

1 hour = for chemicals with data suggesting rapid biodegradation potential 
 

3 hours = for chemicals with data suggesting moderate biodegradation potential 
 

30 hours = for chemicals with data showing slow biodegradation potential 
 

10,000 hours = default rate for chemical with unknown biodegradation potential
 

LEV3EPI - Fugacity Model 

S 	 Provides an indication of which environmental compartment the chemical is expected to partition 

to and calculates an approximate persistence time. 

WVOL - Volatilization from Water 

S 	 Uses molecular weight, Henry's Law Constant, and water solubility to estimate an upper limit 

for volatilization from a body of water. The model does not take into account potential 

adsorption to sediment and suspended organic matter when the Koc is high, which can increase 

the volatilization half-life dramatically. Therefore, if the Koc for a given chemical is high, the 

volatilization half-lives for a model river and model lake are expected to be significantly higher 

than predicted in WVOL. 

Persistence 

U.S. EPA describes Persistence criteria in the PBT category for Premanufacture Notices in the 

Category for Persistent, Bioaccumulative, and Toxic New Chemical Substances at 

http://www.epa.gov/tri/pbt-final_rule.pdfhttp://www.epa.gov/fedrgstr/EPATOX/1999/November/Day-04/t28888.htm and in the final rule for TRI reporting of PBT Chemicals 

http://www.epa.gov/tri/pbt-final_rule.pdf. These criteria are used by the PBT Profiler (described in 

this document) to estimate environmental persistence potential of chemicals. These Persistence 

criteria are: 

PERSISTENCE Not Persistent Persistent 

Water, Soil, Sediment* < 60 d  60 d > 180 d 

Air**  2 d > 2 d 

* New Chemical Program Criteria 

** TRI Reporting Criteria 

B-4 
Hazard Estimations 

Aquatic Toxicity Hazard - ECOSAR 

Develop Full Standard Aquatic Toxicity Profile 

The standard aquatic toxicity profile consists of 3 acute values (fish LC50, daphnid LC50, and algae 

EC50) and 3 chronic values (fish ChV, daphnid ChV, and algae ChV). Examples of toxicity values 

that are generally used to fulfill the standard aquatic toxicity profile are provided below. 

Organism Acute Toxicity Values Chronic Toxicity Values 

Fish 96-hour LC50 30-day ChV 

Daphnid (Aquatic Invertebrate) 48-hour LC50 ChV or 16-day EC50 

Algae 72- or 96-hour EC50 ChV 

A full standard profile for each chemical should be created using either predicted or experimental 

data. If no predicted or experimental data are available for the chemical of interest, then analog data 

may be used. If a single measured or predicted toxicity value is available for a species but the 

corresponding acute or chronic value is not, then an acute to chronic ratio (ACR) can be used to 

estimate the corresponding acute or chronic toxicity value: 

Chronic toxicity estimate = (acute toxicity value) / (ACR) 

Acute toxicity estimate = (chronic toxicity value) x (ACR) 

An ACR of 10 is commonly applied to fish and daphnids and an ACR of 4 is commonly applied to 

algae. Example calculations are provided below. 

Fish LC50 = 0.10 mg/L → extrapolated fish ChV = (0.10 mg/L)/10 = 0.01 mg/L (ppm) 

Algae ChV = 0.02 mg/L → extrapolated algae EC50 = (0.02 mg/L) x 4 = 0.08 mg/L (ppm) 

A full toxicity profile needs to be developed to perform an aquatic toxicity assessment. If an acute 

or chronic toxicity endpoint cannot be determined for one or more species from measured data on 

the chemical or analog or from predicted data, then category data can be used to fulfill the endpoint. 

For example, a fish or daphnid toxicity value can be estimated using the fish-to-daphnid toxicity 

ratio of chemicals within the same category (e.g., acrylates). Use data from multiple chemicals if 

possible. All assumptions and toxicity data used for the estimation need to be documented in the 

Sustainable Futures Summary Assessment. 

B-5
 
The following guidance can be used to assign aquatic toxicity concern levels: 

SF Concern ECOSAR Results 

Low All 3 acute values are >100 mg/L, AND all three chronic values are >10.0 mg/L, or there 

are No Effects at Saturation (NES). NES occurs when a chemical is not soluble enough to 

reach the effect concentration, i.e., the water solubility is lower than an effect 

concentration, or, for liquids, when Kow criteria are exceeded for an endpoint. For solids, 

NES is expected if Kow exceeds the specific SAR Kow cutoffs, or the effect concentration is 

more than one order of magnitude (>10 X) less than water solubility. 

Moderate Any of the 3 acute values are >1.0 mg/L and <100 mg/L, OR any of the chronic values are 

>0.1 mg/L and <10.0 mg/L 

High Any of the 3 acute values are <1.0 mg/L, OR any of the chronic values are <0.1 mg/L 

(except for substances with very low solubility (NES)) 

NOTE: Kow cutoffs are specific to each SAR used in ECOSAR. The criteria can be found on the 

bottom of the results screen for ECOSAR or in the ECOSAR User’s Manual available for download 

at http://www.epa.gov/oppt/newchems/sarman.pdf. 

NOTE: Guidance on the evaluation of polymers can be found in 

Boethling R.S. and J. V. Nabholz. 1997. “Environmental assessment of polymers under the U.S. 

Toxic Substances Control Act”. In: Hamilton, J.D. and R. Sutcliffe, eds. Ecological assessment of 

polymers: Strategies for product stewardship and regulatory programs. New York, NY: Van 

Nostrand Reinhold, 187-234. ISBN 0-442-02328-6. 

Human Health Hazard - Cancer - OncoLogic 

Interpretation of OncoLogic Results:

 SF Concern OncoLogic Results Definition - OncoLogic Result 

Low Low Unlikely to be a carcinogen 

Further Research 

Needed 

Marginal Likely to have equivocal carcinogenic activity 

Moderate Low-Moderate Likely to be weakly carcinogenic 

Moderate Likely to be moderately active carcinogen 

High Moderate-High Highly likely to be a moderately active carcinogen 

High Highly likely to be a potent carcinogen 

B-6
 
Interpretation of Experimental Data: 

SF Concern Definition - Experimental Data 

Low Negative experimental data 

Moderate Positive cancer bioassay in experimental animals or chemical class known to produce 

carcinogenic effects 

High Positive experimental data in humans (e.g. epidemiology study) 

NOTE: Measured data from a properly conducted study on the SF chemical or a relevant analog 

always takes precedence over predicted data. 

Human Health Hazard - Non-Cancer
 

Criteria for Assigning Non-Cancer Hazard Concern Levels:
 

SF Concern Definition - Experimental Data 

Low No basis for concern identified 

Moderate Suggestive animal studies for chemical or analog(s) or chemical class known to 

produce toxicity 

High Evidence of adverse effects in humans or conclusive evidence of severe effects in 

animal studies 

NOTE: Regulatory decisions will be made based on the following human health effects: 

reproductive; immune; developmental; neurotoxicity; and systemic. 

NOTE: Guidance on the evaluation of non-cancer human health concerns of polymers can be found 

in: P2 Framework Manual, Oct 2003 version, edited Jan 2004, pg. 169-170 at 

http://www.epa.gov/oppt/p2framework/docs/p2manua.htm 

PBT Potential Estimation 

PBT Profiler - U.S. EPA describes Persistence, Bioaccumulative, and Toxicity (PBT) criteria in the 

PBT category for Premanufacture Notices in the Category for Persistent, Bioaccumulative, and 

Toxic New Chemical Substances at 

http://www.epa.gov/fedrgstr/EPA-TOX/1999/November/Day-04/t28888.htm and in the final rule for 

TRI reporting of PBT Chemicals http://www.epa.gov/tri/pbt-final_rule.pdf. These criteria are used 

by the PBT Profiler to estimate PBT potential of chemicals. 

These PBT criteria are: 

B-7
 
PERSISTENCE Not Persistent Persistent 

Water, Soil, Sediment* < 60 d ≥ 60 d > 180 d 

Air** ≤ 2 d > 2 d 

BIOACCUMULATION Not Bioaccumulative Bioaccumulative 

Fish BCF* < 1000 ≥ 1000 ≥ 5000 

TOXICITY Not Toxic Toxic 

Fish ChV* > 10 mg/L or No Effects at 

Saturation 

0.1-10 mg/L < 0.1 mg/L 

NOTE: The PBT Profiler is not appropriate for certain types of chemicals, such as metals. Before 

using the PBT Profiler determine if the chemical being evaluated is appropriate for running in the 

PBT Profiler. Extensive information is provided within the on-line model at www.pbtprofiler.net 

* New Chemical Program Criteria 

** TRI Reporting Criteria 

IMPORTANT NOTE: 

Evaluate exposure if a moderate or high hazard concern has been identified for any endpoint. 

Exposure Estimations 

Aquatic Exposure - E-FAST 

Predicted Environmental Concentration (PEC): 

Amount expected to be found in surface water after release from industrial processes; also called 

surface water concentration (SWC). 

Estimated values can be determined using E-FAST and found under the General SIC Code 

Information tab in the results screen. The 10% percentile, 7Q10 stream concentrations (μg/L) are 

used for an SF Assessment. 

To run E-FAST you will need to determine a chronic Concentration of Concern (COC) based on 

the toxicity values derived in the Aquatic Toxicity section. The COC is one of the inputs for the EFAST program and an explanation for the determination of a chronic COC can be found on the 

following page of this document. 

Human Exposure - ChemSTEER and E-FAST 

For Occupational Exposure Doses:
 

LADD, ADD, and APDR values will be estimated by ChemSTEER
 

For General Population Exposure Doses:
 

LADDpot, ADDpot, and ADRpot values will be estimated by E-FAST. The 10% percentile values 
 

(mg/kg/day) are used for an SF Assessment. 
 

B-8
 
Lifetime Average Daily Dose (LADD or LADDpot): 

The predicted lifetime exposure used to determine cancer risk usually based on an average lifetime 

of 70 - 75 years and a working lifetime of 30 - 40 years. 

Potential Average Daily Dose (ADD or ADDpot): 

The predicted dose that represents potential chronic exposure based on a duration of repeated 

exposure usually approximating an average of 30 years. 

Potential Acute Dose Rate (APDR or ADRpot): 

The predicted acute dose rate that represents acute exposure usually based on a single 8 hour 

working day exposure duration. 

NOTE: For the purposes of an SF Assessment, the defaults for average lifetime, body weight, 

exposure duration, and ingestion rate are pre-set in both ChemSTEER and E-FAST and should not 

be changed unless accurate data for these inputs are available. 

Risk Estimations Reminder: RISK = HAZARD x EXPOSURE 

For chemicals with an identified hazard concern, the potential exposure must be determined to make 

an assessment of risk. If a low concern for hazard is identified (hazard approx. = 0) or very low 

exposure is identified (exposure approx. = 0), then there is an inherently low concern for risk 

because of the mathematical relationship between hazard and exposure. 

Estimating Aquatic Risk 

Determine an Acute and Chronic Concentration of Concern (COC): 

Concentration at which potential acute or chronic aquatic toxicity may be of concern for aquatic 

species. Calculate a COC for every species in the full profile. 

Acute COC: 

Acute COC for fish = LC50 / (5) Acute COC for daphnia = EC50 / (5) 
 

Acute COC for algae = EC50 / (4) -OR- If an algae ChV value exists, use that value as the acute 
 

COC and do not estimate the COC using an EC50 value divided by a factor. 
 

If a NOEC value is available from an acute study for any species, that value can be used 

directly as the acute COC. (No assessment factor needed) 

Chronic COC: 

Chronic COC for fish = ChV / (10) Chronic COC for daphnia = ChV / (10) 

Chronic COC for algae = ChV / (10) 

If a NOEC value is available from a chronic study for any species, that value can be used 

directly as the chronic COC. (No assessment factor needed) 

Example calculations are provided below: 

Fish LC50 = 0.10 mg/L → calculated Acute COC = (0.10 mg/L) /5 = 0.02 mg/L (ppm) 

Daphnid ChV = 0.02 mg/L → calculated Chronic COC = (0.02 mg/L) /10 = 0.002 mg/L (ppm) 

B-9
 
NOTE: All COCs are rounded up to 1 significant digit (e.g., a COC of 1.75 ppb is rounded up to 2 

ppb). All COC values less than 1 ppb are rounded up to 1 ppb for assessments due to limitations in 

reliable analytical methods to test below 1 ppb should verification be needed. 

No values less than 1 ppb (the realistic detection limit) should be reported!! 

Estimating Acute Aquatic Risk 

The potential for acute risk to aquatic organisms exists if the predicted environmental concentration 

(PEC) is greater than the acute concentration of concern (COC). 

If Acute COC > PEC Low concern for risk If Acute COC < PEC Potential for risk 

Estimating Chronic Aquatic Risk 

The potential for chronic risk to aquatic organisms may exist if the COC is exceeded for 20 days or 

more per year. There will be instances that you will determine a chronic COC exceeds the PEC, but 

if it is not exceeded for 20 days or more per year, then there is low concern for risk. This is because 

although there is a potential for the concentration of the chemical in the water to reach levels 

exceeding the hazardous level, the levels are not exceeded for a sufficient duration of time to induce 

any chronic effects. 

The 20-day criterion is derived from partial life-cycle tests (daphnid chronic and fish early life- stage 

tests) that typically range from 21 to 28 days in duration. Low concern for chronic risk exists if the 

COC is exceeded on fewer than 20 days per year. 

E-FAST will predict how many days per year the (PEC) exceeds the (COC). The number of days 

the COC is exceeded can be found on the PDM SIC tab in the output screen of E-FAST. 

Example Worksheet for Identification of Acute and Chronic Risk to Aquatic Organisms: 

Acute Endpoint Value Factor Acute COC PEC Risk? 

Fish LC50 0.079 ppm 5 0.02 ppm 0.055 ppm Yes 

Daphnid LC50 0.11 ppm 5 0.02 ppm 0.055 ppm Yes 

Algae EC50 0.083 ppm 4 0.07* ppm 0.055 ppm No 

* Since an algae ChV value was available (see below), the ChV value was used as the algae acute 

COC. 

E-FAST indicated that the PEC exceeds the COC for 9.4 days per year 

Chronic Endpoint Value Factor Chronic COC PEC Risk? 

Fish ChV 0.018 ppm 10 0.002 ppm 0.055 ppm Yes 

Daphnid ChV 0.027 ppm 10 0.003 ppm 0.055 ppm No 

Algae ChV 0.067 ppm 10 0.007 ppm 0.055 ppm No 

B-10
 
Aquatic Risk Summary: There is potential for acute risk to the aquatic environment because the 

PEC is greater than the acute COC (for fish and daphnids). There is low concern for chronic risk 

because even though the PEC exceeds the chronic COC for fish, it is only exceeded for 9.4 days 

according to E-FAST and under EPA guidelines, this is not a sufficiently long enough duration to 

induce chronic effects. 

Estimating Human Health Non-Cancer Risk 

For the determination of risk to the human population from non-cancer human health effects, a 

quantitative value called the Margin of Exposure (MOE) is calculated. This margin is essentially the 

established safety buffer between the hazardous effects level (dose) and the predicted exposure dose. 

The EPA OPPT office utilizes margins of exposure that they believe are sufficiently protective of 

human health when assessing new chemicals. The calculated MOEs for each chemical are compared 

to the MOE criteria used by the OPPT office and the results are evaluated to determine the potential 

for risk. When referring to non-cancer effects, these margins of exposure or safety buffers must be 

at least 100X or 1000X protective of human health depending on the type of non-cancer data 

identified in the hazard assessment. 

If hazard data for ANY of the non-cancer health effect endpoints have indicated a moderate or high 

hazard concern, then an MOE for EACH moderate/high concern endpoint should be determined! 

The lowest MOE value calculated from that group should be recorded for assessment purposes and 

will be used as the quantitative value to determine the potential overall risk to human health from 

non-cancer effects. 

The lowest MOE will represent the worst-case scenario for the chemical and therefore, if the lowest 

MOE does not indicate a risk, then there is an assumed low potential for risk for all other endpoints 

which had mathematically larger MOE values. 

However, if even one of the endpoints has a calculated MOE indicating the potential for risk, then 

overall the chemical should be flagged as having potential risks to human health. The subsequent 

pages give more in-depth guidance on the determination of MOE for acute and chronic risk from 

occupational exposure and from exposures to the general population. 

The following table shows the human health non-cancer endpoints and the corresponding 

acute/chronic exposure values to use for calculation of an MOE: 

B-11
 
Endpoint Exposure dose used for MOE calc. 

Single Dose Studies 

Acute Toxicity ADRpot (acute)* 

Repeated Dose Studies 

Irritation Can not be used to determine MOE 

Skin Sensitizer Can not be used to determine MOE 

Reproductive Effects ADDpot (chronic) 

Immune System Effect ADDpot (chronic) 

Developmental Toxicity ADRpot (acute) 

Genotoxicity Can not be used to determine MOE 

Mutagenicity Can not be used to determine MOE 

Neurotoxicity ADDpot (chronic) 

Systemic Effects ADDpot (chronic) 

* Acute risk is ONLY assessed for chemicals with an LD50 value < 50 

mg/kg. 

Estimating Acute Risk to the General Population using an MOE: 

NOTE: When the acute toxicity studies indicate LD50 values > 50 mg/kg for a chemical, there is no 

need to calculate a Margin of Exposure (MOE) for acute exposure and a low concern for acute risk is 

assumed. 

There is a potential acute hazard concern for chemicals with an LD50 < 50 mg/kg. A MOE needs to 

be calculated and the potential for acute risk to the general population needs to be assessed when 

acute toxicity studies with LD50 values < 50 mg/kg have been identified. 

Margin of Exposure (MOE) based on Acute Exposure: 

Ratio of the identified effect level (LD50 value determined in health hazard section) to the estimated 

acute dose rate (predicted from E-FAST). 

MOEacute = LD50 (mg/kg) / ADRpot (from E-FAST) 

MOE < 1000 indicates potential for risk 

MOE > 1000 indicates low concern for risk 

Estimating Chronic Risk to General Population or to Workers using an MOE: 

NOTE: Regulatory decisions will be made based on the following human health effects: 

reproductive; immune; developmental; neurotoxicity; and systemic. 

B-12
 
Margin of Exposure (MOE) based on Chronic Exposure: 

An MOE is the ratio of the No-Observed Adverse-Effect-Level (NOAEL) or the Lowest-Observed 

Adverse-Effect-Level (LOAEL) for the effect (determined in health hazard section) to the estimated 

exposure value (predicted from exposure models). If both a NOAEL and LOAEL are available, then 

the NOAEL value is used for calculation of the MOE. 

MOE, Occupational = NOAEL or LOAEL(Non-Cancer) / APDR or ADD (from ChemSTEER) 

MOE, General Population = NOAEL or LOAEL(Non-Cancer) /ADRpot or ADDpot (from E-FAST) 

Human Health Risk Summary: There is a potential risk concern for chemicals with an MOE < 100 

based on studies with NOAEL values and for chemicals with MOE < 1000 based on studies with 

only LOAEL values. The preference is to identify a NOAEL value and use that value for your MOE 

calculations. The average daily dose (ADD or ADDpot) is used to determine an MOE with one 

exception; an MOE for developmental toxicity is based on the acute dose rate (APDR or ADRpot). 

For Calculation based on NOAEL: For Calculation based on LOAEL: 

MOE < 100 indicates potential for risk MOE < 1000 indicates potential for risk 

MOE > 100 indicates low concern for risk MOE > 1000 indicates low concern for risk 

For MOE values based on developmental toxicity data a body weight of 60 kg should be used as 

input when determining the exposure values (ADD, ADR, LADD) instead of the default of 70 kg 

because that particular endpoint is only assessed in females. 

B-13
 
Example Worksheet for Identification of the Potential for Acute and Chronic Risk to Human 

Health based on a Non-Cancer MOE: 

Population Effect NOAEL LOAEL Exposure MOE 

Occupational Systemic 40 mg/kg-d 200 mg/kg-d 1.8 x 10-2 mg/kg-d ChemSTEER 

ADD 

2222 

Neurotox 40 mg/kg-d 200 mg/kg-d 1.8 x 10-2 mg/kg-d ChemSTEER 

ADD 

2222 

General 

Population 

Systemic 40 mg/kg-d 200 mg/kg-d 2.1x10-6 mg/kg-d E-FAST ADDpot 1.9x107 

Neurotox 40 mg/kg-d 200 mg/kg-d 2.1 x 10-6 mg/kg-d E-FAST ADDpot 1.9x107 

The MOE used to evaluate Risk from Occupational Exposure = 2222 

The MOE used to evaluate Risk from General Population Exposure = 1.9 x 107 

Occupational Risk Summary: There is low concern for risk from occupational exposure or 

exposures to the general population because the MOE's are greater than 100 (based on studies with a 

NOAEL). 

Estimating Human Health Cancer Risk 

US EPA has purchased the public rights to OncoLogic, the Cancer Expert System, and plans to make 

it publicly available. When it becomes available information on interpreting results from that model 

will be included in this document. 

General Overview for a Cancer Risk Assessment: 

For Occupational Exposure Doses: LADD will be calculated by ChemSTEER 

For General Population Exposure Doses: LADDpot will be calculated by E-FAST. 

Slope Factor = Slope Factor (mg/kg-day)-1 (Calculated) 

A measure of individual's extra risk (increased likelihood) of developing cancer for each incremental 

increase in exposure to a chemical. It approximates the upper bound of the slope of the doseresponse curve using the linearized multistage procedure at low doses. The calculation of a slope 

factor requires tools that are not provided in the P2 Framework but can downloaded from the web 

for free. The software package is called The Benchmark Dose Software (BMDS), can be found at: 

http://cfpub.epa.gov/ncea/ 

Cancer Risk = LADD or LADDpot x Slope Factor 

Generally, a cancer risk of > 1x10-6 (1 in 1,000,000) for the general population and > 1x10-5 (1 in 

100,000) for worker exposure indicates the potential for risk. 

B-14
 
References Cited 

• Boethling R.S. and J. V. Nabholz. 1997. Environmental assessment of polymers under the 

U.S. Toxic Substances Control Act. In: Hamilton, J.D. and R. Sutcliffe, eds. Ecological 

assessment of polymers: Strategies for product stewardship and regulatory programs. New 

York, NY: Van Nostrand Reinhold, 187-234. ISBN 0-442-02328-6. 

• 	 Ecological Assessment of Polymers: Strategies for Product Stewardship and Regulatory 

Programs. John D. Hamilton (Editor), Roger Sutcliffe (Editor) ISBN: 0-471-28782-2. 

• 	 U.S. EPA. 1996. ECOSAR User's Manual. “Estimating Toxicity of Industrial Chemicals to 

Aquatic Organisms Using Structure-Activity Relationships”. R.G.Clements (Editor), 

Contributors: R.G. Clements, J.V. Nabholz, M. Zeeman. Office of Pollution Prevention and 

Toxics 7403M, U.S. Environmental Protection Agency, Washington, DC. 20460. Available 

in PDF at: http://www.epa.gov/oppt/newchems/sarman.pdf. 

• 	 U.S. EPA. 1999a. Category for Persistent, Bioaccumulative, and Toxic New Chemical 

Substances, Federal Register: November 4, 1999 (Volume 64, Number 213), pages 

60194-60204 Available at: 

http://www.epa.gov/fedrgstr/EPA-TOX/1999/November/Day-04/t28888.htm 

• 	 U.S. EPA. 1999b. Persistent Bioaccumulative Toxic (PBT) Chemicals; Lowering of 

Reporting Thresholds for Certain PBT Chemicals; Addition of Certain PBT Chemicals; 

Community Right-to-Know Toxic Chemical Reporting: Final rule, Federal Register: October 

29, 1999 (Volume 64, Number 209), 58666-58753 Available in PDF at: 

http://www.epa.gov/tri/pbt-final_rule.pdf 

• 	 U.S. EPA. 2004. The Pollution Prevention (P2) Framework, EPA-748-B-03-001. Office of 

Pollution Prevention and Toxics 7403M, U.S. Environmental Protection Agency, 

Washington, DC. 20460. October 2003 version updated in January 2004. Available at: 

http://www.epa.gov/opptintr/p2framework/docs/p2manua.htm 

B-15
 
Appendix C 
 

Chemical Regulations List 
 
Chemical Regulations List 

U.S. Federal 

U.S. Environmental Protection Agency 

1. 	 Regulated Toxic, Explosive, or Flammable Substances (Clean Air Act) 

⎯ http://www.epa.gov/ceppo/pubs/title3.pdf 

2. 	 Criteria Air Pollutants (Clean Air Act) 
 

⎯ http://www.epa.gov/airs/criteria.html
 

⎯ http://www.epa.gov/ttn/naaqs/
 

3. 	 Hazardous Air Pollutants (Clean Air Act) 
 

⎯ http://www.epa.gov/ttn/atw/188polls.html
 

⎯ http://www.epa.gov/ttn/atw/atwsmod.html
 

4. 	 Priority Pollutants (Clean Water Act) 

⎯ http://oaspub.epa.gov/wqsdatabase/wqsi_epa_criteria.rep_parameter 

5. 	 Registered Pesticides (Federal Insecticide, Fungicide, and Rodenticide Act) 

⎯ http://www.epa.gov/opppmsd1/PPISdata/ 

6. 	 Maximum Contaminant Levels (Safe Drinking Water Act) 
 

⎯ http://www.epa.gov/safewater/mcl.html
 

⎯ http://www.epa.gov/ost/drinking/standards/dwstandards.pdf
 

7. 	 Extremely Hazardous Substances (Superfund) 
 

⎯ http://www.epa.gov/ceppo/pubs/title3.pdf
 

⎯ http://www.epa.gov/swercepp/ehs/ehslist.html
 

8. 	 Hazardous Substances (Superfund) 
 

⎯ http://www.epa.gov/ceppo/pubs/title3.pdf
 

9. 	 Toxic Release Inventory Chemicals 
 

⎯ http://www.epa.gov/triinter/chemical/chemlist2001.pdf
 

⎯ http://www.epa.gov/triinter/chemical/
 

⎯ http://www.epa.gov/triinter/chemical/chemlistchanges02.pdf
 

C-1 
10. Banned or Severely Restricted Pesticides (U.S. Environmental Protection Agency) 
 

⎯ http://www.epa.gov/oppfead1/international/us-unlist.htm
 

11. Bioaccumulative Chemicals of Concern (U.S. Environmental Protection Agency) 
 

⎯ http://www.epa.gov/waterscience/GLI/index.html
 

12. Persistent, Bioaccumulative, and Toxic Chemicals (U.S. Environmental Protection Agency) 

⎯ http://www.epa.gov/tri/chemical/pbt_chem_list.htm 

⎯ http://www.epa.gov/opptintr/pbt/cheminfo.htm 

⎯ http://www.epa.gov/oppt/pbtprofiler/ 

⎯ http://www.epa.gov/epaoswer/hazwaste/minimize/chemlist.htm 

13. Great Lakes Binational Toxics Strategy Substances (U.S. and Canada) 
 

⎯ http://www.epa.gov/glnpo/p2/bns.html#Level I
 

⎯ http://www.epa.gov/glnpo/bns/levelii/leviisubsus.html
 

U.S. Department of Transportation 

14. Inhalation Hazard Chemicals (Department of Transportation) 
 

⎯ http://www.access.gpo.gov/nara/cfr/waisidx_00/49cfr172_00.html
 

U.S. Department of Energy 

15. Hazardous Constituents (Resource Conservation and Recovery Act) 
 

⎯ http://www.eh.doe.gov/oepa/laws/rcra.html
 

U.S. Department of Labor 

16. Air Contaminants (Occupational and Safety Health Act) 
 

⎯ http://www.osha-slc.gov/SLTC/pel/index.html
 

U.S. State 

17. U.S. State and Territory Web Site List 
 

⎯ http://www.epa.gov/epaoswer/osw/stateweb.htm
 

C-2
 
California 

18. California Air Toxics "Hot Spots" Chemicals (Assembly Bill 2588) 
 

⎯ http://www.arb.ca.gov/ab2588/ab2588.htm
 

⎯ http://www.arb.ca.gov/ab2588/final96/guide96a.pdf
 

19. California Toxic Air Contaminants (Assembly Bill 1807) 
 

⎯ http://www.arb.ca.gov/toxics/id.htm
 

⎯ http://www.arb.ca.gov/toxics/taclist.htm
 

20. Air Contaminants (California Occupational and Safety Health Act) 
 

⎯ http://www.dir.ca.gov/title8/339.html
 

21. Maximum Contaminant Levels (California Safe Drinking Water Act) 

⎯ http://www.dhs.ca.gov/ps/ddwem/publications/lawbook/dwregulations-06-01-04.pdf 

⎯ http://www.dhs.ca.gov/org/ps/ddwem/chemicals/mcl/regextract.pdf 

22. Public Health Goals and Action Levels (California Safe Drinking Water Act) 
 

⎯ http://www.oehha.ca.gov/water.html
 

23. Known Carcinogens and Reproductive Toxicants (California Proposition 65) 
 

⎯ http://www.oehha.ca.gov/prop65/prop65_list/Newlist.html
 

Massachusetts 

24. Hazardous Materials List (Massachusetts) 
 

⎯ http://www.mass.gov/dep/bwsc/files/mohmla.pdf
 

International 

25. Persistent Organic Pollutants (United Nations) 
 

⎯ http://www.pops.int/documents/convtext/convtext_en.pdf
 

⎯ http://irptc.unep.ch/pops/indxhtms/asses0.html
 

26. Initial List of Prior Informed Consent Chemicals (United Nations) 
 

⎯ http://www.fao.org/ag/agp/agpp/pesticid/pic/piclist.htm
 

C-3
 
27. Ozone Depleting Substances (Montreal Protocol) 
 

⎯ http://www.unep.ch/ozone/mont_t.htm
 

⎯ http://www.epa.gov/ozone/ods.html
 

⎯ http://www.epa.gov/ozone/ods2.html
 

28. Greenhouse Gases (Intergovernmental Panel on Climate Change) 
 

⎯ http://www.ipcc.ch/
 

⎯ http://www.grida.no/climate/ipcc_tar/wg1/index.htm
 

⎯ http://unfccc.int/resource/docs/convkp/kpeng.html
 

Europe 

29. Classification, Packaging and Labeling of Dangerous Substances (European Economic 

Community) 

⎯ http://ecb.jrc.it/Legislation/1967L0548EC.htm 

30. List of chemicals banned or severely restricted in the European Union (The Safety, Health 

and Welfare at Work Act) 

⎯ http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/clasann6 

.htm 

31. Dangerous for the Environment (Nordic Council of Ministers. European Chemicals Bureau) 

⎯ http://www.kemi.se/nclass/default.asp 

32. European Inventory of Existing Commercial Chemical Substances 
 

⎯ http://ecb.jrc.it/esis/esis.php?PGM=ein&DEPUIS=autre
 

33. European List of Notified Chemical Substances 
 

⎯ http://ecb.jrc.it/esis/esis.php?PGM=ein&DEPUIS=autre
 

34. Swiss Giftliste 1 and Inventory of Notified New Substances 

⎯ http://www.umweltschweiz.ch/buwal/eng/fachgebiete/fg_stoffe/recht/anmeldung/index.html 

⎯ 	 http://www.umweltschweiz.ch/buwal/eng/fachgebiete/fg_stoffe/recht/stoffverordnung/index.html 

C-4
 
Asia 

35. Japanese Existing and New Chemical Substances 

⎯ http://www.oecd.org/document/29/0,2340,en_2649_33713_1946781_1_1_1_1,00.ht 

ml 

36. Korean Existing Chemicals List (Toxic Chemicals Control Law) 
 

⎯ http://stneasy.cas.org/dbss/chemlist/ecl.html
 

37. Philippines Inventory of Chemicals and Chemical Substances 
 

⎯ http://www.emb.gov.ph/eeid/PICCS.htm
 

38. Taiwan Toxic Chemical Substances List (Toxic Chemical Substances Management Act) 

⎯ http://law.epa.gov.tw/en/laws/808150657.html 

Middle East 

39. Proposed Israel Hazardous Substances List 

⎯ http://www.sviva.gov.il/Enviroment/Static/Binaries/odotHamisrad/haz_man_1.pdf 

North America 

40. Canadian Domestic/ Non-Domestic Substances List (Canadian Environmental Protection 

Act) 

⎯ http://www.ec.gc.ca/CEPARegistry/subs_list/Domestic.cfm 

⎯ http://www.ec.gc.ca/CEPARegistry/subs_list/NonDomestic.cfm 

41. Toxic Substances List (Canadian Environmental Protection Act) 
 

⎯ http://www.ec.gc.ca/CEPARegistry/subs_list/ToxicList.cfm
 

Oceania 

42. Australian Inventory of Chemical Substances 
 

⎯ http://www.nicnas.gov.au/obligations/aics/
 

C-5
 
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-05-002A
 

September 2005
 

www.epa.gov/dfe