SAT Report

PMN Number: P-09-0107

SAT Date: 12/19/2008

Print Date: 9/6/2012

Related cases: : Yes

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2 3

 Persistence Bioaccum Toxicity Comments

1 11

Exposure Based Review:

Health: No

Ecotox: Yes

Routes of exposure: Health: Dermal, inhalation

Ecotox: All releases to water

Fate: ;

P2Rec Comments:

Comment: SAT has no comment

Keywords:

 Keywords: LUNG, IRR/CORR-E,S,MM, AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-09-0107

FATE: Estimations for low weight MW 325.54 

Liquid with MP < 25 EC (E)

log Kow = 5.97 (E)

S = Disp. (ICB)

VP < 1.0E-6 torr at 25 EC (E)
BP > 400 EC (E)

H < 1.00E-8 (E)

log Koc = 4.18 (E)

log Fish BCF = 2.90 (E) 

POTW removal (%) = 88 via sorption; OPPTS835.3210 (SCAS test): 88.07%/7 d. RB.

Time for complete ultimate aerobic biodeg = wk-mo

Sorption to soils/sediments = strong

PBT Potential: P1B1

*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Absorption is poor from the skin, moderate from the GI 

tract, and good from the lung (analog). Concern for surfactant effects on the lung; irritation to 

eye, skin (chronic), mucous membranes and lung based on surfactant properties of the 

compounds. Concern for corrosion to eyes based on statement in the MSDS; and lung toxicity 

from cationic binding to lung membranes.

 Test Data: some eye irritation in 

rabbits, cleared by day 7; some skin irritation in rabbits; rat oral LD0 = 2000 mg/kg

 Ecotox:

Test Organism Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 0.26 0.105 11.3 mg/L with 10% 

HA mitigation

daphnid 48-h LC50 0.061 0.498 53 mg/L with 10% HA 

mitigation

green algal 96-h EC50 0.097 0.200 21 mg/L with 10% HA 

mitigation

fish _ chronic value 0.006

daphnid _ chronic 

value

0.019

algal _ chronic 

value

0.013

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic 

Value

_

Ecotox Values Comments: Predictions are based on SARs for ; SAR 

chemical class = ; MW 394 (major product/worst case); log Kow = 6.02; 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;

P09-0107
EVALUATION OF ECOTOXICITY STUDIES

For Tuesday, December 19, 2008 SAT

Evaluator: S. Cragg

 Nominal ECOSAR

 Function Parameter Conc Predicted

Test Type Evaluated Measured (mg a.i./L)(a) Conc (mg/L)

Acute Fish Lethality 96-hr LC50 0.105 0.26

Fathead Minnow LOEC 0.063

(Pimephales promelas) NOEC 0.031

static ChV 0.044

 96-hr LC50 ajusted by mitigation factor 11.3

Acute Fish Lethality 96-hr LC50 11.3

Fathead Minnow LOEC N/D

(Pimephales promelas) NOEC 6.25

static ChV N/D

10% Humic Acid mitigated mitigation factor 107

Acute Fish Lethality 96-hr LC50 19.0

Fathead Minnow LOEC N/D

(Pimephales promelas) NOEC 12.5

static ChV N/D

20% Humic Acid Mitigated mitigation factor 180

Acute Daphnia Mobility 48-hr EC50 0.498 0.054

(Daphnia magna) LOEC N/D

static NOEC N/D

 ChV N/D

 48-hr EC50 ajusted by mitigation factor 53

Freshwater Algae Growth Inhibition

S capricornutum Growth Rate† 96-hr ErC50 0.200 0.083

 LOEC N/D

 NOEC N/D

 ChV N/D

 48-hr EC50 ajusted by mitigation factor 21

ECOSAR fish chronic 0.006

ECOSAR daphnia ChV 0.016

ECOSAR algal ChV 0.012

(a) Reported test concentrations represent only nominal (loading) values. No chemical analysis 

of the aqueous media was performed. The PMN is characterized as being "dispersible" by 

EPA/EETD with no actual limit of water solubility reported. However, the MSDS 

accompanying the PMN indicates that solubility of this in water is > 10%. 
The testing laboratory indicated that 10 minutes stirring in deionized water with a magnetic 

stirrer (nominal conc = 250,120 mg/L without humic acid) resulted in compete dissolution of the 

test substance within 10 minutes. For these reasons and because the estimated vapor pressure of 

the PMN is <0.00001 torr, Henry's Law Constant is <1.0E-08 indicates that the nominal 

concentratons are probably an accurate reflection of actual concentrations. The attached MSDS 

reports the tested substance had the PMN at a concentration and that the laboratory adjusted 

for this concentration as "active ingredient."

† Concentration that reduced growth rate by 50%.

Conclusion: Results from the four tests are considered valid. The most sensitive species is fish 

with a 96-hr LC50 of 0.105 mg/L. When mitigated with humic acid (10 mg/L), the 96-hr LC50 

is 11.3 mg/L. Thus, to calculate the concentration of concern (CoC), 11.3 mg/L is divided by a 

factor of 10 to simulate a chronic value, then divided again by an assessment (uncertainty) factor 

of 10 yielding a CoC of 0.113 mg/L, rounded to 110 μg/L (ppb). Alternatively, the ChV of 4.70 

(adjusted by the mitigation factor of 107) could have been divided by an assessment 

(uncertainty) factor of 10 to directly yield a CoC of 470 ppb. The more conservative (protective) 

method using the adjusted acute value is used for consistence since the of the 

PMN did not have a LOEC with which to derive a ChV to more directly derive a 

CoC. The PMN is of moderate concern for ecotoxicity.

 Fish

 Fish (mitigated 10% HA) Daphnia Algae

Test cmpnd purity (%) : 

Temp Range (°C): 21.9 - 22.4 21.0 - 22.5 19.2 - 21.1 24.0 - 25.0

O2 conc (mg/L): 6.9 - 7.9 6.2 - 8.0 7.8 - 8.4 Not found

H2O Hrdnss (mg/L CaCO3): 88 110 100 Not found

pH: 7.7 - 7.9 7.3 - 9.0 7.5 - 8.7 7.0 - 8.8

Conductivity (μmhos/cm): 297 302 304 N/D

Nominal or Measured? Nominal Nominal Nominal Nominal

Flow-thru/Static/Semi-static: Static Static Static Static

Certificate of Analysis?: Not reported Not reported Not reported Not reported

Illumination (foot candles): Not reported Not reported Not reported 96 - 100

 Estimated Measured

Physical State Liquid --

VP (mmHg @ 25°C) <1.0E-06 --

Absorptivity (Log Koc) 4.18 --

Log Kow 5.97 --

Water Solubility (mg/L) "Dispersible" --

Henry's Law Constant 1.0E-08 --

Sorption to Soils "strong" --

log fish BCF 2.9 --

Factors Values Comments

Assessment Factor 10
Concentration of Concern 

(ppb)

110

SARs

SAR Class

Ecotox Category 

Ecotox Factors Comments: 

 SAT Chair: L Keifer 546-8916