INITIAL REVIEW ENGINEERING REPORT

PMN: 12-0073

Focus Ready Draft 12/15/2011

ENGINEER: Jon \ JAS

PV (kg/yr): 63,000

SUBMITTER: H.B.Fuller Company

USE: 

 

OTHER USES: 

MSDS: No Label: No

TLV/PEL:

none established.

CRSS :

Chemical Name:

S-H20: Reacts g/L @

VP: 1.0E-6 torr @

MW: 

Physical State and Misc CRSS Info:

Neat: Solid 

Consumer Use: 

SAT (concerns) (12/09/2011):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Caes: 

Migration to groundwater: Negligible

PBT rating: P3B1T1 PMN: P1B1T1 

Health: 1-2 Dermal, Inhalation

Eco: 1 No releases to Water

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OCCUPATIONAL EXPOSURE RATING: 1A

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

 

POLLUTION PREVENTION CONSIDERATIONS:

No Pollution Prevention information provided by the

submitter.

EXPOSURE-BASED REVIEW: No



INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0073

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Number of Sites/ Location: 1

H.B. Fuller Company Grand Rapids MI 49544-1198

H.B. Fuller Pilot Facility Vadnais Heights MN 55110

Days/yr: 67

Basis: The submission indicates 2 sites (CEB assessed one

site, since one site is a pilot site), 3,000 kg/batch

(max), 7 hr/batch, 67 batches.yr. PMN manufactured at 69.

22% concentration. CEB assumes 2 sites, 67

batches/site-yr. CS calculates 940.3 kg PMN/batch.

Process Description

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The submission indicates that 0.5 kg/batch is

sent for off-site incineration , and 0.5

kg/batch is sent for off-site incineration 

 The submission does not address 

 CEB does not assess these releases

below because or SAT requirements or triggers were not

met: WATER - not required, per SAT; LAND - migration to

gw is negl; AIR - VP < 0.01 torr; INCIN - releases << 28,

000 kg/site-day.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 6

Basis: The submission indicates up to 4 total workers may

be potentially exposed. CEB assumes the std. default

minimum of 3 workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 69.22% concentration

High End: 1.2E+3 mg/day over 67 days/yr

Number of workers (all sites) with dermal exposure: 3

Basis: EPA/OPPT 2-Hand

Dermal Contact with Liquids Model.



INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0073

Number of Sites/ Location: 1

Axion Water San Diego CA

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Days/yr: 250

Basis: The submission estimates 1 customer site. CEB

assumes 250 days/yr. CS calculates 252 kg/site-batch.

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The submission indicates that 0.8 kg/batch is

landfilled from , and 0.2 kg/batch

is landfilled .

CEB does not assess releases below because or SAT

requirements or triggers were not met: WATER - not

required, per SAT; LAND - migration to gw is negl; AIR -

VP < 0.01 torr - mists are not expected (see contact

report); INCIN - releases << 28,000 kg/site-day.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: The submission estimates up to 2 workers

potentially exposed. CEB assesses the std default minimum

of 3 workers/site.

Inhalation:

negligible (VP < 0.001 torr).

Dermal:

Exposure to Liquid at 69.22% concentration

High End: 1.2E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 3

Basis: EPA/OPPT

2-Hand Dermal Contact with Liquids Model.



MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Jason A. Sese

Organization: ERG for CEB

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CALL TO: Christine Griese

Organization: Senior Chemist - H.B. Fuller

Date: 12/12/2011

Time: 2:35 PM

Phone: 

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