SAT Report

PMN Number: P-09-0451

SAT Date: 7/7/2009

Print Date: 3/17/2010

Related cases: CBI: Yes

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 3

 Persistence Bioaccum Toxicity Comments

 2 1 1

Exposure Based Review:

Health: No

Ecotox: No

Routes of exposure: Health: Inhalation only

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: MUTA, IRR-E, AQUATOX-A,C

Summary of Assessment:

 Fate:

Fate Summary: P-09-0451

FATE: 

Solid with MP = Dec. > 198 EC (M)

log Kow = 2.90 (M); 

S = 0.0198 mg/L at 25 EC (M)

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

BP > 400 EC (E)

H < 1.00E-8 (E)

log Koc = 2.79 (E)

log Fish BCF = 1.00 (E)

log Fish BAF = 0.847 (E) 

POTW removal (%) = 0-90 via sorption and possible partial biodeg; OECD301B(Mod Sturm

 CO2 ev): 0%/28d. OECD111(Hydrolysis):t1/2(pH4,7):>1yr.

Time for complete ultimate aerobic biodeg = mo
Time for primary anaerobic biodeg = da-wk

Sorption to soils/sediments = moderate - strong

PBT Potential: P2B1

*CEB FATE: Migration to ground water = negl due to and sorption

 Health:

 Health Summary: Absorption is nil all routes based on physical/chemical 

properties. Based on the submitted studies, there is concern for mutagenicity and eye irritation, 

The PMN material is a moderate eye irritant and is positive in Salmonella and E coli with and 

without activation (no Prival modification). Low moderate concern. 

 Test Data: positive in Salmonella with and without activation

positive for chromosome aberrations in CHL cells

negative in an oral mouse micronucleus assay

not a dermal irritant, yellow staining at site of application

moderate eye irritant, all effects cleared by day 8

acute oral study in rats - no deaths at 2000 or 5000 mg/kg, hunched posture and piloerection

acute dermal study in rats - no deaths at 5000 mg/kg

not a dermal sensitizer in the mouse local lymph node assay

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 7.5 >0.20 study data: NOEC=0.2; 

predictions: or *

daphnid 48-h LC50 2.2 >0.17

green algal 96-h EC50 0.52 0.0085

fish _ chronic value 0.044

daphnid _ chronic value 0.047

algal _ chronic value 0.41

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for ; 

SAR chemical class = MW 521; solid with mp = 198 °C with 

decomposition (M); log Kow = 2.90 (M), 3.20 (EPI); S = 0.02 mg/L at 20 °C (P); pH7; 

effective concentrations based on 100% active ingredients and mean measured concentrations; 

hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

This PMN was accompanied by three acute ecotoxicity studies. Analysis details are provided in 

the attached spreadsheet. Conclusions are repeated below.

Conclusion: The guidance document on aquatic toxicity testing of difficult to test substances 

(OECD series on testing and assessment number 23) was consulted for these tests. The stock 

solution was prepared by sonication and then stirred for 47 hours for the algal test and 45 hours 
for the Daphnia and fish tests. Some undissolved test material still remained and was thus 

filtered with a 0.45 μm membrane filter. The test concentrations for the algal test were measured 

at the start of the test and after 24 hours of exposure and decreased significantly (from 70-90 %) 

during this time frame but remained stable until 72 hours. Measured concentrations decreased 

from 0.29 mg/L to 0.22 mg/L after 24-hr exposure and then decreased again to 0.15 mg/L after 

96 hours for the fish test. Time Weight Average concentrations were calculated to correspond to 

the concentrations in the test chambers for both the algal and fish tests. Measured values were 

used to determine the 48-hr EC50 for the Daphnia test because recovery of the test 

concentrations was between 70 and 105% of nominal. All three tests are considered valid. From 

the most sensitive species, algae, the chronic CC is derived from the EyC50 of 0.0085 mg/L for 

yield. Dividing this by an acute to chronic ratio of 4 to derive a simulated chronic value, gives 

0.0021 mg/L. Dividing this value by an assessment (uncertainty) factor of 10 results in a CC of 

0.0002, which rounds up to 0.001 mg/L or 1 μg/L (ppb).

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

1

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: Becky Jones