INITIAL REVIEW ENGINEERING REPORT 

Other New Chem:08-0006

Post Focus Draft 8/04/2008

ENGINEER: Arnold \ CLM

PV (kg/yr): Import Only

SUBMITTER: MORIMURA BROS (U.S.A.)

USE: High-friction agent for automotive brake pads.

SNUR: Find 56 FR 40204

(Aug. 13, 1991).

OTHER USES: 

Analog anode for lithium battery; Analog

 ion exchange material; 

 fuel cell material; 

 material for pencil leads.

MSDS: Yes Label: No

Gen Eqpt: Use local exhaust ventilation to control

airborne levels bellow the exposure guidelines. // Safety

glasses // Protective gloves.

Respirator: Recommend use of NIOSH/MSHA approved

respiratory protection against dust.

Health Effects: Prolonged inhalation of excessive

concentration of respirable fibers may cause deposition

of quantities of fibers in lungs sufficient to cause a

tissue response which could be associated with injury.

TLV/PEL:

none established

CRSS (07/07/2008):

Chemical Name: Potassium titanium oxide (K2Ti6O13)

S-H20: 1 g/L @

VP: 1.0E-6 torr @

MW: 573.60 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Solid (white powder) Mfg: NK: Imported Proc/Form:

Solid: in brake pad formulation End Use: Solid:

entrained in brake pad. The submitter has clarified by

phone that the substance will be imported into the U.S.

as , and will be fabricated into brake pads

in this country. Submitted Data: White powder; MP =

1347°C (Exp.); WS: < 0.1% (Exp.); insoluble in organic

solvents; pH = 8-10; specific gravity = 3.6 g/cm3;

electrical resistance = 3.3E15 .omega.-cm. Submitted:

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average particle size = 5.5 μm by laser light diffraction.

 Particle size analysis by scanning electron microscopy

shows an average diameter = 1.4 μm, average length = 6.2

μm, with ca. 15% of particles less than 0.8 μm in

diameter and shorter than 20 μm. Estimated Data: VP < 0.

000001 torr (Inorganic oxide). Cont'd on p.6.

Consumer Use: No

SAT (concerns) (07/08/2008):

Related Cases and Related Cases and Misc SAT Info:

RELATED CASES: 

 

Migration to groundwater: Negligible

PBT rating: P3B1T1 .

Health: 1-2 Inhalation

Eco: 1 No releases to Water

OCCUPATIONAL EXPOSURE RATING: 2-3A

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. This

PMN contains an element of concern--Titanium--for which

separate release estimates are provided for each activity.

The PMN is import-only; therefore, manufacturing is not assessed

although the submission provides detailed information on

manufacturing which occurs in Japan. Raw materials, titanium dioxide and potassium carbonate, are mixed in a 

vibration mill before they are calcined at 1100 C for 4 hours. The reaction product is cooled, forming lumps which are 

crushed and milled to obtain the commercial product, TOFIX-S, which is exported to the United States. 

According to information provided in an attachment to the PMN, S-08-0006 (trade name:TOFIX-S) is identified as 

dipotassium hexatitanate (K2O.6TiO2). There are fibrous and non-fibrous particles in the new chemical substance. 

About 9.8% are fibrous particles (aspect ratio >3). About 15% of the fibers are <0.8 ?m in diameter; no fibers are 

longer than 20 ?m.

Referenced three same use cases 

 assessed all releases to incineration because it

is the only required release estimate, and the PMN

contained an element of concern (consistent with this

IRER). estimated all releases to

landfill. All three past cases estimated exposures to

particulate from Unloading Solid Raw Material from

Transport Containers (consistent with this IRER).

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claims: Currently, needle-shaped fibers (e.g.

whiskers) of potassium titanium oxide (potassium

octatitanate) are used in automobile brake pads. In 2006,

 the World Health Organization (WHO) reviewed potential

health effects of potassium octatitanate fibers and

advised that respirable potassium octatitanate fibers are

likely to pose a high hazard to humans after inhalation

exposure. Because of the WHO advisory, "TOFIX-S" was

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developed to reduce and eventually eliminate such risks.

This product "TOFIX-S" is potassium hexatitanate and is

in the form of a powder or a stick shape, both of which

are different from potassium octatitanate fibers or

whiskers.

EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

Other New Chem:08-0006

Use: Molding of automotive brake pads

Number of Sites/ Location: 2

unknown sites

Days/yr: 200

Basis: Submission specifies 2 sites, 200 days/yr, and

Process Description: Import PMN 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium. This IRER conservatively presents all

releases to incineration due to presence of element of

concern. Other release media not required, per SAT (no

releases to water, negl. migration, and VP<0.01 torr).

--

Incineration

Output 2: 1.1E+0 kg/site-day over 200 days/yr from 2 sites

or 4.5E+2 kg/yr

to: incineration (submission)

from: Unloading Solid Raw Material from Transport

Containers

basis: User-Defined Loss Rate Model. CEB dust model

estimates 0.5% release to water, incin, air, or land from

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solids transfer activities. Note, submission estimates 0.

5 kg/day from unloading (CEB model is more conservative).

 Per submission, this release is to incineration

(consistent with a conservative assessment due to

presence of Ti).

Incineration

Output 2: 2.3E+0 kg/site-day over 200 days/yr from 2 sites

or 9.0E+2 kg/yr

to: incineration (worst-case)

from: Cleaning Solid/ Powder Residuals from Containers

Used to Transport the Raw Material

basis: EPA/OPPT Solid Residuals in Transport Containers

Model, CEB standard 1% residual.

Incineration

Output 2: 2.2E+0 kg/site-day over 200 days/yr from 2 sites

or 9.0E+2 kg/yr

to: incineration (worst-case)

from: Equipment Cleaning Losses of Solids from Process

Vessels

basis: EPA/OPPT Solid Residuals in Transport Containers

Model, CEB standard 1% residual.

RELEASE TOTAL

2.3E+3 kg/yr - all sites

Titanium element of concern:

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 6

Basis: Submission estimates 2 workers/site. Exposure

assessed at more conservative CEB default of 3

workers/site

Inhalation:

Exposure to Particulate (Class I)

Upper Bound: 1.5E+1 mg/day over 200 days/yr

Number of workers (all sites) with inhalation exposure: 6

Basis: Unloading Solid Raw Material from Transport

Containers; OSHA PNOR PEL-Limiting Model.

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

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 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Not required, per SAT.

CBI:

CALL BY:

Organization:

CALL TO:

Organization:

Date:

Time:

Phone:

-

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