Attachment 19 – Sustainable Futures P2 Assessment for [ ] 024

This chemical is the subject of a P2 Assessment for participation in the Sustainable Futurestm Initiative. 

The P2 assessment of [ ] 024 directly follows this cover letter. This summary includes the collection 

of results, assessment methods, and conclusions from the Sustainable Futurestm P2 Framework 

evaluation of this substance. The original modeling outputs and additional detail can be provided upon 

request.

Incomplete data were available for [ ] 024 and predictive methods were employed in the assessment 

of the chemical. This PMN is for 6 consolidated UVCB substances, the assessment of [ ] 024 was 

based on a representative structure and evaluation of starting materials believed to be indicative of the 

mixture as a whole. Details on representative structure selection and assessment methods are available

in the summaries below.

[ ] 024 is predicted to have a moderate overall concern for persistence. The substance is expected 

to degrade mainly through biodegradation with an environmental half-life of 60 to 180 days. 

[ ] 024 is predicted to have a low concern for bioconcentration or bioaccumulation.

[ ] 024 is predicted to have a high hazard concern for aquatic toxicity. 

[ ] 024 is predicted to have a low overall concern level for human health hazards, including acute 

toxicity, non-concern chronic toxicity, and carcinogenicity.

The conclusion of the [ ] 024 aquatic risk assessment is that, based on the lack of release to the 

aquatic environment and subsequent exposure, there is a low potential for risk.

The conclusion of the [ ] 024 occupational risk assessment is that, based on the low hazard concerns, 

there is a low potential for occupational risk associated with the manufacture and use scenarios 

included in this submission. 

The conclusion of the [ ] 024 general population human health risk assessments is that, based on the 

low hazard concerns as well as lack of exposure to the general population, there is a low potential for 

risk from the manufacture and use scenarios included in this submission.

Further, it should be noted that this risk assessment does not take PPE and other exposure controls into 

account when determining exposure and risk. The [ ] MSDS, which is included with the PMN, 

indicates that workers should wear gloves and use other personal protective measures when handling [ 

] 024 or when exposure may occur. In addition, the PMN and MSDS outline proper handling and 

disposal measures which would further reduce the potential for downstream human or environmental 

exposure to the substance. 

It is our opinion that based on this assessment of the chemical and information included in the PMN 

submission and manufacturer’s MSDS, including use of appropriate PPE and exposure controls, [ ] 

024 will not pose an unreasonable risk to human health or the environment.
Sustainable Futures

Summary Assessment

Using

P2 Framework Models

Chemical Assessed: 

[ ] 024

CAS Registry Number: 

N/R

Participant Name: 

[PPG Industries, Inc.]

Date of Assessment:

06/07/2012

This document was developed to help compile estimation results from U.S. EPA OPPT’s P2 

Framework Models and is used by OPPT during Sustainable Futures (SF) training described on 

the US EPS Sustainable Futures homepage at: http://www.epa.gov/oppt/sf/. Participants in the 

voluntary SF Pilot Project are asked to submit the information contained in this assessment along 

with their SF PMNs in their choice of format.

Use of this specific format is not mandatory.
3

Record ID: [ ] 024 Submitter: [PPG Industries Inc.]

Chemical Structure

Is this a representative structure? Yes

MW: Mixture

MF: Mixture

Physical Form: Liquid (mixture)

CAS RN: N/A

Trade Name: PMN 5072

Use: Coating

Production Volume: 485,000

SMILES: [C1(CNCCC(=O)OCCCC)CCCC(CNCCC(=O)OCCCC)C1]

Name: Multiple

Synonyms: Multiple

SUSTAINABLE FUTURES SUMMARY:

Concern Level HIGH MODERATE LOW

Persistence X

Bioconcentration X

Non-Cancer Health Hazard X

Cancer Health Hazard X

Aquatic Toxicity Hazard X

Is the chemical predicted to be a PBT by PBT Profiler? Not Run in PBT Profiler

Overall Hazard Concern Human Health Hazard: Low

Aquatic Hazard: High

Overall Risk Human Health Risk: Low

Aquatic Risk: Low
4

Record ID: [ ] 024 Submitter: [PPG Industries, Inc. ]

PHYSICAL/CHEMICAL PROPERTIES:

Melting Point (deg C) 135 [representative structure] (EPI)

Boiling Point (deg C) >400 [representative structure] (EPI)

Boiling Point Pressure (mm Hg) 760

Vapor Pressure (mm Hg) 7.5 x 10-8[representative structure] (EPI)

Water Solubility 1.7 mg/L [representative structure] (WSKOW; EPI)

Log Kow 5.0 [representative structure] (EPI)

ENVIRONMENTAL TRANSPORT AND FATE:

Transport

Henry’s Law Constant – HLC (atm-m

3

/mol) <10-8[representative structure] (EPI)

Soil Adsorption Coefficient – Log Koc 

Low potential for migration to groundwater (professional 

judgment)

Bioconcentration Factor – BCF BAF of 141; BCF of 40 [representative structure] (EPI)

Persistence

Experimental Biodeg Tests

Probability of Rapid Biodegradation Biodegrades fast [representative structure] (EPI)

Ultimate Biodeg Model Weeks [representative structure] (EPI)

Primary Biodeg Model Hours – days [representative structure] (EPI)

Ready Biodegradability Ready biodegradable [representative structure] (EPI)

Atmospheric Half-life 0.7 hrs [representative structure] (EPI)

Hydrolysis Half-life >80 days at pH 8 [representative structure] (EPI)

Volatilization Half-life for Model River >1 year [representative structure] (EPI)

Volatilization Half-life for Model Lake >1 year [representative structure] (EPI)

Removal in Sewage Treatment Plant >90% [representative structure] (EPI)

Byproducts

Degradation Products

Metabolites
5

Record ID: [ ] 024 Submitter: [ ] 

ECOTOXICITY:

ECOSAR Class Aliphatic amines; esters

Acute Toxicity

Fish LC5O 0.81 mg/L [Aliphatic amines] (ECOSAR) 

Daphnid LC5O 0.14 mg/L [Aliphatic amines] (ECOSAR)

Green Algae EC5O 0.056 mg/L [Aliphatic amines] (ECOSAR)

Chronic Toxicity

Fish ChV 0.016 mg/L [Aliphatic amines] (ECOSAR) 

Daphnid ChV 0.016 mg/L [Aliphatic amines] (ECOSAR)

Green Algae ChV 0.024 mg/L [Aliphatic amines] (ECOSAR)

Overall Aquatic Toxicity Hazard Concern High

NON-CANCER HEALTH EFFECTS:

Acute Toxicity

Low, based on [1,3-Bis(Aminomethyl) Cyclohexane (CAS 

RN 2579-20-6)]. LD50 >200 mg/kg and < 2000 mg/kg 

(NICNAS)

Irritation Skin and eye irritant, based on positive Draize test for [1,3-

Bis(Aminomethyl) Cyclohexane] (NICNAS)

Skin Sensitizer Not a sensitizer, based on [1,3-Bis(Aminomethyl) 

Cyclohexane] (NICNAS)

Reproductive Effects Inadequate data identified

Developmental Effects Inadequate data identified

Immune System Effects Inadequate data identified

Neurotoxicity Inadequate data identified

Genotoxicity Negative, based on [1,3-Bis(Aminomethyl) Cyclohexane], 

negative SHE transformation assay(NICNAS)

Mutagenicity Negative, based on [1,3-Bis(Aminomethyl) Cyclohexane], 

negative Ames assay(NICNAS)

Systemic Effects

Low, based on [1,3-Bis(Aminomethyl) Cyclohexane], 

NOAEL of 250 mg/kg-day, LOAEL of 1000 mg/kg-day, 

spleen effects, in rats dosed by diet, subchronic study 

(NICNAS)

Overall Human Health Non-Cancer Hazard Concern Low

CANCER HEALTH EFFECTS:

Experimental data No data, but properties suggest low concern

OncoLogic Results No SAR for OncoLogic Evaluation 

Overall Human Carcinogenicity Hazard Concern Low
6

Record ID: [ ] 024 Submitter: [ ] 

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Manufacture Number of Sites 1

Location [PPG Oak Creek Facility] Operating Days Per Year 50

INDUSTRIAL RELEASE SUMMARY:

Media Daily Release 

(kg/site-day)

Release Days 

per Year

No. of Sites 

of Release

Total Annual Releases 

(kg/year -all sites)

Release Site Information

and Control Efficiency

Incineration of 

cleaning 

residuals and 

spent filter 

media

97 50 1 4,850 Incineration; 99+% efficient

OCCUPATIONAL EXPOSURE SUMMARY:

Route Dose Rate Days/yr No. Workers Cancer LADD Chronic ADD Acute APDR

Dermal 1,760 mg/day 50 2 2.0 mg/kg-day 3.5 mg/kg-day 25 mg/kg-day

Inhalation N/A

Total number of Workers – All Sites

GENERAL POPULATION EXPOSURE SUMMARY:

Cancer LADDpot Chronic ADDpot Acute ADRpot

Drinking Water

Fish Ingestion

Fugitive Emissions

Incineration Emissions 0 mg/kg-day 

(VP <10-6 mm Hg cut-off)

0 mg/kg-day 

(VP <10-6 mm Hg cut-off)

0 mg/kg-day 

(VP <10-6 mm Hg cut-off)

Landfill Leaching

Dermal – Consumer Use

Inhalation – Consumer Use
7

Record ID: [ ] 024 Submitter: [ ] 

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Manufacture Number of Sites 1

Location [ ] Oak Creek Facility]] Operating Days Per Year 50

AQUATIC RISK ASSESSMENT

Acute Profile

Endpoint Effect Level 

(ppb)

Assessment

Factor

Acute COC 

(ppb) PEC (ppb) Potential for Risk?

Fish 810 5 160 0 Low

Daphnid 140 5 28 0 Low

Green Algae 56 4 14 0 Low

Chronic 

Profile Endpoint Effect Level (ppb)

Assessment

Factor

Chronic COC 

(ppb)

PEC 

(ppb)

Days of 

Exceedence

Potential 

for Risk?

Fish 16 10 2 0 0 Low

Daphnid 16 10 2 0 0 Low

Green Algae 24 10 2 0 0 Low

HUMAN HEALTH RISK ASSESSMENT

Hazard Concern NOAEL/ LOAEL

(mg/kg-d)

Exposure Dose and 

Source (mg/kg-d)

MOE Potential 

for Risk?

Occupational 

Risk

N/A – Low Hazard Low

General 

Population Risk

N/A – Low Hazard Low

AQUATIC RISK ASSESSMENT SUMMARY

Lowest Acute COC – Aquatic Exposure 14 ppb

Lowest Chronic COC – Aquatic Exposure 2 ppb

Predicted Environmental Concentration (PEC) 0

PEC Exceeds Chronic COC (days / year) 0

HEALTH RISK ASSESSMENT SUMMARY

MOE – Acute Occupational Exposure N/A – Low Hazard

MOE – Chronic Occupational Exposure N/A – Low Hazard

MOE – Acute General Population Exposure N/A – Low Hazard

MOE – Chronic General Population Exposure N/A – Low Hazard
8

Record ID: [ ] 024 Submitter: [PPG Industries, Inc.]

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Processing Number of Sites 1

Location [PPG Oak Creek Facility] Operating Days Per Year 109

INDUSTRIAL RELEASE SUMMARY:

Media Daily Release 

(kg/site-day)

Release Days 

per Year

No. of Sites 

of Release

Total Annual Releases 

(kg/year -all sites)

Release Site Information 

and Control Efficiency

Incineration –

equipment 

cleaning and 

filter residuals 

are incinerated

45 109 1 4,860 Incineration; 99+% efficient

Drums -

residuals are 

solidified and 

sent to landfill

133 109 1 14,550 Landfill; negligible potential 

for groundwater migration

OCCUPATIONAL EXPOSURE SUMMARY:

Route Dose Rate Days/yr No. Workers Cancer LADD Chronic ADD Acute APDR

Dermal 1,760 mg/day 50 2 4.3 mg/kg-day 7.5 mg/kg-day 25 mg/kg-day

Inhalation N/A

Total number of Workers – All Sites 6

GENERAL POPULATION EXPOSURE SUMMARY:

Cancer LADDpot Chronic ADDpot Acute ADRpot

Drinking Water

Fish Ingestion

Fugitive Emissions

Incineration Emissions 0 mg/kg-day 

(VP <10-6 mm Hg cut-off)

0 mg/kg-day 

(VP <10-6 mm Hg cut-off)

0 mg/kg-day 

(VP <10-6 mm Hg cut-off)

Landfill Leaching

0 mg/kg-day 

(Negligible migration 

potential)

0 mg/kg-day 

(Negligible migration 

potential)

0 mg/kg-day 

(Negligible migration 

potential)

Dermal – Consumer Use

Inhalation – Consumer Use
9

Record ID: [ ] 024 Submitter: [ ] 

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Processing Number of Sites 1

Location [ Oak Creek Facility] Operating Days Per Year 109

AQUATIC RISK ASSESSMENT

Acute Profile

Endpoint Effect Level 

(ppb)

Assessment

Factor

Acute COC 

(ppb) PEC (ppb) Potential for Risk?

Fish 810 5 160 0 Low

Daphnid 140 5 28 0 Low

Green Algae 56 4 14 0 Low

Chronic 

Profile Endpoint Effect Level (ppb)

Assessment

Factor

Chronic COC 

(ppb)

PEC 

(ppb)

Days of 

Exceedence

Potential 

for Risk?

Fish 16 10 2 0 0 Low

Daphnid 16 10 2 0 0 Low

Green Algae 24 10 2 0 0 Low

HUMAN HEALTH RISK ASSESSMENT

Hazard Concern NOAEL/ LOAEL

(mg/kg-d)

Exposure Dose and 

Source (mg/kg-d)

MOE Potential 

for Risk?

Occupational 

Risk

N/A – Low Hazard Low

General 

Population Risk

N/A – Low Hazard Low

AQUATIC RISK ASSESSMENT SUMMARY

Lowest Acute COC – Aquatic Exposure 14 ppb

Lowest Chronic COC – Aquatic Exposure 2 ppb

Predicted Environmental Concentration (PEC) 0

PEC Exceeds Chronic COC (days / year) 0

HEALTH RISK ASSESSMENT SUMMARY

MOE – Acute Occupational Exposure N/A – Low Hazard

MOE – Chronic Occupational Exposure N/A – Low Hazard

MOE – Acute General Population Exposure N/A – Low Hazard

MOE – Chronic General Population Exposure N/A – Low Hazard
10

Record ID: [ ] 024 Submitter: [ ] 

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Use Number of Sites 2

Location [Automobile OEM Sites] Operating Days Per Year 250

INDUSTRIAL RELEASE SUMMARY:

Media Daily Release 

(kg/site-day)

Release Days 

per Year

No. of Sites 

of Release

Total Annual Releases 

(kg/year -all sites)

Release Site Information 

and Control Efficiency

Landfill – all 

releases are 

solidified and 

sent to landfill

N/A N/A 2 150,000 Landfill; negligible potential 

for groundwater migration

OCCUPATIONAL EXPOSURE SUMMARY:

Route Dose Rate Days/yr No. Workers Cancer LADD Chronic ADD Acute APDR

Dermal 1,990 mg/day 50 34 11 mg/kg-day 19 mg/kg-day 28 mg/kg-day

Inhalation 21 mg/day 250 34 0.12 mg/kg-day 0.21 mg/kg-day 0.30 mg/kg-day

Total number of Workers – All Sites

GENERAL POPULATION EXPOSURE SUMMARY:

Cancer LADDpot Chronic ADDpot Acute ADRpot

Drinking Water

Fish Ingestion

Fugitive Emissions

Incineration Emissions

Landfill Leaching

0 mg/kg-day 

(Negligible migration 

potential)

0 mg/kg-day 

(Negligible migration 

potential)

0 mg/kg-day 

(Negligible migration 

potential)

Dermal – Consumer Use

Inhalation – Consumer Use
11

Record ID: [ ] 024 Submitter: [ ] 

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Use Number of Sites 2

Location [Automobile OEM Sites] Operating Days Per Year 250

AQUATIC RISK ASSESSMENT

Acute Profile

Endpoint Effect Level 

(ppb)

Assessment

Factor

Acute COC 

(ppb) PEC (ppb) Potential for Risk?

Fish 810 5 160 0 Low

Daphnid 140 5 28 0 Low

Green Algae 56 4 14 0 Low

Chronic 

Profile Endpoint Effect Level (ppb)

Assessment

Factor

Chronic COC 

(ppb)

PEC 

(ppb)

Days of 

Exceedence

Potential 

for Risk?

Fish 16 10 2 0 0 Low

Daphnid 16 10 2 0 0 Low

Green Algae 24 10 2 0 0 Low

HUMAN HEALTH RISK ASSESSMENT

Hazard Concern NOAEL/ LOAEL

(mg/kg-d)

Exposure Dose and

Source (mg/kg-d)

MOE Potential 

for Risk?

Occupational 

Risk

N/A – Low Hazard Low

General 

Population Risk

N/A – Low Hazard Low

AQUATIC RISK ASSESSMENT SUMMARY

Lowest Acute COC – Aquatic Exposure 14 ppb

Lowest Chronic COC – Aquatic Exposure 2 ppb

Predicted Environmental Concentration (PEC) 0

PEC Exceeds Chronic COC (days / year) 0

HEALTH RISK ASSESSMENT SUMMARY

MOE – Acute Occupational Exposure N/A – Low Hazard

MOE – Chronic Occupational Exposure N/A – Low Hazard

MOE – Acute General Population Exposure N/A – Low Hazard

MOE – Chronic General Population Exposure N/A – Low Hazard
Record ID: [ ]024 Submitter: [ ] 

12

SUMMARY CONCLUSIONS:

Occupational Risk:

Risk of Non-Cancer Acute Effects from Occupational Exposure: Low based on low hazard

Risk of Non-Cancer Chronic Effects from Occupational Exposure: Low based on low hazard

Risk of Cancer Effects from Occupational Exposure: Low based on low hazard

General Population Risk:

Risk of Non-Cancer Acute Effects to General Population: Low based on low hazard and lack of exposure

Risk of Non-Cancer Chronic Effects to General Population: Low based on low hazard and lack of exposure

Risk of Cancer Effects to General Population: Low based on low hazard and lack of exposure

Aquatic Risk:

Acute Risk to the Aquatic Environment: Low based on lack of exposure

Chronic Risk to the Aquatic Environment: Low based on lack of exposure

Representative Structure and Assessment Strategy

[ ] 024 represents a consolidated submission for a UVCB product mixture. This substance is made by reaction of 

an acrylate or succinate ester with a cyclic diamino backbone. There are two diamines used for the reaction, [ 1,3-

Cyclohexanedimethanamine (CAS RN 2579-20-6) and Cyclohexanemethanamine, 5-amino-1,3,3-trimethyl- (CAS RN

2855-13-2),] the substituent groups include various acrylates as well as [butyl maleate]. The resulting product is a 

mixture of these substituents on the diamine backbone. Physical property assessment will be based on an the 

reaction product of [CAS RN 2579-20-6 with two equivalents of butyl acrylate], this representative structure is well 

represented in the mixture and will have properties approximately in the median for these substances. The 

ecotoxicity assessment is also based on this structure, which was shown to have significant ecotoxicity effects, 

without a predicted log Kow that would result in no effects at saturation (NES). The structure and SMILES for this 

representative structure are shown above. The human health assessment is based primarily on the based on the 

data available for the diamine starting materials.

Physical/Chemical Properties

[ ] 024 is a mixed substance. No measured physical chemical property data were available for the substance, and 

the physical chemical property assessment is based on the representative structure as discussed above. The 

substance is a liquid in the mixed state. The [ ] 024 representative structure is predicted to be a high boiling solid 

at room temperature, with a melting point of 135 °C and boiling point of >400 °C at atmospheric pressure. The 

substance is expected to be minimally volatile with a vapor pressure of 7.5 x 10-8 mm Hg at room temperature. The 

[ ] 024 representative structure is predicted to be hydrophobic, with a water solubility of 1.7 mg/L and log Kow of 

5.0. These values are expected to be representative or worst case when compared to the mixture as a whole. 

Bioconcentration factor

[ ] 024 is a mixed substance and evaluation is based on the representative structure as discussed above. The EPI 

Suite predicted bioconcentration factor (BCF) for the substance is 40 based on the regression method and the 

bioaccumulation factor (BAF) is 141 based on the Arnot-Gobas method. Both of these values are indicative of a low 

concern level. If a numeric value is required, the BAF value of 141 from the Arnot-Gobas method will be used.
Record ID: [ ]024 Submitter: [ ] 

13

Environmental Fate

[ ] 024 is a UVCB substance containing multiple components, environmental fate assessment will be based on the 

representative structure, with exceptions noted in the text. If released to surface water, [ ] 024 is predicted to 

have >90% removal during wastewater treatment. Since the estimated value is >90%, a high-end input of 90% POTW 

removal will be used for E-FAST or other exposure modeling if required. [ ] 024 is expected to exist solely as a 

particulate in the atmosphere (air) and will not volatilize from dry surfaces at an appreciable rate. [ ] 024, based 

on the representative structure, is predicted to have is predicted to have moderate to high sorption to soil; however, 

the material contains secondary amines which may be protonated in the environment. This would reduce the rate of 

migration to groundwater and, based on this, there is a low overall potential for migration to groundwater. The 

Henry’s Law Constants estimated for the representative structure is <10-8 atm-m3/mol, which indicates negligible 

volatilization from water. Based on this, the half0life for volatilization from the model lake or river has been 

estimated to be >1 year. Based on the above considerations and expected environmental release patterns, BAC007 

is predicted to partition primarily to soil and sediments in the environment.

[ ] 024 is predicted to partition mainly to soil and sediment and degradation in these media will be most relevant 

to the overall persistence of the chemical. The substance is a stable organic molecule and will not pyrolyze or 

spontaneously degrade. [ ] 024 contains both ester groups, which may be susceptible to hydrolysis; however, EPI 

suite estimates that hydrolysis will be slow, with a half-life of 80 days at pH 8 and >1 yea at pH 7. The chemical will 

not partition to the atmosphere to a significant extent and atmospheric oxidation is not expected to be a major route 

of degradation. Due to partitioning and stability, the main route of environmental removal of the chemical is 

expected to be biodegradation. EPI Suite predicts [ ] 024 representative structure will biodegrade fast in the 

environment, with a half-life for primary degradation of hours to days and half-life for ultimate degradation of weeks. 

The substance is also predicted to be Ready Biodegradable in the Japanese MITI test. However, [ ] 024 is 

predicted to bind strongly to soil and sediment, partitioning mainly to those media, and have poor water solubility. 

These factors may significantly reduce the potential rate of environmental degradation for the substance; in 

particular the portion bound to sediment may have significantly decreased biodegradation. Further, the mixture will 

contain larger structures in addition to the representative structure used for EPI Suite evaluation, which will be more 

resistant to degradation. Based on these factors, [ ] 024 is predicted to have a moderate rate of biodegradation 

and moderate overall concern for persistence, with a half-life of between 60 and 180 days.

Overall, [ ] 024 is expected to partition mainly to soil and sediment, where it will have a moderate concern for 

persistence.

Aquatic Hazard

No measured ecotoxicity data were available for [ ] 024 and ECOSAR evaluation of the representative structure 

was used to establish the aquatic toxicity hazards for the compound; after evaluation of multiple structures, this 

structure was found to pose the highest potential hazard, without the predicted log Kow indicated the potential for 

no effects at saturation (NES). The Aliphatic Amines and Esters ECOSAR classes of compounds were identified by the 

software for evaluation of the substance. Acute and chronic endpoints were estimated for all species (fish, daphnid, 

and green algae). In each case the Aliphatic Amines class was found to represent the highest level of toxicity and was 

used in the aquatic toxicity profiles for the [ ] 024. All three of the acute endpoints are estimated to be <1 mg/L

and chronic endpoints estimated to be <0.1 mg/L, which is indicative of a high hazard concern for aquatic effects. 

The ECOSAR class and predicted endpoints used in the [ ] 024 aquatic toxicity hazard assessment are available in 

the table above.

Overall, based on evaluation of the representative structure, [ ] 024 is predicted to pose a high hazard concern 

level for aquatic toxicity.
Record ID: [ ]024 Submitter: [ ] 

14

Human Health Non-Cancer Hazard

Toxicology data were not available for [ ] 024. Therefore, this assessment will be based on the parent compound,

{ ]. 

[ ] 024 is predicted to have low to moderate acute toxicity based on [1,3-Bis(Aminomethyl) cyclohexane] The oral 

LD50 is estimated as being between 200 mg/kg and 2000 mg/kg based on a range finding study in rats that found no 

deaths at 200 mg/kg and 100 lethality at 2000 mg/kg. The dermal LD50 was estimated at 1750 mg/kg in rabbits 

(NICNAS).

[1,3-Bis(Aminomethyl) cyclohexane] was found to be corrosive and irritating to rabbit skin in a Draize test in rabbits 

(NICNAS). Based on this, [ ] 024 is a likely skin and eye irritant. [1,3-Bis(Aminomethyl) cyclohexane] was studied 

in a guinea pig maximization test and was found not sensitizing. 

There are no data for neurological, immunological, reproductive or developmental effects of [1,3-Bis(Aminomethyl) 

cyclohexane]. However, a repeat-dose study with a highest dose of 1000 mg/kg-day found only a reduction of food 

consumption, reduced weight, and changes in weight of the brain, spleen, and liver in the highest dosed group and 

established a NOAEL of 250 mg/kg-day (NICNAS). Based on the lack of overt toxicity in the high-dose group, there is 

minimal potential for organic specific toxicity.

[1,3-Bis(Aminomethyl) cyclohexane] was tested in an Ames assay with and without activation and was found not to 

be mutagenic, and found not to be genotoxic in an SHE assay (NICNAS). Based on this, [ ] 024 is predicted to be 

neither genotoxic nor mutagenic.

In a subchronic study of rats dosed up to 1000 mg/kg-day with [1,3-Bis(Aminomethyl) cyclohexane], only the high 

dose group experienced any significant alterations in clinical parameters. Based on the reduced weight and small but 

statistically significant differences in the weight of the brain, spleen, and liver, the NOAEL was established at 250 

mg/kg-day and the LOAEL of 1000 mg/kg-day (NICNAS). Based on [1,3-Bis(Aminomethyl) cyclohexane], [ ] 024 has 

low concern for systemic toxicity.

Overall, [ ] 024 has a low overall human health hazard.

Human Health Cancer Hazard

There are no cancer studies available either for [ ] 024 or 1,3-Bis(Aminomethyl) cyclohexane. However, [ ] 024 

is not believed to be either a mutagen or genotoxic and additional properties such as hydrophobicity and low water 

solubility suggest low cancer hazard concern. In addition, there is no SAR for OncoLogic evaluation of [ ] 024 or 

the representative structure. Based on the data available and properties, [ ] 024 is not expected to pose a 

concern for cancer hazard.

Based on this, the overall cancer hazard is predicted to be low.
Record ID: [ ]024 Submitter: [ ] 

15

Release and Exposure Sources 

[ [ ] 024 is a one part of a two component system for truck bed coatings.] There are three operations associated 

with [ ] 024 that are the subject of the PMN and this assessment; Manufacture, Processing and Use. [ ] 024

has been predicted to have >90% removal via POTW, BCF of 141, and negligible potential for groundwater migration 

from landfills based on the size and other properties of the substance. Substances with vapor pressures below this 

level are generally not considered a concern for occupation or general population vapor exposure. In some cases, 

exposure to mists, dusts, or other particulates may occur; in the case of [ ] 024, exposure to mists during use may 

occur and has been modeled. Occupation dermal exposure from transfer and cleaning operations, as well as 

potential inhalation exposure from mists has been modeled for the use of [ ] 024. All cleaning residuals

associated with [ ] 024 are collected and either incinerated or solidified and disposed of in landfills and, due to

the low vapor pressure and negligible groundwater migratory potential, no general population exposure has been 

predicted from the modeled Manufacture, Processing, or Use operations.

[ ] 024 is manufactured as a 100% pure liquid (by definition as a UVCB) packaged into drums for transport and 

storage to processing. At the processing site, the material is formulated into the coating product at approximately 

23% by weight. The sites at which [ ] 024 will be manufactured and processed are controlled by [ ] 

Industries, Inc. [ ] maintains “zero discharge” at these facilities and all cleaning residuals are recycled into the 

process, sent to approved landfills, or incinerated. Based on these considerations, no releases to surface water or 

other routes leading to general population exposure from manufacture have been estimated for [ ] 024.

The Use operation will occur at two identified customer sites not controlled by [ ] . [ ] 024, as received, is 

pumped directly into the use process, where it is mixed with the second component of the coating and used directly. 

It should be noted that once the substance has been mixed with the second component of the resin an irreversible 

curing process will begin which occurs at room temperature, which will effectively destroy the [ ] 024. The use of 

[ ] 024 was modeled using the [Automobile OEM Spray Coating operation in] ChemSTEER. This pre-set operation 

estimates occupational release and exposures directly for the operation. The transfer efficiency of this process has 

been adjusted to 65% to account for increased transfer efficiency from the default scenario. However, as noted in 

the PMN, all liquid residuals are collected, solidified and sent for disposal in an approved landfill and no release to 

surface water will occur as a result of use. 

Predicted releases, occupational, general population, and aquatic environmental exposure from operations modeled 

for [ ] 024 are listed on the pages above.
Record ID: [ ]024 Submitter: [ ] 

16

Environmental (Aquatic) Risk Assessment

Assessment of aquatic risk is based on comparison of the concentration of the chemical in the environment, referred 

to as the predicted environmental concentration (PEC), to any acute and/or chronic concentrations of concern (COCs) 

established for the chemical. Acute risk potential is determined by direct comparison of the PEC to an acute COC, 

with the potential for risk being indicated if the PEC is larger than the acute COC. Chronic risk is determined both by 

comparison of the PEC to the chronic COC, similar to the acute risk assessment, and by E-FAST estimation of the 

number of days the PEC will exceed the chronic COC, with risk potential indicated if the PEC exceeds the chronic COC 

for 20 days or more.

Risk is a function of hazard and exposure. In the case of [ ] 024, the chemical is estimated to pose a high 

ecotoxicity hazard based evaluation of the representative structure; however, the information in the PMN and 

subsequent exposure modeling indicate that no release to water will occur. Based on this, there is no potential for 

environmental exposure and the overall risk is predicted to be low.

Overall, based on lack of exposure, [ ] 024 is expected to pose a low potential for risk to the aquatic environment.

Human Health Risk Assessment

Human health risk potential is established by comparison of the potential health effect levels to the occupational and 

general population dose rates estimated for the chemical. The health effect is divided by the largest dose rate for 

either occupational or general population exposure to give a margin of exposure (MOE). Acute risk is only evaluated 

if the acute LD50 is found to be <50 mg/kg. Chronic risk is evaluated for each effect level identified in the human 

health hazard assessment that has a moderate or greater hazard concern. The magnitude of the MOE determines if 

the potential for risk exists; when based on a LOAEL (lowest observed adverse effect level) a MOE of <1,000 indicates 

the potential for human health risk exists, and when based on a NOAEL (no observed adverse effect level) a MOE of 

<100 indicates the potential for risk exists.

Risk is a function of hazard and exposure; if the hazard concern level is low, then the risk will generally also be low. [ 

] 024 has been predicted to have an overall human health cancer and non-concern hazard concern level of low. 

Based on this, the potential for risk to human health from exposure to the substance is also predicted to be low.

Overall, based on low hazard concerns predicted for the substance, [ ] 024 is expected to pose a low potential for 

risk human health.
Record ID: [ ]024 Submitter: [ ] 

17

Table I – Analog Structures

Name CAS RN Structure

References

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