Summary of Physical and Chemical Properties of AAA Reaction Product

1. Vapor pressure: The AAA reaction product is composed of many different 

substances with different vapour pressures. Table 1 shows the vapour pressure of 

the major constituents in the AAA reaction product. The table also shows a 

theoretical calculated partial vapour pressure of each major constituent. From this 

table it is obvious that primarily water contributes to the overall vapour pressure of 

the AAA reaction product (>99%). Therefore, measurement of the vapour pressure 

of the AAA-reaction product is not considered relevant for any purpose, as it mainly 

will reflect the concentration of water in the AAA reaction product and not the vapour 

pressure of any of the constituents.

Another important aspect about this substance is the fact that the substance is only 

used as a binder and that it does no longer exist in the final products (i.e. fibres). 

The binder in the final products has a negligible vapour pressure. 

It is concluded that the measurement of the vapour pressure of the AAA-reaction 

product is not considered to be providing technically useful new information and thus 

scientifically not justified. 

2. Solubility: No available data for the solubility of the substance in other media but 

water is found. Low solubility in hydrophobic solvents is expected.

3. Solubility in water: The AAA reaction product is composed of many different 

substances with different levels of water solubility. Table 2 shows the water solubility 

of major constituents in the AAA reaction product. For a measurement of the water 

solubility of AAA reaction product, the polymer with the lowest water solubility will 

determine the overall water solubility of the AAA reaction product. The monomers 

and main impurities are all very soluble in water, but not the final binder. Further, 

AAA reaction product has low water solubility based on practical experience. 

It is concluded that the measurement of the water solubility of the AAA-reaction 

product is not considered relevant. A measured water solubility of the AAA reaction 

product will be determined by the water solubility of the polymer and cannot be used 

to assess the behaviour of the AAA reaction product in case of contact with water. 

The monomers, main impurities and small mers will be readily dissolved in water, 

whereas the final binder will not.

Table 2: Water solubility of the various constituents in the AAA-reaction product

Substance CAS-RN Water solubility (mg/L) Reference to water solubility data

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4. Dissociation Constant: pKa > 15 (roughly estimated from the measured pH of 

6.5 of the mixture).

5. Particle size distribution: Not relevant, as the substance is a liquid. 
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6. Hennry’s law constant: The AAA reaction product is composed of many 

different substances with different levels of molecular weight, vapour pressure and 

water solubility. The Henrys constant of the various constituents in the AAA-product 

was calculated on the basis of their vapour pressure, water solubility and molecular 

weight. It was found that the Henrys constant for all substances are well below 0.02 

Pa·m3

/mole, which must be considered a very low Henrys constant. 

7. Volatilisation from water

The substance does not tend to evaporate from water. EpiSuite predicts a 

volatilisation half-life from 1m deep river between 0.4 year and much more than 100 

years.

8. Volatilisation from soil

The substances of the AAA product tend to partition to the soil pore water due to 

their low octanol/water partition coefficient (will not adsorp to the soil matrix) and low 

Henrys constant (will not be in the pore air). Due to this and the low Henrys 

constant, the volatilisation half-life from soil is expected to be very low with an order 

of magnitude of years up to more than 100 year. 

9. pH @ concentration

≈6.5 (see MSDS attached to the PMN) 

10. Flammability

Flash point>120 °C (test temperature was between 18 °C and 120 °C, and no flash 

point was tested in the temperature range).

It is evaluated that the Alkanolamine-acid-anhydride reaction product is not 

flammable due to its high water content and flash point. Further, it is evaluated that 

no flammable gas will evolve in contact with water. 

Based upon the structure, it is evaluated that the Alkanolamine-acid-anhydride 

reaction product does not have pyrophoric properties (Bretherick`s Handbook of 

Reactive Chemical Hazards). 

11. Explodability

The Alkanolamine-acid-anhydride reaction product is a water solution/suspension, 

and no dust initiated explosion will occur. 

The single molecules of the Alkanolamine-acid-anhydride reaction product does not 

contain reactive groups that have explosive characteristics (Bretherick`s Handbook 

of Reactive Chemical Hazards). 
12. Partitioning coefficient Log Kow

No test has been initiated as it was not scientifically justified; instead a rationale for 

the waiving has been provided below.

The AAA reaction product is composed of many different substances. Table 3 

shows the LogKow of the major constituents in the AAA reaction product. To illustrate 

the properties of the polymer, estimated values for the hexamers and 20-mers are 

shown. The monomers, dimers and trimers all have a low LogKow and thus a low 

potential for bioaccumulation is expected. 

The final products contain only the binder. The LogKow is not relevant for the binder, 

as the binder is not bioavailable due to the molecular size. Even though, the binder 

has an estimated LogKow of up to about 2.7, it will still not have any potential for 

bioaccumulation. 

An experimental determination of the logKOW using the OECD 117 would be very 

difficult. Further, this method can only be used for the logKOW range of 0-6, but 

several of the ingredients in the AAA reaction product have a logKOW below 0. 

Assignment of the various peaks to specific ingredients would further be very 

challenging, if possible at all, as detection of the various ingredients in the AAA 

reaction product requires at least two chemical analyses and as several of the 

ingredients are foreseen to have peaks in the same range.

The monomers, dimers and trimers all have a low LogKow and thus a very low 

potential for bioaccumulation and low tendency to adsorb to soil and sediments. The 

determination of these ingredients is assessed to be properly determined by the 

current data (measurement and estimation). The final substances in the products 

have logKow of about 2.7. However the polymers are not bioavailable due to their 

size, and will therefore not have any potential for bioaccumulation. 

In conclusion it is not scientifically justified, and it is not technically feasible to 

perform a test.

Table 3: LogKow of the various constituents in the AAA-reaction product

Substance CAS-RN logKow Reference to water solubility data

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13. Ready Biodegradation 

Test substance: AAA reaction product 

Results: 

Not ready biodegradable. 

Partly biodegradability (53%) was found after 28-days, but final pass level for ready 

biodegradability was not reached (at least 60% of the COD in a 10-day window). 

It was not possible to identify which substances (monomer, dimer, trimer or polymer) 

of the Alkanolamine-acid-anhydride reaction product were degraded during the 28-

days incubation period.

Conditions: 

GLP study performed in accordance with OECD 301F and EEC C.4-D using the 

manometric Respirometry test. 

14. Adsorption-desorption 

Test substance

AAA reaction product (same as the substance being notified)

Results: 

 These compounds are estimated to cover about 75-80% of the dry 

matter of the Alkanolamine-acid-anhydride reaction product. 

Monomers

high to very high mobility for both monomers in their fully protonated form. Due to 

deprotonating, the Koc is expected to fall into the highest class for both monomers at 

environmental pH. The estimated Koc values for diethanolamine are indicating a very 

high mobility of this monomer. 

Dimers

All dimers are expected to be of very high mobility in soil based on their estimated 

adsorption coefficients.
Trimers

Most of the trimers are expected to be of very high mobility in soil except of those 

ester linked or ester/amide linked compounds where the molecule overall will be 

positively charged at environmental pH due to protonation of free amino functional 

groups. The mobility is therefore expected to be lower due to ionic interactions with 

soil as this will be the relevant binding mechanism to soil.

Polymers

The mobility of polymers in soil is expected to decrease with increasing molecular 

weight

Conditions: 

The estimation of the adsorption coefficient of Alkanolamine-acid-anhydride reaction 

product to soil was supposed to be performed in accordance with OECD 106, OECD 

121 and ECC C.19 using different HPLC analysis. Due to the complex mixture of 

monomers, dimers, trimers and polymers, this approach was not applicable. The 

adsorption coefficient was therefore estimated using regression equations and 

relating the Koc with the water solubility. A further estimation was performed based 

on log Pow using regression equation relating the log Koc with log Pow. The EPI 

Suite software was used to estimate the Koc of the monomers.

15. Hydrolysis as a Function of pH

Test substance

AAA reaction product (same as the substance being notified)

Results:

QSAR based estimates for the acid- and base catalysed hydrolysis rate led to the 

conclusion that the Alkanolamine-acid-anhydride reaction product will not hydrolyse 

in a slightly acidic to neutral aquatic environment (pH 4 to pH 7). Under these 

conditions both ester and amide type functional groups of dimers, trimers and 

polymers of DEA/acid anhydride reaction product were estimated to be hydrolytically 

stable.

Under alkaline conditions (pH 8 to pH 9), only 

.

Conditions: 

The determination of hydrolysis of the Alkanolamine-acid-anhydride reaction product

at different pH values was supposed to be performed in accordance with OECD 

111, and ECC C.7 using different HPLC analysis. Due to the complex mixture of 
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 the analytical methods were not suitable 

to follow a hydrolysis of the mixture with exception of the monomers. QSAR based 

estimates for the acid- and base-catalysed hydrolysis rate was therefore used.

Summary of additional physical and chemical information 

Surface tension: The surface tension of the Alkanolamine-acid-anhydride reaction 

product was investigated in an aqueous solution by means of a ring tensiometer in 

accordance with EEC A.5 and OECD 115 test guidelines and GLP regulations. The 

surface tension was determined to be 58.0 mN/m at 20.10

C ± 0.10C, indicating that 

the Alkanolamine-acid-anhydride reaction product is a surface active substance. 

Flash Point: The flash point of the Alkanolamine-acid-anhydride reaction product 

was established using the EEC A.9 test guideline and ASTM standard and in 

accordance with GLP regulations. The flash point was evaluated to be > 1200

C 

using the closed cup method.

Self-ignition temperature: It is evaluated that the water content will evaporate and 

the dry matter of the Alkanolamine-acid-anhydride reaction product will 

subsequently polymerise upon heating, thereby releasing further water that will 

evaporate. 

Oxidizing properties: Test for oxidizing properties has not been performed. The 

Alkanolamine-acid-anhydride reaction product is a 

 According to Bretherick`s Handbook of Reactive Chemical Hazards none of 

these components contain groups that may cause an exothermic reaction. In fact, 

when heated he Alkanolamine-acid-anhydride reaction product will polymerise, 

which is an endothermic reaction. 

Full test reports are presents as attachments to the PMN.