SAT ReportPMN Number:P-13-0270SAT Date:2/20/2013Print Date:8/30/2013Related cases:Health related cases:Ecotox related cases:Concern levels:Type of Concern:HealthEcoCommentsLevel of Concern:13PersistenceBioaccumToxicityComments3 11Exposure Based Review:Health:NoEcotox:NoRoutes of exposure:Health:Low ConcernEcotox:All releases to waterFate:;P2Rec Comments:Comment:ForwardKeywords:Keywords:POSS IRR-EAQUATOX-A,CSummary of Assessment:Fate:Fate Summary:P-13-0270FATE:Solid with MP = 111 C (M)log Kow = 6.18 (M)S = 0.004 mg/L at 25 C (M)VP < 1.0E-6 torr at 25 C (M)BP = 418 C (may decompose) (M)H = 8.71E-8 (E)log Koc = 5317 (E)log Fish BCF = (3.75 E)log Fish BAF = 1.60 (E)POTW removal (%) = 90 via sorption; OECD 301F(Mano Resp): 11.5%/28d; OECD111(Hydrolysis): t1/2(pH4,7,9): >1yr/7.5d/<1d. ICB does not believe the PMN hydrolyzes at pH 7.Time for complete ultimate aerobic biodeg = wk-moSorption to soils/sediments = strong - v.strongPBT Potential: P3B1*CEB FATE: Migration to ground water = neglHealth:Health Summary:Absorption of the neat material is nil through the skin, but poor through the skin for thematerial in solution, while absorption is poor through the lung and GI tract, based on physical/chemical properties. Expect very poorester hydrolysis. There is possible concern for eye irritation based on submitted test data. However, overall no significant healthconcerns.Test Data:Submitted with the PMN:Negative in Salmonella with and without activation;Negative in E. coli with and without activation;Rat (F) acute (15D) oral (gavage) LD50 > 2000 mg/kg;Rat acute (15D) dermal LD50 > 2000 mg/kg;Mild eye irritant in male rabbits, cleared by 72 hours;Rat repeated dose (28D) oral (diet) toxicity NOAEL 1000 mg/kg, based on increased mean relative liver weights;Not a dermal irritant in male rabbits;Not a demal sensitizer in female mice;, up to 25% ai;Negative for estrogenic potential in immature female rats at 100 mg/kg (highest dose tested; 21D exposure)Ecotox:Test OrganismTest TypeTest End PointPredictedMeasuredCommentsfish96-hLC50**daphnid48-hLC50**experimental PMN datagreen algal96-hEC50**experimental PMN datafish_chronic value0.001daphnid_chronic value0.008 or *algal_chronic value0.01 or **experimental PMN dataSewage Sludge3-hEC50_Sewage Sludge_Chronic Value_Ecotox Values Comments:Predictions are based on SARs for esters; SAR chemical class = esters; MW 388; S = 0.004 mg/L (P);log Kow = 7.2 (EPI);pH7; effective concentrations based on 100% active ingredients and mean measured concentrations; hardness<180.0 mg/L as CaCO3; and TOC <2.0 mg/L;Ecotoxicity Data Results forThree acute aquatic toxicity tests and an earthworm toxicity test were conducted on P-13-0270. The 96-hour fish acute toxicity studywas conducted in theThe 48-hour aquaticinvertebrate, the 72-hour aquatic plants and the 8 week earthworm toxicity studies were conducted at the Toxicology &Environmental Research and Consulting Laboratory of Dow Chemical. All tests were reported to have been conducted under GLPconditions and followed either or a combination of acceptable OECD and EPA guidelines. The PMN substance water solubility wasreported to be 0.004 mg/L. Other submitted data included: white solid; MP = 111 C; BP = 418 C (this may be a decompositiontemperature; VP = 7.0E-9 torr; log Kow = 7.2 (from ECOSAR version 1.11); density = 1.21 g/cc; not flammable; hydrolysishalf-lives: > 1 year at pH 4, 7.5 days at pH 7 (ICB chemists do not believe this value), and < 1 day at pH 9 (OECD 111); and log Koc> 5.63 (OECD 121.A 96-hour acute toxicity test was conducted in Chinese rare minnow (Gobiocypris rarus) with P-13-0270 (99.9%purity) under staticconditions. This study was reported to follow OECD test guideline 203. The water solubility of the test substance was reported as0.00369 mg/L. Following a range-finding test, a single replicate of ten G. rarus was exposed to a dilution water control (dechlorinatedtap water), a solvent control (0.1 ml/L acetone) or the PMN substance at the nominal test concentration of 100 mg/L. Correspondinggeometric mean measured concentrations of 270 μg/L without centrifugation and 18 μg/L with centrifugation were determined byHPLC analysis (LOD = 5.00 μg/L). The test solution was prepared by adding a slurry of test substance with acetone (concentration of0.1 mL acetone/L) directly to 4 liters of test water in a 5-L glass vessel. The solution was allowed to stir with a magnetic stirrer for 72hours with the vortex height of approximately 1/5 of the solution. After stirring, the test solution (without removing insolublematerial) was used directly for testing. During the test, the measured contents of the test substance determined by HPLC analysis wasnot stable in test water since the solubility of the test substance in water is slight and dispersion of the insoluble fractions wasnon-homogeneous. The contents of the test substance in test solutions were between 129–1144 μg/L, with a measured geometricmean concentration of 270μg/L. At the same time, although most of the insoluble fractions in test solutions were removed aftercentrifugation (10000 rpm for 40 min), the contents of the test substance in test solutions were still not stable because of the residualinsoluble fractions with contents between 11.3–29.0 μg/L and a measured geometric mean concentration of 18 μg/L. Over thecourse of testing, temperature ranged from 22.8–23.6 ̊C,pH ranged from7.09–7.69 and dissolved oxygen ranged from 74.4–90.3%ASV. Dilution water hardness was 165 mg CaCO3/L. A loading rate of 0.5 g fish/L was calculated.No mortalities orabnormalities were observed during the study. The 96-hour LC50 was greater than a nominal test concentration of 100 mg/L(geometric mean measured concentration of non-centrifuged and centrifuged samples was 270 μg/L and 18 μg/L, respectively). Thetest substance was insoluble with materials present in the solution for both the non-centrifuged and centrifuged test solutions. The testwas not conducted on a standard OPPT fish species. The test was considered inadequate. In addition, the PMN substance was testedabove the reported measured water solubility of 0.004 mg/L.96-hour LC50 =NES96-hour NOEC =NESA 48-hour acute toxicity study was conducted in Daphnia magna with P-13-0270 (99.85±0.03%purity) under static conditions. Thisstudy was reported to follow OECD test guideline 202, US EPA FIFRA, 72-2, EPA 540/9-82-020, EEC Directive 92/69/EEC, PartC.2 and US EPA TSCA, 40 CFR 797.1300. The water solubility of the test substance was reported as 0.04 mg/L. Following arange-finding test, four replicates of five D. magna were exposed to a dilution water control or the PMN substance as a water solublefraction (WSF) at nominal test concentrations of 6.25, 12.5, 25.0, 50.0 or 100 mg/L. Corresponding mean measured concentrations of< LLQ (control), 0.000923, 0.00379, 0.0163, 0.0394 and 0.130 mg/L were determined via HPLC/ESI-MS/MS analysis (LOQ =0.000591 mg/L). The bulk test solution was prepared as a WAF at the highest nominal test concentration (100 mg/L). The testmaterial was weighed out (exact weight = 0.1000 g) directly into a tared scintillation vial. A volumetric flask was filled with one literof LDW, which was used to thoroughly rinse the contents of the scintillation vial into a 2-L Erlenmeyer flask. The water control wasprepared by pouring 1 L of dilution water into a 2000-mL Erlenmeyer flask. Both flasks were covered with parafilm and placed onseparate stir plates set to stir at approximately 350 rpm. After approximately 24 hours of stirring, ~ 250 mL of test solutionwas addedto 250-mL plastic bottles to be centrifuged (4 replicates of control and 2 replicates of the nominal 100 mg/L). The vials werecentrifuged at ~ 10,000 rpm for approximately 40 minutes. After centrifuging, the control solution was clear and colorless; thenominal 100 mg/L solution was clear and colorless with some small white particulate suspended. The high-dose stock solution wasdiluted with dilution water to create subsequent stock solution for all lower doses in 250-mL glass beakers at the appropriatenominaltest concentrations. All solutions were clear and colorless. Over the course of testing, temperature ranged from 20 - 21 ̊C,pH rangedfrom 7.3–7.6 and dissolved oxygen ranged from 8.3–9.2 mg/L. Dilution water hardness ranged from 56–60 mg CaCO3/L. Aloading rate of 250 daphnids/L was calculated. Measured concentrations ranged from 0.00747 to 0.0235% of nominal on day 0 and0.0171 and 0.243% of nominal at 48 hours. At test termination, immobility was observed in 10, 0, 0, 0, 0, and 5% of the daphnids inthe 0 (control), 0.000923, 0.00379, 0.0163, 0.0394 and 0.130 mg/L test levels, respectively. The 48-hour EC50 was greater thananominal test concentration of 100 mg/L (mean measured concentration of 0.130 mg/L). In addition, the PMN substance was testedabove the reported measured water solubility of 0.004 mg/L. The test was considered adequate48-hour EC50 =NES48-hour NOEC =NESA 72-hour limit test was conducted in green algae (Pseudokirchneriella subcapitata) with P-13-0270 (99.85±0.03%purity) under staticconditions. The study was reported to follow OECD test guideline 201 and EEC Directive 92/69/EEC, Part C.3. The reported watersolubility of the test substance is 0.003 mg/L. Six replicates of P. subcapitata (10,000 cells/mL) were exposed to an AAP mediumcontrol or the PMN substance at the nominal test concentration of 100 mg/L. Corresponding mean measured concentrations of <LOQ (control) and 0.00253 mg/L were determined via HPLC/ESI-MS/MS analysis (LOQ = 0.0000559 mg/L). An additionalreplicate for the AAP control and 100 mg/L treatment were prepared but not inoculated with algae to serve as a counting blank.Thealgae were illuminated with a light intensity within the range of 4440–5810 lux with constant shaking. Bulk test solutions wereprepared at nominal concentrations of 0 (water control; AAP) and 100 mg/L. After adding the test substance to the AAP media, theflask was covered with parafilm and left to stir for approximately 24 hours. Preliminary analysis showed that filtering with both 0.45and 0.22μm filters removed all of the test substance from the solution. Therefore, in an attempt to reduce the amount of suspendedparticles while maximizing exposure concentrations, solutions were centrifuged prior to use. Approximately 250 mL of each solutionwere added to polypropylene 250-mL bottles which were centrifuged for 45 minutes at approximately 10,000 rpm. Solutions werecarefully decanted into collection vessels which were sampled for analytical confirmation of dose. While centrifuging and decantingremoved much of the particulate matter, some small particulate matter was still visible suspended in the AAP. Therefore, testsolutions were shaken vigorously prior to dosing test vessels and prior to analytical sampling to make test solutions as homogenous aspossible. Test vessels were capped with foam stoppers. Over the course of testing, the temperature ranged from 22.1–23.8 ̊C and pHranged from 7.2–7.3. Measured concentrations were 0.00227% of nominal at 0 hours and 0.00152-0.00368% of nominal at 72 hours.The mean cell density in the control cultures increased by a factor of 184 within 72 hours. Test substance exposure did not have asignificant effect on biomass (p= 0.9094) or growth rate (p= 0.8651); therefore, the 72-hour EC50 and NOEC for both biomass andgrowth rate were > 0.00253 mg/L and 0.00253 mg/L, respectively, based on mean measured concentrations. The test was consideredadequate.72-hour EC50 (biomass and growth rate) =NES72-hour NOEC (biomass and growth rate) =NES72-hour LOEC (biomass and growth rate) =NESConclusion:The acute daphnia and the 72-hour algal tests are considered adquate. The acute fish test was considered inadequate. For comparativepurposes, based on SAR predictions for esters (ECOSAR version 1.11),the 96-hour fish LC50, 48-hour Daphnid EC50, and the96-hour algal EC50 were all NES. An earthworm study was submitted for P-13-0270 and appeared to follow standard OECD testguidelines, but will not be used to set the acute and chronic concentrations of concerns (CoCs).For comparative purposes, ECOSAR version 1.11 using SAR for esters predicted NES for base set aquatic acute values. The chronicfish predicted value was 0.001 mg/L. Chronic data were not submitted for the PMN substance. Based on the results of the acutestudies and the reported measured water solubility for each test, the acute CoC for P-13-0270 is NES. The chronic CoC is 0.001mg/L(1ppb) and was derived by dividing the predicted fish ChV (0.001 mg/L) by an assessment factor of 10.Acute CoC = *Chronic CoC = 1ppbFactorsValuesCommentsAssessment Factor10Concentration of Concern (ppb)1SARsEstersSAR ClassEstersEcotox CategoryEstersEcotox Factors Comments:SAT Chair:J. Kwiat