### SAT Report PMN Number: P-13-0221 SAT Date: 1/25/2013 Print Date: 3/4/2013

Related cases : Health related cases : Ecotox related cases:

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

Persistence Bioaccum Toxicity Comments 1 12

Exposure Based Review : Health: Ecotox: N o
Routes of exposure : Health: Drinking Water Inhalation Ecotox: All releases to water Fate: ;
Keywords : Keywords: ACUTE; IRR-E,MM,L; ONCO; MUTA; DEVEL; N EURO; KIDNEY; BRAIN; REPRO; IMMUNOTOX; AQUATOX
Summary of Assessment :

Fate : Fate Summary: P-13-0221 FATE: Estimations for hydrolysis product tris(2-chloroethyl) p hosphite MW 269 C6H12Cl3O3P log Kow = 1.51 (E) log Koc = 3.91 (E) log Fish BCF = 0.66 (E) log Fish BAF = 0.60 (E) PMN Substance: Solid S = Reacts Hydrolysis Half-life = hr-da VP < 1.0E-6 torr at 25 C (E)BP > 400 C (E) H < 1.00E-8 (E) POTW removal (%) = 90 via biodeg; OECD NS(Closed Btl): 23%/28d NRB. Time for complete ultimate aerobic biodeg = wk Sorption to soils/sediments = low - moderate PBT Potential: PMN P1B1 *CEB FATE: Migration to ground water = negl

Health : Health Summary: N ot absorbed from the skin, moderate absorption from the lung and GI tract ( p che m ); the PMN substance is expected to be an alkylating agent. Concern for acute toxicity and irritation to eyes, mucous membranes and lungs based on submitted test data; oncogenicity, mutagenicity, and developmental toxicity based on alkylation and test data for tris(2-chloroethyl) p hosphate (TCEP; N TP T R -391). Also concern for neurotoxicity ( N TP T R -391) and reproductive toxicity (RAC92040) based on TCEP. Concern for immunotoxicity based on copper. Test Data: (-) Salmonella with and without activation; rat oral LD50 = 894 mg/kg (M), 564 mg/kg (F); no skin irritation in rabbits; slight to moderate eye irritation in rabbits; no skin sensitization in guinea pigs using the Magnusson-Kligman assay at 12% ai

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

fish 96-h LC50 1.7 daphnid 48-h LC50 0.151 green algal 96-h EC50 0.22 fish

_ chronic value 0.151 daphnid

_ chronic value 0.099 3.16 Unacceptable test data

algal

_ chronic value 0.055

Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for Organic Copper; MW 368; solid with unknown mp (P); S = reacts slowly (P); p H7; effective concentrations based on 100% active ingredients and measured concentrations; hardness < 150.0 mg/L as CaCO3; and TOC <2.0 mg/L; Ecotoxicity Data Results: Case Number: P-13-0221 Chemical Name: Copper, chloro[tris(2-chloroethyl) p hosphite-P]-

CAS RN: 24484-01-3Initial Submission Review Daphnid Ecotoxicity Test: The Bayer AG WD-UWS Institute of Environmental Analysis conducted a 48-hour acute toxicity test in water fleas (Daphnia magna) with P-13-0221 (76.9% p urity) under static conditions. The study was reported to follow Council Directive 92/69/EEC C.2 (1992). Two replicates of 10 D. magna were exposed to a dilution water control (M4 medium) or the PMN substance as a water accommodated fraction (WAF) at the nominal loading rates of 0.1, 0.32, 1, 3.2, 10, 31.6 or 100 mg/L. To produce the WAFs, the test substance was weighed into water, treated for 60 seconds at 8000 rpm with an ultra-turrax and afterwards stirred for 24 hours with a magnetic stirrer. To remove undissolved particles, the resulting emulsions were filtered using folded filters of the pore size 7

– 12 μm. Considering the heterogeneous composition of the test substance, WAFs were tested. N o analysis was performe d . Over the course of testing, temperature ranged from 19.9

– 20.3  ̊ C, p H ranged fro m 8.0

– 8.3 and dissolved oxygen ranged from 8.4

– 9.0 mg/L. The dilution water hardness was 267.72 mg CaCO3/L. A loading rate of 500 daphnids/L was calculated. N o immobilization was observed at nominal loading rates ≤ 1 mg/L. At nominal loading rates of 3.2, 10, 31.6 and 100 mg/L, immobilization of 20%, 100%, 100% and 100% were observed, respectively. N o EC50 value was reported. The 48-hour EL0 and EL100 are 1 and 10 mg/L, respectively. The geometric mean of the EL0 and EL100 is 3.16 mg/L. This study is not acceptable because the test material was filtered. Also, it is unclear that the loading rates concentrations are comparable with the actual concentrations of the test material. The reported chronic ChV is 3.16 mg/L 48-hour ChV = 3.16 mg/L

Ecotox Summary Provided Amuel Kennedy 1/31/2013

Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) 6

SARs Organic Copper SAR Class Organic Copper Ecotox Category N one

Ecotox Factors Comments:

SAT Chair: L Keifer 564-8916