United States Chemical Safety December 2011

Environmental Protection and Pollution Prevention

Agency (7510P)

Tri-N Butyl Tetradecyl Phosphonium Chloride

(TTPC)

Summary Document:

Registration Review: Initial Docket

December 2011
Docket Number: EPA-HQ-OPP-2011-0952

www.regulations.gov

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Tri-N Butyl Tetradecyl Phosphonium Chloride (TTPC)

Summary Document

Registration Review: Initial Docket

December 2011

Case # 5111

Approved By:

Joan Harrigan-Farrelly

Director, Antimicrobials Division

Date:
Docket Number: EPA-HQ-OPP-2011-0952

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TABLE OF CONTENTS

Tri-N Butyl Tetradecyl Phosphonium Chloride Registration Review Team....................... 4

I. Preliminary Work Plan ........................................................................................................ 5

II. Fact Sheet .......................................................................................................................... 12

III. Summary of Anticipated Data Requirements................................................................ 16

IV. Appendix A...................................................................................................................... 18

________________________________________

Please Note

This Preliminary Work Plan and Fact Sheet summarize the Environmental Protection Agency's 

current position based on the following documents:

1. Product Chemistry, Environmental Fate, and Ecological Effects Scoping Document in 

Support of the Registration Review of Tri-n-butyl tetradecyl phosphonium chloride. 

December 6, 2011

2. Tributyl Tertradecyl Phosphonium Chloride (TTPC): Human Health Risk Assessment 

Scoping Document in Support of Registration Review. October 31, 2011

Additional supporting documents for the Tri-N Butyl Tetradecyl Phosphonium Chloride Case 

may be found in the registration review docket located on the internet at www.regulations.gov.
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Tri-N Butyl Tetradecyl Phosphonium Chloride Registration Review Team

Nathan Mottl

Human Health & Environmental Effects

Srinivas Gowda

Eliza Blair

Risk Management

Lance Wormell

Philip Ross

Office of General Counsel
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I. Preliminary Work Plan -- Tri-N Butyl Tetradecyl Phosphonium Chloride

The Food Quality Protection Act (FQPA) of 1996 mandated a registration review program. All 

pesticides distributed or sold in the United States generally must be registered by the U.S. 

Environmental Protection Agency (USEPA, EPA, or the Agency) based on scientific data 

showing that they will not cause unreasonable risks to human health or the environment when 

used as directed on product labeling. The registration review program is intended to make sure 

that, as the ability to assess risk evolves and as policies and practices change, all registered 

pesticides continue to meet the statutory standard of no unreasonable adverse effects to human 

health or the environment. Changes in science, public policy, and pesticide use practices will 

occur over time. Through the registration review program, the Agency periodically reevaluates 

pesticides to make sure that as change occurs, products in the marketplace can be used safely. 

Information on this program is provided at 

Introduction:

http://www.epa.gov/oppsrrd1/registration_review/.

The Agency is implementing the registration review program pursuant to Section 3(g) of the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and will review each registered 

pesticide every 15 years to determine whether it continues to meet the FIFRA standard for 

registration. The Agency will consider benefits information and data as required by FIFRA. The 

public phase of registration review begins when the initial docket is opened for each case. The 

docket is the Agency’s opportunity to state what it knows about the pesticide and what additional 

risk analyses and data or information it believes are needed to make a registration review 

decision. After reviewing and responding to comments and data received in the docket during 

this initial comment period, the Agency will develop and commit to a final work plan and 

schedule for the Tri-N Butyl Tetradecyl Phosphonium Chloride Case.

Tri-n butyl tetradecyl phosponium chloride (TTPC) was initially registered as a pesticide in the 

United States in 1987 for use as a disinfectant; it was later withdrawn, and no registered products 

containing TTPC existed until its reactivation in 2006 for use as an algicide, fungicide and 

bacteriocide. Currently there are three registered products containing TTPC. Products containing 

TTPC are registered for use in industrial processes and water systems such as commercial and 

industrial cooling towers, evaporative condensers, heat exchange water systems, evaporative 

coolers, dairy sweetwater systems, industrial process water systems, brewery pasteurizers, can 

warmers, hydrostatic sterilizers and retorts, air washing systems equipped with a mist eliminator, 

and industrial air scrubbing systems as well as enhanced oil recovery systems. There are no 

pesticide tolerances or exemptions from the requirement of tolerance for TTPC.

No RED was developed for this chemical because products containing the active ingredient 

were first registered after November 1, 1984.

Documents associated with the registration review of Tri-n butyl tetradecyl phosphonium 

chloride can be viewed at www.regulations.gov in docket EPA-HQ-OPP-2011-0952. Below is a 

summary of the issues relevant to this registration review case.
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The Agency anticipates the need to conduct a comprehensive ecological risk assessment, 

including an endangered species risk assessment, for all uses of TTPC. The Agency does not 

anticipate the need to conduct a human health risk assessment. The Agency anticipates needing 

additional data for use in conducting the registration review for TTPC.

Anticipated Risk Assessment and Data Needs:

Ecological Risk:

• An ecological risk assessment was performed for TTPC as part of the 2006 registration 

action. TTPC uses that have potential for environmental exposure are industrial 

slimicides used in recirculating water cooling towers and pulp and paper mill discharges. 

The Agency needs to conduct environmental fate and ecological risk assessments for 

industrial slimicides used in recirculating water cooling towers, pulp and paper mills, and 

oilfield drilling and maintenance fluids that potentially pass through waste water 

treatment plants (WWTPs) and may be discharged into terrestrial and aquatic 

environments.

• The Agency has not conducted a risk assessment that supports a complete endangered 

species determination for TTPC. The ecological risk assessment planned during 

registration review will allow the Agency to determine whether TTPC’s use has 'no 

effect' or 'may affect' federally listed threatened or endangered species (listed species) or 

their designated critical habitats. When an assessment concludes that a pesticide’s use 

'may affect' a listed species or its designated critical habitat, the Agency will consult with 

the U.S. Fish and Wildlife Service and/or National Marine Fisheries Services (the 

Services), as appropriate.

• The Agency anticipates the need to require the following additional environmental fate

data for use in the registration review of TTPC.

o 835.4300 Aerobic aquatic metabolism

o 835.4400 Anaerobic aquatic metabolism

o 835.1240 Adsorption/Desorption

o 850.6800 Modified Activated Sludge Respiration Inhibition

o 835.1110 Activated Sludge Sorption Isotherm

o 835.3110 Ready biodegradability

o 835.3220 Porous Pot Test

1

o 835.3280 Simulation Tests to Assess the Biodegradability of Chemicals 

Discharged to Wastewater

1

o 835.3240 Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge 

Units

1

1

 1 The results of the Activated Sludge Respiration Inhibition Test (ASRI) that is expected to be required would 

determine which of these three biodegradation tests are required. If the ASRI test EC50 is less than or equal to 20 

mg/L, then either the Biodegradation in Activated Sludge Study or Simulation Test – Aerobic Sewage Treatment: A. 

Activated Sludge Units or the Porous Pot Test would be anticipated to be required. If the ASRI test EC50 is greater 

than 20 mg/L, then the applicant would choose to conduct either: (i) Ready Biodegradability or (ii) Biodegradation 

in Activated Sludge or Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units or the Porous Pot 
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o 830.7550 - Octanol/water partition coefficient determination for TTPC by the 

Shake Flask Method modified to use measured TTPC ion pair and cation 

concentrations at equilibrium

• The Agency anticipates the need to require the following additional ecotoxicity data for 

use in the registration review of TTPC.

o 850.1400 - Fish early-life stage toxicity test, freshwater species (most acutely 

sensitive Blue gill sunfish, Lepomis macrochirus)

o 850.1300 - Aquatic invertebrate life-cycle, freshwater species

o 850.4400 - Aquatic plant toxicity test, vascular species

o 850.5400 - Aquatic plant toxicity test, non-vascular (4 species: a freshwater green 

alga, a freshwater diatom, a cyanobacterium, and a marine diatom)

o Special Study - Sediment chronic toxicity test, freshwater invertebrate Hyallela 

azteca 2

o 850.1075 - Fish acute toxicity, estuarine/marine species

o 850.1035 - Mysid acute toxicity test 

o 850.1025 or 850.1055 - Mollusc acute toxicity

o 850.1350 - Mysid life-cycle toxicity test

o 850.4100 - Seedling emergence and growth test for rice (Oryza sativa)

o Special Study - Sediment chronic toxicity test, freshwater invertebrate

Chironomous dilutus

• For more information, please refer to Product Chemistry, Environmental Fate, and 

Ecological Effects Scoping Document in Support of the Registration Review of Tri-nbutyl tetradecyl phosphonium chloride, located in the docket.

Human Health Risk: 

• A human health risk assessment was performed for TTPC as part of the 2006 registration 

action. 

• The Agency does not anticipate the need to require additional human health data for this

registration review case at this time.

• For more information, please refer to Tributyl Tertradecyl Phosphonium Chloride 

(TTPC): Human Health Risk Assessment Scoping Document in Support of Registration 

Review, located in the docket.

 Test. If the antimicrobial passes the ready biodegradability study, then no further testing would be expected to be

required. If, however, the antimicrobial fails the ready biodegradability study, then the Biodegradation in Activated 

Sludge or Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units, or the Porous Pot study would 

be expected to be required.

2 The sediment toxicity tests that are anticipated to be required could be waived if acceptable environmental fate 

data are provided to demonstrate that the half-life of the pesticide in the sediment is greater than 10 days and if at 

least one of the following conditions is met: 1) Kd <50, 2) Koc <1000, and/or 3) Kow <3.
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Product Chemistry:

• The Agency does not anticipate the need to require additional product chemistry data for 

this registration review case at this time.

• For more information, please refer to Product Chemistry, Environmental Fate, and 

Ecological Effects Scoping Document in Support of the Registration Review of Tri-nbutyl tetradecyl phosphonium chloride, located in the docket.

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse 

outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and 

chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, 

reproductive, and general or systemic toxicity. These studies include endpoints which may be 

susceptible to endocrine influence, including effects on endocrine target organ histopathology, 

organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, 

and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and 

chronic studies that assess growth, developmental and reproductive effects in different 

taxonomic groups. As part of its most recent registration decision for TTPC, EPA reviewed these 

data and selected the most sensitive endpoints for relevant risk assessment scenarios from the 

existing hazard database. However, as required by FFDCA section 408(p), TTPC is subject to 

the endocrine screening part of the Endocrine Disruptor Screening Program (EDSP). 

Endocrine Disruptor Screening Program

EPA has developed the EDSP to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator 

may designate.” The EDSP employs a two-tiered approach to making the statutorily required 

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a 

chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal 

systems. Chemicals that go through Tier 1 screening and are found to have the potential to 

interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA 

will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 

testing is designed to identify any adverse endocrine-related effects caused by the substance, and 

establish a dose-response relationship between the dose and the E, A, or T effect.

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between October 

2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 chemicals, 

which contains 58 pesticide active ingredients and 9 inert ingredients. TTPC is not among the 

group of 58 pesticide active ingredients on the initial list to be screened under the EDSP.

Accordingly, as part of registration review, EPA will issue future EDSP orders/data call-ins, 

requiring the submission of EDSP screening assays for TTPC. For further information on the 

status of the EDSP, the policies and procedures, the list of 67 chemicals, future lists, the test 

guidelines and the Tier 1 screening battery, please visit our website: http://www.epa.gov/endo/.
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Timeline

EPA has created the following estimated timeline for the completion of the Tri-n butyl tetradecyl 

phosphonium chloride registration review:

Anticipated Schedule

Activities Estimated Month/Year

Phase 1: Opening the docket

Open Public Comment Period for Docket December 2011

Close Public Comment Period for Docket February 2012

Phase 2: Case Development

Develop Final Work Plan (FWP) June 2012

Issue DCI June 2013

Data Submission June 2014

Open Public Comment Period for Preliminary Risk Assessments December 2015

Close Public Comment Period for Preliminary Risk Assessments January 2016

Phase 3: Registration Review Decision

Open Public Comment Period for Proposed Reg. Review Decision June 2016

Close Public Comment Period for Proposed Reg. Review Decision August 2016

Final Decision and Begin Post-Decision Follow-up 2016

Total (years) 5

Guidance for Commenters:

The public is invited to comment on EPA’s Preliminary Work Plan and rationale. The Agency 

will carefully consider all comments as well as any additional information or data provided in a 

timely manner prior to issuing a final work plan for the Tri-n butyl tetradecyl phosphonium 

chloride registration review case.

Trade Irritants:

Through the registration review process, the Agency intends to solicit information on trade 

irritants and, to the extent feasible, take steps toward facilitating irritant resolution. Growers and 

other stakeholders are asked to comment on any trade irritant issues resulting from lack of 

Maximum Residue Limits (MRLs) or disparities between U.S. tolerances and MRLs in key 

export markets, providing as much specificity as possible regarding the nature of the concern. 

Water Quality:

TTPC is not identified as a cause of impairment for any water bodies listed as impaired under 

section 303(d) of the Clean Water Act, based on information provided at 

http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=88

5. In addition, no Total Maximum Daily Loads (TMDL) have been developed for TTPC, based 

on information provided at 
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http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id

=885&p_pollutant_group_name=PESTICIDES.

More information on impaired water bodies and TMDLs can be found at 

http://www.epa.gov/owow/tmdl/. The Agency invites submission of water quality data for this 

pesticide. To the extent possible, data should conform to the quality standards in Appendix A of 

the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and Other Water 

Quality Data in OPP’s Registration Review Risk Assessment and Management Process (see: 

http://www.epa.gov/oppsrrd1/registration_review/water_quality_sop.htm), in order to ensure the 

data can be used quantitatively or qualitatively in pesticide risk assessments.

Environmental Justice:

EPA seeks to achieve environmental justice, the fair treatment and meaningful involvement of all 

people, regardless of race, color, national origin, or income, in the development, implementation, 

and enforcement of environmental laws, regulations, and policies. To help address potential 

environmental justice issues, the Agency seeks information on any groups or segments of the 

population who, as a result of their location, cultural practices, or other factors, may have 

atypical, unusually high exposure to TTPC compared to the general population. Please comment 

if you are aware of any sub-populations that may have atypical, unusually high exposure 

compared to the general population.

Structure Activity Relationships: 

EPA must rely upon information of appropriate quality and reliability for each decision made by 

the Agency. In the Office of Pesticide Programs (OPP), the evaluation process for a pesticide 

chemical traditionally begins with the applicant’s submission of a set of studies conducted with 

the specific pesticide chemical of interest. The use of the results of such testing (measured data) 

is a logical, scientifically rigorous process that identifies the physical, chemical, and 

environmental fate properties of the pesticide, as well as the dose and endpoints at which an 

adverse effect can occur in various animal species. 

Today, there is significant interest in alternative techniques, i.e., techniques other than data 

generation that could significantly inform the Agency’s decision-making process. Recently, OPP 

has made increasing use of structure activity relationship (SAR) as part of its regulatory 

decision-making process. In the SAR process, a chemical's molecular structure is compared to 

that of other chemicals for which data are available. These structural similarities are then used to 

make predictive judgments about a chemical’s physical, chemical, and biological properties. 

Thus, the chemical’s physical, chemical, and biological properties are a function of (or directly 

related to) the chemical’s molecular structure. Quantitative SAR is referred to as QSAR. To 

develop a QSAR, a selected set of measured data on a single physical, chemical, or biological 

property is used to derive a model (an equation) to predict the value of that property. 

Since SAR assessments and QSAR modeling are another set of tools that are available to Agency 

scientists, OPP has begun a process shift that envisions shifting from the current study-by-study 

approach to an approach in which the use of predicted data, generated using validated models, is 

considered along with information from open literature and studies specifically generated under 
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Part 161 requirements. All relevant information would be considered as part of a weight-of-theevidence evaluation. 

At this time, EPA believes that for certain endpoints, especially physical/chemical and fate 

properties, that SAR and QSAR might be effectively utilized to fulfill these data requirements 

for many antimicrobial pesticide chemicals. When considering biological properties, at this time, 

EPA believes that SAR and QSAR can be most effectively utilized in the evaluation of 

chemicals that exhibit lower toxicity for human health and/or ecotoxicity parameters. This is 

appropriate because the risk assessment for lower toxicity chemicals can be stream-lined, i.e., a 

screening-level assessment procedure rather than multiple tiers of assessments with progressively 

more data requirements.

If stakeholders believe that submission of predicted data can fulfill one of the data needs for the 

Tri-N Butyl Tetradecyl Phosphonium Chloride case, then the Agency invites submission of this 

information. The submitter would be expected to supply a rationale describing the utility of the 

information and provide documentation on the scientific validity of the information. The 

determination that the predicted data fulfills the data requirement would be at the sole discretion 

of the Agency. Pre-submission consultation with the Agency is encouraged.

Additional Information:

Stakeholders are also specifically asked to provide available information and data that will assist 

the Agency in refining its risk assessments, including any species-specific ecological effects 

determinations. The Agency is interested in receiving the following information:

1. Confirmation on the following label information:

a. Sites of application

b. Formulations

c. Application methods and equipment

d. Maximum application rates

e. Frequency of application, application intervals and maximum number of 

applications

f. Geographic limitations on use

2. Use or potential use distribution

3. Use history

4. Usage/use information for non-agricultural uses (e.g., materials preservation)

5. Typical application interval

6. State or local use restrictions

7. Ecological incidents (non-target plant damage and avian, fish, reptilian, amphibian 

and mammalian mortalities) not already reported to the Agency

8. Monitoring data

Next Steps:

After the 60-day comment period closes in February 2012, the Agency will review and respond 

to any comments received in a timely manner, and then issue a Final Work Plan for the Tri-N 

Butyl Tetradecyl Phosphonium Chloride case. 
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II. Fact Sheet

Background Information:

• Active Ingredient: Tri-n butyl tetradecyl phosponium chloride (TTPC)

• Case number: 5111

• PC Code: 128824

• CAS number: 81741-28-8

• Technical registrant: BWA Water Additives LLC

• First approved for use in a registered product: 1987 (withdrawn/inactive 1988, reactivated 2006)

• There are no pesticide tolerances or exemptions from the requirement of tolerance for 

TTPC.

• Antimicrobials Division Chemical Review Manager (CRM): Eliza Blair, 

blair.eliza@epa.gov

• Antimicrobials Division Product Manager (PM): Velma Noble, noble.velma@epa.gov

• Chemical Structure:

Use & Usage Information:

• TTPC is a quaternary phosphonium liquid biocide registered for use as an end-use 

product for control of algae, slime-forming bacteria, sulfate-reducing bacteria and fungi 

in industrial process water treatments (Use Site Category VIII). TTPC is delivered to 

industrial process waters using closed metered delivery systems; open pouring is 

prohibited. Examples of registered TTPC uses include water treatment in recirculating 

cooling water and process waters, heat exchange water systems, air washing systems, 

evaporative coolers, brewery pasteurizers, can warmers, hydrostatic sterilizers and 

retorts, pulp/paper/paperboard systems (non-food contact paper and paperboard 

manufacture of brown paper, sheet for corrugated board, Kraft paper, newsprint and 

similar paper), enhanced oil recovery systems (non-marine/non-estuarine use), oil and gas 

production transmission pipelines and systems, gas storage wells and systems, hydrotesting of pipelines and tanks, pipeline pigging and scraping operations and oil and gas 

well drilling and maintenance fluids. 

Recent/Pending Regulatory Actions:

• An application for amendment for a new product use to control microbial growth in 

waters and on pipe surfaces in fire protection systems was submitted to the Agency on 

July 12, 2011. If approved, this requested new use will not change the data needs or risk 

assessments for this registration review.
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Ecological Risk Assessment Status:

Please refer to Product Chemistry, Environmental Fate, and Ecological Effects Scoping 

Document in Support of the Registration Review of Tri-n-butyl tetradecyl phosphonium chloride, 

located in the docket, for a detailed discussion of the ecological risk assessments.

• TTPC is highly to very highly acutely toxic to freshwater fish and invertebrates. TTPC is 

slightly to moderately toxic to birds. 

• The environmental fate and ecological risk assessment for TTPC performed at the time of 

registration did not address all current uses and environmental exposures. The Agency 

needs to conduct environmental fate and ecological risk assessments for industrial 

slimicides used in recirculating water cooling towers and paper mills that potentially pass 

through waste water treatment plants (WWTPs) and may be discharged into terrestrial 

and aquatic environments.

Human Health Risk Assessment Status:

The following are key findings of the recent human health risk assessments for Tri-n butyl 

tetradecyl phosphonium chloride. Please refer to Tributyl Tertradecyl Phosphonium Chloride 

(TTPC): Human Health Risk Assessment Scoping Document in Support of Registration Review,

located in the docket, for a detailed discussion of the human health risk assessment.

Hazard Characterization:

• TTPC exhibits low acute oral and dermal toxicity (Toxicity Category III) and is corrosive 

to the eye (Toxicity Category I). An acute inhalation toxicity study for TTPC was 

waived and Toxicity Category I assigned for inhalation. A formulated manufacturing-use 

product/end-use product (BELLACIDE 350, 50% TGAI) shows low acute oral toxicity 

(Toxicity Category III); however, it is acutely toxic via the dermal route (Toxicity 

Category I) and is highly irritating and corrosive to the eyes and skin (Toxicity Category 

I).

Dietary (Food and Water):

• A dietary risk assessment has not been conducted for TTPC.

• Current labels restrict product use to nonfood applications and no tolerances or 

exemptions from tolerances exist for indirect food contact use of TTPC; therefore, food 

exposure is expected to be negligible and no dietary assessment is anticipated to be 

needed.

• Dietary exposures via drinking water may occur in the event of a down-the-drain 

discharge. The contaminated water could pass through wastewater treatment facilities 

into the drinking water or may be discharged directly to surface water which is later 

treated. However, at this time there are no available environmental fate data to determine 

whether TTPC can pass through wastewater treatment facilities into drinking water or 
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migrate into residential groundwater wells as a result of its current use patterns. Upon 

receipt and review of the environmental fate data the Agency anticipates requiring, the 

Agency will determine the need for a down-the-drain drinking water assessment.

Residential:

• A residential risk assessment has not been performed for TTPC.

• The labels for TTPC are for industrial applications and TTPC is not used to treat products 

registered for household/residential use. Therefore, no residential exposure is expected 

and no residential assessments will be needed for this registration review.

Aggregate:

• An aggregate assessment has not been conducted for TTPC. In examining aggregate 

exposure, EPA takes into account the available and reliable information concerning 

exposures to pesticide residues in food and drinking water, as well as non-occupational 

pesticide exposures. An aggregate risk assessment has not been deemed necessary for 

TTPC because non-occupational exposure other than potential exposure to drinking water 

(see above) is not expected to occur.

Occupational:

• An occupational exposure assessment for TTPC was completed in 2007.

• An occupational risk assessment was conducted at the time of initial registration. TTPC 

products are required to be metered into water via a fully closed system. Labeling also 

requires PPE such as coveralls worn over long-sleeved shirt, goggles, face shield, 

chemical resistant gloves and footwear in case of leaks or breaks in the closed delivery 

system.

• As a result of the closed mixing/loading, PPE for protection against leaks/malfunctions, 

and low volatility, additional occupational handler assessments are not anticipated as 

needed for registration review. Dermal and inhalation post-application risks for watertreatment uses are likely to be minimal based on dilution, limited exposure contact, and 

low volatility.

Cumulative:

• A cumulative risk assessment has not been performed for TTPC. The Agency does not 

have, at this time, available data to determine whether TTPC has a common mechanism 

of toxicity with other substances or how to include this pesticide in a cumulative risk 

assessment. For the purposes of this Registration Review, EPA has assumed that TTPC

does not have a common mechanism of toxicity with other substances when used as an 

antimicrobial as registered.
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Incidents:

Ecological:

• There are no reported incidents in the Agency's Ecological Incident Information System 

(EIIS) regarding TTPC. 

Human Health:

• No TTPC human poisoning incidents have been reported in the OPP incident database.

Tolerances and International Harmonization:

• There are no pesticide tolerances or exemptions from the requirement of tolerance for 

TTPC.

Data Call-In Status:

• No Data Call-In has been issued for TTPC.

Labels:

Registered products, including EPA registration numbers are provided in Table 1 below. For 

future reference, during registration review a list of product registration numbers will be included 

in the docket. Product registration labels may be obtained from the Pesticide Product Label 

System (PPLS) website at: http://oaspub.epa.gov/pestlabl/ppls.home.

Table 1. Registered Products – TTPC

Registration

No.

Registration

Name

Company

Name

Formulation

Type

% of Active

Ingredient

83451-15 Bellacide 350 BWA Water Additives US 

LLC

Soluble Concentrate

MUP/EP

50

83451-16 Bellacide 355 BWA Water Additives US 

LLC

Soluble Concentrate

EP 5

83451-20 Bellacide 303 BWA Water Additives US 

LLC

Flowable Concentrate

EP 15
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III. Summary of Anticipated Data Requirements – Tri-N Butyl Tetradecyl Phosphonium 

Chloride

The table below summarizes anticipated data needs for the Tri-N Butyl Tetradecyl Phosphonium 

Chloride Case in Section I of this document (Preliminary Work Plan), Product Chemistry, 

Environmental Fate, and Ecological Effects Scoping Document in Support of the Registration 

Review of Tri-n-butyl tetradecyl phosphonium chloride, and Tributyl Tertradecyl Phosphonium 

Chloride (TTPC): Human Health Risk Assessment Scoping Document in Support of Registration 

Review.

Table 2. Summary of Anticipated Data Requirements – TTPC

Guideline

Number Anticipated Data Requirement Test Material

Estimated Timeframe 

(Measured in months from 

DCI Receipt)

835.4300 Aerobic aquatic metabolism TGAI 24

835.4400 Anaerobic aquatic metabolism TGAI 24

835.1240 Adsorption/Desorption TGAI 24

850.6800 Modified Activated Sludge Respiration 

Inhibition

TGAI 24

835.1110 Activated Sludge Sorption Isotherm TGAI 24

835.3110 Ready biodegradability3 TGAI 12

835.3220 Porous Pot Test TGAI 3 12

835.3280

Simulation Tests to Assess the 

Biodegradability of Chemicals 

Discharged to Wastewater

TGAI

3

12

835.3240 Simulation Test – Aerobic Sewage 

Treatment: A. Activated Sludge Units

TGAI 3 12

850.1400

Fish early-life stage toxicity test, 

freshwater species (most acutely 

sensitive Blue gill sunfish, Lepomis 

macrochirus)

TGAI

24

 3 The results of the Activated Sludge Respiration Inhibition Test (ASRI) that is expected to be required would 

determine which of these three biodegradation tests are required. If the ASRI test EC50 is less than or equal to 20 

mg/L, then either the Biodegradation in Activated Sludge Study or Simulation Test – Aerobic Sewage Treatment: A. 

Activated Sludge Units or the Porous Pot Test would be anticipated to be required. If the ASRI test EC50 is greater 

than 20 mg/L, then the applicant would choose to conduct either: (i) Ready Biodegradability or (ii) Biodegradation 

in Activated Sludge or Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units or the Porous Pot 

Test. If the antimicrobial passes the ready biodegradability study, then no further testing would be expected to be

required. If, however, the antimicrobial fails the ready biodegradability study, then the Biodegradation in Activated 

Sludge or Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units, or the Porous Pot study would 

be expected to be required.
Docket Number: EPA-HQ-OPP-2011-0952

www.regulations.gov

17 of 17

850.1300 Aquatic invertebrate life-cycle, 

freshwater species

TGAI 24

850.4400 Aquatic plant toxicity test, vascular 

species

TGAI 24

850.5400

Aquatic plant toxicity test, non-vascular 

(4 species: a freshwater green alga, a 

freshwater diatom, a cyanobacterium, 

and a marine diatom)

TGAI

12

830.7550

Octanol/water partition coefficient 

determination for TTPC by the Shake 

Flask Method modified to use measured 

TTPC ion pair and cation concentrations 

at equilibrium

TGAI

12

850.4100 Seedling emergence and growth test for 

rice (Oryza sativa)

TGAI 12

850.1350 Mysid life-cycle toxicity test TGAI 12

850.1025 or 

850.1055 Mollusc acute toxicity TGAI 12

850.1035 Mysid acute toxicity test TGAI 12

850.1075 Fish acute toxicity, estuarine/marine 

species

TGAI 12

Special 

Study

Sediment chronic toxicity test, 

freshwater invertebrate Chironomous 

dilutus

TGAI

24

Special 

Study

Sediment chronic toxicity test, 

freshwater invertebrate

TGAI 24
Appendix A: Tri-n butyl tetradecyl phosphonium chloride (TTPC)

EPA Reg # Formulation % A. I. Use Site Treatment Site/Surfaces Application Method Min App Rate Max App Rate

Max App Rate Converted Units Use Limitatio

83451-15

Soluble Concentrate 50

Industrial processes and water systems

commercial and industrial cooling towers, evaporative condensers, heat exchange water systems, evaporative coolers, dairy sweetwater systems, industrial process water systems, brewery pasteurizers, can warmers, hydrostatic sterilizers and retorts, air washing systems equipped with a mist eliminator, and industrial air scrubbing systems. Metered

1.3-2.6 oz per 1000 gallons

3.8-7.7 oz per 1000 gallons oz per gal

dairy sweetwapasteurizers, csterilizers and systems equipand industrial are not registe

83451-15

Soluble Concentrate 50

Industrial processes and water systems

pulp, paper, and paperboard mill process water systems Metered

0.3-0.5 lbs per ton of pulp or paper (dry basis)

2.0-3.0 lbs per ton of pulp or paper (dry basis) LBS per TON

Only for Papefood contact u

83451-15

Soluble Concentrate 50

Material preservative

Water based coatings, starches, pigments and filler slurries. Metered 200ppm 1000ppm

Only for Papeintended for fo

83451-15

Soluble Concentrate 50

Industrial processes and water systems Enhanced Oil Recovery Systems Metered

4.2 gallons per 1000 barrels

42 gallons per 1000 barrels

Gallons per Barrel

83451-15

Soluble Concentrate 50

Industrial processes and water systems Gas Storage Wells and Systems Metered 100ppm 1000ppm

Gallons per Barrel

83451-15

Soluble Concentrate 50

Industrial processes and water systems Hydrotesting Metered 100ppm 1000ppm

Gallons per Barrel

83451-15

Soluble Concentrate 50

Industrial processes and water systems Pipeline pigging and scraping Metered 100ppm 1000ppm

Gallons per Barrel

83451-15

Soluble Concentrate 50

Industrial processes and water systems

Drilling, packer, completion, workover and fracturing fluids Metered 100ppm 1000ppm

Gallons per Barrel

83451-16

Soluble Concentrate 5

Industrial processes and water systems

commercial and industrial cooling towers, evaporative condensers, heat exchange water systems, evaporative coolers, dairy sweetwater systems, industrial process water systems, brewery pasteurizers, can warmers, hydrostatic sterilizers and retorts, air washing systems equipped with a mist eliminator, and industrial air scrubbing systems. Metered

13-26 oz per 1000 gallons

38-77 oz per 1000 gallons oz per gal

dairy sweetwapasteurizers, csterilizers and systems equipand industrial are not registe

83451-16

Soluble Concentrate 5

Industrial processes and water systems

pulp, paper, and paperboard mill process water systems Metered

3.0-5.0 lbs per ton of pulp or paper (dry 

basis)

20-30 lbs per ton of pulp or paper (dry basis) LBS per TON

Only for Papefood contact u

83451-16

Soluble Concentrate 5

Material preservative

Water based coatings, starches, pigments and filler slurries. Metered 200ppm 1000ppm

Only for Papeintended for fo

83451-16

Soluble Concentrate 5

Industrial processes and water systems Enhanced Oil Recovery Systems Metered

42 gallons per 1000 barrels

420 gallons per 1000 barrels

Gallons per Barrel

83451-16

Soluble Concentrate 5

Industrial processes and water systems Gas Storage Wells and Systems Metered 1000ppm 10000ppm

Gallons per Barrel
Appendix A: Tri-n butyl tetradecyl phosphonium chloride (TTPC)

EPA Reg # Formulation % A. I. Use Site Treatment Site/Surfaces Application Method Min App Rate Max App Rate

Max App Rate Converted Units Use Limitatio

83451-16

Soluble Concentrate 5

Industrial processes and water systems Hydrotesting Metered 1000ppm 10000ppm

Gallons per Barrel

83451-16

Soluble Concentrate 5

Industrial processes and water systems Pipeline pigging and scraping Metered 1000ppm 10000ppm

Gallons per Barrel

83451-16

Soluble Concentrate 5

Industrial processes and water systems

Drilling, packer, completion, workover and fracturing fluids Metered 1000ppm 10000ppm

Gallons per Barrel

83451-20

Flowable Concentrate 15

Industrial processes and water systems

commercial and industrial cooling towers, evaporative condensers, evaporative coolers, closed loop heating and· cooling systems and industrial process water systems. Metered

1.9-6.4oz per 1000 gallons

9.6-19.2 oz per 1000 gallons oz per gal

83451-20

Flowable Concentrate 15

Industrial processes and water systems

air washing systems equipped with a mist eliminator and industrial air scrubbingsystems. Metered

1.9-6.4oz per 1000 gallons

9.6-19.2 oz per 1000 gallons oz per gal

83451-20

Flowable Concentrate 15

Industrial processes and water systems

brewery pasteurizers, bottle and can warmers and hydrostatic sterilizers and retorts. Metered

1.9-6.4oz per 1000 gallons

9.6-19.2 oz per 1000 gallons oz per gal

83451-20

Flowable Concentrate 15

Industrial processes and water systems

pulp, paper, and paperboard millprocess water systems including white water systems Metered

0.3-0.5 lbs per ton of pulp or paper (dry basis)

2.0-3.0 lbs per ton of pulp or paper (dry basis) LBS per TON

Only for Papefood contact u

83451-20

Flowable Concentrate 15

Industrial processes and water systems Enhanced Oil Recovery Systems Metered

4.2 gallons per 1000 barrels

63 gallons per 1000 barrels

Gallons per Barrel

83451-20

Flowable Concentrate 15

Industrial processes and water systems Gas Storage Wells and Systems Metered 100ppm 1500ppm

Gallons per Barrel

83451-20

Flowable Concentrate 15

Industrial processes and water systems Hydrotesting Metered 100ppm 1500ppm

Gallons per Barrel

83451-20

Flowable Concentrate 15

Industrial processes and water systems Pipeline pigging and scraping Metered 100ppm 1500ppm

Gallons per Barrel

83451-20

Flowable Concentrate 15

Industrial processes and water systems

Drilling, packer, completion, workover and fracturing fluids Metered 100ppm 1500ppm

Gallons per Barrel