### 15216110 BERO140519686275978 SC0031

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Quaternary alkyl methyl amine ethoxylate methyl chloride 

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Poly(oxy-1,2-ethanediyl), a-hydro-w-hydroxy- 25322-68-3 C12-14 alkyl methylamine ethoxylate

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Page 9 SANITIZED SUBMISSIONPart I, Section C, 2.a. Additional Consumer Use Text

Category of Use XXX: Hard Surface Cleaner / Degreaser: Industrial Use A hard surface cleaner and degreaser for inanimate non-porous surfaces particularly metal. A typical industrial use includes machine parts and tools. The final industrial product will contain the New Chemical Substance at a level of 0.039% to 0.40%. The New Chemical substance is supplied at 60% in a water blend and formulated at 0.19% - 2.0%. The most common industrial cleaning application is by applying the formulated, diluted product cleaner to a cloth or sponge or by spraying directly onto a hard surface. The surface is wiped with a disposable paper cloth, cloth or sponge and typically not rinsed. Residue is not discharged to the sewer or fresh water storm drains. The soiled paper cloth is disposed via common municipal waste systems. The amount used per application is based upon the same logic as consumer cleaning. A six inch square area required 1 gram of cleaner to saturate. The estimated residue for a typical application would be 0.0039 to 0.00040g of the New Chemical substance to clean a 36 square inch area. Based upon the assumption that 90% of cleaner will adhere to the cloth then the surface residue that theoretically could be rinsed to a public sewer or water treatment facility is in the magnitude of 0.00038-0.00004g. The second type of application common to industrial use is to soak parts and tools in a solution of cleaner to remove grease, oil and other particles. The contaminated solution and rinse water must be disposed of in accordance with the local and federal regulations that govern that cover the grease or oil contaminate that the user is attempting to remove. For industrial applications, disposal would always be to a POTW thus preventing the potential release of the New Chemical substance to surface water. Category of Use XXX: Car Wash: Commercial Use A cleaning solution for automated commercial car washes. This use does not include manual wash commercial car washes or consumer home car wash solutions. The final commercial cleaning solution will contain the New Chemical Substance at a level of 0.038% to 0.4%. The New Chemical substance is supplied at 60% in water and formulated at 0.09% - 2.0% as supplied. Typical present day commercial car washes utilize between 25-45 gallons of water per vehicle. The car wash detergent concentrate will contain approximately 5 -10% of the new chemical substance surfactant. The surfactant solution is injected into the water stream and sprayed by water jets onto the vehicle as a dilute solution. These high-pressure nozzles and pumps control the amount of surfactant dispensed and minimize water usage. A standard friction method carwash uses approximately 2 ounces of detergent per vehicle and a “touchless” car wash method uses approximately 4 – 5 ounces of detergent per vehicle. This corresponds to approximately 0.66g of the New Chemical Substance per application via the “friction” method and 1.26 – 1.62g per the “touchless” method. In the US commercial car wash market, approximately 75% use the “friction” method and 25% use the “touchless” method. Most commercial car washes recycle and reuse the rinse water contaminated with the surfactant and detergent about ten times. The final rinse water will contain approximately 3.88 x 10-6 g of the New Chemical substance for friction method car washes and 7.4 x 10-6 g for “touchless” car washes. Vehicle carry-out water (rinse water adhering to the vehicle post wash) is approximately 3 gallons. Carry-out water is clean rinse water and doe not contain the New Chemical substance. All commercial car washes are required to discharge waste water to a sanitary sewer system or water treatment facility per the 1972 Federal Clean Water Act (CWA). No water waste is permitted to enter storm water drains, roadways or vegetation. The new chemical substance is readily biodegradable and meets the EU Detergent Regulation EC 6482004 requirements. Residues will not persist in the soil or on plant follicles. By nature, surfactants adhere tightly to soil preventing the new chemical substance from migrating from soil or plant surfaces to water sources. A 2006 Fish Toxicity Study by Environmental Partners, Inc., Issaquah, Seattle showed that commercial carwashes are friendlier to the environment than home car washing. Consumer car washes average 70 to 90 gallons of water and allow affluent surfactant to enter water ways via discharge and run-off to storm drains. Discharging the surfactant affluent to water treatment facilities as mandated by the CWA for commercial car washes protects the environment. The proposed new chemical substance use is an alternative to non-biodegradable detergents and surfactants currently used by the commercial car wash industry. The proposed new chemical substance use would be limited to commercial car wash use only.

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Page 16 SANITIZED SUBMISSIONThe PMN substance is a component in one of Akzo Nobel's product used in many cleaning products currently in Europe and offers four

advantages over other conventional cleaners. It is more economical because it is sold as a concentrate. The quantity of water being shipped is minimized resulting in considerable energy saving. The customer prepares a “formulation” from the concentrate containing mostly water and their choice of builders. Builders are typically chelating agents that complex the ions in hard water enabling the surfactant system to work better thus boosting the cleaning performance. The New Chemical Substance is a cationic surfactant designed to function at very low concentration levels. Akzo Nobel recommends that the final surfactant level in the cleaning product is less than 1%. Typically 0.9% is used; the product also works at surfactant levels as low as 0.09%. The New Chemical Substance was designed so that the the surfactant's ability to emulsify the dirt is effective without the addition of volatile organic carbon(VOC)solvents or alkaline cleaning agents. The surfactant solution is water based instead of using oil-based solvents whose emissions are harmful to the health of workers, are biotoxic, non-biodegradable and pose a problem for waste disposal in addition to using scarce fossil fuels as a raw material. This cationic surfactant does not contain nonylphenols, which are known to cause harm to the environment and subsequently been banned in Europe. The PMN substance is a quaternary ammonium compound with improved biodegradability over quaternary ammonium compounds currently in commerce. tests show that it readily biodegrades and complies with the EU Detergent Regulation EC 648/2004. The New Chemical substance can replace solvent based, nonylphenol ethoxylate and non-biodegradable cleaners currently on the market.

Page 17 SANITIZED SUBMISSION001 CAS IES CAS IES SANITIZED.docx Pt.I, Sec.B, 2c. 1 002 Copy of EO dist sanitized Copy of EO dist sanitized.pdf Pt.I, Sec.B, 2a. 1 003 Process and structure Process and structure sanitized.pdf Pt.I, Sec.B, 2e. 1 004 SAR comparison SAR comparisons sanitized.pdf 1 005 Tox Summary Sanitized Tox Summary Sanitized.pdf 1 006 Acute Oral Sanitized Acute Oral Toxicity Study in Rats Sanitized.pdf 19 007 Acute Tox Daphnia Magna SAR Sanitized Acute Tox of Ethoquad MC 1214_25 to Daphnia Magna 26 008 Acute Tox Danio Rerio Sanitized Acute Toxicity of Ethoquad MC 1214_25 to Danio Rerio 27 009 Acute Tox Daphnia Magna Acute Toxicity of quaternary C12- 14 alkyl methylamine ethoxylate 24 010 Toxicity to Marine crustacean sanitized Assessment of the toxicity of Berol R648NG to the Marine 15 011 MSDS sanitized Berol MSDS sanitized.pdf 5

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1.065 Measured

6;9 Measured 1

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## ATTACHMENT HEADER SHEET
Attachment Number 001 Attachment Name CAS IES 

## Associated PMN Section Number

Pt.I, Sec.B, 2c. Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 002 Attachment Name Copy of EO dist sanitized 

## Associated PMN Section Number

Pt.I, Sec.B, 2a. Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 003 Attachment Name Process and structure 

## Associated PMN Section Number

Pt.I, Sec.B, 2e. Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 004 Attachment Name SAR comparison 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 005 Attachment Name Tox Summary Sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 006 Attachment Name Acute Oral Sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 007 Attachment Name Acute Tox Daphnia Magna SAR Sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 008 Attachment Name Acute Tox Danio Rerio Sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 009 Attachment Name Acute Tox Daphnia Magna 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 010 Attachment Name Toxicity to Marine crustacean sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978

## ATTACHMENT HEADER SHEET
Attachment Number 011 Attachment Name MSDS sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BERO140519686275978