### Attachment **19 –**  **Sustainable Futures P2 Assessment for [ ]**  **02 4** 

This chemical is the subject of a P2 Assessment for participation in the Sustainable Futures tm Initiative. The P2 assessment of [ ] 024 directly follows this cover letter. This sum mary includes the collection of results, assessment methods, and conclusions from the Sustainable Futures tm P2 Framework evaluation of this substance. T he 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 materi als believed to be indicative of the mixture as a whole. Details on representative structure selection and assessment methods are available in the summaries below. [ ] 02 4 is predicted to have a moderate overall concern for persistence. T he subst ance 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 co ncern for aquatic toxicity
. [ ] 02 4 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 [ ] 02 4 aquatic risk assessm ent 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 [ ] 02 4 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 w hen determining exposure and risk
. T he [ ] MSDS, which is included with the PMN , indicates that workers should wear gloves and use other personal protective measures when handling [ ] 02 4 or when exposure may occur. In addition, the PMN an d 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 th e 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:** 0 6/0 7/2012 This document was developed to help compile estimation results from U.S. EPA OPPT’s P2 Fram ework Models and is used by O PPT during Sustainable Futures (SF) training described on the US EPS Sustainable Futures hom epage 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 repre sentative 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:** Multipl e **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 i n PBT Profiler

**Overall Hazard Concern Human Health Hazard:**  Low **Aquatic Hazard:** High **Overall Risk Human Health Risk:**  Low **Aquatic Risk:** Low4 **Record ID:** [ ] 024 **Submitter:** [ PPG Industries, Inc. **] PHYSICAL/CHEMICAL PROPERTIES:**  **Melting Point (de g 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 struct ure] (WSKOW; EPI) **Log K ow**  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 K** **oc** Low potential for migratio n 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 str ucture] (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) **Remo val 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 LC**  **5O** 0.81 mg/L [Aliphatic amines] (ECOSAR) **Daphnid LC 5O**  0.14 mg/L [Aliphatic amines] (ECOSAR) **Green Algae EC 5O**  0.056 mg/L [Aliphatic amines] (ECOSAR) **Chronic Toxicity Fish ChV**  0.016 mg/L [Aliphatic amines] (ECOSAR) **Daphnid ChV** 0.016 mg/L [Al iphatic 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) ] . LD 50 >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** Inadequ ate 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 transformati on 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 Carcinog enicity Hazard Concern**  Low6 **Record ID:** [ ] 024 **Submitter:** [ ] **INDUSTRIAL OPERATIONS INFORMATION :**  **Operation Name** Manufacture **Number of S ites**  1 **Location** [ PPG Oak Creek Facility] **Operating Days Per Year** 50 **INDUSTRIA L 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 I**  **nformation 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 W orkers**  **– 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 c ut-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**  Manufactu re **Number of Sites** 1 **Location** [ ] Oak Creek Facility] ] **Operating Days Per Year** 50 **AQUATIC RISK ASSESSMENT Acute Profile**  **E ndpoint**  **Effect Level (ppb)**  **Assess ment** 

**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**  **E ndpoint**  **Effect Level (ppb)**  **Assess ment** 

**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

**HU MAN 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**  **ASSESSMEN T**  **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 Hazard8 **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 Relea se**  **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 (V P <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] **Operati ng Days Per Year**  109 **AQUATIC RISK ASSESSMENT Acute Profile**  **E ndpoint**  **Effect Level (ppb)**  **Assess ment** 

**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**  **E ndpoint**  **Effect Level (ppb)**  **Assess ment** 

**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) Ex** **posure 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 Hazard10 **Record ID:** [ ] 024 **Submitter:** [ ] **INDUSTRIAL OPERATIONS INFORMATION: Operation Name**  Use **Number of Si tes**  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 Contr ol 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**  **Ac ute 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 Yea r**  250 **AQUATIC RISK ASSESSMENT Acute Profile**  **E ndpoint**  **Effect Level (ppb)**  **Assess ment** 

**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**  **E ndpoint**  **Effect Level (p**  **pb) Assess**  **ment**

**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 E xposure**  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 Gen eral 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 Chroni c 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. T his substance is made by reaction of an ac rylate or succinate ester with a cyclic diamino backbone. T here 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 sub stituent groups include various acrylates as well as [ butyl maleate ]
. T he resulting product is a mixture of these substituents on the diamine backbone. P hysical property assessment will be based on an the reaction product of [ CAS RN 2579
- 20
- 6 with two eq uivalents of butyl acrylate ] , this representative structure is well represented in the mixture and will have properties approximately in the median for these substances. T he ecotoxicity assessment is also based on this structure, which was shown to have s ignificant ecotoxicity effects, without a predicted log Kow that would result in no effects at saturation (NES). T he structure and SMILES for this representative structure are shown above. T he human health assessment is based primarily on the based on th e 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. T he 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. T he substance is expected to be minimally volatile with a vapor pressure of 7.5 x 10 -8 mm Hg at room temperature. T he [ ] 024 representative structure is predicted to be hydrophobic, with a wa ter 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. B oth 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 u sed 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
. T he Henry’s Law Constants estimated for the representative structure is <10
-8 atm - m3/mol, which indicates negligible volatilization from water. B ased on this, the half0life for volatilization from the model lake or river has been estimated to be >1 year . B ased 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. T he substance is a stable organic molecule and will not pyrolyze or spontaneously degrade. [ ] 0 24 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 atmosph eric oxidation is not expected to be a major route of degradation. D ue to partitioning and stability, the main route of environmental removal of the chemical is expected to be biodegradation. E PI Suite predicts [ ] 024 representative structure wil l 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. H owever, [ ] 024 is predicted to bind strongly to soil and sediment, partitioning mainly to those media, a nd have poor water solubility. These factors may significantly reduce the potential rate of environmental degradation for the substance; in particular the portion bou nd to sediment may have significantly decreased biodegradation. F urther, 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 w ill 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) . Th e Aliphatic Amines and Esters ECOSAR classes of compounds were id entified 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 us ed 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 a nd p redicted 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 aquati c 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 a t 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 establis hed 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) cyclo hexane ] , 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 25 0 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 can cer 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, t he overall cancer hazard is predicted to be low.**Record ID: [**  ]024 **Submitter: [ ]** 

15 **Release and Exposure Sources** [ [ ] 02 4 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. S ub stances with vapor pressures below this level are generally not considered a concern for occupation or general population vapor exposure. I n 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
. O ccupation dermal exposure from transfer and cleaning operations, as well as potential inhalation exposure from mists has been modeled for the use of [ ] 02 4. A ll 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 d rums for transport and storage to processing. At the processing site, the material is formulated into the coating product at ap proximately 23% by weight. The site s at which [ ] 02 4 will be manufactured and processed are cont rolled by [ ] Industries, Inc. [ ] maintains “zero discharge” at these facilities and a ll cleaning residuals are recycled into the pro cess, 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 [ ] 02 4
. 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 ha s 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 Coatin g 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 scen ario. H owever, 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 aqu atic 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, refe rred 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. C hronic 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 chro nic 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. I n 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. B ased on this, there is no potential for environmental exposure and the overall risk is predicted to be low. Overa ll, 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 occ upational and general population dose rates estimated for the chemical. T he 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 a cute LD 50 is found to be <50 mg/kg. C hronic risk is evaluated for each effect level identified in the human health hazard assessment that has a moderate or greater hazard concern. T he 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 fu nction of hazard and exposure; if the hazard concern level is low, then the risk will generally also be low. [ ] 024 has been predicted to h ave an overall human health cancer and non -concern hazard concern level of low. Based on this, the potentia l 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** (NICNAS) NATIONAL INDUSTRIAL CHEMICALS NOTIFICATION AND ASSESSMENT SCHEME FULL PUBLIC REPORT