### SAT Report PMN Number: P-13-0178 SAT Date: 1/4/2013 Print Date: 2/4/2013

Related cases : Yes

Concern levels : Type of Concern: Health Eco Comments Level of Concern: 1-2 3

Persistence Bioaccum Toxicity Comments 1 11

Exposure Based Review : Health: Ecotox: N o
Routes of exposure : Health: Dermal Inhalation Ecotox: All releases to water Fate: ; Keywords : Keywords: SENS-S; AQUATOX
Summary of Assessment :

Fate : Fate Summary: P-13-0178 FATE: Liquid with MP = -115 C (M) log Kow = 4.26 (M); S = 16 mg/L at 25 C (M) VP = 9.6E-2 torr at 25 C ( N OMO5) BP = 224 C (M) H = 8.29E-4 (E) log Koc = 2.72 (E) log Fish BCF = 2.5 (E)log Fish BAF = 2.1 (E) POTW removal (%) = 31 via sorption and possible partial biodeg; CEE C4.e (Closed Btl): 18.55%/28d. Time for complete ultimate aerobic biodeg = wk-mo Sorption to soils/sediments = strong Volatilization half-life from a standard river = 2.4 hrs Volatilization half-life from a standard lake = 6.0 da Atmospheric Oxidation Half-life = 10 hr via OH radical PBT Potential: P1B1 *CEB FATE: Migration to ground water = negl-slow

Health : Health Summary: Expect moderate absorption via all routes ( p che m ). Concern for dermal sensitization based on submitted test data. Test Data: (-) Salmonella with and without activation; (-) E. coli with and without activation; rat oral LD0 = 2000 mg/kg; slight skin irritation in rabbits; (+) for skin sensitization in a mouse local lymph node assay, EC1.4 = 14.5%

Ecotox :
Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 1.1 daphnid 48-h LC50 1.7 2.0 green algal 96-h EC50 0.50 5.3 fish

_ chronic value 0.049 daphnid

_ chronic value 0.59

algal

_ chronic value 0.28 3.4

Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for Esters; SAR class = Esters; MW 198; log Kow = 4.4; S = 0.016 g/L at 20 C (M); p H7; liquid with mp = -114.8 C (M); effective concentrations based on 100% active ingredients and measured concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Ecotoxicity Test Data Results for P-13-0178: Cyclopentanol, 2-methyl-5-(1-methylethyl)-, 1- p ropanoate (CASRN: 1245725-35-2; Trade name: Mirallyl).
Acute daphnia and algae toxicity studies were completed for PMN P-13-0178 in 2010 by Phytosafe s.a.r.l., France for Mane USA. The PMN material is characterized as an ester and isdescribed as a colorless to pale yellow liquid in the neat form and as a solution with the PMN material in a fragrance blend during processing. The molecular weight is 198.31 g/mol. Based on an experimental water solubility of 16.3 mg/L, an experimental Log Kow of 4.26 and a p redicted Henry’s Law Constant of 8.29 x 10-4 atm-m3/mole this PMN is expected to be moderately volatile and only slightly soluble in water. The PMN material is a fragrance ingredient for use in non-cosmetic products such as laundry detergents and air fresheners (60 %), in fine fragrances (10 %) and in cosmetic products such as shower gels and creams (30 %). Studies followed the respective guidelines of OECD 202 (Daphnia sp., Acute Immobilization Test) and OECD 201 (Freshwater Alga Growth Inhibition Test) and were GLP compliant; study methods concurred with methods specified in the respective guidelines except where specified below.
Daphnid Ecotoxicity Test: Phytosafe s.a.r.l. conducted a 48-hour immobilization test in water fleas (Daphnia magna) with P-13-0178 (99.96 % p urity) under static conditions with tightly capped glass tubes. The study was reported to follow OECD test guideline 202. Following a preliminary range-finding test, four replicates of five D. magna (< 24 hours old) p er concentration were exposed to nominal concentrations of 0 (dilution water control; M4 mineral medium), 0 (solvent control), or the PMN substance in acetone at nominal test concentrations of 0.92, 1.56, 2.64, 4.47 or 7.58 mg/L. Analytical monitoring was conducted using GC/FID with external calibration, which resulted in initial mean measured concentrations that were 108.5

–119.1 % and final mean measured concentrations that were 80.5

–101.2 % of the nominal concentrations. Corresponding mean measured concentrations were not reported and effect levels were calculated using nominal test concentrations. For the definitive test, the initial test concentrations were set at 110 % the nominal values. The treatment solutions were prepared in acetone. Over the course the study, water temperature was maintained at 20.0 ± 1.0  ̊ C, p H ranged fro m 7.05

–7.66 and dissolved oxygen ranged from 5.9

–7.5 mg/L. A loading of 500 daphnid/L was calculated, which exceeds OPPTS recommendations (40 daphnid/L) and may result in crowding. The percentage immobilization at 0.92, 1.56, 2.64, 4.47 and 7.58 mg/L was 0.5 %, 35 %, 65 %, 100 % and 100 %, respectively. The 48-hour EC50, based on nominal test concentrations, was 2.0 mg/L (95 % confidence interval: 1.48

–2.67 mg/L) and a mean measured 48-hour EC50 between 1.67 and 2.37 mg/L was approximated. The study was considered to be adequate. 48-hour EC50 = 2.0 mg/L
Algal Ecotoxicity Test: Phytosafe s.a.r.l. conducted a 72-hour algal growth inhibition test in green algae (Desmodesmus subspicatus) with P-13-0178 (99.96% p urity) under static-renewal conditions, with PMN substance renewal twice a day. The study was reported to follow OECD test guideline 201. Following a preliminary range-finding test, three replicates per concentration of D. subspicatus (3.98 x 106 cells/mL) were exposed to nominal concentrations of 0 (dilution water control; OECD medium), 0 (solvent control) or the PMN substance in acetone at nominal test concentrations of 9.9, 15.9, 25.4, 40.6 or 65.0 mg/L. Analytical monitoring was conducted via GC/FID with external calibration; however, mean measured test concentrations were not p rovided. The submitter notes that “due to the high instability of the test item in water, it was not possible to maintain the test concentration within 80

–100 % of the nominal value, even though the test concentration was adjusted twice per day.” This indicates a deviation fromOECD 201. Appendix 4 reports the results of the test concentration analysis at the beginning and end of each renewal period that were used by EPA to approximate the corresponding geometric mean measured concentrations of 2.03, 3.03, 3.91, 6.39 and 10.85 mg/L The treatment solutions were prepared in acetone. The concentrations of the treatment solutions were set in such a manner that the treatment concentrations were achieved when delivering 50 μL of the treatment solution per test vessel. Test concentrations were adjusted twice per day, after 6, 24, 32, 48 and 56 hours of testing by adding a new 50 μL of treatment solution per vessel. Physical damage may have resulted from renewal of the test solution. EPA does not recommend using these testing methods. Algae were illuminated at a light intensity of 4440

–8880 lux, with constant shaking. The test vessels were capped with air- p ermeable stoppers. Measured concentrations of old medium ranged from 1.7

–16.2% of nominal test concentrations. Measured concentrations of new medium ranged from 44.7

–88.7% of nominal test concentrations. Over the course of testing, the temperature was maintained at 21

–24  ̊ C and the p H ranged fro m 7.6

–8.8. The cell density in the water and solvent control cultures increased by a factor of approximately 250 after 72 hours. EPA re-calculated growth rate inhibition and yield inhibition using approximate geometric mean measured concentration based on methods detailed in OECD 201 (2006) and used linear regression to derive EC50 values. The geometric mean measured 72-hour EC50 values for growth rate and yield were 9.3 and 5.3 mg/L, respectively. The nominal 72-hour NOEC and LOEC, for both growth rate and yield, were 9.9 and 15.9 mg/L, respectively, and the geometric mean measured NOEC and LOEC were 3.03 and 3.91 using Dunnett’s test. The geometric mean measured ChV (geometric mean of the NOEC and LOEC) was 3.4 mg/L. This study was considered to be adequate. 72-hour ErC50 = 9.3 mg/L 72-hour EbC50 = 5.3 mg/L 72-hour ChV = 3.4 mg/L
The 48-hour daphnid (EC50 = 2.0 mg/L) and 72-hour algal (EbC50 = 5.3 mg/L; ChV = 3.4 mg/L) toxicity tests were adequate for P-13-0178. For comparative purposes, the 96-hour fish LC50 of 1.1 mg/L, the 48-hour daphnid LC50 of 1.7 mg/L, the 96-hour algae EC50 of 0.50 mg/L, the fish ChV of 0.049 mg/L, the daphnid ChV of 0.59 mg/L and the algae ChV of 0.28 mg/L were calculated using the Ester’s QSAR in ECOSAR. Available data indicate fish to be the most sensitive species for calculating the acute and chronic concentrations of concern (CoC). Based on the predicted 96-hour fish LC50 of 1.1 mg/L (1100 p pb), and the application of an assessment factor of 5, the acute CoC for P-13-0178 is 220 p pb. The chronic CoC for P-13-0178 is derived by dividing the predicted fish ChV of 0.049 (49 p pb) by a factor of 10 (uncertainty factor) yielding a chronic CoC of 5.

Acute CoC = 220 p pb Chronic CoC = 5 p pb
Ecotox Study Reviewer: K. Eisenreich January 7, 2013

Factors Values Comments Assessment Factor 10 Concentration of Concern 5( p pb) SARs Esters SAR Class Esters Ecotox Category Esters

Ecotox Factors Comments:

SAT Chair: L Keifer 564-8916