### MEMORANDUM

TO: Greg Macek, EPA/OPPT/CEB

FROM: Jason A. Sese , ERG

Kurt Rindfusz , ERG

DATE: May 31 , 201 3

SUBJECT: Analysis of Potential Uses in the “ Glyme s ” Chemical Category

On March 22, 2012, ERG provided a deliverable in support for the proposed SNUR on the Glymes chemical category

, “ Update of Determination of Potential Consumer Uses for the Glymes Significant New Use Rule". The deliverable compiled a table of all the potential consumer uses of 14 chemicals in the Glymes chemical category through research, direct contacts, and comments on the SNUR.

For each use

, the table assigned two separate classifications: (1) actual ve rsus reported use; and ( 2 ) consumer versus non

- consumer use

. Confirmed uses were designated as “actual” while

unconfirmed uses were designated as “reported” (this includes industrial, commercial, and/or consumer use). Confirmed uses were discussed with an industry contact or were provided as comments in response to the proposed SNUR. All other uses were designated as unconfirmed.

ERG made a separate determination as to whether there was a potential consumer use.

ERG r eceived a Technical Directive (TD) on May 23, 2012 to refine the analyses by dividing the

main table into three separate tables

. ERG delivered the updated draft on May 31, 2012, and received an additional TD on July 23, 2012 to update the analysis based on EPA comments. On May 20, 2013, ERG received an additional TD that limited the scope of the Glymes SNUR to seven glyme chemicals. The seven glymes included in the final scope are:

CASRN Common Name

110

- 71

- 4 Monoglyme

111

- 96

- 6 Diglyme

629

- 14

- 1 Ethylglyme

112

- 36

- 7 Ethyldiglyme

112

- 49

- 2 Triglyme

112

- 73

- 2 Butyldiglyme

63512

- 36

- 7 Butyltriglyme



### The purpose of this memorandum is to present the following tables for the seven glymes of

interest :

### T able 1 includes the uses where there is a n indication that there is an actual current consumer

use. These uses were identified from discussions with technical contacts from Clariant and Novolyte, or were explicitly discussed by industry in comments to the proposed SNUR.

Table 2 includes the uses where there is a n indication that there is no actual current consumer

use. As with Table 1, these determinations were based on discussions with technical contacts from industry or from information provided in the SNUR comments. These uses are primarily

ind ustrial or commercial

.

Table 3 includes both potential consumer and non

- consumer uses that have been reported in

various sources but have not been confirmed by direct contact with industry

. These uses have been identified through internet and literature searches, but have not been definitively classified

in Table s 1 or 2.Table 1. Consumer Uses for Glymes Chemicals (C onfirmed)

Glyme CAS # Use Description Consumer

Use? (Yes / No ; Actual / Reported) Basis

Monoglyme 110

- 71

- 4 Electrolyte solutions for

lithium batteries Yes (actual) Kirk Othmer lists use as an electrolyte in lithium batteries (Blomgren and Hunter, 2000). Clariant Corporation states that it is used as a solvent for electrolytes of lithium batteries (Clariant, 2008a) and Novolyte Technologies indicates a use as a lithium battery electrolyte solvent component (Novolyte, 2008a)

. Joe Valcho of Novolyte stated that it is possible that batteries containing 1 to 5 percent monoglyme may be sold to consumers through battery distributors; therefore, these batteries may potentially have consumer use (Novolyte, 2009). Comments from the AAM, Global Automakers, and Novol yte confirm this use (AAM, 2011; Global Automakers, 2011; Novolyte, 2011).

Diglyme 111

- 96

- 6 None

Ethylglyme 629

- 14

- 1 None

Ethyldiglyme 112

- 36

- 7 Coatings and adhesives manufacturing Yes (actual) Scorecard reports use in coatings and adhesives manufacturing ( Scorecard, 2005 as cited

in Abt, 2009), AAM reports use in glues and sealants (AAM, 2011), and Novolyte states consumer use in adhesives and coatings (Novolyte, 2011)

Solvent in printing inks Yes (actual) The Handbook of Paint and Coating Raw Materials reports potential use as a solvent in printing inks ( Ash, 199 6 as cited in Abt, 2009), AAM reports use in inks for lenses, marking parts, and printed circuit boards/integrated circuits (AAM, 2011), and Novoly te states that ethyldiglyme is used in consumer inks (Novolyte, 2011)

Paint and graffiti removal Yes (actual) Novolyte states that ethyldiglyme is used in consumer paint and graffiti removers (Novolyte, 2011)

Triglyme 112

- 49

- 2 Process solvent for

adhesives Yes (actual) Clariant Corporation and Novolyte Technologies list use as a solvent for adhesives (Clariant, 2008c, Novolyte, 2008c) . Terry Wells of Clariant could not specifically state

that the final adhesive would not be used by consumers (Clariant, 2009). However, Joe Valcho of Novolyte stated that it is possible that adhesives containing between one and five percent glyme may be sold to consumers through distributors. (Novolyte, 2009) AAM and Global Automakers also reported use as a solv ent in adhesives for liquid display panels, but in the context of motor vehicle manufacturing (AAM, 2011; Global Automakers, 2011).

Note that Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for triglyme (Novolyte, 20 11).Table 1. Consumer Uses for Glymes Chemicals (C onfirmed)

Glyme CAS # Use Description Consumer

Use? (Yes / No ; Actual / Reported) Basis

Component of brake fluids Yes (actual) Clariant Corporation lists a use as a component of brake fluids (Clariant, 2008c) and a

German MSDS lists triglyme as a component for a brake fluid (Continental Teves, 2006). No information was found limiting use of this brake fluid to industrial or commercial settings. Additionally, Terry Wells of Clariant could not affirm that the final brake fluid would not be used by consumers; therefore it is assumed that triglyme may be present in

brake fluid accessible b y consumers (Clariant, 2009). AAM and Global Automakers also reported use in brake fluid, but in the context of motor vehicle manufacturing (AAM, 2011; Global Automakers, 2011).

Note that Novolyte’s comments on the proposed SNUR state that there are no cu rrent consumer uses for triglyme (Novolyte, 2011).

Component of paint/graffiti

remover Yes (actual) Clariant Corporation lists a use as a component of paint/graffiti remover formulations and delacquers (Clariant, 2008c)

. No information was found limiting use of these removers to industrial or commercial settings. Terry Wells of Clariant could not affirm that the final

remover would not be used by consumers; therefore it is assumed that triglyme may be present in paint/graffiti remover accessible by consumers . (Clariant, 2009)

Note that Novolyte’s comments on the proposed SNUR state that there are no current

consumer uses for triglyme (Novolyte, 2011).

Butyldiglyme 112

- 73

- 2 Inks, adhesives, and coatings Yes (actual) Novolyte reported consumer use of butyldiglyme in inks, adhesives, and coatings (Novolyte, 2011).

Solder paste Yes (actual) AAM and Global Automakers reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011; Global Automakers, 2011) , but Novolyte reported consumer use of butyldiglyme in soldering compounds (Novolyte, 2011).

Butyltriglyme 63512

- 36

- 7 NoneTable 2

. Non

- Consumer Uses for Glymes Chemicals

Glyme CAS # Use Description Consumer

Use? ( Y es / N o ; Actual / Reported) Basis

Monoglyme 110

- 71

- 4 Solvent in pharmaceutical syntheses No (actual) Monoglyme is listed as a solvent by the Merck Encyclopedia of Chemicals, Drugs and Biologicals ( HSDB, 2009a) and Novolyte Technologies lists a use as a solvent vehicle for pharmaceuticals (Novolyte, 2008a) . Joe Valcho of Novolyte stated that the use of monoglyme in pharmaceutical syntheses i s a closed

- loop process, where no glyme is present in the final product (Novolyte, 2009).

Component of anti

- AIDS drugs No (actual) Clariant Corporation lists use as a process solvent for manufacture of anti

- HIV drugs (Clariant, 2008a) . Terry Wells of Clariant stated that the glyme would only be used as a process solvent, with none present in the final product (Clariant, 2009).

Wheel and tire assembly No (actual) AAM reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011).

Electrolysis fluids No (actual) AAM and Global Automakers reported the use of glymes in several automotive components, which would be primarily used in industry (AAM, 2011; Global Automakers, 2011). Valve in tire

- pressure monitoring system and tire

Diglyme 111

- 96

- 6 Solvent in printing ink manufacturing No (actual) Novolyte Technologies lists a use as a solvent for printing inks (Novolyte, 2008b) and the

Printers National Environmental Assistance Center (PNEAC) includes diglyme on a listing of TRI chemicals possibly found in printing (PNEAC, 1996). Joe Valcho of Novolyte stated that it is possible that printing inks containing between one and five percent glyme may be sold to consumers through distributor s (Novolyte, 2009). However, Novolyte’s most recent comments on the proposed SNUR state that there are no current consumer uses of diglyme (Novolyte, 2011).

Solvent in intermediate and pharmaceutical syntheses No (actual) Diglyme is listed as a solvent by the Merck Encyclopedia of Chemicals, Drugs and Biologicals (HSDB, 2009b). Joe Valcho of Novolyte stated that the use of diglyme in pharmaceutical syntheses a closed

- loop process, where no glyme is present in the final product (Novolyte, 2009).

Component of anti

- AIDS drugs No (actual) Clariant Corporation lists a use as a process solvent for manufacture of anti

- HIV drugs (Clariant, 2008b) . Terry Wells of Clariant stated that the glyme would only be used as a process solvent, with none present i n the final product (Clariant, 2009)

. Instrument cluster No (actual) AAM reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011).

Ethylglyme 629

- 14

- 1 Dielectric substance used in composition of audio assembly, electronic component head unit assembly, varistor No (actual) AAM and Global Automakers reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011; Global Automakers, 2011).

Ethyldiglyme 112

- 36

- 7 Receiver assembly radio with navigation display No (actual) AAM reported the use of glymes in several automotive components that would be primarily used in industry (AAM , 2011)Table 2

. Non

- Consumer Uses for Glymes Chemicals

Glyme CAS # Use Description Consumer

Use? ( Y es / N o ; Actual / Reported) Basis

Electronic switches

Silver paste for integrated

circuits mounted on printed circuit boards, display, combination meter, or other. No (actual) AAM and Global Automakers reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011; Global Automakers, 2011).

Solvent for:

- Sealant for Navigation

Touch Panel

- Ink for lens

- Audio assembly No (actual) AAM reported the use of glymes in several automotive manufacturing processes that would be primarily used in industry (AAM , 2011)

Electronic Parts No (actual) Global Automakers reported the use of glymes in several automotive components that would be primarily used in industry (Global Automakers, 2011). Glues and sealants

Inks for lens

Solvent in Carbon Ink

Triglyme 112

- 49

- 2 Binding agent in porcelain powders No (actual) Novolyte Technologies lists a use as a binding agent in porcelain powders (Novolyte, 2008c)

. Joe Valcho of Novolyte was unsure of this type of process, but stated that the porcelain would have to be fired, therefore burning off any glyme present (Novolyte, 2009).

Sodium cyanide

– restricted use pesticide (may be limited to commercial farming) No (actual) Novolyte Technologies lists a use as a process solvent for sodium cyanide production powders (Novolyte, 2008c) . These powders are used in restricted

- use pesticides that are regulated under the Federal Insecticide, Fungicide, and Rodenticide ACT (FIFRA) , and require certification for use; therefore even if the glyme s were present in the s odium cyanide, it would not typically be available for consumer use.

Butyldiglyme 112

- 73

- 2 Solvent for conductive ink No (actual) Novolyte Technologies lists a use as a solvent for conductive inks (Novolyte, 2008d)

. After printing, the solvent is evaporated out of the mixture. Joe Valcho of Novolyte stated that this is expected to be used 1 00 percent industrially (Novolyte, 2009).

Printed circuit etchants No (actual) Novolyte Technologies lists a use as a printed circuit etchants (Novolyte, 2008d)

. No information was found limiting the use of these products to industrial or commercial settings. Etchants are used in the manufacture of printed circuit boars to remove layers from the surface of the wafer. Joe Valcho of Novolyte state d that this is expected to be used 100 percent industrially (Novolyte, 2009).

Control assembly for lift
gate power No (actual) AAM reported the use of glymes in several automotive components that would be primarily used in industry (AAM , 2011).

Headlamp assembly,

instrument clusterTable 2

. Non

- Consumer Uses for Glymes Chemicals

Glyme CAS # Use Description Consumer

Use? ( Y es / N o ; Actual / Reported) Basis

Differential pressure sensor assembly: conductor Ag/Pd within the hybrid pressure chip assembly

Packaging material

Raw material of ceramics

for tuners No (actual) AAM and Global Automakers reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011; Global Automakers, 2011). Electrical conduction silver paste in thermal wire

Insulation glass

Dielectric substance in

varistor

Glue/sealant No (actual) The Association of Global Automakers indicated that this glyme is used in the motor vehicle manufacturing process (Global Automakers, 2011). Dielectric substance

Butyltriglyme 63512

- 36

- 7 NoneTable 3

. Reported but Unconfirmed Uses

Glyme CAS # Use Description Consumer

Use? (Yes / No ; Actual / Reported) Basis

Monoglyme 110

- 71

- 4 Printed circuit board manufacturing No (reported) Scorecard listed reported industrial uses in the inner and outer layer etching of printed board manufacturing (Scorecard, 2005 as cited in Abt, 2009)

Solvent in organometallic

reactions No (reported) The Clariant website reported industrial use as a solvent in organometallic reactions, as a solvent in sugar and carbohydrate reactions, and in surface treatment for aluminum

, according to the Clariant website (Clariant, 2008 as cited in Abt, 2009). Solvent in sugar and carbohydrate chemistry

Surface treatment of

aluminum

IUR “other” use No (reported) Commercial/Consumer use in the 2006 IUR was classified as “other,” but the specific uses cannot be identified ( USEPA, 2006 as cited in Abt, 2009).

Diglyme 111

- 96

- 6 Automotive Care Yes (reported) The Ferro website reported the use of diglyme in automotive care products and brake fluid, which may have consumer use ( Ferro, 2009 as cited in Abt, 2009).

Note that Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for diglyme (Novolyte, 2011). Also note that the American Coatings Association (ACA) comments on the proposed SNUR dispute that glymes are used in the paints and coatings industry (ACA, 2011). Brake Fluid

Component of paints and coatings Yes (reported) The 2006 non

- CBI IUR database lists consumer use in paints and coatings (USEPA, 2006). It also listed commercial/consumer use in adhesives, sealants and automotive care products.

Note that Novolyte’s comments on the proposed SNUR state that there are no current

consumer uses for diglyme (Novolyte, 2011).

Adhesives and Sealants Yes (reported) The 2006 non

- CBI IUR lists commercial/consumer use of diglyme in adhesives in sealants, which may have consumer use ( USEPA, 2006 as cited by Abt, 2009). AAM also

indicated the use of diglyme in solvent applications for sealants (AAM, 2011)

.

Note that Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for diglyme (Novolyte, 2011).

Solvent for lithium aluminum hydride and sodium borohydride

reductions No (reported) The Ferro website reported the use of diglyme in lithium aluminum hydride and sodium borohydride reactions ( Ferro, 2009 as cited in Abt, 2009).

IUR “other” use No (reported) The 2006 IUR database reported additional “other” comm ercial/consumer use for diglyme, but did not provide specifics ( USEPA, 2006 as cited in Abt, 2009).Table 3

. Reported but Unconfirmed Uses

Glyme CAS # Use Description Consumer

Use? (Yes / No ; Actual / Reported) Basis

Ethylglyme 629

- 14

- 1 Paint production Yes (reported) The Specialty Chemical Source Book reported the use of ethylglyme in paint production ( Ash, 2009 as cited in Abt, 2009).

Note that Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for ethylglyme (Novolyte, 2011). Also note that ACA comments on the proposed SNUR dispute that glymes are used in the paints and coati ngs industry (ACA, 2011).

Production of “other” polishes Yes (reported) Scorecard listed the use of ethylglyme in production of polishes that may have consumer use ( Scorecard, 2005 as cited in Abt, 2009).

Note that Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for ethylglyme (Novolyte, 2011).

Adhesive solvent and polycarbonate swelling
agent Yes (reported) The Ferro website reported the use of ethylglyme as an adhesive solvent and polycarbonate swelling agent with potential consumer use ( Ferro, 2009 as cited in Abt, 2009).

Note that Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for ethylglyme (Novolyte, 2011).

Production of ester gum, shellac, resins and oils No (reported) HSDB reported the use of ethylglyme in production of ester gum, shellac, resins, and oils, ( HSDB, 2009 as cited in Abt, 2009).

Note that Novolyte’s comments on the proposed SNUR state that there are no current

consumer uses for ethylglyme (Novolyte, 2011).

Ethyldiglyme 112

- 36

- 7 Paint and paint varnishes Yes (reported) Scorecard reports potential consumer use in paint and paint varnishes ( Scorecard, 2005 as cited in Abt, 2009), but the American Coatings Association (ACA) disputes that glymes are used in the paints and coatings industry (ACA, 2011).

Note that the ACA comments on the proposed SNUR dispute that glymes are used in the paints and coatings industry (ACA, 2011).

Solvent in plastic resins and compounds No (reported) HSDB reports industrial use as a solvent in plastic resins, compounds, and rubber chemicals ( HSDB, 2009 as cited in Abt, 2009).

Solvent in rubber chemicalsTable 3

. Reported but Unconfirmed Uses

Glyme CAS # Use Description Consumer

Use? (Yes / No ; Actual / Reported) Basis

Triglyme 112

- 49

- 2 Paint production Yes (reported) Patent No. 5,919,851 indicates that triglyme may be used a solvent in a paint composition (Yamaguchi et al., 1999). Joe Valcho of Novolyte stated that it is possible that paint containing between one and five percent glyme may be sold to consumers through distributors. (Novolyte, 2009).

Novolyte’s comments on the proposed SNUR state that there are no current consumer uses for triglyme (Novolyte, 2011). Also note that ACA disputes that glymes are used in the paints and coatings industry (ACA, 2011).

Solvent in methylation

reactions No (reported) The Clariant website reported industrial use as a solvent in methylation reactions ( Clariant, 2008 as cited in Abt, 2009).

Unit assembly in front suspension No (reported) AAM reported the use of glymes in several automotive components that would be primarily used in industry (AAM , 2011).

Carbon ink No (reported) AAM and Global Automakers reported the use of glymes in several automotive components that would be primarily used in industry (AAM, 2011; Globa l Automakers, 2011).

Butyldiglyme 112

- 73

- 2 Solvent in Gringard
reagents No (reported) The Clariant website reported industrial use as a solvent in Gringard and metal extraction reagents (Clariant, 2008 as cited in Abt, 2009).

Metal extraction

Butyltriglyme 63512

- 36

- 7 Gas scrubbing No (reported) A journal article reported industrial use of this glyme in gas scrubbing ( Schiller and Gmehling, 1992 as cited in Abt, 2009).

Production of methacrylic

acid No (reported) A patent described industrial use of this glyme in the production of methacrylic acid (LONGZA AG, 1967 as cited in Abt, 2009).

Unidentified glymes Unknown Surface preparation of plastics No (reported) Boeing indicates that they use several types of glymes for specialized applications in aerospace manufacturing (Boeing, 2011).

Adhesive bonding applications

Specialty coatings

Structural and sound dampening foams

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