CPSC Staff Preliminary Risk Assessment of ? 

Flame Retardant (FR) Chemicals in 

Upholstered Furniture Foam* 

December 21,2006 

Michael A. Babich, Ph.D. 

Directorate for Health Sciences 

U.S. Consumer Product Safety Commission 

Bethesda, MD 20814 

* A draft version of this report appeared in the~lanuary 2006 Briefing Package on Upholstered Furniture. 

This report was prepared by the CPSC staff; it has not been reviewed or approved by, and may not necessarily 

reflect the views of, the Commission. 
. . 

Contents 

... Summary ....................... .: .................................................................................................. ill 

Abbreviations ........................................................................................... ... ......................... v 

I . Introduction .......... ...............................

1 

A . Upholstered Furniture Cover Fabrics ............................................. ........... 1 

B . Upholstered Furniture Foam ............................... ; ..................................... 2 

C . Risk Assessment and the Federal Hazardous Substances Act .................... 3 

I1 . Hazard ...................................................................... i... ..................................... 5 

/ 

A . Tris(l,3.Dichloro. 2.Propyl) Phosphate (TDCP) ........................................ 5 

B . Aromatic Phosphate Plasticizers (APP) .................................................... 12 

C . Triphenyl Phosphate (TPP) ...................................................................... -16 

D . Phenol Isopropylated Phosphate (PIP) ..................................................... 21 

E . Octyl Tetrabromobenzoate (OTB) ............................................................ 24 

F . Melamine ..................................................... .'. ............................................ 24 

111 . Dose Response ............................................................................................... -27 

A . Tris(l,3.Dichloro. 2.Propyl) Phosphate (TDCP) ...................................... 27 

B . Triphenyl Phosphate (TPP) and Phenol Isopropylated Phosphate (PIP) .. 29 

C . Octyl Tetrabromobenzoate (OTB) ............................................................ 29 

D . Melamine ............. ... .................................................................................. 29 

IV . Exposure and Bioavailability .................................... : ..................................... 30 

A . Laboratory Studies .................................................................................... 30 

B . Calculations ............................................................................................ 1 

C . Input Parameters ....................................................................................... 35 

V . Risk ........................ : ............................................................................ : ......... 46 

A . Triscl,3.Dichloro. 2.Propyl) Phosphate (TDCP) ...................................... 46 

B . Triphenyl Phosphate (TPP) ....................................................................... 46 

C . Phenol Isopropylated Phosphate (PIP) ...................................................... 48 

D . Octyl ~etrabromobenzoate (OTB) .......................... ; ................................. 48 

E . Sensitivity Analysis ....................... ; ........................................................... 48 
VI . Discussion ......................................... ............................................................... 52 

A Toxicity . .................................................................................. i .............. 52 

B . Exposure ................................................................................................ 55 

C . Variabilityanduncertainty ................................. ................................. 59 

D . Conclusions ........................................................................................... 60 

VII .. References ........................................................................................................ -62 

Tables 

Figures 

Classification . of Chronic Hazards under the FHSA .......................................... 4 

Chronic Health Effects of selected Flame Retardant Chemicals ....................... 6 

Incidence of Selected Histopathological Effects in Sprague-Dawley Rats 

Exposed to TDCP in Feed ........................................................ : ......................... 9 

Tumor Incidence in Sprague-Dawley Rats Exposed to TDCP in Feed ........... 10 

General Input Parameters ................................................................................ -36 

Input Parameters for Estimating Dermal Exposure ......................................... 37 

Chemical-Specific Input Parameters ................................................................ 38 

Fraction of Test Substance Transferred from Textile to Skin .......................... 39 

Input Parameters for Estimating Oral Exposure .............................................. 40 

Input Parameters for Estimating Inhalation Exposure ..................................... 42 

Physico-Chemical Properties ........................................................................... 43 

Exposure and Risk ........................................................................................... 47 

Route-Specific Sensitivity Analysis ................................................................ 49 

Sensitivity of Cancer Risk to Selected Parameters .......................................... 50 

Sensitivity Analysis of Oral Exposure to Children .......................................... 51 

Effect of Vapor Pressure on TDCP Hazard Index and Cancer Risk ................ 58 

1 Structures . of FR chemicals ................................................................................ 3 

2 Metabolism . of tris(l,3.dichloro. 2.propyl)phosphate ........................................ 7 

3 Metabolism .. of o-tricresyl phosphate ............................................................... 13 

4 Mock-up for exposure studies . ................. : .................................................... 1 
Summary 

The U.S. Consumer Product Safety Commission (CPSC) staff developed a draft performance 

. standard to address the hazards associated with fires involving residential upholstered 

furniture. Manufacturers are likely to treat some products with flame retardant (FR) 

chemicals if the draft standard is adopted. The CPSC staff previously assessed the potential 

health risks associated with the use of FR chemicals in upholstered furniture cover fabrics. 

In this report, the CPSC staff presents a preliminary assessment of the potential health risks 

associated with the use of selected FR chemicals in upholstered furniture foam. FR-treated 

foam samples that were available to the CPSC staff for testing included those with three 

different FR chemicals or mixtures that could be used to meet the draft standard: melamine 

(108-78-1); tris(l,3-dichloro-2-propy1)phosphate (TDCP) (13674-87-8); and FiremasterTM 

550 (FM-550TM). FM-550TM is a mixture containing triphenyl phosphate (TPP) (1 145-86-6), 

phenol isopropylated phosphate (PIP) (68937-41-7), and octyl tetrabromobenzoate (OTB). 

Samples with the highest available TDCP or FM-550TM levels were included in the study. 

Numerous other FR treatments that could be used in foam have been discussed by the U.S. 

Environmental Protection Agency's (EPA' s) Design for the Environment Program. 

Q The toxicity of FR chemicals was assessed according to the Federal Hazardous Substances 

Act (FHSA), the supplemental definition of "toxic," and the CPSC chronic hazard guidelines. 

Although melamine has been studied in chronic bioassays, it does not satisfy the FHSA 

definition of toxic. Thus, exposure studies with melamine-treated foam were not necessary. 

Based on the available data, melamine-treated foam would not present a hazard to 

consumers. TDCP is considered a probable human carcinogen, based on sufficient evidence 

in animal studies. TDCP also induces non-cancer chronic health effects in animals. Little 

toxicity information on FM-550TM and its components is available. However, the CPSC staff 

has previously reviewed the toxicity of two FM-550TM components, TPP and PIP, as well as 

closely related compounds. No toxicity data were available for OTB. 

Mock-ups made with the foam samples were tested by the staff to assess the liquid-mediated 

migration of FR chemicals. These data were used to estimate dermal and oral exposures. 

The mock-ups were also subjected to an accelerated wear procedure to measure the release of 

airborne particles containing FR chemical. Two foam samples containing TDCP and one 

containing FM-550TM were tested. Measurements of migration and particle release from 

FM-550TM-treated foam were based on the OTB component. The other components were not 

measured. Exposure to vapor phase chemicals that may be emitted from the foam was 

assessed using a mathematical model. 

Based on the CPSC staff's analysis, it appears that inhalation of vapor phase FR chemical 

contributes the greatest portion of the total exposure. However, a mathematical model was 

used to estimate inhalation exposure due to the lack of empirical data. Thus, the estimated 

inhalation exposure is highly uncertain. Toxicity studies by the inhalation route are also 

lacking. Therefore, the following conclusions are based on limited exposure and/or toxicity 

data, and should be regarded as preliminary. 
Most of the predicted exposure to TDCP is from the inhalation of TDCP, which was 

estimated from a mathematical model. Regarding non-cancer health effects, estimated TDCP 

exposures were above the acceptable daily intake (ADI). The hazard index (HI) values were 

2 for adults and 5 for children. When the estimated exposure exceeds that AD1 a substance 

may be considered "hazardous," as defined in the CPSC chronic hazard guidelines and FHSA 

regulations. 16 CFR 1500.135 and 16 CFR 1500.3 (c)(2). The estimated cancer risk for a 

lifetime of exposure to TDCP-treated upholstered furniture was 300 per million. In children, 

the estimated cancer risk from exposure during the first two years of life alone was 20 per 

million. Both of these risks exceed one-in-a-million. A substance may be considered 

hazardous if the lifetime individual cancer risk exceeds one-in-a-million (ibid.). However, 

empirical measurements of TDCP emissions, which were not available for this study, are 

needed to assess more definitively whether TDCP may present a hazard to consumers. 

Limited toxicity data are available for TPP and PIP. Thus, the range of AD1 values for other 

aromatic phosphates or blends previously reviewed by the CPSC staff was used as a 

surrogate. Using these surrogate toxicity data, HI values for TPP were estimated to be 

between 0.002 and 0.2 in adults and between 0.005 and 0.5 in children. The HI'S for PIP 

were about 10-fold lower. If TPP and PIP are not more toxic than the other aromatic 

phosphates, then TPP and PIP are not expected to pose any appreciable health risk to 

consumers. The staff will review any additional toxicity data on TPP and PIP that may 

become available. Additional toxicity data and measurements of TPP and PIP emissions are 

needed to assess more definitively whether these compounds may present a hazard to 

consumers. Measurements of the TPP and PIP components of FM-550TM are needed to 

reduce the uncertainty in estimating exposure. The CPSC staff has requested the National 

Toxicology Program to perform additional toxicity tests on aromatic phosphates. 

Insufficient toxicity data on OTB, another component of FM-550TM, or related compounds 

were available to assess whether OTB could present a hazard to consumers. Basic toxicity 

data, physico-chemical data, and additional exposure data are needed to assess whether OTB 

may be hazardous to consumers. 

In summary, the staff concludes that: 

Based on the available data, melamine-treated foam is not expected to present a 

hazard to consumers. 

Inhalation studies are lacking for TDCP, TPP, PIP, and OTB. This is significant 

because inhalation appears to contribute the greatest portion of the total exposure. 

Empirical data on vapor phase emissions or indoor concentrations are needed to 

assess whether TDCP, TPP, PIP, or OTB may present a hazard to consumers. 

Chemical-specific migration and release data are needed to assess more accurately 

whether TPP and PIP may present a hazard to consumers. 

<Additional toxicity data are needed to derive AD1 values for TPP and PIP. 

Basic toxicity and physico-chemical data for OTB are needed to derive an acceptable 

daily intake value and to estimate exposure. 
Abbreviations 

ADD Average daily dose 

AD1 Acceptable daily intake 

AFSC American Fire Safety Council 

APP Aromatic phosphate plasticizer 

AT Antimony trioxide 

BMD Benchmark dose 

CAR Constitutively active receptor 

CPSC U.S. Consumer Product Safety Commission 

DBDPO Decabromodiphenyl oxide 

DfE Design for the Environment (U.S. EPA) 

ED50 Median effective dose 

EHDP 2-Ethylhexyl diphenyl phosphate 

EPA Environmental Protection Agency (U.S.) 

FHSA Federal Hazardous Substances Act 

FM-550TM FiremasterTM 550 

FR Flame retardant 

FRCA Fire Retardant Chemicals Association (currently AFSC) 

GD Gestational day 

HBCD Hexabromocyclododecane 

HI Hazard index 

Ic50 Concentration at 50% inhibition 

IDDP Isodecyl diphenyl phosphate 

PDP Isopropylphenyl diphenyl phosphate 

Kow Octanol-water partition coefficient 

LADD Lifetime average daily dose 

LD5o Median lethal dose 

LOAEL Lowest-observed-adverse-effect level 

MSDS Material safety data sheet 

NOAEL No-observed-adverse-effect level 

NRC National Research Council 

NTE Neurotoxic esterase 

NTP National Toxicology Program 

OPlDN Organophosphate induced delayed neurotoxicity 

OTB Octyl tetrabromobenzoate . 

PA Phosphonic acid, (3- { [hydroxymethyl]amino) -3-oxopropy1)-, dimethyl ester 

Penta-BDE Pentabromodiphenyl ether 

PIP Phenol isopropylated phosphate 

PUF Polyurethane foam 

PXR Pregnane X receptor 

RfD Reference dose 

SCE Sister chromatid exchange 

SD Sprague-Dawley 

SNUR Significant new use rule 
TCP 

TDCP 

THPC 

TPP 

TRIS 

UDS 

UF 

VCCEP 

Abbreviations (continued) 

' Tricresyl phosphate 

Tris(l,3-dichloro-2-propy1)phosphate 

Tetrakis(hydroxymethy1)phosphonium chloride 

Triphenyl phosphate 

Tris(2,3-dibromopropy1)phosphate 

Unscheduled DNA synthesis 

Uncertainty factor 

Voluntary Children's Chemical Evaluation Program 
I. INTRODUCTION 

Upholstered furniture fires account for more fire deaths than any other category of products 

under the jurisdiction of the U.S. Consumer Product Safety Commission (CPSC). The staff 

estimates that an annual average of 4,800 fires, 360 deaths, 740 injuries, and $133 million in 

property damage would be addressed if the draft standard is enacted (Levenson 2005). These 

fires are most commonly ignited by either smoldering sources, such as cigarettes, or open flame 

sources, such as cigarette lighters and candles. CPSC initiated a regulatory proceeding to 

address the hazard of small open flame ignitions of upholstered furniture (CPSC 2003). The 

CPSC staff has developed a draft performance standard to address the hazards associated with 

both small open flame and cigarette ignitions. 

I 

While furniture manufacturers would be free to choose the means of complying with the draft 

standard, it is likely that some products would be treated with flame retardant (FR) chemicals if 

the draft standard were adopted. In addressing the hazard associated with the flammability of 

upholstered furniture, the CPSC staff is working to develop a performance standard to reduce 

furniture fires without creating other hazards to consumers. Thus, the CPSC staff has been 

assessing the potential for health risks associated with the use of selected FR chemicals in 

upholstered furniture. The purpose of this report is to assess the potential health risks associated 

with the use of selected FR chemicals in upholstered furniture foam. 

A. Upholstered Furniture Cover Fabrics 

The first version of the draft flammability standard developed by the CPSC staff involved 

exposing the upholstered furniture cover fabric to a gas flame that was roughly equivalent to that 

of a cigarette lighter (CPSC 1997). As part of the risk assessment process for FR chemicals, the 

Commission held a public hearing in May 1998. In its testimony, the Fire Retardant Chemicals 

Association (FRCA) (currently the American Fire Safety Council, AFSC) reported that in many 

cases the furniture cover fabric would be treated with FR chemicals if the draft standard were 

adopted (Parkes 1998). The FRCA also provided a list of 16 chemicals or chemical classes that 

its members would market for use in upholstered furniture. 

The 16 FR chemicals and classes included over 50 individual compounds. The CPSC staff 

reviewed all the available toxicity data on these chemicals and derived acceptable daily intake 

(ADI) levels where sufficient data were available (Babich et al. 2004; Babich and Saltzman 

1999; Bittner 1999a-d; Bittner 2001; Bittner et al., 2001; Bittner and Ferrante, 1999; Ferrante 

1999a-f; Hatlelid 1999a-h). Overall, a considerable number of toxicological studies were 

available for review. While some FR chemicals have been well studied, only limited data were 

available for others. 

The CPSC staff performed quantitative risk assessments for five FR chemicals: antimony 

trioxide (AT) (CAS no. 1309-64-4); decabromodiphenyl oxide (DBDPO) (1 163- 19-5); 

hexabromocyclododecane (HBCD) (3 194-55-6); phosphonic acid, (3-{ [hydroxymethyl] amino) - 

3-oxopropy1)-, dimethyl ester (PA) (20120-33-6); and tetrakis (hydroxymethyl) phosphonium 

chloride (THPC) (124-64-1) (Babich and Thomas 2001). These FR's were selected for study 

because they are used to comply with the U.K. upholstered furniture flammability standard 
(except THPC) and fabric samples were available for testing. The staff concluded that DBDPO, 

HBCD, and PA would not present a hazard to consumers, and that additional data would be 

needed to assess AT and THPC. 

Prior to the completion of the CPSC staff risk assessment, the National Research Council (NRC) 

performed a risk assessment of 16 FR chemicals that might be used in upholstered furniture 

cover fabrics (NRC 2000). The NRC subcommittee, which had minimal exposure data available 

to them, selected the most toxic chemical to represent each of the same 16 chemicals or classes 

described by the FRCA. The NRC concluded that eight of these chemicals could be used 

without presenting a hazard to consumers, including DBDPO, HBCD, PA, and THPC. They 

also concluded that additional exposure or toxicity data were needed for the remaining 

chemicals, including AT, tris(l,3-dichloro-2-propyl) phosphate (TDCP), and aromatic phosphate 

plasticizers. Following the completion of the NRC report, the CPSC staff found that unidentified 

compounds were released from THPC-treated fabrics. Thus, the staff concluded that additional 

information on the identity and toxicity of the THPC by-products was needed. 

The CPSC staff is participating in several regulatory and voluntary programs of the U.S. 

Environmental Protection Agency (EPA) that involve the potential health and environmental 

effects of FR chemicals. EPA is developing a significant new use rule (SNUR) for FR chemicals 

that may be used in upholstered furniture. A SNUR requires manufacturers to notify EPA before 

engaging in activities subject to the SNUR. The SNUR process can be used to obtain additional 

toxicity or exposure data if needed. The EPA Design for the Environment (DfE) program is a 

cooperative effort with industry that is evaluating the potential health risks of FR chemicals that 

may be used in polyurethane foam (PUF). The EPA Voluntary Children's Chemical Evaluation 

Program (VCCEP) is investigating children's exposure to penta- and octa-bromodiphenyl ether 

and DBDPO. 

B. Upholstered Furniture Foam 

In 2003, the Commission amended the rulemaking activity for upholstered furniture to include 

smoldering ignition sources, such as cigarettes, and the staff revised the draft performance 

standard (CPSC 2003). Due to the changes in the draft flammability standard, fewer upholstery 

cover fabrics are likely to be treated with FR chemicals if the standard is adopted. Rather, in 

many cases the flexible PUF or other filling materials may require FR treatment to meet the draft 

standard. I 

Until recently, mixtures containing pentabromodiphenyl ether (penta-BDE) and aromatic 

phosphate esters were the principal FR chemicals for flexible PUF. However, the sole U.S. 

manufacturer of penta-BDE voluntarily ceased production in December 2004 due to concerns 

about environmental persistence and bioaccumulation. A number of alternative treatments are 

available, including several new proprietary formulations (reviewed in EPA 2005a). FR 

treatments that may be used in upholstered furniture foam include tris(l,3-dichloro-2-propyl) 

phosphate (TDCP) (13674-87-8), melamine (108-78-I), and a proprietary formulation marketed 

as FiremasterTM 550 (FM-550TM) (Figure 1). FM-550TM is a mixture containing triphenyl 

phosphate (TPP) (1 145-86-6), phenol isopropylated phosphate (PIP) (68937-41-7), and octyl 
tetrabromobenzoate (mixture of isomers) (OTB) (CAS no. not available) (EPA 2005a).* ' 

According to its material safety data sheet (MSDS) (Great Lakes 2005), FM-550TM contains , 

6-24% TPP, 24-51% PIP, and 40-60% OTB. Melamine may be blended with other FR7s, 

including TDCP. several other alternative FR chemicals for use in PUF are mixtures that 

include various aromatic phosphates. This report will assess the potential chronic health risks 

associated with the use of TDCP, FM-550TM, and melamine in upholstered furniture foam. 

CI-H2C\ CH2-CI 

c / 

I 

CI-H2C, ? C H2-C I 

c-,P-,< 

CI-H~C/ 0 II C H2-C I me!-+ 0 

TDCP TPP 

QXIy I**[-* 0 1 2 

PIP 

Br4w,-o-c,H,, 

NH2 

OTB Melamine 

Figure 1. Structures of FR Chemicals 

C. Risk Assessment and the Federal Hazardous Substances Act 

CPSC addresses chemical hazards under the Federal Hazardous Substances Act (FHSA). The 

FHSA is risk-based. To be considered a "hazardous substance" under the FHSA, a substance or 

product must satisfy a two-part definition. 15 USC 1261 (f)(l)(A). First, it must be "toxic" as 

defined under the FHSA, or present one of the other hazards enumerated in the statute. Second, 

it must have the potential to cause "substantial illness or injury" during or as a result of 

* Some of the abbreviations used in the January 2006 draft of this report were changed to reflect new information 

that more specifically identifies certain chemicals. BAE (brominated aryl ester) was changed to OTB (octyl 

tetrabromobenzoate) and ITP (isopropylated triphenyl phosphate) was changed to PIP (phenol isopropylated 

phosphate). 
"reasonably foreseeable handling or use." Therefore, exposure and risk must be considered in 

addition to toxicity when assessing potential hazards under the FHSA (CPSC, 1992). 

.The first step in the risk assessment process is hazard identification, that is, to review the 

available toxicity data for each chemical under consideration and determine whether the 

chemical is "toxic" under the FHSA. Acute toxicity is defined by LDS0 (median lethal dose) 

values in regulations issued under the FHSA. 16 CFR 1500.3 (c) (2) (i). However, reliable 

human experience data take precedence over animal data. 16 CFR 1500.4. In 1992, the 

Commission issued guidelines for assessing chronic hazards under the FHSA, including 

carcinogenicity, neurotoxicity, reproductive and developmental toxicity, exposure, 

bioavailability, risk assessment, and acceptable risk (CPSC, 1992; summarized at 16 CFR 

1500.135). A substance is considered "toxic" under the FHSA due to chronic toxicity if it is 

either known to be, or probably, toxic in humans. 16 CFR 1500.3 (c)(2)(ii). Under the FHSA, a 

substance or mixture is classified as "known to be toxic" in humans only if there is sufficient 

evidence in humans (Table 1). It is considered "probably toxic" if there is either limited 

evidence in humans or sufficient evidence in animals. 

Table 1. Classification of Chronic Hazards under the FHSA 

Satisfies the regulatory definition of "toxic." 

If a substance is "toxic" under the FHSA due to chronic toxicity, then a quantitative assessment 

of exposure and risk is performed to determine whether the chemical may be a "hazardous 

substance" under the FHSA. The quantitative risk assessment includes a consideration of dose 

response, bioavailability, and exposure. 

The acceptable daily intake (ADI) and/or cancer unit risk are derived from appropriate doseresponse information, and the exposure is estimated. If the estimated exposure exceeds the AD1 

or if the estimated cancer risk is greater than one-in-a-million then the substance may be 

considered a "hazardous substance" (CPSC 1992). 16 CFR 1500.3 (c)(2)(ii). 
11. HAZARD 

A. Tris(l,3-Dichloro-2-Propy1)Phosphate (TDCP) 

The toxicity of tris(l,3-dichloro-2-propy1)phosphate (TDCP) has been reviewed by the CPSC 

staff (Bittner et al. 2001; Ferrante 1999b; Ulsamer et al. 1980) and others (Brandwene 2001; 

EPA 2005a; IPCS 1998; NRC 2000). The toxicity of TDCP is summarized below (see Table 2). 

TDCP is a viscous liquid with molecular weight 430.9, log KO, 3.8, vapor pressure 0.01 ton, and 

low water solubility (reviewed in IPCS 1998). Oral LDso values ranged from 2.36 to 3.16 g/kg 

in rats and from 2.25 to 4.99 mL/kg in mice (reviewed in Ferrante 1999b). The symptoms 

associated with acute exposure included ataxia, irritability, hyperactivity, tetanus, and 

convulsions, suggesting neurological effects. TDCP was not a sensitizer in guinea pigs. It was 

either a non-imtant or mild irritant in the skin and eyes of rabbits (Stauffer 198 1). 

1. Genotoxicity 

TDCP was either inactive or weakly mutagenic in Salmonella strain TAlOO (Brusick et al. 1980; 

Gold et al. 1978; Nakamura et al. 1979; Prival et al. 1977; Soderlund et al. 1985; Stauffer 1981) 

and inactive in yeast (Stauffer 1981). Negative results that were reported in some studies 

(Brusick et al. 1980; Prival et al. 1977; Soderlund et al. 1985; Stauffer 1981) may be due to the 

method of metabolic activation (Brusick et al. 1980; Gold et al. 1978; Nakamura et al. 1979; 

Soderlund et al. 1985). The major urinary metabolite of TDCP, bis(l,3-dichloro-2-propyl) 

phosphate, was not mutagenic (Gold et al. 1978). However, another metabolite, 1,3-dichloro-2- 

propanol, was reported to be weakly mutagenic. In addition, the putative metabolite 1,3- 

dichloro-2-propanone was a strong direct-acting mutagen. TDCP was less mutagenic than the 

structural analog tris(2,3-dibromopropyl) phosphate (TRIS) (Brusick et al. 1980; Nakamura et al. 

1979). 

TDCP generally gave weak or negative results in mammalian systems. TDCP transformed 

Syrian hamster embryo cells (Soderlund et al. 1985), but not Balb 3T3 cells (Brusick et al. 1980; 

~tauffer 1981), in vitro. TDCP was weakly active in several in vitro assays, including the 

induction of forward mutations (thymidine kinase), sister chromatid exchanges, and 

chromosomal aberrations. TDCP did not induce 6-thioguanine resistance in V79 cells, nor did it 

induce unscheduled DNA synthesis in rat hepatocytes, although TRIS was active at similar doses 

(Soderlund et al. 1985). 

TDCP failed to induce chromosomal aberrations in mouse bone marrow cells in vivo (Brusick et 

al. 1980; Stauffer 1981). TDCP failed to induce unscheduled DNA synthesis in rat hepatocytes, 

following oral exposure at doses up to 2,000 mglkg (Cifone 2005), and did not induce 

micronuclei inmice (Thomas and Collier 1985). TDCP was reported to bind to DNA and 

proteins in mice exposed in vivo (Morales and Matthews 1980). 
Table 2. Chronic Health Effects of Selected Flame Retardant Chemicals a 

a Adapted from Bittner et al. 2001. 

Chronic toxicity as defined by the FHSA and the CPSC chronic hazard guidelines: A, known to be toxic in humans; B, probably toxic in humans; 

C, possibly toxic in humans; I, insufficient data. . 

Chronic endpoint(s): C, cancer; D, developmental; N, neurotoxic; R, reproductive; 0, other (e.g., liver or other organ toxicity). * ADI, acceptable daily intake; LOAEL, lowest-observed-adverse-effect level; NOAEL, no-observed-adverse-effect level; UF, uncertainty factor. 

L, LOAEL; ND, not determined; X, data available. 

Chronic Health Effects 

n i 1 j .! ' a j 

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Aromatic phosphate plasticizers (APP's): .. .. . . 

Availability of Toxicity Data 

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! i j I .- .............................. i > + ....-i...... +......-. " r"-".."-.."" .i ...i............i.............i.....i...i.....i........-............ ....................... 

Phenol isopropylated . .-...................... phosphate . .- (PIP) xeIxj-j-IxI-!x - .... i L 1 . 2 C : NO .. j I ND~ ! -. 4 ! -" 

Triphenyl phosphate (TPP) x/x~-/x/xIx/x c / 0, j i s....... .. . -" .... ......".........................".............-...........-......-~....~...I.-III"I."-~ . -.---,! .-.. +,." ... -.,,.; ,-...- .....-..... ..... ,,,"-" ....... .- ",-" .... * ........-.... .... "! ..... ............................. j ..... -...... .......- .............. 1" .-... ND 

:xI-!-;xixix I 'I t-Butylphenyl diphenyl phosphate (BPDP) - i i .............. .. . . ....... . ......... ........... ............ .... ................. .... ...... ....... i ND - - ._. .! ".i "i .-. ",,!,,," 1 4 L" 

2-Ethylhexyl diphenyl phosphate (EHDP) x~xlxIxix~x/- B I 0 1100 1100 i 1.0 - . .- .............. .......... . . ...............-... *.-.+ "..."! 4 "-",." ,-,--,j ..... ",-,",,."! .*-......-........ ..,,; .........-....-...- . -..-......-...... "-,,+-"" ..... -... .......--...- & ............. ..............-.- + ..--.....- .................... ...---.. 

lsodecyl diphenyl phosphate (IDDP) ......... .................... ..... -- ..... - " ......... 

Santicizer 141 (>go% EHDP) . . .. 

XIXI-: i - /XIXI- clo, j ! ND . ..j.................. " ... i.".-jj.jjjjj-.-jjji." J . ,,.,,, ............. ","& ...........; x' x'I-j x r-'x 1 i< I- .............................. - .....-.. -- "- " ............... .+ ............. ! ....... g !--" &. ........ .... "-,,: ....... 

Santicizer 148 (> 90% IDDP) x x 1 -j x 1 x 1.x ] - -.-......-.--.--I-. - 2.. .. .-.l".&." -i., i ..i......ii -.i . iii.. i........... .? 

Santicizer 154 (TPP + BPDP) xxf-;xjxIx!- i ........... -.--. .... .. . "- -" . .. i ":jjjjjjj-jjjj-jjjj ~jjjj~i.iiiiii.~iiiiiiiiii~ii./................/~.......~.iiiiiiiii~.... ,v-,,,," .................... 

B I 0 100 , 100 11.0. ......*.-..... ................... 4 ..-.......-........ ",-"",,"; .....-.. "*" .......*.......... !. .........-....-...... .........-.?-..-...... " ........ B;oi i 1 0.01 "2 iiii~iiiiii! . j C ' N,O I ..-. $" . .. "L . . ND 

o-Tricresyl phosphate (0-TCP) X,X~-IX!X;-,X ...... AIN/ .. ..... ........ ....... .................. . ..................................... ..................... ............ I I ND - - - 4 - 4". iiiiiii... ..LL.L...LL..LLL.L.LLLLLLL.LL~iiii.i~iiii.iiiiii...iiii_j_j "-,i "4 

Tricresyl ,phosphate (TCP) (isoiners) X,X~X!XIX~X[X i i B R,N,O i 50 . L~ 1,000 1 0.05 ................... i ,-,--" ",,-;,".-" i Melamine (1,3,5-triazine-2,4,6-triamine) x~xix~xi- I X i - c , C. I j i" - i ND 

Octyl tetrabromobenzoate (OTB) 

Tris(l,3-chloropropyl-2) phosphate (TDCP) 

x/ji-I-~-~ I 1. -. 

x,x.ix,xIx~x,- 

I i 1 ) ND ! 

B I C 1 5 L 1 1,000 1 0.005 
2. Toxicokinetics 

Ninety percent of orally administered [l ,3-14~]2-propyl-labeled TDCP was absorbed in rats 

(Matthews and Anderson 1979). The highest levels of TDCP were found in the kidney, liver, 

and lung (Matthews and Anderson 1979; Nomeir et al. 1981; Ulsamer et al. 1979, 1980). Eighty 

percent of TDCP was eliminated within 24 hours, primarily in the urine, in both rats and rabbits. 

From 9-to-15% was converted to C02. Bis(l,3-dichlor-2-propyl) phosphate was the primary 

metabolite in urine. Other metabolites included 1,3-dichloro-2-propanol and 3-chloro- 1,2- 

propanediol (Figure 2). TDCP is also directly conjugated by glutathione, probably through one 

of the ester groups. It has been suggested that TDCP may also be metabolized to 1,3-dichloro-2- 

propanone, by analogy to TRIS (Gold et al. 1978), but this has not been observed. 

In vitro studies suggest that TDCP is metabolized to the diester by an NADPH-dependent mixed 

function oxidase, as well as by glutathione conjugation (Nomeir et al. 198 1; Sasaki et al. 1984). 

A glutathione-conjugated metabolite was also identified. 

Figure 2. Metabolism of tris(l,3-dichloro-2-propy1)phosphate. Structures: 1) tris(l,3- 

dichloro-2-propy1)phosphate (TDCP); 2) bis(l,3-dichlor-2-propyl) phosphate; 3) 1,3-dichloro-2- 

propanol; 4) glutathione conjugate of TDCP; 5) 3-chloro-l,2-propanediol; 6) putative metabolite 

1,3-dichloro-2-propanone. Sources: Lynn et al. 1981 ; Nomeir et al. 1981 ; Gold et al. 1978. 

TDCP was rapidly absorbed through the skin in both rats and rabbits (Nomeir et al. 1981; 

Ulsamer et al. 1979, 1980). TDCP was absorbed at double the rate of tris(2,3- 

dibromopropy1)phosphate (Ulsamer et al. 1979). When was applied to the clipped skin 

of New Zealand white rabbits, up to 15% of the applied dose was absorbed over 96 hours 

(Ulsamer et al. 1978a). Thus, TRIS was absorbed at a rate of 0.0016 h-'. Nomeir et al. (1981) 

showed that TDCP is rapidly absorbed in rats, although the absorption rate was not determined. 

Percutaneous absorption of 14c-TDcp was also studied in vim with hairless mouse skin 

(Hughes et al. 2001). After 24 hours, from 39-to-57% of applied TDCP was found in the 

receptor fluid. From 28-to-35% remained in the skin after the skin surface was washed with 

ethanol. From 73 to 85% of applied TDCP was absorbed in 24 hours. Combining the amounts 
in the receptor fluid and skin, TDCP was absorbed at a rate up to 0.035 h-I (Babich and Thomas 

2001). 

Five days following intravenous administration of I4c-labeled TDCP in rats, 92% of the 

radiolabel was excreted (Lynn et al. 198 1). Fifty-four percent of radiolabel was found in urine, 

16% in feces, and 22% was expired as 14c02. The primary metabolite was bis(l,3-dichlor-2- 

propyl) phosphate, which accounted for 63% of the radiolabel. Other metabolites included 

1,3-chloropropyl phosphate and 1,3-dichloro-2-propanol. Less than 0.1 % of the radiolabel was 

recovered as TDCP. 

3. Subchronic and chronic Studies 

Groups of 12 male and 12 female mice were fed up to 1.33% TDCP for 3 months (Kamata et al. 

1989). All animals in the high-dose group died within one month. Liver weights were elevated 

in males at 0.13% and 0.42% and in females at 0.04%, 0.13%, and 0.42%. The overall study noobserved-adverse-effect level (NOAEL) was 0.01% (15 mgkg-d) in females. 

TDCP was studied in a 24-month dietary bioassay in Sprague-Dawley (SD) rats (Biodynamics ' 

198 1 ; Freudenthal and Henrich 2000; Henrich 1998).* Animals were exposed to TDCP in feed 

at doses of 0,5,20, or 80 mgkg-d in groups of 60 per dose and sex. Ten animals from each 

dose-sex group were sacrificed at 12 months. Complete histopathology was performed on all 

high-dose animals, but only on a small number of animals at the low- and mid-doses. Liver and 

kidney were examined in all animals at all doses. 

Non-cancer effects observed at terminal sacrifice included convoluted tubule hyperplasia in 

males at all doses and in high-dose females (Table 3) (reviewed in NRC 2000). The incidence of 

parathyroid hyperplasia was significantly elevated in high-dose males only. Erythroidlmyeloid 

metaplasia of the spleen was significantly elevated in females at all doses; this is not considered 

a pre-neoplastic lesion. In addition, there were reproductive system lesions in males, including 

the seminal vesicles (atrophy and decreased secretory product, all doses), testes (periarteritis 

nodosa and eosinophilic material in the lumen, mid-and high doses), and epididymes 

(oligospennia and/or degenerated seminal product, mid- and high dose). Altered liver foci, 

which suggest the presence of initiated cells, were elevated only in high-dose females. The NRC 

subcommittee considered the low dose (5 mgkg-d) as a lowest observed adverse effect level 

(LOAEL) (NRC 2000). TDCP may be considered probably toxic to humans (see CPSC 1992), 

based on sufficient evidence of chronic toxicity (histopathological effects at multiple organ sites) 

in animals. 

* This study was first described in an unpublished report (Biodynamics 1981), which is also referred to as the 

"Stauffer Chemical Co. report." The tumorigenic effects were later published in (Freudenthal and Henrich 2000). 

Henrich (1998) provided additional discussion of tumor incidences. 
Table 3. Incidence of Selected Histopathological Effects in Sprague-Dawley Rats 

Exposed t~ TDCP in Feed a 

Sex 

Dose (mdka-dl 

5 . 20 

Liver, altered foci M Incidence 22/60 20160 16/60 31/60 

F Incidence 1 6/60 23/60 18/55 36/60 

Kidney, convoluted tubule Incidence . 2/60 1 0160 29/60 . 24/59 

hyperplasia P 0.01 5 4.3~1 om9 3.4x10-' 

F Incidence 0160 1/60 3/57 22/60 . - .................... .--.. ........................ 

P 0.50 0.1 1 1.4~1 o-~ 

Spleen, erythroidlmyeloid . Incidence 1 3/60 . - 316 ' 416 1 7/58 . 

metaplasia 0.15 0.034 0.23 

I. 

F Incidence 1 3/60 516 314 33/60 

Parathyroid, hyperplasia M Incidence 1/29 111 012 12/38 - - ...... ..... 

P 0:067 0.94 3.3~1 o-~ . .... - ...- .. . .... ..... 

F Incidence 6/29 hlR " NR 912 8 ....... . . . 

P 0.24 ' 

~estes, eosinophilic M ........... Incidence --. ...... . .............. 2/57 4/60 12/60 . 1 1/56 . . 

material in the lumen P 0.36 5.5~10" 7.1 XI c3 

Testes, periatteritis 

nodosa 

M l ncidence 5/57 10160 1 9/60 16/56 

M Incidence 1 1/55 9/33 711 4 36/55 Ep/didymes, oligospermia 

P 0.30 0.030 1.2~1 u6 

Epididymes, degenerated Incidence 8/55 ' 7/33 311 4 ................. 22/55 .......... 

seminal product P 0.30 0.39 2.4~1 o9 

Seminal vesicle, M Incidence 1 I56 11/13 1 7/20 23/52 

decreased .- ........... . .. secretory 

product P 4.2x10-'O 4.0~1 0-j3 2.5~1 0-a ...................... .............. .............. 

Seminal vesicle, atrophy M Incidence 0156 411 3 6/20 10152 ............. -, .- . - ..................... 

' P 8.3~1 o-~- 1.8~1 0"4.1 XIO" 

a Data are from NRC 2000, Table 16-4. Includes only significantly elevated sites. 

One-tailed Fisher's exact test performed by CPSC staff. Probabilities <0.05 are in bold. 

IVR, not reported; P, probability. 
1 

Table 4. Tumor lncidence in S~raaue-Dawlev Rats Ex~osed to TDCP in Feed a 

Dose (mqlkq-dl 

Tumor ., Sex 0 5 20 80 

Renal cortex tumor M Incidence 1/60 3/60 9/60 32/59 . ..--.- 

pb 0.309 8.3~10~ 1.1~10'" 

F Incidence 0160 1/60 8/57 29/60 . - .... .- .. . 

P 0.500 . 2.4~10" 2.0x10-" 

Testicular interstitial cell M Incidence 7/57 . .- . 8/60 . 26/60 .- .-.-. 39/56 . 

adenoma P. 0.540 1.6~1 om4 2.5~10'~~ 

Hepatocelullar adenoma M Incidence' 2/60 7/60 1/60 16/60 -" . . 

P 0.081 OA78 2.7~1 o4 

F Incidence 1 160 1/60 4/55 9/60 . .. . .- . -. . ......... ........... . 

P 0.752 0.156 8.3~1 om3 

Hepatocellular carcinoma M Incidence 1/60 2/60 3/60 7/60 . . ..... . ...... . 

P 0.500 0.309 0.031 . . . ...................... 

F Incidence 0160 2/60 2/55 4/60 . . . . - . ...... 

P 0.248 0.227 0.059 

M Incidence 3/60 9/60 4/60 23/60 Hepatocellular acknoma ............. .. . .-.. . . - .. ..................... 

.or carcinoma P 0.220 0.500 5.7~1 o'~ 

F Incidence 1 160 3/60 6/55 1 3/60 . . .. .... 

P 0.309 0.044 4.9~1 o4 

Adrenal cortex adenoma M Incidence 5/59 311 4. 511 6 5/57 .......................... .. 

.- P 0.421 0.031 0.607 . . ! ........................ 

F 5/27 2/33 . 20159 . . -

P 0.740 0.040 0.109 

a Tumor data are from NRC 2000, Table 16-5. 

one-tailed Fisher's exact test performed by CPSC staff. Probabilities (P) ~0.05 are in bold. 

Several neoplastic lesions were also reported (Biodynamics 1981; Freudenthal and Henrich 

2000; Henrich 1998 and reviewed in EPA 2005a; Ferrante 1999b; NRC 2000). The incidence of 

renal cortical tumors was significantly elevated relative to the controls in mid- and high-dose 

males and females (Table 4). Benign testicular interstitial cell tumors were also significantly 

elevated in mid- and high-dose males. Hepatocellular adenomas were significantly elevated at 

the high dose in both sexes, while hepatocellular carcinomas were significantly elevated in highdose males only. The incidence of hepatocellular adenoma % carcinoma was significantly 

elevated at the high dose in males and the mid- and high doses in females. Adenomas of the 
adrenal cortex were significantly elevated in mid-dose males (not at the high dose) and 

significantly reduced in mid-dose females. 

4. Reproductive and Developmental Toxicity 

Groups of 10 male rabbits were given 0,2,20, or 200 mgkg-d TDCP by gavage for, 12 weeks 

*(Wilczynski et a1 1983; see also Brandwene 2001). No changes in mating behavior, fertility, or 

sperm quantity or quality were observed.. ~abbits' atthe high dose had elevated kidney and liver 

weights. No histopathological effects were observed in the pituitary, testes, epididymes, liver, or 

kidneys. Other tissue's were not examined. 

Groups of 20 female rats were given 0,25, 100, or 400 mglkg-d TDCP by gavage on gestational . 

days (GD's) 6 through 15 (Stauffer 1981). At GD 19, high-dose fetuses exhibited reduced 

viability, weight, and length. The incidences of resorption and incomplete ossification were also 

increased at the high dose. No malformations were reported. Signs of maternal toxicity included 

increased mortality at the high dose and decreased body weight and food consumption at the 

mid- and high doses. 

In another developmental screen, Kawashima et al. (1983) gavaged female rats at doses of 0,25, 

50,200, or 400 mgkg-d on gestational days 7 through 15. Fetal deaths were observed at the 

high dose, but no malformations occurred. There were signs of maternal toxicity at 200 and 400 

mgkg-d, including decreased.body weight and food consumption. 

No malformations were observed in two developmental screening assays in rats (Kawashima 

1983; Stauffer 1981; reviewed in Ferrante 1999a; NRC 2000). Fetal effects such as reduced 

viability and body weight, along with signs of maternal toxicity, were observed at the doses of 

200 mgkg-d or greater in both studies. The highest NOAEL in the developmental studies was 

100 mgkg-d. No effects on male fertility were observed in rabbits exposed to doses up to 200 

mgkg-d for 12 weeks (Wilczynski et a1 1983). This is somewhat in contrast to the observation 

of histopathological effects in the testes at 5 mgtkg-d in the two-year bioassay in rats 

(Biodynamics 1981). However, the lesions in the chronic study did not appear until after the 12- 

month interim sacrifice. 

5. Neurotoxici ty 

The neurotoxicity of TDCP was studied in hens. No signs of neurotoxicity or paralysis were 

reported at 420 mgkg-d (by gavage) for 5 days (Stauffer 1981). TDCP was a weak inhibitor of 

brain neurotoxic esterase in hens given 10,000 mglkg-d. Oral TDCP at 4,800 mgkg was fatal in 

chickens, although lower doses (unspecified) resulted in leg and wing weakness (Celanese 1960). 

It does not appear that TDCP is capable of inducing organophosphate-induced delayed 

neurotoxicity (OPIDN) in hens (see below). Exposure of rats to TDCP at high doses lead to 

clinical signs suggestive of neurotoxicity, such as hyperactivity and convulsions (see above). 
6. Toxicity under the FHSA 

TDCP is acutely toxic, as defined in FHSA regulations, although it is not considered "highly" 

toxic.* That is, the rat LD50 is less than or equal to 5,000 mgkg, but greater than 50 mgkg. 

TDCP exposure led to histopathological effects in rats exposed for up to two years (Biodynamics 

1981). Organ sites affected include the liver, kidney, spleen, parathyroid, and male reproductive 

organs. Thus, TDCP may be considered probably toxic in humans, based on sufficient evidence 

of chronic toxicity in animals. 

TDCP exposure also induced tumors at multiple doses in the kidneys and liver of both male and 

female rats. Therefore, TDCP may be considered a probable human carcinogen based on 

sufficient evidence in animals (Ferrante 1999b; Bittner et al. 2001). This conclusion is further 

supported by structural similarity to another animal carcinogen, TRIS. TDCP and its metabolites 

were genotoxic in some assays, although the majority of tests were negative. 

Based on the available data, the CPSC staff concludes that there is inadequate evidence of 

reproductive toxicity and or developmental toxicity in animals (CPSC 1992). In addition, there 

is inadequate evidence of neurotoxicity in animals. 

B. Aromatic Phosphate Plasticizers (APP's) 

The toxicity of various aromatic phosphate plasticizers (APP's) has been reviewed by the CPSC 

staff (Bittner 2001; Bittner et al. 2001; Ferrante 1999a) and others (EPA 2005a; IPCS 1990, 

1991; NRC 2000). The toxicity of the APP's varies among individual compounds and 

commercial mixtures. Much of the available toxicity data are for commercial mixtures 

containing two or more APP's. The toxicity data for the APP's are summarized below. 

In general, the acute toxicity of APP's is low, with oral LD50 values in rats ranging from 3,000 

mgkg to >20,000 mgkg (Ferrante 1999a). Tricresyl phosphate (TCP) (mixture of isomers) 

(1330-78-5) and o-tricresyl phosphate (0-TCP) (78-30-8) are the most toxic with regard to acute 

toxicity. APP's are weakly irritating or non-irritating in the skin and eyes of rats or rabbits. The 

APP's were generally non-genotoxic in Salmonella and in mammalian systems. 

1. Toxicokinetics 

TCP (mixed isomers) (NTP 1994) and o-TCP (Somkuti and Abou-Donia 1990) were readily 

absorbed following oral exposure in rats. The highest levels of radiolabel were found in adipose 

tissue, muscle, erythrocytes, and liver in rats given [14c]-o-~c~ (Sornkuti and Abou-Donia 

1990). However, the highest level of the neurotoxic metabolite, saligenin cyclic o-tolyl 

phosphate, was found in the testes. Percutaneous absorption of o-TCP in cats was biphasic. 

Initially, 73% of o-TCP applied to skin was absorbed in 12 hours, while the remainder was 

absorbed at a constant rate of 0.34 d-' (Nomeir and Abou-Donia, 1984). Initially, unmetabolized 

o-TCP was found primarily in the brain, spinal cord, and sciatic nerve in cats. Metabolites were 

found primarily in the liver, lung, and kidney. In contrast to TCP, 2-ethyhexyldiphenyl 

* 16 CFR 1500.3 [c)(l). 
phosphate (EHDP) was reported to be poorly absorbed from the intestinal tract in humans and 

Wistar rats (reviewed in Ferrante 1999a; IPCS 1990). 

o-TCP is metabolized by three pathways (Abou-Donia et al. 1990; Casida et al. 1961 ; Eto et a1 

1962; PCS 1990; Nomeir and Abou-Donia 1984, 1986; Somkuti and Abou-Donia 1990). First, 

one or more methyl groups are hydroxylated by 'mixed function oxidase. The resulting 

hydroxylated compound then undergoes a cyclization reaction to form saligenin cyclic o-tolyl 

phosphate, and releasing o-cresol (Figure 3). Second, o-TCP is hydrolyzed to the diester, 

monoester, and inorganic phosphate, which also releases o-cresol. Third, hydroxymethyl groups 

may be further oxidized to the aldehyde and carboxylic acid. The meta and para isomers of TCP 

are also hydroxylated (Kurebayashi et al. 1985; Johnson 1975). In rats, o-TCP metabolites are 

excreted mainly in urine, while the meta isomer metabolites are mainly excreted in feces, and the 

para isomer divided between urine and feces (Kurebayashi et al. 1985; NTP 1994). TPP was 

hydrolyzed to the diester by mixed function oxidase and aryl esterase in rat liver microsomes 

(Sasaki et al. 1984). 

PII 0 &13 - 0 {-b), 2 + H-5 3 

'\ 

d%{&) 2 7 -C; (&) \ / 

4b O I 2 

4a 1 

/ \ 

&:r{-b)2 5 0 %:& 0 \ / + H& 

6 3 

HO, 

2 

Figure 3. Metabolism of etricresyl phosphate. Structures: 1) tricresyl phosphate (TCP); 

2) dicresyl phosphate; 3) cresol; 4a,b) hydroxymethyl intermediate; 5) aldehyde; 6) saligenin 

cyclic o-tolyl phosphate; 7) carboxylic acid. Adapted from Somkuti and Abou-Donia (1990). 
2. Subchronic and Chronic Studies 

TCP was tested in two-year gavage bioassays in B6C3F1 mice and F-344 rats (NTP 1994). 

There was "no evidence of carcinogenic activity" in mice or rats. Non-neoplastic effects were 

found in female rats at 300 ppm (15 mgkg-d), including cytoplasmic vacuolization of the 

adrenal cortex and ovarian interstitial cells hyperplasia. The NOAEL was 150 ppm (7 mgkg-d) 

in female rats. The incidences of clear cell foci, fatty change, and ceroid pigmentation of the 

liver were significantly increased in male mice at 125 or 250 ppm (13 or 27 mgkg-d). In 

addition, increased incidence and severity of ceroid pigmentation of the adrenal cortex occurred 

in female mice at 250 ppm (37 mgkg-d). The NOAEL was 60 ppm (7 mgkg-d) in male mice. 

SD rats exposed to EHDP in feed for 90 days had enlarged livers and adrenal glands (Solutia 

1998). astopathological effects were observed in.the adrenal cortex in both sexes and ovarian 

hyperplasia in females. The overall LOAEL was 0.2% (about 164 mgkg-d). A NOAEL was not 

established. EHDP was also tested in a two-year bioassay in Carworth albino rats (Treon et al. 

1953). Rats were given 0,0.0625,0.125, or 1 .O% EHDP in feed. There was no evidence of 

carcinogenicity, but there was a decreased growth rate at 1% in feed. No significant increases in 

gross or microscopic histopathological effects were found. No effects in the adrenal cortex or 

ovaries were reported. However, the histopathological methods and the organs examined were 

not described in detail. The NOAEL was 0.125% or approximately 100 mglkg-d (Ferrante 

1999a).. 

3. Reproductive and Developmental Toxicity 

Oral TCP exposure led to infertility and reduced fertility in mice (Chapin et al. 1988; NTP 1985) 

and rats (Carlton et al. 1987). The fertility of both male and female mice was affected (NTP 

1994). Reduced sperm concentration and motility, as well as increased incidence of abnormal 

morphology, was reported in rats (Carlton et al. 1987) and mice (Chapin et al. 1988; NTP 1985). 

Histopathological effects in the testes, epididymes, and ovaries were also observed (Carlton et al. 

1987). The LOAEL for reproductive effects was 62.5 mglkg-d (the lowest dose tested) in a 

continuous breeding study in male CD-1 mice (Chapin et al. 1988; NTP 1985). 

Oral exposure to o-TCP lead to effects on sperm motility and morphology, as well as testicular 

effects, in F-344 rats (Somkuti et al. 1987a,b, 1991). The authors considered 25 mglkg-d as the 

NOAEL and 10 mglkg-d as the NOAEL. The teratogenicity of o-TCP was tested in Long Evans 

rats at doses of 0, 87.5, 175, and 350 mgkg-d (Tocco et al. 1987). Dams were treated on GD's 6 

through 18. The high dose was lethal to the dams. Malformations and variations at the low- and 

mid-doses were not significantly different from the controls. Mele and Jensh (1977) gave doses 

of 0,500, or 750 mgkg-d o-TCP to pregnant Wistar rats on GD's 18 and 19. The authors 

reported that there were no malformations or skeletal variations. No other details are available. 

A mixture of two commercial products containing EHDP was tested in a.one-generation study in 

SD rats (Monsanto 1993; Robinson et al. 1986). Groups of 16 male and 32 female rats were fed 

0,0.2%, 0.4%, or 0.8% DEHP. Males received EHDP continuously from 70 days prior to 

mating through the end of the study, while females received EHDP from 21 days prior to mating 

through the end of the study. Initially, treatment-related reductions in food and water 

10 5 
consumption were observed in mid- and high-dose males and high dose females.. This was 

attributed to the unpalatability of EHDP. Reduced 'food and water consumption persisted in 

high-dose females throughout the study.' 

There were no adverse effects on fertility in either sex. Liver weights were increased in a dosedependent manner in parental (Fo) males and females. Relative increases in adrenal, caecal, and 

kidney weights were observed in high-dose males and females. In addition, spleen weights were 

reduced in mid- and high-dose females, while hypertrophy and luteinization of ovarian stromal 

cells occurred at the high dose. Centrilobular and periportal hypertrophy was found in the liver 

in high-dose males and females. 

Body weight gain was significantly reduced in mid- and high-dose pups (F1). Pup survival was 

reduced at the high dose. The authors attributed these effects to the nutritional status of the 

dams. In mid- and high-dose pups, liver and adrenal weights were significantly increased, while 

spleen weights were reduced. The reproductive NOAEL considered to be 0.2% EHDP, or 

roughly 144 mgkg-d. 

In a teratology screening study, female CD rats were given 0, 300, 1000, or 3000 mgkg-d 

SanticizerTM 141 (>go% EHDP) orally on GD's 6 through 15 (Robinson et al. 1986; Solutia 

1998). Maternal effects included increased hair loss and yellow staining or matting in the midand high-dose groups. Maternal weight was reduced at the high dose, and some animals had 

inguinal fissures. The incidences of skeletal variations were increased at all doses. 

Malformations-such as eye anomalies, scoliosis, and dwarfism-were found at the mid- and 

high doses. The authors considered the incidences of variations and malformations to be not 

treatment-related, because they were within the range of historical controls. 

In developmental assays in rats, reported fetal effects included increased frequency soft tissue 

variations with TPP (see below) (Welsch et al. 1987). 

4. Neurotoxicity 

The APP's are known primarily for their neurotoxicity. An estimated 50,000 cases of accidental 

ingestion of o-TCP occurred in the 1930's in the southern U.S. when "Ginger Jake," an alcoholic 

extract of Jamaican ginger popular during prohibition, was adulterated with o-TCP (reviewed in 

Ferrante 1999a; PCS 1990; Weiner and Jortner 1999). Ingestion of mixtures containing o-TCP 

have resulted in neuropathy, paralysis, axonal degeneration, andlor death. Most patients 

recovered over a period of up to two years, although some remained permanently paralyzed. 

Other ingestions have occurred in an occupational setting. Sensitivity among humans is quite 

variable. Paralysis may occur with doses as low as 2 mgkg, and 1,000 mgkg may be fatal 

(Ferrante 1999a). 

APP's induce a delayed neurotoxicity in animals and humans characterized by ataxia, flaccid 

paralysis, axonal degeneration, and demyelination, referred to as organophosphate-induced 

delayed neurotoxicity (OPIDN) (reviewed in Weiner and Jortner 1999). The syndrome 

associated with the APP's is distinct from the effects associated with anticholinergic nerve 

agents. Humans and other primates, canines, felines, ruminants, and hens are sensitive to 
OPIDN, while laboratory rodents are less sensitive. Hens are considered the best animal model 

for OPIDN in humans, and have been used extensively in laboratory studies (e.g., Johannsen et 

al. 1977; Johnson 1975; Weiner and Jortner 1999). The domestic hen is susceptible, exhibits 

clearly detectable clinical signs, and the time course for developing neuropathy is similar to that 

in humans (Weiner and Jortner 1999). o-TCP is the most neurotoxic APP in animals and is a 

known neurotoxicant in humans (Ferrante 1999a; NRC 2000). APP's inhibit a variety of 

esterases, including plasma pseudocholinesterase, erythrocyte cholinesterase, non-specific 

carboxylesterase, acetylcholinesterase, and neurotoxic esterase (NTE). The severity of OPIDN 

symptoms generally correlate with the inhibition of NTE, which is a smooth endoplasmic 

reticulum-bound carboxylesterase found especially in nervous tissue (e.g., Dollahite and Pierce 

1969; Johnson 1974; NTP 1994; Weiner and Jortner 1999). Neurotoxicity appears to require 

irreversible inhibition of NTE, through the formation of a stable, covalently-bound intermediate 

(Johnson 1974, 1975). Non-toxic APP's are reversible NTE inhibitors, and may protect against 

neurotoxic APP' s. 

Extensive studies of structure activity relationships have been performed (Johannsen et al. 1977; 

Johnson 1975). APP's having one or more alkyl groups at the ortho position are neurotoxic, 

provided that there is at least one hydrogen at the a-alkyl position to allow formation of the 

cyclic metabolite. Thus, the t-butyl group is inactive. Neurotoxicity is greater in isomers having 

only one ortho substituent. Increasing chain size and branching of the ortho substituent tends to 

reduce neurotoxicity. Para-substituted APP's are neurotoxic provided that there are .at least two 

a-hydrogens. Meta-substituted and unsubstituted APP's (i.e., TPP) are not neurotoxic. Thus, 

the relative toxicity of the APP's is as follows: TPP < butylphenyl phosphate < isopropylphenyl 

phosphate < trixylenyl phosphate < TCP < o-TCP (Weiner and Jortner 1999). Using a multiple 

dose regimen, the dose causing a 50% incidence of neurotoxicity in hens (EDs0) was estimated to 

be 420 mgkg for o-TCP and 10,000 mgkg for isopropylphenyl diphenyl phosphate (IPDP) 

(Johannsen et al. 1977). 

5. Toxicity under the FHSA 

Previously, the CPSC staff concluded that o-TCP is known to be neurotoxic in humans (Bittner 

2001; Ferrante 1999a). The staff also concluded that TCP (mixed isomers) is probably toxic, 

based on sufficient evidence of neurotoxicity, chronic organ toxicity, and reproductive toxicity in 

animals;.2-ethylhexyl diphenylphosphate (EHDP) is probably toxic, based on sufficient evidence 

of chronic organ toxicity in animals; and isodecyl diphenylphosphate (IDDP) is possibly toxic, 

based on limited evidence of chronic organ toxicity in animals (Table 2). TPP and PIP are 

discussed below. 

C. Triphenyl Phosphate (TPP) 

The toxicity data for TPP have been reviewed by the CPSC staff (Bittner et al. 2001; Ferrante 

1999b) and others (EPA 2005a; PCS 1991). The range of studies on TPP was limited. Oral 

LDS0 values were reported to range from 1,320 mglkg to >5,000 in mice; 3,000 mgkg in rabbits; 

and from 3,000 mgkg to >20,000 mglkg in rats (reviewed in Ferrante 1999a; PCS 1991). A 

70% solution of TPP in alcohol was not irritating to mouse skin (Sutton et al. 1960). No other 
data on skin or eye irritation were reported, although other APP's were either non-irritating or 

weakly irritating to rabbit skin and eyes. 

Several cases of contact dermatitis from products contajning TPP or related compounds have 

been reported (Camarasa and Serra-Baldrich 1992; Carlsen et al. 1986; Hjorth 1964; Holden et 

al. 2006). TPP is used as a plasticizer in plastics and cellulose acetate. The products involved 

included eyeglass frames, an oxygen mask, an adhesive, and cellulose acetate. Patients reacted 

to TPP in patch testing, at levels from 0.05% to 0.5% in petrolatum. Thus, TPP is capable of 

eliciting an allergic response in humans by dermal exposure. Cross-reactivity with other triaryl 

phosphates and triaryl phosphites is likely to occur. 

1. Genotoxicity 

TPP was not mutagenic in Salmonella (TA 1535, TA 1537, TA 1-538, TA 98, and TA loo), 

Saccharomyces cerevisiae (D4 strain), or L5178Y mouse lymphoma cells (thyrnidine kinase 

locus) (reviewed in Ferrante 1999a; PCS 1991). Studies were done both with and without 

metabolic activation. 

2. Toxicokinetics 

No data are available on the metabolism of TPP in animals or humans. TPP was reported to be 

hydrolyzed to the diester by rat liver rnicrosomes (Sasaki et al. 1984). Because TPP lacks alkyl 

substituents, it cannot be oxidized to the neurotoxic metabolite, as occurs with other APP7s 

(Johannsen et al. 1977; Johnson 1975). 

The percutaneous absorption of formulations containing TPP through human epidermis was 

reported (Scott and Thompson 1985). Neat ReofosTM 50 or ReolubeTM 46 were applied as an 

"infinite dose" to the epidermal side of cadaver epidermis placed on a static diffusion cell. The 

receptor fluid was 70% ethanol. The authors calculated a diffusion constant of 1.6x10-~ crdh for 

TPP. However, the experimental design was unusual in that the other components of the 

formulation were not identified and the receptor fluid was essentially non-aqueous. The use of a 

static cell could lead to an underestimate of absorption. Therefore, the usefulness of this study 

for estimating human risk was considered questionable (EPA 1985). 

3. Subchronic and Chronic Studies 

TPP has been subjected to several repeated-dose oral studies in animals. However, no 

subchronic or chronic studies with full pathology have been reported. In one study, groups of 5 

male Holtzman rats were exposed to 0,0.01%, or 0.5% TPP in feed for 35 days (Sutton et al. 

1960). Relative liver weights were significantly elevated at 0.5% TPP; absolute organ weights 

were not reported. Body weights of exposed animals were slightly reduced, but this effects was 

reversible during the two-week recovery period. Hematology tests were normal and no gross 

abnormalities observed. Detailed histopathology results were not provided. 

In a study of neuromotor function, groups of 10 male SD rats were given 0,0.25%, 0.5%, 0.75%, 

or 1% TPP in feed for 4 months (Sobotka et a1 1986). The resulting dose levels were 0, 161, 
345, 517, and 71 1 mgkg-d. Behavioral tests were performed monthly. No significant effects on 

behavior were observed. There was a significant, dose-dependent reduction in weight gain. The 

NOAEL for reduced weight gain was 0.25% (1 61 mgkg-d). 

In an immunotoxicity study from the same laboratory, groups of 10 male and 10 female SD rats 

were given TPP at 0, 0.25%, 0.5%, 0.75%, or 1% in feed for 4 months (Hinton et al. 1987). At 

60 days, 3 rats from each sexldose group were sacrificed. Beginning at 60 days, 5 rats from each 

doselsex group were immunized with sheep red blood cells. Immunized and non-immunized 

TPP-exposed males generally gained weight at a reduced rate, but the differences were 

statistically significant only for some combinations of dose and time. TPP-exposed animals 

generally consumed slightly more food than controls. Body weights and food consumption were 

generally similar in immunized and non-immunized animals. Relative weights of the thymus 

and spleen were generally unaffected by TIT exposure or immunization. No significant effects 

on thymus and spleen histopathology or antibody titers were observed. There was a small, nonsignificant increase in total serum protein in TPP-exposed animals. 

TPP gave negative results in the strain A mouse assay for pulmonary carcinogens (Theiss et al. 

1977). Groups of 20 male strain A mice were given up to 18 intraperitoneal injections of 0, 20, 

40, or 80 mgkg TPP. All mice were sacrificed at 24 weeks following the first injection. TPP 

did not significantly increase the incidence of pulmonary adenoma in treated mice. 

Workers exposed to a weighted average concentration of 3.5 mg/m3 TPP (range 1.8 to 12 mg/m3 

for different operations) showed no neurological symptoms, dermatitis or other unusual 

 symptom.^ (Sutton et al. 1960). Erythrocyte esterase activity was significantly reduced (8% 

lower than controls), but plasma esterase activity was not affected. The duration of exposure 

was not reported. Potential dermal and oral exposures were not assessed. 

. , 4. Reproductive and Developmental Toxicity , . 

One study of the potential reproductive and developmental effects of TPP has been reported. 

Groups of 40 male and 40 female SD rats were fed TPP at levels of 0, 0.25%, 0.5%, 0.75%, or 

1% for 9 1 days prior to breeding (Welsh et al. 1987). The resulting dose levels were 0, 166, 341, 

5 16, and 690 mgkg-d. The dams were sacrificed on GD 20. Dams exposed to TPP consumed 

more feed than controls. There was a dose-dependent decrease in dam body weights, although it 

was statistically significant only at the high dose. No effects on reproduction were observed. 

TPP-exposed male pups weighed significantly more than controls at 0.5% and 1 %. The 

incidences of hydroureter and enlarged ureters (both moderate to severe) were significantly 

increased in all TPP-exposed groups, although there was no clear'dose-response. The number of 

fetuses with two or more soft tissue variations was significantly elevated in all TPP-exposed 

groups, except the high dose, which was non-significantly elevated. The number of litters with 

fetuses having at least two soft tissue variations was significantly elevated at 0.5% and 1%. A 

clear dose response was not observed for any of the reported effects. The numbers of fetuses or 

litters with one or more soft tissue variations were not significantly elevated. The authors 

concluded that there was evidence of maternal toxicity at the high dose (decreased weight gain), 

and that the observed increases in soft tissue variations were not dose-dependent. The CPSC 
staff concludes that it is uncertain whether the increased in soft tissue variations is biologically 

significant. 

5. Neurotoxicity 

In an early study, TPP was reported to cause delayed paralysis with demyelination in cats and 

monkeys, but not chickens or rabbits (Smith et al. 1932). Subsequently, practical grade TPP was 

reported to cause a delayed paralysis suggestive of OPIDN in cats at 200 to 400 mgkg (Sutton et 

al. 1960). No effects were found in rats, mice, or guinea pigs. However, in studies with purified, 

synthetic TPP, no evidence of neurotoxicity or neuropathology was observed in cats given from 

400 mgkg to 1,000 mglkg TPP subcutaneously (Wills et al. 1979). Other toxic effectsanorexia, weight loss, and generalized vascular damage, perivascular edema, and fatty changes in 

the liver-were observed at all doses, except controls. The authors suggested that the earlier 

study (Smith et al. 1932) used TPP derived from coal tar, and probably contained neurotoxic 

impurities. 

TPP caused a dose-dependent inhibition of whole blood cholinesterase in mice exposed either 

orally or intraperitoneally at doses from 10 to 500 mglkg-d (Sutton et al. 1960). No evidence of 

neurotoxicity was observed. In mice exposed by inhalation (757 mg/m3 TPP for up to 4 hours or 

363 mg/m3 for 6 hours), there was a small, non-significant decrease in whole blood 

cholinesterase activity. TPP inhibited human plasma and erythrocyte cholinesterase activity in 

vitro, 

TPP did not induce delayed neurotoxicity (OPIDN) in numerous studies in hens (reviewed in 

Johannsen et al. 1977; Johnson 1975; Weiner and Jortner ,1999).cannot be metabolized to a 

neurotoxic intermediate due to the absence of alkyl substituents. 

No neuromotor effects were observed in SD rats fed TPP for 4 months at doses up to 71 1 

mgkg-d (Sobotka et al. 1986) (see above). Measures of neuromotor function included motility, 

exploratory behavior, balance, coordinated motor activity, and grip strength. 

TPP inhibited the development of neurite-like outgrowths in mouse neuroblastoma and rat 

glioma cells in vitro (Henschler et al. 1992). .With TPP, 50% inhibition was observed at 

concentrations (IC50'S) from 1.5x10-~ to 7.7x10-~ M. TPP was roughly as effective as o-TCP, 

which had ICso values from 3.1~10'~ to 3.8x10-~ M. The authors concluded that TPP may have 

"very slight" neurotoxic potential. 

No neurological symptoms were observed in workers exposed to a weighted average 

concentration of 3.5 mg/m3 TPP (range 1.8 to 12 mg/m3 for different operations) (Sutton et al. 

1960) (see above). Erythrocyte esterase activity was significantly reduced (8% lower than 

controls), but plasma esterase activity was not affected. 

Several cases of accidental ingestions or occupational exposures to TPP have been reported 

(reviewed in Ferrante 1999a; IPCS 1991). However, all of these were mixtures containing other 

neurotoxic compounds. Therefore, the significance of these reports is unknown. 
6. Other Studies 

Micromolar levels of TPP and some isopropylated triphosphates activated (or derepressed) 

human constitutively active receptor (CAR) and pregnane X receptor (PXR) in vitro 

(Honkakoski et al. 2004). Variable results were obtained with mouse receptors. CAR and PXR 

are ligand activated transcription factors that are part of the superfamily of nuclear receptors. 

CAR and PXR induce genes that are involved in steroid metabolism, as well as numerous other 

unidentified genes. 

7. Toxicity under the FHSA 

The database for TPP toxicity is limited. No chronic studies of any kind and no subchronic 

studies with complete histopathology have been reported. The range of reported LDso values is 

broad. Reported LDso values in rats ranged from 3,000 mgkg to >20,000 mgkd (reviewed in 

Ferrante 1999a; IPCS 1991). While some LDS0 values were below 5,000 mglkg, the majority 

were greater than 5,000 mgkg. The lower (more toxic) values could be due to the presence of 

impurities in some preparations. Considering all of the data, the CPSC staff concludes that there 

is limited evidence of acute toxicity in animals. Therefore, TPP is not considered acutely toxic, 

as defined by the FHSA.* 

In addition, the staff concludes that there is limited evidence of chronic toxicity in animals, based 

on decreased body weight gain in a 90-day neurotoxicity study in male rats (Sobotka et al. 1986). 

Additional data are needed to assess the chronic toxicity of TPP. The staff further concludes that 

there is inadequate evidence of developmental toxicity in animals, based on increased incidence 

of soft tissue variations in one study (Welsh et al. 1987). In the same study, there was 

inadequate evidence of reproductive effects. Finally, the staff concludes that there is, at most, 

limited evidence of neurotoxicity in animals. TPP was neurotoxic in some studies in cats, 

although it was not neurotoxic in hens or mice (reviewed in Johannsen et al. 1977; Johnson 

1975; Weiner and Jortner 1999). The positive studies may have been due to the presence of 

impurities. Alternatively, TPP may simply be a very weak neurotoxicant. Thus, there is 

inadequate evidence of neurotoxicity in animals. 

Overall, T~P may be considered "possibly toxic in humans" based on limited evidence of 

toxicity in animals, that is, reduced weight gain in a 90-day feeding study (Sobotka et al. 1986; 

reviewed in Bittner et al. 2001; Ferrante 1999a). The finding that TPP is "possibly" toxic is not 

sufficient to satisfy the regulatory definition of "toxic" (CPSC 1992). However, this conclusion 

is based on limited data. It does not mean that TPP is not toxic. Rather, it means that additional 

information is needed to assess its toxicity and derive an ADI. 

* 16 CFR 1500.3 (c)(l). 
D. Phenol Isopropylated Phosphate (PIP) 

The toxicity of PIP has been reviewed by the CPSC staff (Bittner et al. 2001; Ferrante 1999a) 

and others @PA 2005a; Henrich 2001). Briefly, PIP is typically a complex mixture of PIP 

isomers and TPP, and may be blended with other aromatic phosphates. PIP i's generally prepared 

by alkylation of phenol prior to reaction with phosphorus oxychloride (POC13). Commercial 

products differ in their degree of alkylation, which determines the viscosity of the mixture. PIP 

is sold under a variety of trade names, including KronitexTM, and DuradTM, 0s-70TM, and 

ReofosTM. Various commercial products and isomers have been assigned different Chemical 

Abstracts Service numbers.' The toxicity of PIP, including various commercial products and 

specific isomers, is summarized below. 

1. Acute Toxicity 

PIP and formulations containing PIP are not acutely toxic (reviewed in EPA 2005a; Ferrante 

1999a; Henrich 2001). The oral LDSo in various strains of rat is greater than 5,000 mgkg (FMC 

1969; FMC 1979; Freeman 1990; Stauffer 1979). The minimum lethal oral dose of 0s-70TM 

was from 3.2-to-4.7 mLkg in rats (Ferrante 1999a). Observations included respiratory distress 

and CNS effecrts. Rabbits dying after oral or dermal exposure to 0s-70TM had degenerative 

liver and kidney changes, and acute hyperemia in the viscera (Ferrante 1999a). 

The dermal LDSo was >2,000 mgkg in SD rats (Freeman 1990; Henrich 2001). The minimum 

lethal dose of Durad-1 10TM was from 1.6-to-2.5 mLkg by the dermal route (Ferrante 1998a). 

The 1-hour inhalation LCSo was > 200 mg/L in SD rats (Ferrante 1999a; Freeman 1990; Henrich 

2001). 

The oral LDSoYs of KronitexTM K-50, K-100, K-200, K-200B, and K-300 in albino Wistar rats 

were all >20,000 mgkg (FMC 1979). Clinical signs of toxicity generally included visceral 

hemorrhage and hematuria. These products are PIP formulations with increasing degrees of 

isopropylation. No mortalities occurred in rats administered up to 40,000 mgkg of K-300. 

However, clinical signs of toxicity included alternating hypoactivity and hyperactivity, increased 

salivation, piloerection, diarrhea, excessive urination, and wet, oily coat. The dermal LDSo 

values of these compounds in rabbits were all >10,000 mgkg. Their inhalation LC50's in rats 

were all less than 200 mg/L. 

2. Dermal and Ocular Effects 

PIP was non-irritating to moderately irritating to rabbit skin and either non-irritating or slightly 

irritating in the rabbit eye (FMC 1979; Ferrante 1999a; Freeman 1990; Henrich 2001; Stauffer 

1979). KronitexTM K-100 was mildly irritating to skin and non-irritating to eye in rabbits (FMC 

1976). K-50, K-200, and K-300 were non-irritating to both the skin and eye in rabbits. 

* 

68937-41-7,28108-99-8,64532-94-1,93925-53-2,28109-00-4,69500-29-4,96300-97-9,74315-11-0, 

26967-76-0,64532-95-2,695 15-46-4, and 68155-51-1. 
3. Genotoxicity 

PIP was not mutagenic in Salmonella tester strains TA98, TA100, TA1535, TA1537, and 

TA1538, either with or without metabolic activation (reviewed in EPA, 2005, Ferrante 1999a; 

FMC 1979; Henrich 2001; Stauffer 1979). KronitexTM 110 was mutagenic without metabolic 

activation in TA1535 and TA1537, but not in strains TA98, TA100, or TA1538 (Microbiological 

Associates 1978). Interestingly, KronitexTM 110 was not mutagenic metabolic activation in 

either TA98, TA100, TA1535, TA1537, or TA 1538. However, in another study, KronitexTM 

K-110, K-100B, and K-200 were not mutagenic in the same strains, with or without activation. 

o-IPDP was reported to be non-mutagenic in Salmonella (Stauffer 1979). 

PIP failed to induce unscheduled DNA synthesis (UDS) in rat hepatocytes in vitro. It was unable 

to induce phenotypic transformation of Balblc 3T3 cells in vitro (EPA 2005a; FMC 1981). 

However, o-isopropylphenyl diphenyl phosphate was able to transform Balblc cells, and was 

weakly mutagenic with metabolic activation in mouse lymphoma cells (Stauffer 1979). In 

addition, PIP induced sister chromatid exchange in the bone marrow cells of Chinese hamsters 

following two oral doses, but not following a single dose. 

4. Toxicokinetics 

No data were available on the metabolism of PIP. However, other aromatic phosphates are 

hydrolyzed to the diester (see above). In addition, alkyl substituted APP7s are oxidized at the 

2-alkyl position. The resulting hydroxylated compound may then form a cyclic intermediate that 

is neurotoxic. 

The percutaneous absorption of formulations containing IPDP through human epidermis was 

reported (Scott and Thompson 1985). Neat ReofosTM 50 or ReolubeTM 46 were applied as an 

"infinite dose" to the epidermal side of cadaver epidermis placed on a static diffusion cell. The 

receptor fluid was 70% ethanol. The authors calculated a diffusion constant of 2.2xl0-~ cm/h for 

IPDP. However, the experimental design was unusual in that the other components of the 

formulation were not identified and the receptor fluid was essentially non-aqueous. The use of a 

static cell could lead to an underestimate of absorption. Therefore, the usefulness of this study 

for estimating human risk was considered questionable (EPA 1985). 

5. Subchronic and Chronic Studies 

Limited data are available on the subchronic toxicity of PIP in mammals. No chronic studies 

have been reported. Groups of 10 male and 10 female SD rats were given 0, 0.1, 0.5 or 1% PIP 

(KronitexTM 100) in the diet for 28 days (FMC 1977). These doses correspond to 0, 350, 1600, 

and 3000 mglkg-d in males and 0,380, 1500, and 3400 mglkg-d in females. There were 4 deaths 

each at the low- and mid-dose, and 3 deaths at the high dose, as compared to 1 death in the 

controls. The incidence of deaths is not significantly different from the controls by a Fisher's 

exact test. Relative liver weights were increased at all doses. There were clinical chemistry 

effects at the mid and high dose, and hematological effects at the high dose. There were no gross 

lesions and no abnormal histopathology in the liver or kidney. Other organs were not examined 

microscopically. No other details were provided. 
Increased white blood cell and lymphocyte counts were observed in workers exposed to K-SOTM 

(Kolodner et al. 1987). Erythrocyte cholinesterase was not affected, and no neurological 

symptoms were reported. White blood cell and lymphocyte counts were elevated at all doses. 

There was no reduction in erythrocyte cholinesterase and there were no neurological effects. No 

other details were reported. 

6. Reproductive and Developmental Toxicity 

In a reproductive and developmental screen, male and female rats were administered PIP by 

gavage for 40 days at doses of 0, 25, 100, or 400 mgkg-d (reviewed in EPA 2005a). The liver 

and adrenal glands were affected in adult males and females; females were more sensitive. The 

LOAEL for organ toxicity was 25 mgkg-d. There was reduced fertility at the mid- and high 

dose, and reduced pup survival at the high dose. In addition, ovarian weights were affected at all 

doses, and epididymal weights at the mid and high dose. No other details were reported. 

See above (Subchronic and Chronic Studies). 

7. Neurotoxicity 

Numerous studies on the neurotoxicity of PIP in hens have been reported (reviewed in EPA 

2005a; Ferrante 1999a; FMC 1977, 1979; Henrich 2001; Johannsen et al. 1977). PIP and related 

isomers are capable of causing OPIDN in hens at relatively high doses. PhosphoflexTM 41P was 

neurotoxic in hens at 4,000 mgkg (FMC 1977). The EDso for KronitexTM 200 was reported to 

be greater than 20,000 mgkg (Cascieri and Poinsett 1977; Ross et al. 1979). The EDso for oIPDP was 10,000 mgkg, as compared to 420 mgkg for o-TCP (Johannsen et al. 1977). 

In a series of studies, the acute EDso in hens was estimated as: >4,000 mgkg for KronitexTM 

K-50; -8,000 mg/kg for K-100; >20,000 mgkg for K-200; and >16,000 mag for K-300 (FMC 

1977). In these studies, 400 mgkg o-TCP caused paralysis in at least 90% of hens. 

8. Other effects 

KronitexTM 50 was reported to inhibit monocyte phagocytosis and IgG synthesis in human cells 

in vitro, while stimulating the release of leukotrienes and prostaglandins (Newcombe and Warr 

1985). A tris(isopropy1ated) phenyl phosphate was reported to reduce Fc receptor activity and 

chemotaxis in vitro, with guinea pig alveolar macrophages (BIBRA 1987). These studies 

suggest possible effects of PIP on the immune system and inflammation. 

9. Toxicity under the FHSA 

The CPSC staff concludes that there is limited evidence of neurotoxicity in animals. Although 

PIP is neurotoxic in hens at high doses, it is very weak in comparison to other APP7s. There are 

no reports of neurotoxicity 'in humans or other mammals. There is also limited evidence of 

chronic organ effects in animals, including two poorly documented studies in rats, and 

inadequate evidence of reproductive/developmental effects in animals. Therefore, the CPSC 
staff concludes that PIP is possibly toxic in humans, based on limited evidence of toxicity in 

animals (neurotoxicity and chronic organ toxicity). 

E. Octyl Tetrabromobenzoate (OTB) 

Limited toxicity data for octyl tetrabromobenzoate (OTB) are available (reviewed in EPA 

2005a). SD rats were given single oral doses of either OTB isomer. There were no deaths, 

although exposed animals exhibited effects including piloerection and hunched posture. Thus, 

both isomers have oral LDso values >2000 mgtkg in rats. No other animal or human toxicity 

data or empirical physico-chemical properties are available. 

There is insufficient information to determine whether OTB is "toxic" under the FHSA. The only 

conclusion that may be made is that OTB is not "highly toxic" with regard to acute toxicity. In 

addition, no toxicity data on structural analogues were identified in National Library of Medicine 

databases. 

F. Melamine 

The toxicity of melamine (1,3,5-triazine-2,4,6-triamine) was reviewed by the CPSC staff 

(Thomas and Brundage 2004) and IARC (IARC 1986, 1999). Briefly, the oral LDso was 

between 3,200 and 3,800 mgkg in F344 rats (NTP 1983). Symptoms included lacrimation, 

dyspnea, intermittent tremors, paralysis, and coma. A single dose of 2,400 mgkg melamine in 

rats lead to crystalluria (dimelamine monophosphate) and diuresis (Lefaux 1968). 

A 1 % aqueous solution caused little or no irritation and did not induce sensitization on occluded 

guinea pig skin (Trochimowicz et al. 1994). Melamine was not irritating to rabbit skin at doses 

up to 1,000 mgkg for 18 hours. A 10% aqueous solution was not irritating to the eyes of rabbits, 

although the dry solid caused mild, reversible irritation. 

1. Genotoxici ty 

Melamine was not mutagenic in Salmonella with or without metabolic activation (Haworth et al. 

1983; NTP 1983). It did not induce sister chromatid exchange (SCE) in Chinese hamster ovary 

cells in vitro or micronuclei in mouse bone marrow in vivo (Mast et al. 1982a,b). Melamine 

failed to initiate papilloma formation in an initiation-promotion assay in mouse skin (Perrella and 

Boutwell, 1983). 

2. Toxicokinetics . 

In rats given a single oral dose of 14~-melamine, radiolabel was found primarily in the kidney 

and bladder (Mast et al. 1983). Ninety percent was excretedin the urine, as unmetabolized 

melamine, within 24 hours. Negligible amounts of radiolabel were found in exhaled air or feces. 
3. Suchronic and Chronic Studies 1 

F344 rats and B6C3F1 mice were given melamine in the diet at levels up to 1.8% for 13 weeks 

(Melnick et al. 1984). These doses were equivalent to 1700 mgkg-d in male rats; 1600 mag-d 

in female rats; 4700 mgkg-d in male mice; and 5900 mgkg-d in female mice. Uroliths (bladder 

stones) were found in treated animals, especially males. Ulceration of the bladder epithelium 

was observed in treated male and female mice, but this was statistically independent of urolith 

formation. Increased incidence of epithelial hyperplasia was found in treated male rats. 

In a two-year dietary study, male F344 rats and B6C3F1 mice were given 0,0.225, or 0.45% 

melamine, and females were given 0,0.45, or 0.9% melamine (Melnick et al. 1984; NTP, 1983). 

This resulted in doses of 0, 125, and 270 mgkg-d in males rats and 0,252, and 566 mag-d in 

female rats. The doses in mice were 0,327, and 688 mag-d in males and 0,367, and 964 

mgkg-d in females. The incidence of transitional-cell carcinomas of the urinary bladder was 

significantly elevated in high-dose male rats. In addition, there was a statistically significant 

association between the presence of bladder carcinoma and uroliths. In female rats, the 

incidence of chronic kidney inflammation was elevated at both the low and high dose. The 

incidence of chronic inflammation and epithelial hyperplasia of the urinary bladder and increased 

incidence of uroliths were elevated in dosed male mice. No tumors were found in male or 

female mice. 

In another study, male F344IDuCrj rats were fed melamine at 0,430, or 1200 mgkg-day for 36 

weeks. Treated animals hadurinary calculi and bladder tumors (Ogasawara et al. 1995). Cotreatment with 5% or 10% NaCl decreased the formation of both the calculi and bladder tumors. 

The increase in water intake caused by the NaCl, which increased urinary volume diluting the 

urinary melamine, was thought to be responsible for reduction in the precipitation of urinary 

melamine. Thus, decreased calculi formation was considered to be directly related to the 

reduction in bladder tumors. 

4. Reproductive and Developmental Effects 

Pregnant rats were given intraperitoneal injections of 70 mglkg on GD's 5 and 6, 8 and 9, or 12 

and 13 (Thiersch 1957). The author reporteddhat there were no toxic effects or gross 

malformations in the fetuses. 

5. Neurotoxicity 

No neurotoxicity data were available. 

6. Toxicity under the FHSA 

Melamine may be considered acutely toxic under the FHSA, although it is not highly toxic. The 

oral LDso in F344 rats was between 3,200 and 3,800 mgkg (NTP 1983). Aqueous solutions of 

melamine were non-irritating to the skin and eyes of animals. The dry solid was mildly irritating 

to the eyes of rabbits. Thus, pure melamine is possibly a mild eye irritant. Based on limited 

data, there is no evidence of teratogenicity in animals. Reproductive toxicity and neurotoxicity 

were not studied. 
Dietary melamine caused the formation 6f papillomas and transitional cell carcinomas in the 

bladder epithelium of high-dose male F344 rats in a two-year bioassay. The incidence of tumors 

was not increased in low-dose males rats, female rats, or in mice. There was a significant 

statistical association between the presence of tumors and calculi. The tumors are considered to 

result from chronic irritation from the bladder calculi, followed by epithelial hyperplasia (Burin 

et al. 1995; Meek et al. 2003; Rodent Bladder Carcinogenesis Working Group 1995). 

Although the formation of bladder calculi is possible in humans, calculi are typically not present 

in the human urinary tract for a sufficient length of time to cause epithelial hyperplasia (Burin et 

al. 1995; Meek et al. 2003; Rodent Bladder Carcinogenesis Working Group 1995). Calculi in 

humans are typically quickly voided as a result of the anatomy of the urinary tract and the 

upright, bipedal nature of humans. Therefore, the mode of action by which melamine induces 

bladder tumors in male rats is considered to be not relevant to humans. Because melamine 

caused tumors only at high doses in one sex and species, and the mode of action is probably not 

relevant to humans, melamine may be considered a possible human carcinogen, based on limited 

evidence in animals. The finding that melamine is possibly carcinogenic to humans does not 

satisfy the regulatory definition of "toxic." 
111. DOSE RESPONSE 

A. Tris(l,3-Dichloro-2-Propyl) Phosphate (TDCP) 

The LOAEL for non-cancer effects in the two-year rat study was 5 mglkg-d (Biodynamics 198 1 ; 

EPA 2005a; NRC 2000). Histopathological effects were observed in several organs, including 

the liver, kidney, spleen, parathyroid, testes, epididyrnes, and seminal vesicle. Histopathological 

effects that were significantly elevated at the LOAEL included seminal vesicle atrophy and 

decreased seminal vesicle secretory product in males, and erythroidlmyeloid metaplasia of the 

spleen in females (Table 3). A benchmark dose was not calculated in this case, due to an 

incomplete database. With the exception of liver and kidney, only a subset of animals from each 

doselsex group were subjected to complete histopathology (see also NRC 2000). None of the 

available dose-response models was able to adequately fit the available data. Therefore, an 

uncertainty factor approach was used. An overall uncertainty factor of 1,000 was applied to the 

LOAEL, including 10-fold for animal to human extrapolation, 10-fold for inter-individual 

variability, and 10-fold because a no-observed-adverse-effect level (NOAEL) was not 

established. This results in an AD1 level of 0.005 mglkg-d. 

The NRC subcommittee derived a reference dose (R~D)* of 0.005 mglkg-d (NRC 2000). 

However, the NRC subcommittee applied uncertainty factors of 10-fold for animal to human 

extrapolation, 3-fold for inter-individual variability, 10-fold because a NOAEL was not 

established, and 3-fold for an incomplete database. The CPSC chronic hazard guidelines do not 

provide for an additional uncertainty factor for an incomplete database (CPSC 1992). The 

default factor for inter-individual variability used by CPSC and others is 10-fold. The NRC 

subcommittee applied a 3-fold factor for inter-individ~al~variability in this case, because there 

was no evidence of increased sensitivity of juvenile animals from developmental toxicity stules 

(NRC 2000). They did not indicate what studies were lacking from the database. 

The CPSC staff derived a cancer unit risk (potency) estimate for TDCP, based on the incidence 

of hepatocellular tumors (carcinoma and adenoma) and tumors of the renal cortex. Benign 

tumors of the testes and adrenal cortex were not included, because no malignancies were present 

in the organ sites. Thus, it does not appear that these particular tumors would progress to 

malignancy. In addition, testicular interstitial cell adenomas have a high background rate in rats, 

and their relevance to human cancer risk is uncertain (CPSC 1992, p. 46636). Hepatocellular 

carcinomas and adenomas were combined,+ because hepatocellular adenomas are known to 

progress to carcinomas (CPSC 1992, p. 46636). Tumor incidence data for males and females 

were combined, because their unit risks differed by less than a factor of two when computed 

separately (CPSC 1992, p. 46654). 

Animal bioassay data were fitted to the multistage model using Global83 (Howe and Crump 

1983; Crump 1984), as described in the chronic hazard guidelines (CPSC 1992, p. 46654). The 

* Both the acceptable daily intake (ADI) and reference dose (RfD) are estimates of the amount of a chemical a 

person can be exposed to on a daily basis over an extended period of time (up to a lifetime) with a negligible risk 

of suffering deleterious effects. 

That is, the incidence is the number of animals with adenoma carcinoma. 
unit risk was based on the maximum likelihood estimate of extra risk, that is, the linear term (ql) 

in the model: 

where: P(D), lifetime cancer risk at dose D; qi, model parameters to be fitted. The 

parameters qi must be non-negative, and i is an integer with a value from 1 to 9. 

Unit risks for liver and renal tumors were calculated separately and then added, as described in 

the CPSC chronic hazard guidelines (CPSC 1992, p. 46654). The unit risks in animals for liver 

and renal tumors, res ectively, were 6.4x10-~ and 2.5x10-~ (mg/kg-d)-'. The overall unit risk in 2 animals was 8.9~ 10- (mg/kg-d)-'. 

Animal-to-human extrapolation was by the surface area correction, that is, the unit risk is 

proportional to body weight to the three-quarters power (CPSC 1992, p. 46654; EPA 1992). 

Mean terminal body weights in untreated controls were 612 g in males and 386 g in females 

(Freudenthal and Henrich 2000). The average of males and females was 499 g. Thus, humans 

are estimated to be 3.5-fold more sensitive than the rats: 

where: F, interspecies conversion factor, unitless; BWaimal,- average animal body weight 

(0.499 kg); and BWhumm, average human body weight (75 kg). 

By this methodology, the unit risk for kidney and liver tumors combined is estimated to be 0.031 

(mg/kg-d)-l : 

Q = F -q, =3.5x8.9~10" = 3.1~10" (mglkg -d)-' 

where: Q, unit risk in humans, (mg/kg-d)-'; F, interspecies conversion factor, unitless; 

and ql, unit risk in animals, (mg/kg-d)-'. 

The NRC subcommittee derived a unit risk of 0.06 (mg/kg-d)-' (NRC 2000). This was based on 

the incidence of testicular interstitial cell tumors in the same bioassay cited here (Biodynamics 

1981; Freudenthal and Henrich 2000). According to the NRC report, the testicular tumors were 

used because they were the most sensitive tumor site (NRC 2000). The subcommittee calculated 

the LEDlo, that is, the 95a lower confidence limit of the dose at which the cancer risk is 0.1, 

using the multistage model. Linear extrapolation was then used to calculate the unit risk. 
B. Triphenyl Phosphate (TPP) and Phenol Isopropylated Phosphate (PIP) 

Previously, the CPSC staff concluded that there were sufficient data to derive AD1 values for 

three of the 10 aromatic phosphates or mixtures that the staff reviewed: Santicizer 148 (roughly 

90% isodecyl diphenyl phosphate), 0.01 mgkg-d; TCP isomers, 0.05 mgkg-d; and 2-ethylhexyl 

diphenyl phosphate, 1.0 mglkg-d (Bittner et al. 2001; Ferrante 1999b) (see Table 2). The NRC 

subcommittee derived an RfD of 0.07 mgkg-d for TCP isomers. 

The CPSC staff also concluded that there was insufficient information to derive AD1 levels for 

PIP or TPP (Ferrante 1999a; Bittner et al. 2001). There are no subchronic or chronic studies 

with full histopathology for either compound. For the purpose of the present preliminary risk 

assessment, estimated exposures to these compounds will be compared to the AD1 values for 

other aromatic phosphates, which range from 0.01 to 1.0 mgkg-d (Bittner 2001; Bittner et al. 

2001; Ferrante 1999a) (see Table 2). 

C. Octyl Tetrabromobenzoate (OTB) 

There is insufficient information to derive an AD1 value for OTB. No structurally related 

compounds were identified that had sufficient data to derive an ADI. 

D. Melamine 

Melamine did not satisfy the FHSA definition of "toxic." Therefore, an AD1 cannot be 

calculated. A quantitative risk assessment is not needed to determine whether products 

containing melamine may be hazardous (CPSC 1992). 
IV. EXPOSURE AND BIOAVAILABILITY 

As in previous risk assessments involving FR chemicals, exposure was estimated by analyzing 

various exposure scenarios (Babich and Thomas 2001; Thomas and Brundage 2006). This was 

accomplished through a combination of laboratory studies and mathematical models. Dermal, 

inhalation, and oral exposure routes were included. Inhalation exposure considered both vapor 

phase and particles. Separate exposure estimates were made for adults and small children. 

A. Laboratory Studies 

The CPSC staff conducted laboratory studies to estimate the possible migration of FR chemicals 

from upholstery foam (Cobb and Bhooshan 2005). Experiments utilized a mock-up consisting of 

a 9x9~s-inch (23x23~ 1.25 cm) sheet of plywood supporting a 3-inch thick slab of the FR-treated 

upholstery foam to be tested (Figure 4). The foam was covered by a standard non-FR fabric 

(50-50 cotton-polyester blend). No interliner or batting was present in the mock-up, because 

some upholstered furniture does not have these components. The presence of an interliner or 

batting might be expected to reduce migration. The mock-up and experimental methods were 

adapted from the staff exposure and risk assessment for mattresses (Cobb 2005; Thomas and 

Brundage 2005). Three foam samples that could be used to meet the draft flammability standard 

were tested. Foam "S" contained 6.6% TDCP, foam "Y" contained 3.5% TDCP and 11% 

melamine, and foam "Z contained 6% FM-550TM and 2.8% melamine (Cobb and Chen 2005). 

Foams S and Z contained the highest TDCP and FM-550TM concentrations among the samples 

available for testing. 

To study the potential for dermal and oral exposure, the mock-up was wetted with 25 mL of 

isotonic saline solution (0.9% NaCl). Two 55 mm diameter pieces of #2 filter paper were placed 

on the wetted portion and covered with weights. The weights were 2 inches in diameter (5.1 cm) 

and weighed 3.14 pounds (1.4 kg), resulting in one pound per square-inch (psi) of pressure (6.9 . 

kPa). After 6 hours, the filter paper was removed and analyzed for FR content. The test was 

repeated with the same foam sample for up to eight consecutive days. FR chemical in the filter 

paper is assumed to be available for transfer to the shn or mouthing by children (Thomas and 

Brundage 2006). FR chemicals on the skin can be absorbed percutaneously or transferred to the 

mouth by hand-to-mouth activity. Foams S and Y were each tested once. Two specimens of 

foam Z were tested, one for 4 days and the second for 8 days. The average migration from each 

iteration was used to estimate exposure. 

Experiments were also conducted to estimate the release of particles containing FR chemicals 

into air (Cobb and Bhooshan 2005). Mock-ups were subjected to repetitive impaction with an 

air-driven piston attached to a 4-inch diameter semi-spherical form.. Mock-ups were impacted 

100,000 times at a rate of 1 per second and 3 pounds per square inch pressure. Tests were done 

inside a closed, inflatable glove bag supported by a metal frame, with a volume of 216 L. 

Recirculated air was continuously sampled at a rate of 2 L per minute to collect inhalable 

particles. The total amount of particulate phase FR chemical collected was assumed to be 

released during the lifetime of the furniture. Duplicate samples of foam S and Z were tested. 

Foam Y was not subjected to this test. Three filter cassettes were used in each test. 
COVER 

FABRIC 

FOAM 

Figure 4. Mock-up for exposur= studies 

B. Calculations 

To estimate dermal exposure, it is assumed that an external liquid phase facilitates the transfer of 

FR chemical from the foam to the surface of the cover fabric and then to the skin (compare NRC 

2000). During normal use, that is, whlle sitting on furniture, perspiration is assumed to be the 

liquid phase. The amount of FR chemical migrating to the fabric surface was measured in the 

laboratory as described above (Cobb and Bhooshan 2005). 

The AD1 and unit risk values for the chemicals of interest are derived from oral studies. The 

bioavailability, that is, the fraction of the applied dose that is absorbed, generally varies for 

different exposure routes. Therefore, in calculating exposure and risk from dermal and 

inhalation exposure, it is appropriate to make a route-to-route adjustment to account for 

differences in bioavailability (Babich and Thomas 2001). 

The average daily dose (ADD) from dermal exposure was calculated by: 

ADD, = Ma F.S.K,.T 

W.B 

where: ADDD, average daily dose from dermal exposure, mglkg-d; M, amount of FR 

chemical that migrates to the fabric surface, mg/cm2; F, fraction of liquid phase transferred 

to the skin, unitless; S, skin surface area exposed, cm2; KT, percutaneous absorption rate, 

h-l; T, exposure duration, hld; W, body weight, kg; and B is the oral bioavailability, 

unitless. 

Oral exposure may occur either by direct mouthing of furniture cover fabric or by hand-to-mouth 

activity. As with dermal exposure, migration of FR chemical from foam is assumed to be 

mediated by an external liquid phase, in this case saliva. The amount of FR chemical migrating 

to the surface of the cover fabric was estimated in laboratory studies as described above (Cobb 
and Bhooshan 2005). The average daily dose from indirect mouthing, that is, hand-to-mouth 

activity was calculated by: 

M-F .SH-FH ADD,, = W 

where: ADDoH, average daily dose from hand-to-mouth activity, mglkg-d; M, amount of 

FR chemical that migrates to the fabric surface, mg/cm2; F, fraction transferred from the 

fabric to the hand; SH, surface area of the hand that is mouthed, cm2; FH, hand to mouth 

transfer factor, d-l; and W, body weight, kg. 

The average daily dose from direct mouthing activity was calculated by: 

M-S, .FM ADD,, = W 

where: ADDoM, average daily dose from direct mouthing activity, mgkg-d; M, amount of 

FR chemical that migrates to the fabric surface, mg/cm2; SM, surface area of fabric that is 

mouthed, cm2; FM, fabric to mouth transfer factor, d-l; and W, body weight, kg. 

The total oral exposure is given by: 

M(F.SH .FH +SM -F,) ADD, = W 

where: ADDo, average daily dose from oral exposure, mgkg-d; M, amount of FR chemical 

that migrates to the fabric surface, mg/cm2; F, fraction transferred from the fabric to the 

hand; SHY surface area of the hand that is mouthed, cm2; FH, hand to mouth transfer factor, 

d-l; SM, surface area of fabric that is mouthed, cm2; FM, fabric to mouth transfer, d-l; and 

W, body weight, kg. 

Inhalation exposure may occur from the release of semi-volatile FR chemicals into the vapor 

phase or from the release of FR-containing particles during normal wear or aging. The release of 

FR-containing particles was measured in the laboratory as described above (Cobb and Bhooshan 

2005). The total amount of particle-bound FR chemical released during the accelerated wear test 

was assumed to be released over the lifetime of the furniture (compare Thomas and Brundage 

2005). Inhalation exposures were estimated using a two-zone mass balance model, where zone 1 

is the breathing zone (Thompson and Thompson 1990) and zone 2 is the room containing the 

upholstered furniture. The source of FR emissions is located in the breathing zone. 

The average daily dose from inhalation exposure to vapor phase FR chemical was calculated by: 
where: ADDIv, average daily dose from inhalation exposure of vapor phase chemical, 

mglkg-d; Cvl, CV2, concentrations of .vapor phase FR chemical in zones 1 and 2, 

- respectively, mg/m3; TI, T2, exposure duration in zones 1 and 2, h; FR chemical in zone 2, 

the living or family room, mg/m3; exposure duration in zone 2, h; I, average inhalation rate, 

m3/h; W, body weight, kg; and B, oral bioavailability, unitless. 

The concentration of vapor phase chemical was calculated from a two-zone mass-balance model 

(NRC, 1981). This model assumes that the outdoor concentration of FR chemical is zero, and 

that the breathing zone (zone 1) does not exchange directly with the outdoor air. Thus, the 

concentrations of vapor phase I3 chemical in zones 1 and 2 are given by: 

where: Cvl; CV2, concentrations of vapor phase FR chemical in zones 1 and 2, respectively, 

mg/m3; K, air infiltration rate, h-l; V1, volume of zone 1 (breathing zone); A, inter-zone air 

exchange rate, m3/h; Ev, source strength for vapor phase chemical, in zone 1, mgth; V1, V2, 

volumes of zones 1 and 2, m3; Kv, decay rate for vapor phase chemical; and T, time, h. 

This system of two differential equations was solved by Euler's method. The concentrations at 

12 hours were used to calculate exposure, as steady-state is generally reached before this time. 

The source strength for vapor phase FR, Ev, was estimated by means of a mathematical model 

(Babich and Thomas 2001) that is essentially similar t6 the model described by the NRC 

subcommittee (NRC 2000). The difference is that the CPSC staff separated the source strength 

and mass-balance expressions. This allowed us to change from a l-zone to a 2-zone model, for 

example. The source strength is given by: 

Ev1= 1 Csat 

H for TMm 2 P years 

TMU .41 

42= p for TMU < P years 

where: 

[10.000~~~~]~[,+1x10~S~D~~~ 

TMm = Csat - DAir - 8,766 A-V.H (8) 

and where: T,, maximum time that vapor phase FR can be released at the estimated rate, 

y; 1x10-~, to convert from cm2 to m2; 10,000, to convert from mg/cm2 to mg/m2; FRL, FR 

chemical loading rate, mg/cm2; H, boundary layer height, m; CSa, saturation concentration 
in air, mg/m3; D&, diffusivity in air, m2/h; 8766, number of hours per year; Sp, surface area 

of foam in a suite of furniture, cm2; K, air infiltration rate, h-'; V, room volume, m3; P, 

product lifetime, y;, and-Ev, source strength, mgh. 

Csat was estimated as previously (Babich and Thomas 2001): 

- MM .vP-~x~o~ 

Csal = R . Temp 

where: NIM, molecular mass, grams/mole; VP, vapor pressure, ton; 1x106, to convert 

from grams per liter to mg/m3; R, gas constant, 62.4 ton-Llmole-degree Kelvin; Temp, 

temperature (298°K). 

Dh was estimated as described by Schwope et al. (1989): 

where: DAir, m2/h, MM, molecular mass, gramslmole; and 3600/10,000 is to convert from 

cm2/sec to m2/hour. 

The average daily dose from inhalation of particle-bound FR chemical is given by: 

where: ADDp, average daily dose from inhalation exposure of particle-bound chemical, 

mglkg-d; Cpl, CP2, concentrations of particle-bound FR chemical in zones 1 and 2, mg/m3; 

TI, T2, exposure duration in zones 1 and 2, hld; I, average inhalation rate, m3/h; W body 

weight, kg; and B, oral bioavailability, unitless. 

The concentrations in each zone (Cpl, Cp2) were calculated from the two-zone mass balance 

model: - - 

where: CPl, CP2, concentrations of particle-bound FR chemical in zones 1 and 2, 

respectively, mg/m3; A, inter-zone air exchange rate, m3/h; Ep, source strength for particlebound FR chemical, mg/h; K, air infiltration rate, h-'; K;, particle decay (deposition) rate, 

h-'; and V1, V2, volumes of zones 1 and 2. 
As with equation (6) above, this system of two differential equations was solved by Euler's 

method. The concentrations at 12 hours, were used to calculate exposure, as steady-state is . 

generally reached before this time. 

Th? source strength (Ep) was estimated by: s 

where: Ep, source strength, mgh; Mp, mass of FR chemical released in the impaction 

experiment, mg; Fp, scaling factor, unitless; 24, hours per day; 365, days per year; and P, 

average product lifetime, years. Fp is the ratio of the total surface area of foam in the 

product to the area of the mock-up. 

The overall ADD value was obtained by summing the ADD values for each route of exposure: 

ADD = ADD, + ADD, +ADD, (14) 

where: ADD, total average daily dose from all routes, mgkg-d; ADDo, ADDD, and ADDI, 

average daily doses from oral, dermal, and inhalation exposure, respectively, mgkg-d. 

The lifetime average daily dose (LADD) was calculated from the ADD as follows: 

LADD = ADD -Y 

where: LADD, lifetime average daily dose; ADD, average daily dose, mgkg-d; Y, number 

of years the consumer is exposed, y; L, average life expectancy, y. 

C. Input Parameters 

1. General parameters 

General input parameters are summarized in Table 5. The average lifetime of a suite of 

upholstered furniture (P), 15 years, was estimated by industry representatives (Babich and 

Thomas 2001; NRC 2000). For the purpose of uncertainty analysis,'5 and 25 years were 

assumed to be reasonable lower and upper bounds, respectively. The average number of years of 

exposure to upholstered furniture (Y) is not necessarily the same as the average product life. A 

consumer may be exposed to several different types of furniture, which may be treated with 

different FR chemicals or none at all. For calculating cancer risk, it was assumed that adults are 

exposed to the same FR treatments for a lifetime, which is the most conservative approach. This 

assumption is only relevant to cancer risk. The average furniture lifetime (15 years) may be 

considered a reasonable lower bound for exposure duration. 
For children, an exposure duration (Y) of two years, the first two years of life, was assumed. 

Children are most likely to place objects in their mouths between 3 months and 12 months of 

age; mouthing activity declines significantly by 24 months of age (Greene 1998). Mouthing 

activity is one of the principal quantifiable differences between children and adults that may 

affect exposure to FR chemicals. The body weight, surface area, and respiration rate are also 

different in children. 

The average life expectancy (L) and average body weight (W) for adults are from the EPA 

"Exposure Factors Handbook" (EPA 1997). Body weights for males and females 45-54 years 

old were averaged (EPA 1997 Tables 7-4,7-5). The 5", 50", and 95" percentile values were 

used as the lower bound, best estimate, and upper bound, respectively. Children's body weights 

and lengths were for one-year-olds (CDC, 2000). The 5", 50", and 95" percentile values for 

boys and girls were averaged, and used as the lower bound, best estimate, and upper bound, 

respectively. 

The foam surface area, Sp, was estimated as 2.8 m2 (28,000 cm2) for a suite of furniture including 

a sofa, love seat, and chair (Babich and Thomas 2001). The seating area and seat back were 

assumed to be constructed with polyurethane foam. The average foam mass, Wp, for a similar 

suite of furniture was estimated by the Directorate for Economic ~nal~sis* to be 15 kg. 

Table 5. General Input Parameters 

Parameter Best Lower Upper Reference Estimate Bound Bound 

Body weight, W, kg 72 50 101 EPA 1997, Tables 7-4, 7-5 

Children 10 8.3 12 . "" 

CDC 2000 

Life expectancy, L, y 75 ND N 

Years of exposure, Y, y 75 15 75 

Assumptions; see text 

Children 2 2 2 

Product lifetime, P, y 15 5 2 5 

Product (foam) surface area, Sp, cm2 28,000 1 TO00 56,000 Estimates; see text 

Product (foam) mass, Wp, kg 25 ND ND 

ND, not determined. 

2. Dermal Exposure 

For estimating dermal exposure, it was assumed that the consumer is lying on a sofa and wearing 

a short-sleeved shirt and short pants (Babich and Thomas 2001; Smith 2000). Due to the 

3-dimensional shape of the limbs, it was assumed that roughly one-third of the exposed surface 

area was in contact with the furniture surface at a given time. Thus, the surface areas for the 

lower leg and arms were combined, then divided by three. For adults, median values for males 

and females were averaged (EPA 1997, Table 6-2, 6-3). The lower bound for adults was 

* Personal communication from Charles Smith, Directorate for Economic Analysis. 
assumed to be one-third the combined surface areas for the hands and feet. The upper bound was 

assumed to be one-third the total surface area. Parameters relating to dermal exposure are 

summarized in Table 6. 

For children, surface areas for body parts were available as the percentage of the total surface 

area. Mean values for the age groups <1 year and 1 to <2 years old were averaged (EPA 1997, 

Table 6-8). Data for the lower leg were not provided; thus, the lower leg was assumed to be 40% 

of the area of the entire leg, which is the case for adults. For children <2 years old, the total 

surface area was not available (EPA 1997, Tables 6-6 and 6-7). Thus, the average total surface 

area was calculated as follows (EPA 1997, Equation 6A-8 and Table 6A-1): 

where: STotal, total body surface area, m2; L, length, cm; and W, body weight (kg). 

Absolute surface areas were computed from percent areas and the total surface area. Upper and 

lower bounds were analogous to the adult values. 

An average exposure of 4 hours per day (T) for adults was estimated (Babich and Thomas 2001; 

Smith, 2000) from compiled activity data. This is the amount of time that adults and older 

children spend in "indoor/leisure" activities (EPA 1997, Table 15-8 to 15-10). Exposure 

durations of 0.5 hours and 16 hours were assumed as reasonable lower and upper bounds. 

Children up to 2 years old spend approximately 3 hours per day in "passive leisure" activities 

(EPA 1997 Table 15-12). An average exposure duration of 3 hours per day, with lower and 

upper bounds of 0.5 and 12 hours per day, was assumed. The total daily exposure duration may, 

in fact, be divided among several events. However, dividing the total exposure among several 

events does not affect the exposure calculation. 

Table 6. Input Parameters for Estimating Dermal Exposure ' . 

Parameter Best Lower Upper Reference Estimate Bound Bound 

Fabric to skin transfer F 0.13 0.024 0.84 See Table 8 

. . 

Children 35 v 

EPA 1-997; Smith 2000; see 

Exposure duration, T, h/d 4 

Children 3 0.5 12 

ND, not determined. 

Chemical-specific input parameters are summarized in Table 7. Liquid-mediated migration to 

the fabric surface (M) was measured as described above. FR chemical migrating to the filter 

paper was assumed to be deposited on the surface of the cover fabric and, therefore, available for 

transfer to the skin. The components of FM-550TM could not be quantified individually (Cobb 
and Bhooshan 2005). Migration measurements for FM-550TM are based on the OTB component. 

Thus, OTB is a surrogate for TPP and PIP. The average migration from each iteration (that is, 

from each daily measurement) was used to estimate exposure. Results from the two TDCPcontaining samples (n=16) were averaged. Results from two FM-550TM-treated specimens were 

also averaged (n=12). 

Table 7. Chemical-Specific Input Parameters 

Parameter Symbol Units TDCP TPP PIP OTB 

FR mass percent in' FRW mass 

foam 5.1 a'b 6.8 6.8 a'C 6.8 a 

; . ~e~ce-nt. ..t.ttt.t.tt.t.t.tt.....t.t..t...t.ttttttttttt... ........ ..t...........t.t.tt.... .... 

FR loading rate FRL mg/cm2 46 36 36 36 

Total FR in product FRT mg 1.3~1 o6 1x10~~ 1x10~~ 1 XI o6 

Migration to liquid M mg/cm2 1.5x10-~~'~ 4.5~10~~~~ 4.510-~~*~. 4.5~10-~~ ...... eha5e" - - ..... ................ ......... - ....... -- 

Mass released from 

impaction . ' . . MP mg 

0.001 5 <0.0004 <0.0004 <0.0004 . ..... ............................ . . -*-- .... ........... - ............... 

Oral bioavailability B unitless 0.9 1.0 1.0~ 1.0~ 

Dermal absorption rate KT h-' 0.08 ' 0.1' 0.1 ' 0.01 

Acceptable daily intake AD1 . mg/kg-d 0.005' 0.01-1.0~ 0.01-l.Om ND .... .. . .-. .- ..... . .- ................................... 

Cancer unit risk Q (mg/kg-d)" 0.031 ' N A IVA IV A 

a Measured by CPSC staff (Cobb and Bhooshan 2005; Cobb and Chen-2005). 

b Average from two samples, foam S and foam Y. 

Value is for the OTB component of FM-550TM. Individual components were not quantified. 

d Estimated from the mass percent. " Average migration from up to 8 repeated tests on consecutive days with the same sample (Cobb and 

Bhooshan 2005). In calculating the average, non-detects were regarded as one-half the detection 

limit. Converted from mg to mg/cm2 by dividing by the area of the filter paper, 24 cm2. 

f Five of 6 TDCP replicates (foam S) and 5 of 5 FM-55OTW replicates (foam Z) were below the method 

detection limit. Non-detects were regarded as one-half the detection limit. 

Matthews and Anderson 1979. 

h Default assumption. 

i Estimated from in vitro data (Hughes et al. 2001). 

j Estimated from in vivo data for o-tricresyl phosphate (Nomeir and Abou-Donia 1984). 

k Assumed (see text). 

I Estimated from two-year study in rats (Biodynamics 1981; Brandwene 2001; Freudenthal and Heinrich 

2000). 

Range of values for aromatic phosphates (Bittner et al. 2001; Ferrante 1999a). " NA, not applicable; IVD, not determined. 
FR chemical migration from the foam to the filter paper depends, in part, on the volume of liquid 

phase (25 mL) and the pressure (1 psi) applied to the filter paper. The 1 psi was based on the 

average peak pressure of an adult lying on a mattress (reviewed in Midgett 2005). Upholstered 

furniture is generally less firm than mattresses, and the consumer is typically seated. Sitting 

would increase the pressure, relative to lying down. However, some of the weight may be 

supported by the side and back of the furniture, and the feet. The relatively soft furniture would 

probably distribute the weight more evenly. 

The amount of liquid phase was based on the amount of perspiration excreted from the body 

during an 8-hour period, about 0.05 mL per square centimeter of skin area (reviewed in Thomas 

and Brundage 2005). However, the average exposure duration of adults to upholstered furniture 

is estimated as 4 hours. Therefore, the amount of saline solution may tend to overestimate 

exposure. 

Several authors have studied the transfer of various chemicals from treated textiles to human or 

animal skin. These studies were used to estimate the fraction of FR chemical transferred from 

the fabric surface (represented by the filter paper) to the skin, that is, the fabric-to-skin transfer 

efficiency (Table 8). Substances included dust particles (Rodes et al. 200 I), glyphosate and 

malathion (Wester et al. 1996), permethrin (Snodgrass 1992), riboflavin (Cohen-Hubal et al. 

2005), and TRIS (Ulsamer et al. 1978b). For the present risk assessment, the overall mean 

transfer efficiency 0.13 was assumed to be the best estimate for the transfer efficiency, with the 

minimum (0.024) and maximum (0.84) as the lower and upper bounds. The percutaneous 

absorption rate (KT) is described below (Bioavailability). 

Table 8. Fraction of Test Substance Transferred from Textile to Skin 

Substance Fraction Transferred Textile Skin Method Reference 

Dry Moist 

Dust 0.061 0.050 Carpet Human In vivo Rodes et at. 2001 . ....... . . 

Glyphosate 0.056 0.254 Cloth Human In vitro Wester et al. 1996 .............................. . . .-. . 

Malathion 0.068 0.837 Cloth Human In vitro Wester et al. 1996 

Permethrin 0.031 0.037 Cloth . Rabbit In vivo Snodgrass 1992 . .. . 

Riboflavin .- 

0.024 0.050 Carpet Human In vivo ~~hen-~ubal et al. 2004 .... . ....... - ... . -

-TRIS 0.046 0.060 Cloth Rabbit In vivo ~lsamer et al. 1978b 

Mean . 0.048 0.22 . .................. .......... . ...... - -...... - ... 

Overall Mean 

Minimum 0.024 ..-.. . 

Maximum 0.84 
3. Oral Exposure 

Oral exposure to FR chemical may occur either indirectly by transfer of FR chemical from the 

fabric surface to the hand or directly by mouthing of upholstered furniture. FR chemical on the 

hand may be ingested by hand-to-mouth contact or by transfer of FR chemical from the hands to 

food or other objects. Indirect transfer is assumed to occur in both children and adults, while 

direct mouthing is assumed to occur primarily in children. The relevant surface area for hand-tomouth activity (SH) was assumed to be the ventral surface (palm) of the hands or roughly onehalf the surface area of the hands. Parameters are summarized in Table 9. One-tenth of the best 

estimate, roughly equivalent to the fingertips, was assumed as a reasonable lower bound. The 

entire surface area of both hands, the theoretical maximum, was used as an upper bound. 

Table 9. Input Parameters for Estimating Oral Exposure 

Parameter Best Lower Upper Reference Estimate Bound Bound 

Mouthed surface area, hand, SH, cm2 450 45 900 

EPA 1997; see text 

Children 130 13 260 

Hand to mouth transfer, FH, d" 0.4 0.03 Hatlelid 2003 

Mouthed surface area, fabric, SM, cm2 0 0 50 Assumption; see text 

Children 10 0 50 CPSC 1983; NRC 2000 

Fabric to mouth transfer, FM, d-' 0.4 0.03 7 Hatlelid 2003 

ND, not determined. 

For adults, the median surface area of the hands is 0.099 m2 in men and 0.0817 m2 in women 

(EPA 1997, Tables 6-2 and 6-3). Averaging the two values and dividing by two gives 0.045 m2 

or 450 cm2. For children aged c1 and 1 to Q years old, the hands represent 5.3 and 5.7 % of the 

total body surface area, respectively (EPA 1997, Table 6-8). The total surface area was 

calculated as 0.48 m2 (equation (16)). Multiplying the total surface area by 5.5 % (the average of 

5.3 and 5.7) and dividing by two gives roughly 0.013 m2 or 130 cm2. 

For direct mouthing, a surface area (SM) of 10 cm2 was assumed for children. The CPSC staff 

has previously used values of 10 or 11 cm2 for direct mouthing (Babich et al. 2004; Babich and 

Thomas 2001; CPSC 1983). Upper and lower bounds of 0 and 50 cm2 were assumed. The upper 

bound is the value used by the NRC subcommittee (NRC 2000). For adults, zero cm2 was 

assumed as both the best estimate and lower bound, while 50 cm2 was assumed for the upper 

bound. 

Few data on the transfer of chemicals from the hand to the mouth (FH) or fabric to the mouth 

(FM) are available. For playground equipment made from pressure-treated lumber, the CPSC 

staff used an average value of 0.43 for hand-to-mouth transfer, with a range of 0.03 to 7 (Hatlelid 

2003). This was derived from the ratio of soil loading on the hands and soil ingestion (Hatlelid 

2003; Lee 1990a,b). This value was for a 24-hour period, independent of the number& 

individual mouthing events. The upper bound is greater than one, because the hand can be 
"re-loaded" during the course of a day. For the present risk assessment, an average value of 0.4, 

with lower and upper bounds of 0.03 and 7, was assumed for both hand-to-mouth and fabric-tomouth transfer. 

4. Inhalation Exposure I 

Long term average inhalation rates (I)--0.55 m3/h for adults and 0.24 m3/h for children (EPA 

1997, Table 5-23)-were used, as the exposure duration includes sleep and other indoor 

activities (Table 10). The adult value is the average for men and women. The lower and upper 

bounds for adults are for rest and light activities, respectively. For children, the upper and lower 

bounds were assumed to be proportional to the adult values. 

Consumers spend an average of 16 hours in their residence each day (EPA 1997, p.15-17). Thus, 

it was assumed that the total exposure duration for inhalation exposure is 16 h/d. The time in the 

breathing zone was assumed to be the time spent sitting on upholstered furniture, that is, the 

exposure duration for dermal exposure (see above, Table 6). Thus, the exposure duration in the 

breathing zone (TI) was 4 h/d for adults and 3 h/d for children. The time spent outside the 

breathing zone (Tz) was assumed to be the difference between the total exposure duration 

(16 hours) and TI, or 12 hours for adults and 13 hours for children. The lower and upper bounds 

for TI are also the same as for dermal exposure. The lower and upper bounds for the total time 

indoors were assumed to be 8 and 24 h/d, respectively. The total of T1 and T2 in any given 

instance cannot exceed 24 hours. Thus, the lower and upper bounds for Tz were assumed to be 

8 h/d and 23.5 h/d. 

A breathing zone of 1 m3 is typically used for estimating the exposure of a consumer to volatile 

compounds, such as arts and crafts materials (Thompson and Thompson 1990). For the present 

case, the breathing zone was assumed to include a 1 meter-high rectangle over the horizontal 

seating area of a suite of furniture. The horizontal surface area was estimated as 1.7 m2 (see 

above). Thus V1 was 1.7 m3. One-half this value was assumed as the lower bound, and twice 

this value as the upper bound. The best estimate of the room volume (V2) was assumed as the 

upper bound. The room volume (V2) was estimated as 120 m3. This represents the volume of an 

open living room, dining room, and kitchen in a typical 1,500 ft2 ranch home (CPSC 1990). 

One-half the value (60 m3) was assumed to be the lower bound. The upper bound was assumed 

to be the median total volume for U.S. residences (EPA 1997, Table 17-1). 

The average (whole-house) air infiltration rate (K) is the median value for all seasons and all 

regions of the U.S. (Koontz and Rector 1993, Table 2). The 5'h and 95'h percentiles were used as 

lower and upper bounds. 

The air exchange rate between the breathing zone and the room (A) was estimated as 17 m3/h. 

The breathing zone is an abstract volume of space, bounded only by the seating area and seat 

back of the furniture. Thus, the air exchange rate was assumed to be greater than the exchange 

between rooms or between indoors and outdoors. The value for A is equivalent to 10 air changes 

per hour (10 h-I). That is, the air in the breathing zone is replaced 10 times per hour or once 

every 6 minutes. This is, in turn, equivalent to a linear air flow ("cross-breeze") of 17 m/h or 

0.01 miles per hour. For comparison, whole house air infiltration rates are typically on the order 
of 2 h-' with the windows open (Koontz and Rector 1993). Outdoors, the air exchange rate may 

range from 10 to over 100 h-'. A one mile per hour breeze is equivalent to 160 h-l. The lower 

and upper bounds were assumed to be equivalent to 1 and 20 air changes per hour. 

Table 10. Input Parameters for Estimating Inhalation Exposure 

Parameter Best Lower Upper Reference Estimate Bound Bound 

Average inhalation rate, I, m3/h 0.55 0.4 1 .O 

EPA 1997; Table 5-23 

Children 0.24 0.1 7 0.4 .. .. - . -. .........- 

Exposure duration, in the breathing 

zone, TI, h/d 4 0.5 16 

Children 3 0.5 12 EPA 1997, Table 5-23; ......... . ........................................ see text 

Exposureduration, outside the 

breathing zone, T2, h/d a 12 8 23.5 

Children 13 8 23.5 

Volume, breathing zone, V,, m3 1.7 0.85 ' 3.4 Assumption;,see text ... - . 

Volume, room, V, m3 120 60 EPA 1997, Table 17-1 ; see 

320 text . - .- ... ......... .......... 

Air infiltration rate, K, h-' 0.4 0.1 5. 1.7 Koontz & Rector 1993 

Inter-zone air exchange rate, A, m3/h 17 I .7. 34 Assumption; see text . .. - . . 

Particle decay rate, KD, h-' 2.0 0.5 , 4.0 EPA 1997; Table 17-1 3 

Vapor phase decay rate, Kv, h-' 0 0 1 Assumption; NRC 2000 .. - . . ... . - . ... . - . 

Scaling factor, FP 60 30 120 calculated from SP 

Boundary layer height, H, m 0.01 0.001 0.1 NRC 2000; see .text -. .. - . . 

a The total of TI and T2 in any given case may not exceed 24 hours. 

Exposure to particles deposited in the nasopharyngeal (-5-30 pm), tracheobronchial (- 1-5 pm), 

and alveolar (-1 pm) regions of the respiratory tract are all relevant, because the chemicals of 

interest are systemic toxicants. Deposition rates for particles roughly corresponding to these size 

ranges include: 0.5 h-' (1 -5 pm), 1.4 h-' (5-10 pm), and 2.4 h-' (10-25 pm) (EPA 1997, Table 17- 

13). Particles released from the wear and aging of upholstered furniture components are likely to 

include a broad range of particle sizes (Stevens et al. 2003). A decay rate of 2 h-', representing 

particles from 1 to 25 pm in diameter, was considered as the best estimate. The lower and upper 

bound values were for particles in the size ranges 1-to-5 pm and >25 pm, respectively. 

The mass of FR chemical released from impaction (Mp) was measured as described above. Nondetects were assumed to equal one-half the detection limit (Table 7). All of the FM-550TM 

samples and most of the TDCP samples were non-detects. The components of FM-550TM could 

not be quantified individually (Cobb and Bhooshan 2005). Therefore, the total migration of 

FM-550TM was used to calculate exposure to each component (TPP, PIP, or Om). The total 

amount of FR chemical retained by the filters was assumed to be released over the lifetime of the 

product (15 years). 
The seating area and seat back are assumed to be constructed with polyurethane foam. This area 

was estimated as 2.8 m2 (28,000 cm2) for a suite of furniture including a sofa, love seat, and chair 

(Babich and Thomas 2001). The mock-up has a surface area of 530 cm2 or 0.053 m2 (9x9 inch). 

Thus, the scaling factor was calculated by dividing 2.8 m2 by 0.053 m3, which is approximately 

60-fold. The lower bound assumed a suite of furniture in which only the horizontal seating area 

included foam. The upper bound assumed two suites of furniture in the home, such as in a living 

room and family room. The source strength (Ep) was calculated using equation (13). 

Physico-chemical properties are summarized in Table 1 1. The saturation concentration (CSat) 

was calculated from the vapor pressure using equation (9). The diffusivity was estimated with 

equation (10). The boundary layer height was the value used by the NRC subcommittee (NRC 

2000). Values of 0.1-fold and 10-fold were assumed as lower and upper bounds. The decay rate 

for vapor phase FR was assumed to equal zero (Babich and Thomas 2001; NRC 2000). A value 

of one was assumed as an upper bound. 

Table 11. Physico-Chemical Properties 

Parameter Symbol Units 'TDCP TPP PIP a OTB 

Molecular mass MM dm01 430.91 326.29 368.37 549.93 " " " " " " -....-...u-......--..--" 

vapor pressure VP torr 2.7~1 o-' 6.3~1 0-6 Csd 3.5x10-' dse <1xl0-~~ 

Saturation 

concentration in air Csat ' m g/m 0.63 0.24 0.0069 0.01 5 " " *...- 

Diffusivity in air Dair m2/h 0.012 0.01 3 0.01 3 0.01 0 " " 

Octanol-water partition 

coefficient.' Log Kow unitless 3.65 4.59 5.31 8.75, 12.0' 

a Data are for c-IPDP, a component of PIP 

b Extrapolated from data for TDCP-treated foam in Cobb and Bhooshan 2005. 

Extrapolated from empirical data [EPA 2005a, SRC 2006). 

d Syracuse Research Corp. physical properties database, accessed through the National Library of 

Medicine ChemlD database. June 2006. 

. Model estimate. 

f Upper bound model estimate (EPA 2005a). One-half this value (5x10-') was used to estimate Csat. 

Calculated from the vapor pressure and molecular mass. 

Estimated as described in Schwope et al. 1989. ' The log Kow is not required for the risk assessment. It is included for discussion purposes. 

Model estimates for the two component isomers (EPA 2005a). 

The physical properties of o-PDP (28108-99-8) were used for PP. PDP is a component of PIP, 

which is a complex substance. The molecular mass of OTB was calculated from the molecular 

formula (Cobb and Bhooshan 2005). The vapor pressure of OTB is an upper bound estimate I 

from a mathematical model (EPA 2005a). Because it is an upper-bound, one-half the upper 

bound estimate was used to estimate exposure. The vapor pressure of PDP is an estimated value 

(SRC 2006). The log Kow values for the two OTB isomers are model estimates. The log KowYs 

of TDCP, TPP, and IPDP are empirical (SRC 2006). Log Kow is not required for the risk 

134 
assessment calculations, but is useful in comparing the other physico-chemical and biological 

properties of environmental contaminants. 

The effective saturation concentration of TDCP was extrapolated from data in Cobb and 

Bhooshan (2005). TDCP-treated foam was placed in a sealed flask. The TDCP concentration in . 

the air inside the flask was measured at 65°C and 120°C. The concentration at 25°C was 

estimated from a plot of the logarithm of the concentration against the reciprocal of the absolute 

temperature, by analogy to the Clausius-Clapeyron equation: 

I 

where: m, slope; and C1, C2, concentrations (mg/m3) at temperatures T1 and T2 (OK). 

The concentration at 25°C (273°K) was then calculated from: 

5. Bioavailability 

In general, little information on the bioavailability of the chemicals of interest was available. 

The AD1 values are based on oral studies. The oral bioavailability of TDCP was reported to be 

about 90% (Matthews and Anderson 1979). In the absence of appropriate data, the 

bioavailabilities of the other chemicals are assumed to be 100% (CPSC 1992). 

Inhalation may also contribute to total FR chemical exposure. In the absence of appropriate data, 

100% of inhaled FR chemical, whether in the vapor phase or bound to particles, is assumed to be 

absorbed. 

Dermal exposure is likely to be a significant exposure route for FR chemicals in upholstered 

furniture. The percutaneous absorption rate for o-TCP, estimated from animal studies, .was used 

for the aromatic phosphates TPP and PIP. A dose of 50 mg radiolabeled o-TCP dissolved in 

acetone was applied to the clipped necks of cats (Nomeir and Abou-Donia 1984). The acetone 

was evaporated under a stream of air. The application site was approximately 10 cm2. Thus, the 

specific dose was approximately 5 mg/cm2. After 12 hours, 73% of the applied dose was 

absorbed. Assuming lSt-order kinetics, the absorption rate was about 0.1 h-l: 

where: FA, fraction of applied dose absorbed, unitless; KT, percutaneous absorption rate 

(or transfer rate), h-l; and T, time, h. 
Solving for KT: 

-ln(l- FA) KT = T 

The percutaneous absorption rate (KT) for TDCP was derived from in vitro studies using hairless 

mouse skin (Hughes et al. 2001). It is the same value used previously by the CPSC staff (Babich 

and Thomas 2001). 14c-~abeled TDCP was applied to the skin by solvent deposition. At 24 

hours, from 39 to 57% of the applied dose was found in the receptor fluid. From 28 to 34% was 

found in the skin, after unabsorbed TDCP was removed by thorough washing. The percentage 

absorption at 24 hours, including TDCP in both the receptor fluid and skin, was used to estimate 

the percutaneous absorption rate. Total absorption of TDCP ranged from 73 percent to 85 

percent of the applied dose, depending on the applied dose (0.014 to 0.14 pg/cm2). Based on 85 

percent absorption at 24 hours, and assuming lSt-order kinetics, the percutaneous absorption rate 

for TDCP was estimated as 0.08 h-l. 

No data relating to percutaneous absorption of OTB were available. The OTB isomers are 

expected to be extremely hydrophobic, with predicted log &, values of 8.75 and 12 (EPA 

2005a). The molecular mass (549.93) is relatively high. Percutaneous absorption generally 

increases with increasing &, and decreases with increasing molecular mass (Potts and Guy 

1992). Other brominated FR chemicals reviewed by the CPSC staff include DBDPO and 

HBCD. HBCD was absorbed at a rate of approximately 0.003 h-' (Babich and Thomas 2001), 

based on in vitro studies (Hughes 2000). In the same study, DBDPO was absorbed at a rate of 

0.001 h-I to 0.01 h-I (Babich and Thomas 2001), depending on the applied dose (Hughes 2000; 

Hughes et al. 2001). In the absence of appropriate data, a value of 0.01 h-' was assumed for 

OTB. 
V. RISK 

The potential risk from non-cancer endpoints is evaluated by calculating the hazard index (HI), 

which is the ratio of the ADD to the acceptable daily intake (ADI), that is: 

ADD HI =- ADI 

where: HI, hazard index, unitless; ADD, overall average daily dose, mgkg-d; and ADI, 

acceptable daily intake, mglkg-d. 

When the HI is greater than one, the product or exposure scenario under consideration is 

considered to present a hazard to consumers. 

The lifetime individual excess cancer risk was calculated by: 

where: R, lifetime individual excess cancer risk; Q, unit cancer risk or cancer potency, 

(mag-d)-'; and LADD, lifetime average daily dose, mag-d. 

The results of the exposure and risk assessment are summarized in Table 12. 

A. Tris(l,3-Dichloro-2-Propyl) Phosphate (TDCP) 

The estimated HI for non-cancer effects is 2 in adults and 5 in children. Thus, the estimated 

exposure exceeds the ADI. The estimated lifetime individual cancer risk in adults is 300 per 

million, based on a lifetime of exposure to'furniture with similar levels of TDCP. The estimated 

cancer risk in children from two-years of exposure to TDCP-containing furniture is 20 per 

million. Cancer risks greater than one-in-a-million are considered relevant for regulatory 

consideration under the CPSC chronic hazard guidelines (CPSC 1992). In both adults and 

children, inhalation of vapor phase TDCP contributed the largest fraction, over 95%, of the total 

exposure. TDCP exposure from the dermal and oral routes, is based on migration measurements 

using a mock-up (Cobb and Bhooshan 2005). TDCP exposure from inhalation of airborne 

particles is also based on studies with the mock-up. The exposure estimate for vapor phase 

TDCP is based on a mathematical model. Empirical data on inhalation exposure to vapor phase 

TDCP are needed to assess whether TDCP may present a hazard to consumers. 
Table 12. Exposure and Risk 

Result TDCP - TPP a - PIP a - OTB 

Adults Children Adults Children Adults Children Adults Children 

ADD (mglkg-d) 9.5~10" 2.6x10-* 1.8~1 4.8~10" 1.8~1 c4 4.0~1 o-~ 2.0~1 0"'5.5~1 o-~ . ---." . . . .......... . 

Percent of total: 0 .. . -,.. .. .- ..........-.. ... .... - . . . .............. ..... .................... 

Dermal 1.7 0.7 3.6 1.4 35.3 17.4 2.9 . 1.1 . . .. . ... ..-. . 

Oral, indirect 0.5 0.4 0.9 0.6 8.5 7.8 7.7 5.7 . ... . - ...... ...... .- 

Oral, direct 0.0 0.2 0.0 0.4 0.0 ' . 4.6 0.0 3.4 

Inhalation, vapor 97.7 98.7 95.6 97.5 56.2 70.1 89.4,. 89.8 ... . ... . .- ..... . . . . . ",,-" ........ .- .. . ... .,,-,,* --..- ..... .- 

Inhalation, particles 0.0 0.0 0.0 0.0 0.0 0.0 0.0' 0.0 

AD1 (mglkg-d) 0.005 

........... ........ - ........ ....... . -... - .. - ....... -" . ........ ......... ....... . .- . ... 

LADD (mglkg-d) 9.5~10" 7.4~1 o-~ 1.8~1 o-~ 1.3~1 1.8~1 c4 1 .1x10-~ 2.0~10.~ 1.5~1 o-'

Cancer risk per million 300 

ADD, average daily dose; HI, hazard index; LADD, lifetime average daily dose; ND, not determined. 

a Deimal, oral, and airborne particle exposures are based on measurements of the OTB component of FM-550TM (Cobb and Bhooshan 2005). 

b Inhalation exposure to vapor phase FR chemical is based on a mathematical model (see text). 

Insufficient data were available to derive ADl's for TPP and PIP. The Hl's a're based on the range of AD1 values for other aromatic phosphate 

plasticizers (Ferrante 1999a). 

d Insufficient data were available to derive an AD1 for OTB or related compounds. 
B. Triphenyl Phosphate (TPP) 

There was insufficient information to derive an AD1 for TPP. Therefore, the ADI's for other 

aromatic phosphates (0.01 to 1 mgkg-d) were used to calculate a range of hazard indices. The 

estimated HI, based on non-cancer effects, ranges from 0.002 to 0.2 in adults and 0.005 to 0.5 in 

children. As with TDCP, inhalation of vapor phase TPP contributed the largest fraction of the 

total estimated exposure, over 95%. TPP exposure from the dermal and oral routes is based on 

migration measurements for the OTB component of FM-550TM (Cobb and Bhooshan 2005). 

TPP exposure from inhalation of airborne particles is based on measurements of OTB release. 

Exposure to vapor phase TPP was estimated by a mathematical model. Empirical data are 

needed to estimate TPP exposure more accurately. 

C. Phenol Isopropylated Phosphate (PIP) 

There was insufficient information to derive an AD1 for PIP. Therefore, the ADI's for other 

aromatic phosphates (0.01 to 1 mgkg-d) were used to calculate a range of hazard indices. The 

estimated HI, based on non-cancer effects, ranges from 0.0002 to 0.02 in adults and 0.0004 to 

0.04 in children. Znhalation of vapor phase PIP contributed about 56% of the total estimated 

exposure in adults and 70% in children. Dermal exposure contributed about 19% in adults and 

9% in children. PIP exposure from the dermal and oral routes is based on migration 

measurements for the OTB component of FM-550TM (Cobb and Bhooshan 2005). PIP exposure 

from inhalation of airborne particles is based on measurements of OTB release. Exposure to 

vapor phase PIP was estimated by a mathematical model. Empirical data are needed to estimate 

PIP exposure more accurately. 

D. Octyl Tetrabromobenzoate (OTB) 

There was insufficient information to derive an AD1 for OTB or related compounds. The 

average daily dose was estimated to be 2.0x10-~ mgkg-d in adults and 5.5x10-~ in children. Over 

89% of the total estimated exposure in adults and children was from inhalation of vapor phase 

OTB. Exposure to vapor phase OTB was estimated by a mathematical model. . E. Sensitivity Analysis 

A sensitivity analysis of the exposure model was conducted to assess variability and uncertainty. 

This was done by individually adjusting input parameters to the lower or upper bound, and then 

determining the relative effect (ratio) on the estimated average daily dose (ADD). This was done 

in a route-specific manner. That is, the effect of varying parameters that apply to multiple routes 

was based on the total ADD. The effects of varying parameters that apply only to dermal, oral, 

or inhalation exposure, were based on ADDD, ADDo, and ADDI, respectively. TDCP exposure 

was the basis for the sensitivity analysis (Table 13). 
Table 13. Route-Specific Sensitivity Analysis 

I Best I . . Parameter . / Estimate 1 Lower Bound I Upper Bound . iiiiiiiii iiii ..... L .- ... - ..... I 

i 

j 

I value Ratio I . Value Ratio 

f All Routes i I i i Body weight, W, kg . 1 72 i 50 1.4 1 105 0.7 

Years of exposure, Y, y 15 1.0 1 75 1 .O 

Product 

Product 

; lifetime, >P, y i : 15 1 5 -1.0 I i 25 I .O ......... i.i.-.i-. .~.....i..i..i.i.i..i.i~i... ...... .ii ...i...i.......i..+... -. .... .. ..... 

surface area, Sp, cm2. / 28,000 1 17,000 0.6 , 56,000 . 1.9 

i Dermal I i I 

i i 

I i Fabric to skintransfer, F 1 0.13 1 0.024 0.2 1 0.84 6.5 

Surface area of exposed skin, S, cm2 ( 1,700 1 700 0.4 1 . 6,000 3.5 

i 

Exposure duration, T, h/d " / 4 I 0.5 0.1 I 16 4.0 I I j Oral . , i 

i 

Mouthed surface area, hand, SH, cm2 1 450 ( 45 0.1 1 900 2.0 I 

Hand to mouth transfer, FH, d-' 1 0.4 ( 0.03 0.1 1 7 17.5 i 

~~uthed surface area, fabric, S, cm2 I 0 I 0 -- ! 50 . "- .. ............. I . ................................. . i ...i...i~..ii..i~i..ii.i.ii..i..ii.i..iiii.iiiiiii.iiiiii.iii..ii.ii.. .-.L . - . . . . 1.8 

Fabric to mouth transfer, FM, d-' 1 i 0.4 1 i 0.03 1.0 1 .7 1 .O ; .......... 4 2 . . - 

Fabric to skin transfer, F / 0.13 0.024 0.2 1 0.84 6.5 

i ! Inhalation i 

i 

Average inhalation rate, I, m3/h i 0.55 1' 0.4 0.7 1 .O 1.8 . -.. i . i . . .-*- .. .... i Exposure duration, breathing zone, j ! 0.5 TI, h/d 0.5 j 24 2.7 .- . . .- . i 4 ; 

Exposure duration, outside breathing 1 i I. 12 1 2, 

8 0.8 23.5 zone, TP, h/d 0.9 a 

, ................................................................................................................................................................................ -. ...... .....I....... . +." + 

Scaling factor, FP 30 1.0 I - 120 , I -0 i 

Breathing zone volume, V1,' m3 1 1.7 1 - 0.85 1.0 I 3.4 1 .O .. ................. . ....... . .... iii.ii~iiiii..iiii.iiii.iiiiiiii.i.iiiii.~ ........................................ ......- .. 2 - . ........-..... ......... - ....... - ........ ....... i Room volume;V2, m3 / 120 / 60 1.5 f 320 0.9 .. L . ..-r ................... . 4 .... - - ..................... 

Air infiltration rate, A, hi' I -0.4 1 0.15 1.6 1 1.7 0.6 

Inter-zone exchange rate, m3/h 

i Particle decay rate, KD, h-' 1, 2.0 ] 0.5 1.0 I 4.0 1 .O ...... ......... ....... :. . ............ :. i Vapor phase decay rate, Kv, h-' 10 0 -- i i 0.6 . ....... .. .. 4 . .. ................... 

Boundary layer height, H, m 1 0.01 / 0.001 2.9 / 0.1 0.1 

This sensitivity analysis is based on the estimated TDCP exposure to adults. The ratio is the relative 

effect on the ADD when parameters are varied individually from the best estimate to the lower or upper 

bound. Ratios for parameters affecting all routes are based on the total ADD. Ratios for the dermal, oral, 

and inhalation parameters are based on ADD(D), ADD(O), and ADD(I), respectively. 

a TI was set to the lower bound so that T1 + T2 I24 h. 
Varying the parameters that affect all routes-body weight, years exposed, product lifetime, and 

product surface area-had very small effects on the overall average daily dose. Varying these 

parameters generally had a small effect on cancer risk, except that the cancer risk is directly 

related to years of exposure (Table 14). , 

Table 14. Sensitivity of Cancer Risk to Selected Parameters 

Parameter I Best / Lower Bound 

i Estimate l Upper Bound i ........ : . . - L. 4 . . : . : . 

i ! Value Ratio Value Ratio 

Body weight, W, kg , 72 1 I 50 1.4 / 105 0.7 ....... .- . iiiiiiiii ..... .............. .......... 4 ............. ... 

Years of exposure, Y, y , 1 75 1 15 0.2 1 -- -- .- ... .- L . ...LLL.......L..... .L,...LL~ jii .......... - .i.i..i.i ....... ............... .-..1 . I Product lifetime, P, y i 15 5 1.0 ( 25 1 .O . ....................................................................................................................................................... j . 

Product surface area, Sp, cm2 / 28,000 , 17,000 0.6 ] 56,000 1.9 

This sensitivity analysis is based on the estimated cancer risk in adults exposed to TDCP in upholstery 

foam. The ratio is the relative effect on risk when parameters are varied individually from the best 

estimate to the lower or upper bound. 

By varying the dermal exposure parameters, the estimated dermal exposure ranged from roughly 

one-tenth to 7 times the best estimate (Table 13). The hand-to-mouth transfer factor had a 

substantial effect on oral exposure; the estimated oral exposure ranged from one-tenth to almost 

20-fold, relative to the best estimate. Most of the inhalation parameters had less than a 3-fold 

effect on exposure. 

Changing the inter-zone air exchange rate to the lower bound resulted in a 5-fold increase in 

exposure. Increasing the boundary layer height to the upper bound reduced exposure to 

one-tenth. Reducing the boundary layer height to the lower bound increased exposure by 3-fold. 

A sensitivity analysis was also performed using input parameters for children (Table 15). For 

children, the fabric-to-mouth transfer factor had a significant effect, due to the direct mouthing 

scenario. Raising this factor to the upper bound resulted in a 12-fold increase in oral exposure. 

The fabric-to-skin transfer factor also had a substantial effect on oral exposure, due to indirect 

mouthing. All other results (not shown) were essentially similar to those for adults. 

Generally, the chemical-specific input parameters (Table 7) were based on limited data. For 

example, the amount of chemical migrating to the liquid phase (M) and the amount released from 

impaction were (Mp) measured with a limited number of samples and limited number of 

replicates. Thus, the uncertainty in these values cannot be assessed. The equations for dermal 

(1) and oral (4) exposure are linear and, therefore, the variance in migration (M) would lead to a 

proportional effect in dermal and oral exposure. Although the equations for inhalation exposure 

are nonlinear, the concentrations in the breathing zone (C1) and the room are (Cz) are 

proportional to the source strength (not shown). The source strength (Ep) for particle-phase F'R 

chemical is proportional to the amount released by impaction (Mp), as in equation (13). Thus, 
the variance in the amount released from impaction (Mp) would lead to a proportional effect in 

the inhalation exposure to particles. 

Information on the uncertainties of the physico-chemical properties (Table 11) is generally not 

available. The precisions of empirical measurements are not usually reported. Several of the 

values used here are model estimates or extrapolated values, including the vapor pressures for 

TPP, PIP, and OTB. The saturation concentration in air (CSat) and diffusivity (D~) were 

estimated. 

Table 15. Sensitivity Analysis of Oral Exposure to Children 

Parameter 

. j 

Best I Lower Bouna , : Upper Bound 

i I Estimate I value Ratio . , Value Ratio 

. . 

Mouthedsurface area, hand, SH, cm2 1 130 1 13 0.4 , 260 1.7 

I Hand to mouth transfer, FH, d-' 1 0.4 1 0.03 0.4 1 7 12 

0 ! Mouthed surface area, fabric, SM, cm2 1 10 1 0.6 1 50 2.5 

Fabric to mouth transfer, FM, d-' 1 0.4 1 0.03 0.7 1 7 7.3 : 

Fabric-to skin transfer, F 1 0.13 1 0.024 0.5 1 0.84 4.5 1 

This sensitivity analysis is based on the estimated oral TDCP exposure to children. The ratio is the 

relative effect on the oral average daily dose when parameters are varied individually from the best 

estimate to the lower or upper bound. 
VI. DISCUSSION 

This risk assessment should be considered preliminary due to data gaps in several areas. 

Insufficient toxicity data were available to derive ADI's for TPP, PIP, and OTB. Only three 

foam samples were subjected to exposure testing, and the components of FM-550TM (TPP, PIP, 

and OTB) could not be individually quantified. No empirical data on emissions of vapor phase 

chemicals were available. Thus, a mathematical model was used to estimate exposure. 

However, the lack of vapor pressure data for TPP, PIP, and OTB severely limits the usefulness 

of the vapor phase model. Data on vapor phase emissions are critical, because inhalation of 

vapor phase FR chemical appears to contribute the greatest portion of the total exposure. 

A. Toxicity 

There was a general lack of inhalation toxicity studies, which is significant because inhalation 

appears to be the most impoftant route of exposure. 

There are no data relating to possible interactions among aromatic phosphates and OTB. 

There are no data to evaluate the relative sensitivity of children or juvenile animals to any of the 

FR chemicals under consideration. Exposure to carcinogens early in life or in utero may lead to 

an increased cancer risk (reviewed in EPA 2005b). No adjustments were applied to account for 

the possible increased sensitivity of children (CSPC 1992). Thus, the risk assessment for 

children is based only on differences in exposure. The HI'S calculated for children are 

conservative in that they are based on a two-year exposure period, while the ADI's used to 

calculated the HI'S are generally based on a lifetime of exposure. 

The cancer risk in children represents the contribution to the lifetime risk from exposure during 

the first two years of life. Because only children are exposed by direct mouthing, the risk from 

this route of exposure may be added to the risk in adults to obtain the true lifetime risk. 

'However, the estimated cancer risk from mouthing is negligible in comparison to the lifetime 

cancer risk in adults 

Limited toxicological and bioavailability data are available for the components of F'M-550TM. 

No toxicological data on the mixture is available. There was insufficient information to derive 

AD1 values for TPP, PIP, or OTB. TPP and PIP are members of a broader class of compounds, 

the aromatic phosphate plasticizers, that has been reviewed by the CPSC staff. AD1 values for 

other aromatic phosphates, including mixtures, were used as surrogates for TPP and PIP. These 

other AD1 values ranged from 0.01 to 1.0 mglkg-d (Ferrante 1999a; Bittner et al. 200 1). 

Although several aromatic phosphates have been studied in subchronic studies, only two have 

been tested in chronic studies. The CPSC staff has nominated the aromatic phosphates, as a 

class, for additional testing by the National Toxicology Program (NTP). 

There was insufficient information to assess the acute toxicity of OTB, and no information on 

chronic toxicity. Furthermore, no toxicity data for structurally-related chemicals were identified. 

Thus, an AD1 and HI could not be estimated. 
2. Melamine 

Melamine has been well studied in comparison to TPP, PIP, and OTB, including two-year 

studies in mice and rats. The CPSC staff concludes that melamine does not satisfy the regulatory 

definition of "toxic." However, we note that the database includes no neurotoxicity or 

reproductive studies, and only one limited developmental screen. 

3. Tris(l,3-Dichloro-2-Propyl) Phosphate (TDCP) 

TDCP has also been well studied, including a two-year study in rats. This study was sufficient to 

derive a chronic AD1 level and cancer potency estimate. However, inhalation appears to be the 

primary route of exposure, whereas the bioassay was by the oral route. Differences in absorption 

(i.e., bioavailability), distribution, and metabolism between exposure routes could significantly 

affect toxicity and carcinogenicity. 

No information on the inhalation bioavailability of TDCP was available. heref fore, we made the 

default assumption that 100% of inhaled TDCP was absorbed. To the extent that the 

bioavailability is less than loo%, the inhalation exposure and resulting risk will be 

overestimated. 

Any chemical absorbed through the lungs will enter the systemic circulation prior to being 

metabolized in the liver. Thus, systemic exposure to the parent compound may be increased. 

The effect of increased systemic exposure depends on whether the parent compound or a 

metabolite is the proximate toxic species. If the parent compound is responsible for either 

carcinogenicity or non-cancer effects, then the effective dose and its resulting risk may be 

underestimated. 

TDCP is metabolized to the diester plus 1,3-dichloro-2-propanol (Nomeir et al. 1981; Sasaki et 

al. 1984). The alcohol is further metabolized to 3-chloro-l,2-propanediol. TDCP is also directly 

conjugated by glutathione. The species responsible for toxicity and carcinogenicity are 

unknown, and need not be the same. TDCP is a phosphotriester and , thus, could be an 

alkylating agent. TDCP formed adducts with protein and DNA in mice (Morales and Matthews 

1980). Thus, direct alkylation by TDCP might contribute to either organ toxicity or 

carcinogenicity. TDCP is, at best, weakly mutagenic. The diester was not mutagenic in 

Salmonella, while the diol metabolite was weakly mutagenic (Gold et al. 1978). However, the 

putative metabolite 1,3-dichloro-2-propanone was a strong direct-acting mutagen. This suggests 

that a metabolite may be responsible for carcinogenicity andlor toxicity. 

Overall, TDCP was weakly genotoxic in bacteria and in some mammalian systems. It was 

generally less mutagenic than the structural analog TRIS. Although TDCP is only weakly 

genotoxic, the metabolite 1,3-dichloro-2-propanol was mutagenic in Salmonella TA-100 without 

metabolic activation. Furthermore, TDCP was shown to bind to DNA in vivo. Therefore, the 

possibility of a genotoxic mode of action for carcinogenicity cannot be dismissed. On the other 

hand, the absence of the putative metabolite 1,3-dichloro-2-propanone could explain why TDCP 

is less mutagenic than TRIS. 
In any case, genotoxicity is not a prerequisite for applying a linear dose-response model to 

estimate cancer risk. Linearity at low doses is the default assumption in the absence of 

convincing evidence to the contrary (CPSC 1992). An understanding of the mode of action or 

other information relating to the dose response would be needed to support a different dose 

response model. Obtaining sufficient data is generally very difficult and may require years of 

research (Meek et al. 2003). 

If the default assumption of low-dose linearity is not applied, then the cancer risk could be 

assessed by a variety of methods, including a non-linear risk model, such as the probit or logit, or 

by an uncertainty factor approach, applying uncertainty factors to either the NOAEL or a 

benchmark dose (BMD). For example, using the benchmark dose approach, the dose at which 

the extra risk is 5% (BMDo5) was estimated to be 7.7 mgkg-d, using the multistage model 

(equation (I)) and data for renal tumors. Applying the default uncertainty factors for interspecies 

differences in sensitivity and to protect sensitive individuals, the AD1 for cancer would be 

0.08 mgkg-d. Comparing this to the ADD (Table 12), the HI for cancer would be 0.1 in adults 

and 0.3 in children. Thus, by this approach TDCP probably would not present a cancer hazard to 

consumers. 

The percutaneous absorption rate of TDCP was estimated from an in vitro study using hairless 

mouse skin (Hughes et al. 2001). When human skin is not available, skin from the hairless 

mouse is preferred for in vitro studies (Bronaugh et al. 2005). The studies were performed by 

U.S. EPA staff at the request of CPSC (Hughes et al. 2001). TDCP was applied to the skin in an 

acetone solution. The acetone was evaporated under a stream of air. Acetone is not likely to 

damage the skin due to the limited contact time. 

The cumulative amount of TDCP in the receptor fluid at 24 hours was added to the amount 

remaining in the skin after thoroughly removing TDCP from the surface of the skin. This is to 

estimate systemic exposure, since hydrophobic compounds do not partition well into the aqueous 

receptor fluid (Bronaugh et al. 2005). It is assumed that TDCP in the skin would be absorbed in 

vivo. In this case, more than half of the TDCP was in the receptor fluid (Hughes et al. 2001). 

Thus, including only TDCP in the receptor fluid would reduce the estimated dermal dose by less 

than 2-fold. 

In vivo, the amount of chemical remaining within the skin may be considered as a reservoir that 

may be absorbed over time. If absorption from this reservoir is sufficiently slow, the reservoir 

may be lost due to normal exfoliation. Thus, net systemic absorption is the result of two 

competing events-absorption and exfoliation. As discussed above, over half of TDCP 

was found in the receptor fluid. Thus, even if the entire reservoir is lost due to exfoliation, which 

occurs over a period of about 14 days, then the effect on systemic absorption would be less than 

two-fold. 

Percutaneous absorption rates may be greater with animal than human skin (Bronaugh 2005). 

The percutaneous absorption of a related FRY tris(chloropropyl)phosphate (TCPP), was tested in 

vitro using human skin and an aqueous vehicle (Maas 2005a). TCPP was absorbed at roughly 

the same rate as TDCP. This suggests that the hairless mouse model is a reasonable surrogate for 
human skin, and that the acetone in the Hughes et al. (2001) study probably did not adversely 

affect skin permeability. 

While in vitro studies are generally predictive of in vivo percutaneous absorption rates, in vivo 

studies are preferred. In vitro studies may under-predict absorption of hydrophobic compounds, 

because hydrophobic compounds do not partition well into the aqueous receptor fluid (Bronaugh 

2005). TDCP was reported to be readily absorbed through the skin of rats in vivo, although the 

study was not designed to measure the absorption rate (Nomeir et al. 198 1). Ulsamer et al. 

(1979, 1980) reported that TDCP was absorbed at twice the rate of TRIS in rabbits. No other 

detail's were reported. In another study, however, 15% of the applied dose of TRIS was absorbed 

through the skin of rabbits in 96 hours (Ulsamer et al. 1978a). Thus, TRIS was apparently 

absorbed at a much lower rate in vivo in rabbits (0.0016 h-l) than TDCP was absorbed in vitro 

(0.035 h-') using mouse skin. 

B. Exposure 

The exposure assessment is limited in that only a small number of foam samples were tested, as 

well as the limited number of tests on each sample. Therefore, it is uncertain whether these 

results may be applicable to other foam samples treated with the same chemicals, and how 

precisely the results can be replicated. However, with the two TDCP samples, migration was 

roughly proportional to the TDCP content. Foam S (TDCP) and Foam Z (FM-550TM) were 

selected because they contained the highest FR concentrations available. Furniture treated with 

the FR chemicals was not available for testing. 

The aromatic phosphate components of FM-550TM generally were not quantified in the exposure 

studies. The migration data used to estimate dermal and oral exposure, as well as data on the ' 

release of airborne particles, are based on the OTB component of FM-550TM (Cobb and 

Bhooshan 2005). Therefore, the exposures for these routes are uncertain. 

Except for mass-balance models in general, the laboratory or mathematical models used to 

estimate exposure have not been validated by comparison with reliable exposure data, such as 

from field studies. Appropriate data do not exist. The mathematical models generally assume 

conditions of chemical equilibrium and steady-state. These assumptions are commonly used, in 

part, because dynamic models are much more complicated. However, the assumption of 

equilibrium or steady-state conditions may over-estimate exposure if steady-state is not reached 

during exposure. If exposure depends on a series of intermittent events that begin each time one 

sits on an upholstered chair, then it is possible that steady-state is not achieved. This might be 

the case for dermal exposure, for example. On the other hand, if exposure is a continuous 

process, then steady-state is more likely to be achieved. This might apply to the inhalation of 

vapor phase FR chemicals, which does not require direct contact with the product. The indoor 

concentration of vapor phase FR would vary to a degree, depending on ventilation and other 

factors, but it might be relatively stable over time. 
1. Dermal Exposure 

The method for estimating the potential for dermal exposure was adapted from exposure studies 

for mattress filling materials (Thomas and Brundage 2006). The method was intended to provide 

a realistic exposure estimate. However, the appropriate pressure and amount of liquid phase are 

difficult to estimate, and the values used for mattresses might not be optimal for upholstered 

furniture. No interliner or batting was present in the mock-up, because some upholstered 

furniture does not have these components. The presence of an interliner or batting might be 

expected to reduce migration. As with mattresses, these migration data were also used to 

estimate oral exposure. 

Recently, the migration of TCPP from polyurethane foam was studied using artificial sweat as a 

solvent (Maas 2005b). TCPP is structurally related to TDCP. A stack of 15 filters was placed 

directly on the foam. Total TCPP released was 5.6 pg/cm2 withno pressure applied and 9.2 

pg/dm2 with pressure applied (Maas 2005b, Appendix 1). Jn comparison, the migration of TDCP ' , 

was 0.15 pg/cm2, as measured by the CPSC staff (Cobb and Bhooshan 2005). The different 

results may be due, in part, to differences in methodology and the type of foam. Jn addition, 

TCPP is about 10-fold more water-soluble than TDCP (IPCS 1998). 

2. Inhalation Exposure 

The potential for release of particles containing FR chemicals was also assessed using a method 

developed for mattresses. For the most part, FR chemicals were not detectable in airborne 

particles released when the mock-up was subjected to impaction. Therefore, it does not appear 

that inhalation of particles would contribute significantly to consumer exposure. This is not 

unexpected, since the foam is resilient and is an internal component. However, aged or inservice foams were not tested. 

The source strength of vapor phase FR chemical was estimated using a mathematical model that 

is essentially similar to the model described by the NRC Subcommittee on Flame Retardant 

Chemicals (NRC 2000; see also Babich and Thomas 2001). The model includes several 

conservative assumptions, including the lack of affinity of the FR for the foam and barriers to 

vaporization of FR chemical. In practice, the FR chemicals may have an affinity for the foam 

matrix due to covalent or non-covalent binding. The foam, interliner, and cover fabric may all 

impede the release of FR chemical into air. 

Also in accordance with the NRC study, we assumed that there are no sinks or decay processes 

to attenuate the indoor concentration due to the lack of data to estimate the rates of these 

processes. Semi-volatile chemicals are known to be absorbed by other household furnishings or 

materials, including carpets, draperies, and wallboard. This tends to reduce the indoor air levels 

of these chemicals. Vapor phase FR chemicals may also be adsorbed to airborne particles or 

break down to other substances. Therefore, the model is expected to overestimate exposure to 

vapor phase FR chemical. Furthermore, in the absence of bioavailability data, 100% absorption 

and retention of vapor phase chemicals was assumed. 
Although.the vapor phase model includes a number of conservative assumptions, the source 

strength calculation is based on diffusion in a static environment. This may be most applicable 

to a scenario in which upholstered furniture sits in an unoccupied room. However, typical use of 

the furniture such as sitting, fidgeting, or active child play will apply mechanical actions that 

might increase the release of vapor phase FR chemical, as well as particles. 

The reliance on a purely theoretical model to estimate vapor phase exposure is of concern, 

because inhalation was the major route of exposure for all of the compounds under 

consideration, accounting for between 75% and 99% of the total estimated exposure (Table 12). 

Furthermore, there is considerable uncertainty in the vapor pressures of several of the FR 

chemicals, which are primary input values to the model. Empirical vapor pressures are not 

available for PIP and OTB. The vapor pressures for PIP (SRC 2006) and OTB (EPA 2005a) 

were estimated from mathematical models. The vapor pressure of TPP was extrapolated from 

empirical data (EPA 2005a; SRC 2006). 

Several different vapor pressures have been reported for TDCP. The empirical vapor pressure 

was reported to be 0.01 torr at 30°C (IPCS 1998) and 0.024 ton at 20°C (Supresta 2006). 

Another report gives the empirical vapor pressure at temperatures ranging from 50 to 500°F 

(Akzo 1998), from which we interpolated the vapor pressure to be 0.15 torr at 20°C and 0.2 torr 

at 25°C. Other authoritative sources cite estimated vapor pressures of 1x10-~ torr (EPA 2005a) 

and 7.4x10-~ torr at 25°C (SRC 2006). The CPSC staff measured the concentration of TDCP 

vapor at 65°C and 120°C in a sealed flask containing either liquid TDCP or TDCP-treated foam 

(Bhooshan and Cobb 2005). From these data we extrapolated the vapor pressure at 25°C as 

0.0014 tom. In addition, the effective vapor pressure with TDCP treated foam was estimated as 

2.7x10-~ torr at 25°C. Because TDCP was not detected at 65"C, we used one-half the detection 

limit for extrapolation. The vapor pressure estimated from TDCP-treated foam was used in the 

present risk assessment, because it is based on empirical data and it was obtained with TDCPtreated foam. Thus, it replaces two conservative assumptions of the mathematical model, that 

the FR chemical does not have an affinity for the foam and that the foam does not impede 

evaporation. 

The average daily dose (ADD) for TDCP was estimated to be 0.023 mglkg-d, with over 99% 

from inhalation of vapor phase TDCP (Table 12). Because most of the exposure was from 

inhalation of vapor phase TDCP, the vapor pressure has a significant impact on risk. However, 

changing the vapor pressure to the highest reported value increases the estimated hazard index 

and cancer risk only slightly (Table 16). This is because in the standard case, the source strength 

is near the maximum value allowed by the model. The maximum emission rate is the rate that 

would deplete all of the FR chemical during the lifetime of the product, defined by equation (7). 

Changing the vapor pressure to the lowest reported value decreases the hazard index for noncancer effects to well below a value of one. However, the cancer risk is still greater than one per 

million, largely due to the contribution of the other exposure routes. Even if the vapor pressure 

were zero, the estimated risk would be 7 per million (not shown). 
Table 16. Effect of Vapor Pressure on 'TDCP Hazard Index and Cancer Risk a 

VP, Torr HI VP Source Note Cancer Risk per 

Million 

7.4~10" 0.05 7 SRC 2006 Estimate 

<I .ox1 0-6 0.08 20 EPA 2005a Estimate " 

2.7~1 o-~ 2 300 Bhooshan and ' Empirical, with 

Cobb 2005 treated foam " - 

1.4~1 6 900 Bhooshan and 

Cobb 2006 Empirical ... " " " ...,,, " . 

1 .ox1 0-' . . 6 900 IPCS 1998 Empirical " " - . . 

2.0~10-' 6 900 Akzo 1998 Empirical 

a In adults. VP, vapor pressure; HI, hazard index. 

b Calculated as one-half the detection limit, or 5x1 0-'. 

. Value used in the risk assessment. 

The uncertainty in estimating inhalation exposure can be reduced by obtaining empirical data in 

a setting that at least approximates typical use. A simple approach would be to measure vapor 

levels in the impaction studies that were used for particle release. Another approach would be to 

make measurements in a test house with FR-treated furniture. 

In estimating inhalation exposures, the indoor environment was modeled as a two-zone model, 

including a breathing zone (Thompson and Thompson 1990) and the room in which the 

upholstered furniture is located. This approach was used because concentrations of airborne 

pollutants are generally higher near the source. A consumer sitting on a couch is not only close 

to the source, but the consumer's movements may contribute to it. This breathing zone approach 

requires assumptions regarding the size of the breathing zone, the air exchange rate between the 

breathing zone and room air, and the exposure duration in each zone. 

An alternative to the two-zone model is a single-zone model in which the zone is the size of an 

entire home. Any emissions of vapor or particles are assumed to be evenly distributed 

throughout the home. In reality, the concentrations of airborne pollutants are greater near the 

source (breathing zone) and in the room where the source is located. However, when interior 

doors are open or when forced air heating and air conditioning are operating, the differences in 

concentration are relatively small. Treating the entire home as a single zone essentially averages 

the various microenvironments (rooms and proximity to the source). Using a one-zone model 

with a volume equivalent to the room volume (V2) (120 m3) would reduce the ADD of TDCP 

from 9.5~10'~ mglkg-d to 5.7x10-~, or less than Zfold (not shown). Therefore, in this case the 

choice of model has a small, perhaps Zfold, effect on the estimated HI and cancer risk. 1 

Other than the impaction experiments, the potential effects of accelerated aging or wear on 

dermal or oral exposure were not evaluated. Small-scale mock-ups were used in lieu of furniture 

samples, which were not available. 
. . 

C. Variability and Uncertainty 

The variability and uncertainty associated with general input parameters were assessed by a 

sensitivity analysis. That is, the input variables were varied individually from the lower to upper 

bound. The effects on the estimated exposure were generally modest. In most cases, the 

estimated exposure varied by less than 5-fold from the best estimate (Tables 13-15). The oral 

exposure was most sensitive to the hand-to-mouth transfer factor. Changing this parameter to 

the lower or upper bound changed the oral exposure to either one-tenth or 18-times the best 

estimate. Dermal exposure was most sensitive to the fabric-to-slun transfer factor, with a range 

of from one-fifth to 7-fold. Inhalation exposure was most sensitive to the inter-zone air 

exchange rate. At the lower bound, the estimated exposure increased by almost 5-fold. The 

effect was minor at the upper bound however. 

Furthermore, the sensitivity analysis does not capture all sources of uncertainty. Some 

parameters are based on data with surrogate chemicals, including the fabric-to-skin and hand-tomouth transfer factors (Tables 5-1 1). Hand-to-mouth transfer was used as a surrogate for the 

fabric-to-mouth transfer factor. Some input parameters, such as the surface area of exposed skin 

and exposure durations, are based on a combination of empirical data and assumptions. Others, 

such as the inter-zone air exchange rate and boundary value height, are assumptions. The 

variability of chemical-specific input parameters, such as migration and particle release, were not 

considered due to the limited number of samples tested. Thus, variability between diffeient 

products cannot be assessed. 

The primary contributor to the estimated exposure is inhalation of vapor phase FR chemical. 

However, there are no empirical data to estimate inhalation exposure. Rather, a purely 

mathematical model was used. Furthermore, this model is highly dependent on the vapor 

pressure of the chemical. Empirical vapor pressure values are not available for several of the FR 

chemicals of interest. Their vapor pressures were estimated by mathematical models, in part 

because the vapor pressures are low and difficult to measure. Nonetheless, we used a 

mathematical model using input data from another model, compounding the uncertainty. TDCP 

has measured vapor pressures between 0.01 to 0.24 ton. In contrast, model estimates range from 

1x10-~ torr and 7.4x10-* torr at 25OC. The discrepancy between the empirical and estimated 

vapor pressures suggests that the estimated vapor pressures for PIP and OTB may be highly 

uncertain. 

Probabilistic methods were not used in this case to assess variability and uncertainty, due to the 

lack of adequate information on the distributions of most of the variables. 

Some potentially significant sources of uncertainty are difficult or impossible to quantify. Most 

of the models and methods used to estimate exposure have not been validated. Thus, it is 

impossible to know whether these methods reasonably approximate true exposures. 

The effect of additional toxicity data on AD1 values cannot be predicted. The cancer unit risk 

estimate for TDCP is highly dependent on the choice of dose response model. At present, it is 

impossible to know which model is more likely to be correct. The default model used by the 

CPSC staff generally results in a higher cancer risk estimate. The use of alternative models (e-g., 
non-linear dose response models) would most likely reduce the estimated cancer risk. Using an 

uncertainty factor approach could result in a negligible cancer risk. However, based on the 

CPSC chronic hazard guidelines, the default assumption of low-dose linearity is applied unless 

there is convincing evidence to justify an alternative approach. 

while there are many sources of uncertainty, most of them can be addressed by additional 

studies on toxicity and exposure. 

D. Conclusions 

The following conclusions are based on limited exposure and/or toxicity data, and should be 

regarded as preliminary. 

Based on a mathematical model derived by the National Research Council (NRC 2000), 

inhalation of vapor phase FR chemical appears to be the primary route of exposure for TDCP 

and the components of FM-550TM. The model contains several assumptions that may tend to 

overestimate inhalation exposure. However, the model and certain input parameters are also 

highly uncertain and, therefore, may either overestimate or underestimate exposure. '~m~irical 

data on vapor phase emissions or indoor concentrations are needed to assess whether these 

chemicals may present a hazard to consumers. 

Based on the limited available exposure data, upholstered furniture manufactured with TDCPtreated foam in upholstered furniture might present a hazard to consumers, based on both cancer 

and non-cancer hazards. As discussed above, empirical data relating to TDCP emissions are 

needed to assess whether TDCP may be hazardous to consumers. 

Based on the limited available toxicity and exposure data, it does not appear that TPP or PIP 

would present a hazard to consumers. However, there were insufficient toxicity data to derive 

ADI's for TPP and PIP. This conclusion is based on the assumption that TPP and PIP are not 

more toxic than other aromatic phosphates. Additional toxicity and exposure data are needed to 

assess whether TPP or PIP may be hazardous to consumers. The National Toxicology Program 

(NTP) is considering a request from the CPSC staff to perform additional toxicity studies on 

aromatic phosphates. The staff will review any additional toxicity data that become available. 

As discussed above, empirical data relating to emissions of these compounds are also needed to 

assess whether they may be hazardous to consumers. Exposure data specific for TPP and PIP are 

also needed to reduce the uncertainty in exposure. 

No chronic toxicity data on OTB or related compounds are available. The toxicity andipotential 

risks of OTB cannot be assessed. Basic toxicity data and an empirical vapor pressure (or upper 

bound) are needed to conduct a preliminary risk assessment for OTB. 

Continued development and validation of the exposure methods in general would also serve to 

reduce the uncertainty in estimating exposure to FR chemicals. 

Melamine has been studied in chronic bioassays (reviewed in Thomas and Brundage 2004). 

Melamine does not satisfy the regulatory definition of toxic. Thus, exposure studies with 
melamine-treated foam were not pecessary. Based on the available data, melamine-treated foam 

is not expected to present a hazard to consumers. 

A number of other FR treatments that could be used in foam have been discussed by the U.S. 

EPA's Design for the Environment Program @PA 2005a). 

In summary, the staff concludes that: 

Based on the available data, melamine-treated foam is not expected to present a hazard to 

consumers. 

Inhalation studies are lacking for TDCP, TPP, PIP, and OTl3. This is significant because 

inhalation appears to contribute the greatest portion of the total exposure. 

Empirical data on vapor phase emissions or indoor concentrations are needed to assess 

whether TDCP, TPP, PIP, or OTB may present a hazard to consumers. 

Chemical-specific data on liquid-mediation migration and airborne particle release are 

needed to assess more accurately whether TPP and PIP may present a hazard to 

consumers. 

Additional toxicity data are needed to derive acceptable daily intake values for TPP and 

PIP. 

Basic toxicity and physico-chemical data for OTl3 are needed to derive an acceptable 

daily intake value and to estimate exposure. 
VII. REFERENCES' . 

Abou-Donia MB, Momeir AA, Bower JH, Makkawy HA (1990) Absorption, distribution, 

excretion and metabolism of a single oral dose of [14C]tri-o-cresyl phosphate (TOCP) in the 

male rat. Toxicology 65: 61-74. 

Akzo Nobel (1998) Technical Data Sheet for Fyrol FR-2. Akzo Nobel Functional Chemicals 

LLC, Dobbs Ferry, NY. November 1,1998. Accessed July 25,2006. 

http://phosphorus.akzonobelusa.com/business/ phosphorus/TDS/TDS Fyrol.htm1 

Babich MA, Hatlelid K, Osterhout C (2004) Update on the toxicity of selected flame retardant 

chemicals. U.S. Consumer Product Safety Commission, Directorate for Health Sciences, 

Bethesda, MD 208 14. July 20,2004. 

Babich MA, Saltzman LE (1999) Tris(chloropropy1) phosphate (TCPP). U.S. Consumer Product 

Safety Commission, Directorate for Health Sciences, Bethesda, MD 20814. August 4, 1999. 

Babich MA, Thomas TA (2001) CPSC staff exposure and risk assessment of flame retardant 

chemicals in residential upholstered furniture. U.S. Consumer Product Safety Commission, 

Bethesda, MD 20814. April 2001. 

BIBRA (1987) The effects of DVP412 on cultures of guinea-pig alveolar macrophages. British 

Industrial Research Association ; Surrey, UK. Prepared for Ciba-Geigy, Cheshire UK. October 

1987. EPA document no. 86-8800001 10. 

Biodynamics (1981) A two-year oral toxicity/carcinogenicity study on Fyrol FR-2 in rats (final 

report). EPA no. OTS2049 1 1. 

Bittner PM (1999a) Toxicity review for decabromodiphenyl oxide. U.S. Consumer Product 

. Safety Commission, Directorate for Health Sciences, Bethesda, MD 20814. March 3, 1999. , 

Bittner PM (1 999b) Toxicity review for phosphonic acid, (3- { [hydroxymethyl]a~hino) -3- 

oxopropyl-, dimethyl ester. U.S. Consumer Product Safety Commission, Directorate for Health 

Sciences, Bethesda, MD 20814. March 3, 1999. 

Bittner PM (1999~) Toxicity review for tetrakis(hydroxymethy1) phosphonium salts 

precondensate with urea. U.S. Consumer Product Safety Commission, Directorate for Health 

Sciences, Bethesda, MD 20814. March 6,1999. 

Bittner PM (1999d) Toxicity review for tris(2~chloropropyl) phosphate. U.S. Consumer Product 

Safety Commission, Directorate for Health Sciences, Bethesda, MD 20814. March 3, 1999. 

Bittner PM (2001) Update on the flame retardant (FR) chemicals toxicity reviews. U.S. 

Consumer Product Safety Commission, Directorate for Health Sciences, Bethesda, MD 20814. 

April 4,200 1. 
Bittner PM, Ferrante J (1999) Comparison of British Department of Trade and Industry toxicity 

assessments on selected flame retardant (FR) chemicals to the CPSC toxicity reviews of identical 

or similar FR chemicals or chemical classes. U.S. Consumer Product Safety Commission, 

Directorate for Health Sciences, Bethesda, MD 20814. August 6, 1999. 

Bittner PM, Ferrante J, Hatlelid KM, Saltzman LE, Babich MA (2001) An evaluation of the 

toxicity data for selected flame retardant chemicals. The Toxicologist 60: 2014A. 

- Brandwene D (2001) High Production Volume (HPV) Challenge Program test plan and robust 

summary for tris(l,3-dichloro-2-propy1)phosphate. Akzo Nobel Functional Chemicals LLC, 

Dobbs Ferry, NY. March 2001. 

Bronaugh RL, Kraeling MEK, Yourick JJ (2005) Determination of percutaneous absorption by 

in vitro techniques. In, "Percutaneous Absorption," 4" Edition, Bronaugh RL, Maibach HI, 

editrs. Taylor and Francis Group, New York. Chapter 18. Pages 265-269. 

Brusick D, Matheson D., Janannath DR, Goode S, Lebowitz H, Reed M, Roy G, Benson S 

(1980). A comparis,on of the genotoxic properties of tris(2,3-dibromopropy1)pohosphate and 

tris(l,3,-dichloro-2-propy1)phosphate in a battery of short-term bioassays. Journal of 

Environmental Pathology and Toxicology 3: 207-226. 

Burin GJ, Gibb HJ, Hill RN (1995) Human bladder cancer: evidence for a potential irritationinduced mechanism. Food and Chemical Toxicology 33: 785-795. As cited in Thomas and 

Brundage 2004. 

Camarasa JG, Serra-Baldrich E (1992) Allergic contact dermatitis from triphenyl phosphate. 

Contact Dermatitis 26: 264-5. 

Carlsen L, Andersen KE, Egsgaard H (1986) Triphenyl phosphate allergy from spectacle frames. 

Contact Dermatitis, 15: 274-277. 

Carlton BD, Basaran AH, Mezza LE, Smith MK. (1987) Examination of the reproductive effects 

of tricresyl phosphate administered to Long-Evans rats. Toxicology 46: 321-8. 

Cascieri T, Poinsett WW (1977) KronitexTM 200 triaryl phosphate neurotoxicity screening study 

in hens. FMC Corporation, Princeton, NJ. EPA document no. 40-7742029. September 1977. 

Casida JE, Eto M, Baron RL (1961) Biological activity of a tri-o-cresyl phosphate metabolite. 

Nature 191: 1396-1397. 

Celanese Corporation (1960) Mellon Institute Report, Cellulube FR-2. Celanese Corporation of 

America. February 1960. As cited in Ulsamer et al., 1980. 

Centers for Disease Control (CDC) (2000) CDC Growth Charts: United States. National Center 

for Health Statistics, Centers for Disease Control and Prevention, Hyattsville, MD. December 4, 

2000. 
Chapin RE, George JD, Lamb JC 4th. (1988) Reproductive toxicity of tricresyl phosphate in a 

continuous breeding protocol in Swiss (CD-1) mice. Fundamental and Applied Toxicology 1988 

10: 344-54. 

Cifone MA (2005) In vivo/in vitro unscheduled DNA synthesis in rat primary hepatocyte 

cultures at two timepoints with a dose range finding assay. Covance Laboratories, Vienna, VA. 

Prepared for Albemarle Corporation, Baton Rouge, LA and Supresta, Ardsley, NY. Study 

number 7674- 102. November 4,2005. 

Cobb D (2005) Migration of Flame Retardant Chemicals in Mattress Barriers. U.S. Consumer 

Product Safety Commission, Bethesda, MD 20814. December 2005. 

Cobb D, Bhooshan B (2005) Migration of flame retardant chemicals in upholstered furniture 

foam. U.S. Consumer Product Safety Commission, Bethesda, MD 20814. December 10,2005. 

Cobb D, Chen S-B (2005) Analysis of FR chemicals added to foams, fabric, batting, loose fill, 

and barriers. U.S. Consumer Product Safety Commission, Bethesda, MD 20814. May 10,2005. 

Cohen Hubal EA, Suggs JC, Nishioka MG, Ivancic WA (2005) Characterizing residue transfer 

efficiencies using a fluorescent imaging technique. Journal of Exposure Analysis and 

Environmental Epidemiology 15: 26 1-270. 

Consumer Product Safety Commission (CPSC) (1983) Risk Assessment on Di (2-ethylhexyl) 

Phthalate in Children's Products. U.S. CPSC, Washington, DC 20207. August 1983. 

Consumer Product Safety Commission (CPSC) (1 990) CPS C HAZARD-I Fire Assessment 

Model. User Manual and Tutorial. U.S. Consumer Product Safety Commission, Bethesda, MD 

20814. September 29,1990. Page 3. 

Consumer Product Safety Commission (CPSC) (1992) Labeling requirements for art materials 

presenting chronic hazards; guidelines for determining chronic toxicity of products subject to the 

FHSA; supplementary definition of "toxic" under the Federal Hazardous Substances Act; final 

rules. Federal Register 57:46626-46674. 

Consumer Product Safety Commission (CPSC) (1997) Briefing Package on Upholstered 

Furniture Flammability: Regulatory Options for Small Open Flame and Smoking Material 

Ignited Fires. U.S. Consumer Product Safety Commission, Bethesda, MD 20814. October 1997. 

Consumer Product Safety Commission (CPSC) (2003) Ignition of Upholstered Furniture by 

Small Open Flames andlor Smoldering Cigarettes; Advance Notice of Proposed Rulemaking; 

Request for Comments and Information. Federal Register 68: 60629-60632. Thursday, October 

23,2003. 

Crump KS (1984) An improved method for low-dose carcinogenic risk assessment from animal 

data. Journal of Environmental Pathology and Toxicology, 5: 675-684. 
Dollahite JW, Pierce KR (1 969) Neurologic disturbances due to triaryl phosphate toxicity. 

American Journal of Veterinary Research 30: 1461- 1464. 

Environmental Protection Agency (EPA) (1985) Review of in vivo absorption through human 

epidermis of Reofos 50. Internal memorandum from Letty Tahan to John Helm. Environmental 

Protection Agency, Office of Toxic Substances, Washington, DC 20460. October 1985. EPA 

document no. 40-85421350. 

Environmental Protection Agency (EPA) (1992) A cross-species scaling factor for carcinogen 

risk assessment based on equivalence of mg/kg3'4/day. Federal Register 57: 24152-24173. 

Environmental Protection Agency (EPA) (1997) Exposure Factors Handbook. Office of 

Research and Development, U.S. Environmental Protection Agency, Office of Toxic Substances, 

Washington, DC 20460. August 1997. EPA 600P-951002F. 

Environmental ~rotiction Agency (EPA) (2005a) "Furniture Flame Retardancy Partnership: 

Environmental Profiles of Chemical Flame-Retardant Alternatives for Low-Density 

Polyurethane Foam." Design for the Environment Program, U.S. Environmental Protection 

Agency, Washington, DC. September 2005. 

Environmental Protection Agency (EPA) (2005b) Supplemental Guidance for Assessing Cancer 

Susceptibility from Early-Life Exposure to Carcinogens. U.S. Environmental Protection 

Agency, Risk Assessment Forum, Washington DC 20460. March 2005. EPAl630lR-031003F. 

Eto M, Casida J, Eto T (1962) Hydroxylation and cyclization reactions involved in the 

metabolism of tri-o-cresyl phosphate. Biochemical Pharmacology 1 1: 337-352. 

Ferrante J (1999a) Toxicity review of aromatic phosphate plasticizers. U.S. Consumer Product 

Safety Commission, Bethesda, MD 20814. June 7, 1999. 

Ferrante J (1999b) Toxicity review of tris (1,3-dichloropropyl-2) phosphate (Fyrol FR-2 or 

TDCP). U.S. Consumer Product Safety Commission, Bethesda, MD 208 14. Undated. 

Ferrante J (1999~) Toxicity review for tris(1-chloro-2-propy1)phosphate and bis(2-chloropropyl) 

1-(chloro-2-propyl) phosphate. U.S. Consumer Product Safety Commission, Directorate for 

Health Sciences, Bethesda, MD 20814. July 9, 1999. 

Ferrante J (1999d) Toxicity review for alumina tihydrate. U.S. Consumer Product Safety 

Commission, Directorate for Health Sciences, Bethesda, MD 208 14. Undated. 

Ferrante J (1999e) Toxicity,review for magnesium hydroxide. U.S. Consumer Product Safety 

Commission, Directorate for ~ealth' Sciences, Bethesda, MD 208 14. Undated. 

Ferrante J (1999f) Toxicity review for ammonium polyphosphates. U.S. Consumer Product 

Safety Commission, Directorate for Health Sciences, Bethesda, MD 20814. Undated. 

156 
FMc Corporation (FMC) (1969) Acute toxicity study in rats administered 10 materials. FMC, 

Corporation, ~altimore, MD. EPA document number 40-69421 88. June 1969. 

FMC Corporation (FMC) (1977) A neurotoxicity study in hens administered commercially 

available phosphate ester products. FMC, Corporation, Princeton, NJ. EPA document number 

40-7642197. April 1977. 

FMC Corporation (FMC) (1979) Health effect studies on various aryl phosphates. FMC, 

Corporation, Philadelphia, PA. EPA'document number 40-7442485. November 1979. 

FMC Corporation (FMC) (1981) Evaluation of the test article Kronitex 50 for mutagenic 

potential employing the L5178Y TK +I- mutagenesis assay. FMC, Corporation, Philadelphia, 

PA. EPA document number 40-8 142497. August 198 1. 

Freeman C (1990) Nandefinitive acute toxicity studies--dermal, oral, primary kin and eye 

irritation with triaryl phosphate esters-Durad TM 110, 300 and 20B. FMC Corporation, 

Philadelphia, PA. EPA document number 86-9 10000033. 

Freudenthal RI, Henrich RT (2000) Chronic toxicity and carcinogenic potential of tris-(1,3- 

dichloro-2-propyl) phosphate in Sprague-Dawley rat. International Journal of Toxicology 19: 

119-125. 

Gold NID, Blum A, Ames BN (1978) Another flame retardant, tris-(l,3-dichloro-2-propy1)- 

phosphate, and its expected metabolites are mutagens. Science 200: 785-787. 

Great Lakes Chemical Company (2005) Material Safety Data Sheet for FiremasterTM 550. Great 

Lakes Chemical Company, West Lafayette, IN. March 10,2005. MSDS no. 00896. 

Greene, M.A. (1998) Statistical methods for prediction of DINP intake by young children. U.S. 

Consumer Product Safety ~omdssion, Bethesda, MD 20814. December 1998. 

Hatlelid K (1999a) Toxicity review for antimony trioxide. U.S. Consumer Product Safety , 

Commission, Bethesda, MD 20814. March 2, 1999. 

Hatlelid'K (1999b) Toxicity review for hexabromocyclododecane. U.S. Consumer Product 

Safety Commission, Bethesda, MD 20814. March 2, 1999. 

Hatlelid K (1999~) Toxicity review for cyclic phosphonate esters. U.S. Consumer Product 

Safety Commission, Bethesda, MD 20814. February 8, 1999. 

Hatlelid K (1999d) Toxicity review for organic phosphonates. U.S. Consumer Product Safety 

Commission, Bethesda, MD 20814. February 8, 1999. 

Hatlelid K (1 999e) Toxicity review for chlorinated paraffins. U.S. Consumer Product Safety 

Commission, Bethesda, MD 208 14. March 25, 1999. 
Hatlelid K (1 999f) Toxicity review for calcium molybdate and zinc molybdate. U.S. Consumer 

Product Safety Commission, Bethesda, MD 20814. March 2, 1999. 

Hatlelid K (19998) Toxicity review for antimony pentoxide and sodium antimonate. U.S. 

Consumer Product Safety Commission, Bethesda, MD 20814. March 2, 1999. 

Hatlelid K (199911) Toxicity review for zinc borate. U.S. Consumer product Safety Commission, 

Bethesda, MD 20814. March 2, 1999. 

Hatlelid K (2003) Cancer risk assessment for arsenic exposure from CCA-treated playground 

structures. U.S. Consumer Product Safety Commission, Bethesda, MD 20814. January 23, 

2003. 

Haworth S, Lawlor T, Mortelmans K, Speck W, Zeiger E (1983) Salmonella mutagenicity test 

results for 250 chemicals. Environmental Mutagenesis 5 (Suppl. 1):l-142. 

Henrich RT (1998) Letter from RT Henrich, Akzo-Nobel Chemicals, Dobbs Ferry, NY, to Dale 

Ray and Michael Babich, U.S. Consumer Product Safety Commission, Bethesda, MD. June 2, 

1998. 

Henrich R (2001) Test and robust summaries for isopropylated diphenyl phosphate. Great Lakes 

Chemical Corporation, west Lafayette, IN. November 29,2001. 

Henschler D, Schmuck G, van Aerssen M, Schiffmann D (1992) The inhibitory effect of 

neuropathic organophosphate esters on neurite outgroyth in cell cultures: a basis for screening 

for delayed neurotoxicity. Toxicology in Vitro 6: 327-335. 

Hinton DM, Jessop JJ, Arnold A, Albert RH, Hines FA (1987) Evaluation of immunotoxicity in 

a subchronic feeding study of triphenyl phosphate. Toxicology and Industrial Health 3: 71-89. 

Hjorth N (1964) Contact dermatitis from cellulose acetate film. Cross-sensitization between 

tricresyl phosphate (TCP) and triphenyl phosphate (TPP). Contact Dermatitis 12: 86-100. As 

cited in lPCS 199 1. 

Holden CR, Shum KW, Gawkrodger DJ (2006) Contact allergy to triphenyl phosphate: probable 

cross-reactivity to triphenyl phosphite present in an EN46001 System 22 clear oxygen facemask. 

Contact Dermatitis 54: 299-300. 

Honkakoski P, Palvimo JJ, Penttila L, Vepsalainen J, Auriola S (2004) Effects of triaryl 

phosphates on mouse and human nuclear receptors. Biochemical Pharmacology 67: 97-106. 

Howe RB, Crump KS (1983) Globa183. Science Research Systems, Inc., 1201 Gaines Street, 

Ruston, LA 71270. September 1983. 
Hughes MF (2000) In vitro dermal absorption rate testing of flame retardant chemicals. National 

Health and Environmental Effects Research Laboratory, U.S. Environmental Protection Agency, 

Research Triangle Park, NC 2771 1. July 25,2000. 

Hughes MF, Edwards BC, Mitchell CT, Bhooshan B (2001) In vitro dermal absorption of flame 

retardant chemicals. Food and Chemical Toxicology 39: 1263: 1270. 

International Agency for Research on Cancer (IARC) (1986) Melamine. IARC Monographs on 

the Evaluation of Carcinogenic Risks to Humans 39: 333-346. 

International Agency for Research on Cancer (IARC) (1999) Melamine. IARC Monographs on 

the Evaluation of Carcinogenic Risks to Humans 73: 329-338. 

International Programme on Chemical Safety (IPCS) (1990) Tricresyl Phosphate. 

, Environmental Health Criteria No. 110. World Health Organization, Geneva. 

International Programme on Chemical Safety (IPCS) (1991) Triphenyl Phosphate. 

Environmental Health Criteria No. 1 1 1. World Health Organization, Geneva. 

International Programme on Chemical Safety (IPCS) (1998) Flame Retardants: 

Tris(chloropropy1) Phosphate and Tris(2-chloroethyl) Phosphate. Environmental Health Criteria 

No. 209. World Health Organization, Geneva. 

Johannsen FR, Wright PL, Gordon DE, Levinskas GK, Radue RW, am PR (1977) 

Evaluation of delayed neurotoxicity and dose-response relationships of phosphate esters in the 

adult hen. Toxicology and Applied Pharmacology 4 1 : 29 1-304. 

Johnson MK (1 974) The primary biochemical lesion leading to the delayed neurotoxic effects of 

some organophosphorus esters. Journal of Neurochemistry 23: 785-789. 

Johnson MK (1975) Organophosphorus esters causing delayed neurotoxic effects. Archives of 

Toxicology 34: 259-288. 

Kamata E, Naito K, Nakaji Y, Ogawa Y, Suzuki S, Kaneko T, Takada K, Kurokawa Y, Tobe M 

(1989) cute and subacute toxicity studies of tris(l,3-dichloro-2-propyl) phosphate on mice. 

Eisel Shikenjo Hokoku 107: 36-43. English abstract. As cited in Ferrante 1999b. 

Kawashima K, Tanaka S, Nakaura D, Nagao S, Endo T, Onoda K, Takanaka A, Omori Y (1983) 

Effect of phosphoric acid tri-esters on the prenatal and postnatal developments of rats. Journal of 

Toxicological Sciences 8: 339. (Abstract only). 

Kolodner K, Cameron L, Gittlesohn A, Emmett EA (1987) Morbidity study of workers in a 

resin-production processing plant. Johns Hopkins University, Baltimore, MD. December 1987. 

Prepared for General Electric Company, Pittsfield, MA. EPA document no. 86-900000030. 
Koontz MD, Rector HE (1993) Estimation of distributions for residential air exchange rates. 

GEOMET Technologies, Inc., Germantown, NID 20874. October 29, 1993. GEOMET Report 

Number IE-2603. Table 2. 

Kurebayashi H, Tanaka A, Yarnaha T (1985) Metabolism and disposition of the flame retardant 

plasticizer, tri-p-cresyl phosphate, in the rat. Toxicology and Applied Pharmacology 77: 395- 

404. 

Lee BC (1990a) Dislodgeable arsenic on playground equipment wood and the estimated risk of 

skin cancer. U.S. Consumer Product Safety Commission, Bethesda, MD. August 1990. 

Lee BC (1990b) Estimation of hand-to-mouth activity by children based on soil ingestion for 

dislodgeable arsenic exposure assessment. U.S. Consumer Product Safety Commission, 

Bethesda, MD. August 1990. 

Lefaux, R. (1968) Practical Toxicology of Plastics. CRC Press, Inc. Cleveland, OH. As cited in 

Thomas and Brundage 2004. 

Levenson M (2005) Upholstered Furniture Addressable Fire Loss Estimates for 1999 - 2002. 

U.S. Consumer Product Safety Commission, Bethesda, NID. November 2005. 

Lynn RK, Wong K, GarvieGould C, Kennish JM (198 1) Disposition of the flame retardant, tris 

(1,3-dichloro-2-propyl) phosphate, in the rat. Drug Metababolism and Disposition 9 (5): 434. 

Maas WJM (2005a) In vitro percutaneous absorption of [14c] tris(2-chloro- 1-methylethyl) 

phosphate (TCPP) through human skin membranes using flow-through diffusion cells. 

Netherlands Organization for Applied Scientific Research, the Netherlands. December 8,2005. 

Report no. V6578102. Prepared for, Chlorinated Phosphates 4' Priority Consortium, Brussels, 

Belgium. 

Maas WJM (2005b) Release test for tris(2-chloro-1-methylethy1)-phosphate (TCPP) from a. 

flexible foam. Netherlands Organization for Applied Scientific Research, the Netherlands. 

December 9,2005. Report no. V6578101. Prepared for, Chlorinated phosphates 4" Priority 

Consortium, Brussels, Belgium. 

Mast RW, Friedman MA, Finch R A (1982a) Mutagenicity testing of melamine. Toxicologist 2: 

172. As cited in Thomas and Brundage 2004. 

Mast RW, Naisrnith RW, Friedman MA (1982b) Mouse micronucleus assay of melamine. 

Environmental and Molecular Mutagenesis 4: 340-341. As cited in Thomas and Brundage 2004. 

Mast RW, Jeffcoat AR, Sadler BM, Kraska RC, Friedman MA (1983) Metabolism, disposition 

and excretion of [14C]melamine in male Fischer 344 rats. Food and Chemical Toxicology 21: 

807-8 10. As cited in Thomas and Brundage 2004. 
Matthews HB, Anderson MW (1979) Disposition of tris-(l,3-dichloro-2-propy1)-phosphate in 

the rat. Toxicology and Applied Pharmacology 48: A184. 

Meek ME, Bucher JR, Cohen SM, Dellarco V, Hill RN, Lehman-McKeeman LD, Longfellow 

DG, Pastoor T, Seed J, Patton DE (2003) A framework for human relevance analysis of 

information on carcinogenic modes of action. Critical Reviews in Toxicology 33: 591-653. 

Mele JM,' Jensh RP (1977) Teratogenic effects of orally administered tri-o-cresyl phosphate on 

Wistar albino rats.' Teratology 15: 32A. 

Melnick RL, Boorman GA, Haseman JK., Montali RJ, Huff J (1984) Urolithiasis and bladder 

carcinogenicity of melamine in rodents. Toxicology and Applied Pharmacology 72: 292-303. As 

cited in Thomas and Brundage 2004. 

Microbiological Associates (1 978) Activity of KronitexTM in the Salmonella/microsomal assay 

for bacterial mutagenicity. Microbiological Associates, Bethesda, MD. Prepared for FMC 

Corporation, Princeton, NJ. August 1978. EPA document no. 87-8210440. 

Midgett JD (2005). Human factors affecting sampling on mattress surfaces. U.S. Consumer 

Product Safety Commission, Bethesda, MD. October 2005. 

Monsanto (1993) A single generation reproduction study with 2-ethylhexyl diphenyl phosphate 

(EHDP) in rats. Monsanto Company, St. Louis, MO. EPA document no. 88-930000142. As 

cited in Ferrante 1999a. 

Morales NM, Matthews HI3 (1980) In vivo binding of the flame retardants tris(2,3- 

dibromopropyl) phosphate and tris(l,3-dichloro-2-propyl) phosphate to macromolecules of 

mouse liver, kidney and muscle. Bulletin of Environmental Contamination and Toxicology 25: 

34-8. 

Nakamura A, Aateno N, Kojima S, Kaniwa M-A, Kawamura T (1979) The mutagenicity of 

halogenated alkanols and their phosphoric acid esters for Salmonella typhimurium. Mutation 

Research 66: 373-380. 

National Research Council (NRC) (1981) Monitoring and modeling of indoor air pollution. In, 

Indoor Pollutants. Committee on Indoor Pollutants, National Research Council, National 

Academy of Sciences. National Academy Press, Washington, DC. Chapter VI, pages VI-24 - 

VI-27. 

National Research Council (NRC) (2000) Toxicological Risks of Selected Flame-Retardant 

Chemicals. Subcommittee on Flame Retardant Chemicals, National Research Council, National 

Academy of Sciences. National Academy Press, Washington, DC. 

National Toxicology Program (NTP) (1983) Carcinogenesis Bioassay of Melamine (CAS No. 

108-78- 1) in F344/N Rats and B6C3F1 Mice (Feed Study). Report No. 245. 
National Toxicology Program (NTP) (1985) Tricresyl Phosphate (CAS #1330-78-5) 

Reproduction and Fertility Assessment in CD-1 Mice When Administered In Feed. Report 

No. RACB84114. 

National Toxicology Program (NTP) (1994) Toxicology and Carcinogenesis Studies of Tricresyl , 

Phosphate in F334/N Rats and B6C3F1 Mice (Gavage and Feed Studies). Report No. 433. 

Newcombe DS, Warr GA (1985) Effects of organophosphates on monocyte nonspecific esterase 

activity and peripheral blood monocyte functions. Johns Hopkins University, Baltimore, MD. 

December 1985. Prepared for General Electric Corporation, Pittsfield, MA. EPA document no. 

87-8216228. 

Nomeir AA, Abou-Donia MB (1984) Disposition of [14C]tri-o-cresyl phosphate and its 

metabolites in various tissues of the male cat following a single dermal application.. Drug 

Metabolism and Disposition 12: 705-7 1 1. 

Nomeir AA, Abou-Donia MB (1986) Studies on the metabolism of the neurotoxic tri-o-cresyl 

phosphate. Distribution, excretion, and metabolism in male cats after a single, dermal 

application. Toxicology 38: 15-33. 

Nomeir AA, Kato S, Matthews HB (1981) The metabolism and disposition of tris (1,3-dichloro2-propyl) phosphate (Fyrol FR-2) in the rat. Toxicology and Applied Pharmacology 57: 401-413. 

Ogasawara H, Imaida K, Ishiwata H, Toyoda K, Kawanishi T, Uneyania C, Hayashi S, 

Takahashi M, Hayashi Y (1995) Urinary bladder carcinogenesis induced by melamine in F344 

male rats: correlation between carcinogenicity and urolith formation. Carcinogenesis 16: 2773- 

2777. As cited in Thomas and Brundage 2004. 

Parkes D (1998) Testimony presented to the U.S. Consumer Product Safety Commission, for the 

Fire Retardant Chemicals Association (currently the American Fire Safety Council), Lancaster, 

PA. May 5,1998. 

Perrella FW, Boutwell RK (1983) Triethylenemelamine: an initiator of two-stage carcinogenesis 

in mouse skin which lacks the potential of a complete carcinogen. Cancer Letters 21 : 37-41. As 

cited in Thomas and Brundage 2004. 

Potts RO, Guy RH (1992) Predicting skin permeability. Pharmaceutical Research 9: 663-669. 

Prival MJ, McCoy EC, Gutter B, Rosenkranz HS (1977) Tris (2,3-dibromopropyl) phosphate: 

mutagenicity of a widely used flame retardant. Science 195: 76-78. 

Robinson EC, Hammond BG, Johannsen FR, Levinskas GJ, Rodwell DE (1986) Teratogenicity 

studies of alkylaryl phosphate ester plasticizers in rats. Fundamental and Applied Toxicology 

7:138-143. 
Rodent Bladder Carcinogenesis Working Group (RBCWG) (1995) Urinary bladder 

carcinogenesis: Implications for risk assessment. Food and Chemical Toxicology 33: 797-802. 

Rodes CE,Newsome JR, Vanderpool RW, Antley JT, Lewis RG (2001) ~x~erimental. 

methodologies and preliminary transfer factor data for estimation of dermal exposures to 

particles. Journal of ~x~osure Analysis and Environmental Epidemiology 11: 123-39. 

Ross DB, Robers NL, Phillips CNK, Prentice DE, Majeed SK (1979) The neurotoxic effects of 

KronitexTM 200 on the domestic hen. ~udtin~don Research Centre, Cambridgeshire, UK. 

Prepared for FMC Corporation, Princeton, NJ. May 1979. EPA document no. 40-7942040. 

Sasaki K, SuzukiT, Takeda M, Uchiyama M (1984) Metabolism of phosphoric acid triesters by 

rat liver homogenate. Bulletin of Environmental Contamination and Toxicology 33: 281-288. 

Schwope AD, Lyman WJ, Reid RC (1989) Methods for Assessing Exposure to Chemical 

Substances. Volume 1 1. Methodology for Estimating the Migration of Additives and Impurities 

from Polymeric Materials. Prepared for, Office of Pesticides and Toxic Substances, U.S. 

Environmental Protection Agency, Washington, DC 20460. August 1989. EPA 56015-85-015. 

Scott RC, Thompson MA (1985) In vitro absorption through human epidermis of "Reofos 50" 

and "Reolube Hyd 46." Imperial Chemical Industries, Cheshire, UK. October 1985. EPA 

document no. 40-8542167. 

Smith TP (2000) Estimates of input parameters for upholstered furniture risk assessment. U.S. 

Consumer Product Safety Commission, Bethesda, MD 20814. August 4, 2000. 

Smith MI, Engel EW, Stohlman FF (1932) Further studies on the pharmacology of certain 

phenol esters with special reference to the relation of chemical constitution and physiologic 

action. National Institutes of Health Bulletin 160: 1-53. Washington, DC. As cited in Sobotka et 

al. 1986. 

Snodgrass HL (1992) ~Lrmethrin transfer from treated cloth to the skin surface: potential for 

exposure in humans. Journal of Toxicology and Environmental Health 35: 9 1 - 105. 

Sobotka TJ, Brodie RE, Arnold A, West GL, OYDonnell MW (1986) Neuromotor function in rats 

during subchronic dietary exposure to triphenyl phosphate. Neurobehavioral Toxicology and 

Teratology 8: 7-10. 

Soderlund EJ, Dybing E, Holme JA, Hongslo JK, Rivedal E, Sanner T, Nelson SD (1985) Acta 

Pharmacologica et Toxicologica 56: 20-29. 

Solutia, Inc. (1998) Toxicology reports for Santicizer 141. Submitted to CPSC July 10, 1998. 

Sornkuti SG, Abou-Donia MB (1990) Disposition, elimination, and metabolism of tri-o-cresyl . 

phosphate following daily oral administration in Fischer 344 male rats. Archives of Toxicology 

64: 572-579. 
Somkuti SG, Lapadula DM, Chapin RE, Lamb JC 4th, Abou-Donia MB (1987a) Reproductive 

tract lesions resulting from subchronic administration (63 days) of tri-o-crebyl phosphate in male 

rats. 'Toxicology and Applied Pharmacology 89: 49-63. 

Somkuti SG, Lapadula DM, Chapin RE, Lamb JC 4th, Abou-Donia NIB (1987b) Time course of 

the tri-o-cresyl phosphate-induced testicular lesion in F-344 rats: enzymatic, hormonal, and 

sperm parameter studies. Toxicology and Applied Pharmacology 89: 64-72. 

Somkuti SG, Lapadula DM, Chapin RE, Abou-Donia MB (1991) Light and electron microscopic 

evidence of tri-o-cresylphosphate (T0CP)-mediated testicular toxicity in Fischer 344 rats. 

Toxicology and Applied Pharmacology 107: 35-46. 

Stauffer Chemical Company (1979) Test protocols and data summaries for t-butyl phenyl 

diphenyl phosphate, tricresyl phosphate, trixylenyl phosphate, mixed triaryl phosphate and 

isopropyl phenyl diphenyl. Stauffer Chemical 'Company, Westport, CT. December 1979. EPA 

document no. 40-7942072. 

Stauffer Chemical Company (1 98 1) Toxicological tests on Fyrol FR-2, Volumes I and IT. 

February 3, 198 1. EPA doc. no. 8EHQ-028 1-040 1 ; microfiche no. OTS02049 1. 

Stevens GC, Ghanem R, Thomas JL, Horrocks AR, Kandola N (2003) Understanding flame 

retardant release to the environment. Polymer Research Centre, University of Surrey, UK. 

Supresta (2006) Material Data Safety Sheet for Fyrol FR-2. Supresta, Ardsley, NY. July 20, 

2006. Accessed July 26, 2006. http://www.supresta.com/safetv data sheets.php 

Sutton WL, Terhaar CJ, Miller FA, Scherberger RF, Riley EC, Roudabush RL, Fassett DW 

(1 960) Studies on the industrial hygiene and toxicology of triphenyl phosphate. Archives of 

Environmental Health 1: 45-58. 

Syracuse Research Corporation (SRC) (2006) Physical Properties Database, Syracuse Research 

Corp., Syracuse, NY. Accessed through ..the National Library of Medicine ChemlD database. 

June 2006. >. 

Theiss JC, Stoner GD, Shimkin MB, Weisburger EK (1977) Test for carcinogenicity of organic 

contaminants of United States drinking waters by pulmonary tumor response in strain A mice. 

Cancer Research 37: 2717-20. 

Thiersch JB (1957) Effect of 2,4,6-triamino-'S1-triazine(TR),2,4,6-~eimino)-'S"- 

triazine (TEM) and N,N1,N"-triethylenephosphoamide (TEPA) on rat litter in utero. Proceedings 

of the Society of Experimental Biology and Medicine 94: 36-40. As cited in Thomas and 

Brundage 2004. 
Thomas TA, Brundage P (2004) Qualitative assessment of potential health effects from the use 

of flame retardant chemicals in mattresses. U.S. Consumer Product Safety Commission, 

Bethesda, MD 20814. September 2004. In CPSC 2004. 

Thomas TA, Brundage P (2006) Quantitative assessment of potential health effects from the use 

of flame retardant (FR) chemicals in mattresses. U.S. Consumer Product Safety Commission, 

Bethesda, MD 208 14. January 2006. 

Thomas MB, Collier, TA (1985) Tolgard T.D.C.P. LV: OECD 474 micronucleus study in the 

mouse. Safephann Laboratories Limited, Derby, UK. Prepared for Albright and Wilson 

Limited, Bristol, UK, Experiment no. 16418507. September 8, 1985. 

Thompson FM, Thompson PG (1990) Arts and Crafts. In, Health and Safety Beyond the 

Workplace. Cralley LV, Cralley LJ, Cooper WC, editors. John Wiley and Sons, Inc., New 

York, NY. Chapter 2, pp. 9-32. 

Tocco DRY Randall JL, York RG, Smith MK (1987) Evaluation of the teratogenic effects of triortho-cresyl phosphate in the Long-Evans hooded rat. Fundamental and Applied Toxicology 8: 

29 1-297. 

Treon JE, Dutra FM, Cleveland FP (1953) Toxicity of 2-ethylhexyl diphenyl phosphate, I. 

Immediate toxicity and effects of long-term feeding experiments. AMA Archives of Industrial 

Hygiene and Occupational Medicine 8: 268-280. 

Trochimowicz HJ, Kennedy GL, Krivanek ND (1994) Heterocyclic and Miscellaneous Nitrogen 

Compounds. In Patty's Industrial Hygiene and Toxicology. Wiley Interscience, New York. Pp. 

3402-3405. 

Ulsamer AG, Osterberg RE, McLaughlin J (1980) Flame-retardant chemicals in textiles. Clinical 

Toxicology 17: 101 - 13 1. 

Ulsamer AG, Porter WK, Osterberg RE (1978a) The oral and dermal uptake of radiolabeled 

TRIS (2,3-dibromopropyl) phosphate by rats and rabbits. Toxicology and Applied 

Pharmacology 45: 251. As cited in Ulsamer et al. 1980. 

Ulsamer AG, Porter WK, Osterberg RE (1978b) Percutaneous absorption of radiolabeled TRIS 

from flame-retarded fabric. Journal of Experimental Pathology and Toxicology 1: 543-549. 

Ulsamer AG, Wright PL, Collins R (1979) The oral and dermal uptake of radiolabeled Fyrol. 

18th Annual Meeting of the Society of Toxicology, 1979. 

Weiner ML, Jortner BS (1999) Organophosphate-induced delayed neurotoxicity of triaryl 

phosphates. Neurotoxicology 20: 653-674. 
Welsh JJ, Collins TFX, Whitby KE, Black TN, Arnold A (1987) Teratogenic potential of 

triphenyl phosphate in Sprague-Dawley (Spartan) rats. Toxicology and Industrial Health 3: 357- 

369: 

Wester RC, Quan D, Maibach HI (1996) In vitro percutaneous absorption of model compounds 

glyphosphate and malathion from cotton fabric into and through human skin. Food and 

Chemical Toxicology 34: 73 1-735. 

Wilczynski SL, Killinger JM. Zwicker GM, Freudenthal RI (1983) Fyrol FR-2 fertility study in 

male rabbits. The Toxicologist 3: 22. (Abstract only). 

Wills JH, Barron K, Groblewski GE, Benitz KF, Johnson MK (1979) Does triphenyl phosphate 

produce delayed neurotoxic effects? Toxicology Letters 4: 221-24. 
Memorandum 

Date: December 21, 2006 

TO : Dale Ray, Project Manager for Upholstered Furniture, Directorate for 

Analysis 

THROUGH : ary Ann Danello, Ph.D., Associate Executive Director for Health Sciences 

~ri E. Saltman, M.S., Director, Division of Health Sciences 

FROM 6ichael A. Babich, Ph.D., Chemist, Division of Health Sciences 

SUBJECT : Response to Peer Review Comments on the CPSC Staff Preliminary Risk 

Assessment of Flame Retardant (FR) Chemicals in Upholstered Furniture 

~oarn* 

The CPSC staff completed a draft risk assessment on the use of flame retardant (FR) chemicals 

in upholstered furniture foam in January 2006 (Babich et al. 2006). This document was peerreviewed by two independent experts in toxicology and risk assessment. The staff has made 

appropriate revisions to the risk assessment (Babich 2006), based on comments from peer 

reviewers and public comments. Below are the staff responses to the peer reviewers7 

comments. t 

The peer reviewers' comments included the methods and models used to estimate exposure. In 

particular, the reviewers suggested the use of a "breathing zone" model to estimate inhalation 

exposure. This resulted in a slight increase in the estimated inhalation exposure. The peer 

reviewers also requested additional details and discussion. As a result of the changes made in 

response to the peer review and public comments, the relative contribution of inhalation to total 

exposure increased. However, the overall conclusions of the risk assessment did not change. 

- 

* These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily 

reflect the views of, the Commission. 

The peer reviewers' responses are reported verbatim. 

167 , 

CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http://www.cpsc.gov 
I. COMMENTS ON EXPOSURE ASSESSMENT 

Comment: 

"The experimental work presented in the provided documents is excellent and provides some 

much-needed data. As mentioned in a previous review for FR in mattresses and bedding, these 

data have been lacking from evaluations of flame-retardant materials conducted to date, and 

these experimental results are precious in that they represent a significant contribution to the 

field. Once again we have noted that CPSC staff needs to conduct a painstaking reconstruction 

and check of all of the algorithm details and calculations that went into the risk assessment. This 

detailed evaluation of the specific calculations was considered beyond the scope of this peer 

review, aside from the comments below on a key computational error discovered in all the 

spreadsheets." 

Response: 

The CPSC staff has reviewed and verified the calculations. 

comment: 

"The most significant issue found in this review was a computational error in the spreadsheets. 

The calculation of the density of the FR substances measured in the extraction tests drives the 

estimation of exposure and risk for both the dermal and oral portions of the evaluation. This 

calculation takes the average amount of FR detected on the 5.5 cm diameter filter paper and 

calculates a surface density by dividing this amount by the surface area of the filter @i*(dia/2)2)). 

This calculation is done in cell E24 of the spreadsheets. 

The content of cell E24 of all the spreadsheet is: =El 9/(PI()*(5.5/2A2)) 

Microsoft Excel does power or exponentiation calculation before it does division or 

multiplication +thin parenthetical expressions. Thus instead of dividing 5.512 to calculate the 

radius and then squaring the result, the 2 in the denominator was squared first and then divided. 

This resulted in an OVERESTIMATION of all dermal and oral exposures and risk (HI 

determinations) of 5.5 fold. 

Thus, all the predicted Hazard Indices will be lower. Those analyses that were driven 

predominantly by dermal and oral exposure (TDCP and BAE) * with HIS of about 5 or less 

within this analysis should now correctly have HIS less than 1. The HI for TPP (FM-550) was 

reduced less (about 2 fold) with the corrections of this error because of the greater contribution 

of estimated inhalation exposure to overall risk from this FR substance. 

Since the dermal and oral routes made up the vast majority of the exposure and risk for TDCP 

and BAE, correcting this error does not materially change the relative estimated contributions of 

Some of the abbreviations were changed to reflect new information that more specifically identifies certain 

chemicals. BAE (brominated aryl ester) was changed to OTB (octyl tetrabromobenzoate) and ITP (isopropylated 

triphenyl phosphate) was changed to PIP (phenol isopropylated phosphate). 
these routes. It does materially change the distribution of estimated contributions for TPP (FM550) taking the inhalation portion of HI from 50% to 85%." 

Response: 

2 

The expression was inadvertently entered as ($1 instead of [y ) . This error was corrected 

in the revised risk assessment. However, some other changes were made in response to 

comments from the peer reviewers and public comments. Changes were made to some of the 

input parameters for estimating dermal exposure, the vapor pressure of TDCP, and the model for 

estimating inhalation exposure. These changes are discussed in detail below: As a net result of 

these changes, HI for TDCP is still roughly 1. However, the relative importance of inhalation 

has increased for TDCP, TPP, and PIP (ITP). 

Comment:. , 

"Since the estimated dermal exposure accounts for a majority of the estimated risk for TDCP and 

BAE, any error or omissions in this analysis will have a significant effect on the overall 

predictions. The primary manner of estimating systemic absorption in this document was the use 

of a percutaneous absorption rate combined with other parameters. This assumes that a steadystate has been established between material going onto the skin and then into the circulating 

elements of the body. This is clearly an overestimating assumption which deserves some 

discussion in the text especially related to the characteristics of the FR compounds under study." 

Response: . . 

The staff agrees that the assumption of steady-state conditions may lead to an overestimation of 

exposure. We have added this point to our discussion. However, we also note that this approach 

is protective of public health and is typically used for risk assessment purposes. 

Comment: 

"Perhaps the largest factor absent from consideration in this analysis is the integration of the 

effects of standard skin shedding (desquamation) into the estimation of the ultimate absorption of 

compounds with high values of MW or &,. Skin is continuously replaced through epidermal 

turnover, the process by which new cells are generated at the base of the epidermis while the 

outermost surface flakes off (i. e., desquamates) at the same rate. Of course, any chemical in 

desquamated skin cannot be absorbed systemically. The typical time required to replace all of 

the skin cells (birth-to-shedding) in the stratum cornium (sc) is approximately 14 days, but varies 

with physiological location and age and can be as long as 60 days or shorter than 14 days for 

diseased skin. 

In short, substances that take a relatively long time to penetrate skin will not be absorbed by the 

body if this up-welling of skin layers occur at a significantly faster rate than the penetration of 

the toxicant through the sc to the viable dermis. The substance would be shed with the skin cells 
! 

and thus eliminated from the body. It would be analogous to a weak or slow salmon that never 

made it upstream to the "target" pool to spawn but was instead washed back out to sea. 

Dr. Wil tenBerge has actually put together a kinetic model of dermal penetration which accounts 

for the rate of dermal penetration that occurs versus the nominal amount that might be lost via 

desquamation. This model is available for download at the bottom of the following web page 

which provides the details of the model: http://home.planet.nl/-wtberge/skinperm.html 

Last year, Dr. Annette Bunge shared a preprint entitled: Does Desquamation Reduce 

Permeation? (Micaela B. Reddy and Annette L. Bunge) which I believe confirms the reality and 

im ortance of this mechanism for chemicals with high MW (>350 g/mole or high Kow (Kow > 

log,. 

Excerpted text from this paper: 

Except for highly IipopHilic or large lblW chemicals, nearly all of the chemical in the epidermis at 

the end of an exposure will systemically absorb (i.e., Fraction Absorbed or FA - I), regardless of 

the length of time the skin was exposed to the chemical. Only for chemicals with large values of 

MW (> about 350 Da) or IogKolw (> approximately 4 for most chemicals) will epidermal turnover 

reduce FA significantly. 

Clearly, TDCP and BAE fall into this category of MW >350 or logKow >4. While the 

SKINPERM model could be used to predict the magnitude of this effect, there is arguably not 

enough data available at this point to specifically quantify this effect on systemic absorption. 

However, it would be appropriate for the evaluation to include a discussion as explanatory text of 

the issue of desquamation and its potentially striking implication on dermal exposure and risk.:' 

Response: 

Percutaneous absorption of TDCP was measured in vitro (Hughes et al. 2001), under an 

interagency agreement between CPSC and the EPA Human Effects Research Laboratory 

(HERL). During the planning stages of this work, we sought the advice of Dr. Robert Bronaugh, 

FDA, who is an expert in percutaneous absorption and has contributed to the development of in 

vitro methods. Because TDCP is hydrophobic, transfer from skin to the receptor medium is 

expected to be slow, relative to in vivo studies. Therefore, we assumed as a reasonable default 

that any TDCP that reaches the upper, papillary dermis would be absorbed in vivo. We agree 

that this assumption merits additional discussion. We have expanded the discussion on this point 

in the revised risk assessment. 

Comment: 

"Oral exposure occurring from hand-to-mouth activity appears to be adequately described by 

taking the amount of chemical that migrated to the fabric surface from the somewhat superficial 

wetting/pressure protocol and applying the predicting factors used in the report. The amount of 

material extracted by direct mouthing or sucking, however, may not be reasonably simulated by 

using the amount of chemical that migrates to the fabric surface in this test. 
Two factors could combine to exacerbate the oral exposure from sucking. First, the volume of 

saliva injected into and potentially sucked out of the foam by a child could be anticipated to be 

much greater than the amount used in the migration protocol. Second, this added volume of 

warm "extractant" would be expected to penetrate more deeply into the foam and thus potentially 

be able to pull out more FR substance from it per active sucking event and unit area. 

A simple protocol to gauge this exposure potential would be to saturate a small (ca. 3 cm x 3 cm 

x 1 cm thick) section of foam with approximately 10 cm3 of saline initially at 36-38°C in a small 

watch glass or dish. After wetting, knead the wetted foam for 10 minutes, s ueeze to express the 9 water from the foam, analyze the extractant and estimate the amount per cm extracted. One 

could then use this value for M in equation 3. Please note: that M for hand-to-mouth transfer 

would continue to use the current migration data and these experimental values would also be 

used in equations 1 and 2. If a different protocol results in a different values of M for direct 

mouthing - it should have a different notation to differentiate it from transfer, perhaps M, for 

direct mouthing transfer and Mt for hand-to-mouth transfer. This would also mean that equation 

4 would need to be reconstructed to account for these two types of M values. 

The above protocol is only one suggested approach. The point is that the amount of FR obtained 

from the current migration procedure is most likely not representative of that obtainable during 

the direct mouthing/sucking scenario and that a more rigorous extraction test is needed to 

simulate this potentially critical exposure route." 

Response: 

In prior work, the CPSC staff has used several methods to estimate oral exposure due to 

migration of chemicals from various substrates. We have considered the comments presented 

here. However, the staff concludes that the CPSC staff method of measuring leaching, which 

involves a significant volume of liquid and a weight, is sufficiently stringent to estimate oral 

exposure in children. Furthermore, in observational studies conducted by the CPSC staff, direct 

mouthing of furniture by children was an infrequent event (Kiss 2002; Smith and Kiss 1998). 

Comment: 

"Inhalation exposure represents a relatively small portion of the overall predicted exposure for 

TDCP and BAE but represents a significant portion of the exposure predicted for TPP (FM-550). 

There are a number of issues related to this estimate in the report that are worthy of mention. 

While these comments and suggested actions would most likely not provide results that would 

change the conclusions of the report for TDCP and BAE, they could change the results of the 

estimated exposure to TPP (FM-550). 

The only experimental measurement related to inhalation exposure in the report occurred for the 

determination of particulate emission during normal use. The protocol used is quite ingenious. 

and does indeed show that the level of exposure from airborne particulate is extremely low 

relative to any reasonable exposure limit (i. e., truly de minimus). 
Unfortunately, there is no experimental determination of Csat, only its estimation from VP (cited 

for TPP and model-estimated for TDCP and BAE). Csat in turn drives the estimation of source 

strength, which is used to calculate breathing zone concentrations. This approach introduces a 

considerable amount of uncertainty which could be reduced by the direct measurement of Csat. 

The value for VP for TDCP and BAE is estimated in the report at % the estimated upper bound 

figure or 5 x 10'~ ton. This vapor pressure would render a Csat of: 

Csat TDCP = 0.012 mg/m3 

Csat TPPIITP = 0.110 mg/m3 (based on VP = 6.3 x 

Csat BAE = 0.01 5 mg/m3 

Note: The following relationship was used to convert ppm v/v to mg/m3. 

?\ 

It is suggested that a relative simple laboratory protocol could be used to significantly refine 

these estimates. This would be done by first taking 6 square pieces of 1 m2 foam joined to form 

a 1 m3 cubic box and then allowing the interior volume of this closed foam box to equilibrate at 

room temperature. Given enough time, the offgassing FR substance will equilibrate at Csat in the 

box without the effect of absorptive losses to any non-ventilatory surface sinks. 

Consider a volume with an initial fixed level of airborne concentration (Co = 100) and no new 

material entering the room air with the incoming ventilation. Given good mixing, this situation 

is described as: 

C= concentration in the room at any time 

Co = concentration in the room at time = 0 

ventilation rate = volume/time 

When the product of (ventilation rate) and (time) equals the chamber volume, a single mixing air ' 

change has occurred and C = Co e-' or C/ Co = .368. In this situation C would be reduced from 

100 to 36.8 after a single air change and approximately 63% of the original molecules (air and 

contaminant) were removed. - 

Thus, it can be shown with first principle kinetic modeling that any volume of contaminated air 

that is replaced with good mixing with an equal volume of incoming pure air (i.e., 1 m3 of air 

into a lm3 box) will lose 63% of the original air (and contaminant) molecules and retain 37% of 

the original air and contaminant. Thus, a 1 m3 air sample taken from the interior volume of this 
box should capture at least 63% of the FR molecules originally in the box air with approximately 

33% remaining in the box due to the influx and mixing of make up air that would occur during 

air sampling. Assuming all of the above estimated vapor pressures are correct, this would mean 

the collection of an analytical sample amount of 8 micrograms of TDCP and 9 micrograms of 

BAE. Doing the same analysis with TPPIITP should yield a sample of about 69 micrograms. 

Thus the determination of Csat for each FR substance out of the foam box would simply be the 

sampled concentration divided by 0.63. Note that this analysis also assumes that there are no 

new emissions to the air volume during the relatively short sampling period. 

. Indeed, given the excellent laboratory capabilities demonstrated by the CPSC, analytical 

detection limits in the fraction of a microgram range could dramatically drive down the 

determined Csat for any and all of the compounds out of real foam. For example, assume that 

BAE was a "non-detect" at a limit of detection (LOD) <0.5 ug. Since the estimated Csat predicts 

9 ug of BAE, a "non-detect" at LOD <0.5 ug would lower the determined Csat (and subsequently 

the estimated exposure) by approximately 18 fold versus the current estimate. 

Csat is a critical value for the estimation of inhalation potential; however, the length of time it 

takes to reach a significant portion of this saturated concentration could also be an important 

factor especially as it relates to bolus injection of vapors into room air from foam contraction 

which will be discussed below. Once the time-to-equilibrium is established at room temperature, 

conducting the tests at 45', 35" and 25" C would dramatically enhance the amount of available 

analytical sample and improve our understanding of just how much FR is potentially coming off 

as a vapor into real rooms." 

Response: 

The reviewer provided a helpful discussion on the importance of Csat in estimating inhalation 

exposure to vapor phase FR chemicals. 

For a pure compound, Csat should.equa1 the theoretical value estimated from the vapor pressure, 

provided that the temperature and atmospheric pressure are the same. For FR-treated foam, an 

empirically determined Csat may be lower due to interactions between the FR and the foam. 

Using an empirical or "effective" CSat measured with treated foam would be slightly more 

accurate. However, even with an empirical CSathere would still be considerable uncertainty in 

estimating inhalation exposure, because the source strength was estimated by means of a 

theoretical model, rather than measuring it in a chamber or test house. 

In revising the risk assessment, we estimated the "effective" vapor pressure of TDCP using 

TDCP-treated foam (Cobb and Bhooshan 2005). We used this value (2.7~10'~ torr) to estimate 

inhalation exposure in the revised risk assessment. In addition, we more thoroughly investigated 

the available data on the vapor pressure of pure TDCP (Babich 2006). We found empirical and 

estimated values from authoritative sources (EPA, National Library of Medicine, International 

Programme on Chemical Safety, and industry reports) that ranged over seven orders of 

magnitude (7.4x10-' to 0.2 torr). The "effective" vapor pressure from TDCP-treated foam was 

much greater than the value we used in the draft risk assessment (5x10-~ tom), although it is less 

than empirical values for pure TDCP (0.0014 to 0.2 torr). 
In response to comments fiom peer reviewers and others, the staff made a number of changes in 

the input parameters and models used to estimate exposure. As a result of these changes, the 

estimated dermal exposures were generally lower, while the estimated inhalation exposures 

generally increased. Therefore, the relative contribution of vapor phase inhalation has greatly 

increased. 

Comment: 

"Other areas of the analysis that could be improved include the determination of the affected 

volume for emissions from foam furniture and the determination of the diffusivity (Dair - or D& of 

FR compounds in air. Finally the topic of bolus injection of vapors into room air from rapid 

foam contraction (sitting) will be discussed separately below. 

The current methodology estimates the source term for release of particles from a small-volume 

(glove box) experiment and then scales that source term into a much larger well-mixed single 

box (320 m3) roornhouse model. As mentioned in our previous review, the exposure scenario 

suggested by these particle emissions can be reasonably described using the following 

characteristics: 

Relatively small emission area in a relatively large room and house volume, 

impaction source proximate to the breathing zone of the subject (i.e., the subject is 

causing the emission and persona cloud, and 

the potential for relatively large and quickly settling particles 

All of the above suggests that the well-mixed room or house volume model will dramatically 

under-estimate the breathing zone concentration of particles resulting from this essentially "nearfield" or proximate source. It would be more appropriate to take the airborne concentration in 

the smaller volume of the glove bag as a reasonable approximation of the "near-field" 

concentration around the breathing zone of the person in bed. Going from 320 m3 for the whole 

house volume to 1 m3 as a personal cloud volume represents two to three order of magnitude 

increase in exposure. Values for potential inhalation exposure from particulate are so small, 

however, as to still be de minimus, even with this increase." 

Response: 

As discussed in the risk assessment, we considered two approaches. One approach is to consider 

exposure in the room where the furniture is located, which requires assumptions for consumer 

activity patterns, that is, the amount of time spent in each room. We chose a simpler approach, 

which was essentially to "average" the exposure over the entire home for 16 h, the average time 

that a consumer spends at home. Thus, the increased concentration in the room where the source 

is located, in the first approach, would be off-set by the shorter exposure duration in the second 

approach. 

Nonetheless, we agree that our approach could significantly underestimate exposure to 

particulate and vapor emissions. As suggested by the reviewer, we used a third approach to 
estimate inhalation exposure in the revised risk assessment. In this approach, a consumer sitting 

on the furniture is considered to be in a "breathing zone," that is, a location that is intimately 

associated with the source of emiksion. The breathing zone exchanges air rapidly with the 

remainder of the room. This change increased the estimated inhalation exposure by less than 

2-fold. 

Comment: 

"There is also a strong likelihood that exposure fiom FR vapors is relatively low and this is 

particularly true for emissions from TDCP and BAE. In light of the above mentioned 

imprecision in the likely overestimation of Csat vapor concentrations and vapor emission source 

rates we believe that an uncertainty analysis with the primary diffusion of vapors into smaller 

affected volumes would be appropriate. This analysis could help to inform a decision on 

whether to do actually testing of Csat especially for TPP (FM-550)." 

Response: 

As discussed above, the staff made a number of changes in the input parameters and models used 

to estimate exposure in response to comments from peer reviewers and others. As a result of 

these changes, the estimated dermal exposures were generally lower, while the estimated 

inhalation exposures generally increased. Therefore, the relative contribution of vapor phase 

inhalation has greatly increased. 

Comment: 

"The molecular diffusivity in air (Dair) calculated for the FR substances used a referenced 

relationship from Schwope et a1 1989. A more refined algorithm to estimate Dair has actually 

been developed and published more recently by the EPA. Specifically, this includes the 

evaporative source term algorithms from a subsequent publication of the US Environmental 

Protection Agency (EPA 199 1 Engineering Manual [EPA (1 99 1). Preparation of Engineering 

~ssessments, Volume I: CEB Manual, Chemical Engineering Branch, Economics and 

Technology Division, Office of Toxic Substances, Washington, D.C. February 28, 1991. pp. 4- 

23 to 4-33] were used. The key equations in this document for emission from vaporizing pools 

are presented below along with their designations within this reference: 

Equation 4-22 

where: G = Generation rate, lblhr 

M = Molecular weight, lb/lb mole 

P- = Vapor Pressure, inches of Hg 

A = Area, fi2 
Dab = Diffusion coefficient, ft2/sec of coinpound a through b (in this case 

b is air) - the same as Dair. 

VZ = Air velocity, ftlmin 

T = Temperature, OK 

Az = Pool length along flow direction, ft 

Gas diffusivities of volatile compounds in air are available for several existing chemicals. 

However, the diffusion coefficient often will not be known. An equation to estimate diffusion 

coefficient is expressed as: 

where: Dab . = Diffusion coefficient, cm2/sec 

(NB : the units of Dab are different in Equations 4-22 and 4-23) 

T = Temperature, OK 

M = Molecular weight, lb/lb mole 

pt = Pressure, atm 

Equation 4-23 is arguably more refined than equation 10 in the evaluation. 

Converting Dab in Equation 4.23 to units of ft2/sec and substituting: 

(J= 0.5 0.5 TO.~~AZ 4 Equation 4-24 

where: G - - 

M = 

P ' - - 

vz - - 

A - 

T - 

Az = 

Pt = 

Generation rate, lbh 

Molecular weight, lb/lb mole 

Vapor Pressure, in. Hg 

Air velocity, Wmin 

Area, ft2 

Temperature, OK 

Pool length along flow direction, ft 

Overall pressure, atm 

One could use any Csat determined experimentally as suggested above to directly calculate the 

effective vapor pressure, P', using a rearrangement of equation (9) of the CPSC report. Given a 

value for Pethe above equation could be used to estimate or gain some insight into the time 

required to achieve equilibrium in any enclosed volume." 
Response: 

The CPSCstaff could consider using a different algorithm for estimating Du, or the source 

strength. However, the exposure from vapor phase inhalation is based on a theoretical model. A 

different algorithm would not address the many other uncertainties in the exposure estimate. 

Due to its relative importance to overall exposure, it is more important to obtain empirical data to 

estimate inhalation exposure. 

Comment: 

"Bolus Injection of Vapors Into Room Air from Foam Contraction 

[While working on anotherproject, one of our colleagues] suggested the following inhalation 

exposure scenario for FR treated foam: 

"Given enough time, the FR compound will vaporize into the void volume of the foam ultimately 

to a concentration of CSat for that compound coming out of that polymeric matrix. When the 

foam is contracted (from someone sitting on it) the amount of FR substance potentially injected 

into the surrounding air would be equal to (Csat) x (Compressed Volume). This direct injection 

mechanism could conceivable result in relatively high localized breathing zone concentrations of 

the FR substance around the contracted area. 

The appropriate gauging of this effect would require the estimation of both Csat and the 

compressed volume. One would also need to understand the kinetics of vaporization to 

determine the time course and capacity of this effect. If the vaporization rate is relatively slow, 

then this effect would not contribute significantly to the indoor concentrations or the exposure 

potential. 

Given a more accurate estimation of Csat and the emission rate of FR vaporization to air from 

foam, our opinion is that it is highly unlikely that the bolus injection from foam contraction 

would provide a significant level of exposure for the current FR substances of interest. 

However, our opinion is not a risk assessment. Conformation of that opinion means first 

conducting a reasonable worst-case uncertainty analysis of this factor with the current uncertain 

(but likely over-estimated) estimates of Csat . ~kasonable worst case estimates of compressed 

volumes, rates of sitting, and an assumption of quick "recharge" of the FR concentration in the 

void volume could also dramatically overestimate the exposure and risk from this mechanism. If 

this analysis indicated an HI significantly greater than 1, then refined estimates for Csat and FR 

vaporization rate might be necessary." - 

Response: 

As discussed by the reviewer, the importance of this pathway depends on the rate at which vapor 

phase FR chemical in the cells of the foam is replenished. Given the surface to volume ratio, this 

might occur rapidly. One way to assess this would be to measure vapor phase FR during the 

impaction tests. We added a discussion of this model to the revised risk, assessment. 
We performed some simulations to gauge the relative contribution of an "injection" model to 

inhalation exposure. Such a model requires several assumptions, such as how frequently and to 

what depth the foam is compressed. The depth of foam compression would depend on the foam 

properties, weight of the consumer, and velocity of motion. These assumptions, which are 

difficult to verify or measure, make the model highly uncertain. We estimated that the vapor 

phase inhalation exposure from the injection model is about 40% of that from the NRC model. 

Comment: 

"Uncertaintv Analysis 

We commend CPSC for conducting a sensitivity analysis for the exposure parameters. While it 

can be more informative to vary multiple parameters simultaneously, the approach used by 

CPSC gives reasonable estimates of the impact of uncertainty in the input parameters and the 

magnitude of a reasonable upper bound estimate of exposure. CPSC also provided practical and 

level-headed interpretations of the results of the sensitivity analysis. Aside from the additional 

analyses suggested above, we have no comments on the sensitivity analysis or discussion of 

uncertainty." 

Response: 

We chose to perform a sensitivity analysis for exposure parameters, rather than a probabilistic 

analysis, because only limited information was available on the distributions of the input 

parameters. We consider that a probabilistic analysis with such limited data could provide the 

reader with a false sense that the uncertainty and variability in this risk assessment are wellcharacterized. 
11. COMMENTS ON TOXICITY AND DOSE-RESPONSE ASSESSMENT 

Comment: 

"While it is recognized that CPSC is an independent agency, CPSC may wish to consider further 

harmonization with the methods of other organizations*. This includes the use of benchmark 

dose methods, inhalation dosimetry for effects on the respiratory tract, consideration of the 

implication of extrapolation from subchronic to lifetime exposures, and the use of chemicalspecific adjustment factors instead of uncertainty factors. Other agencies and organizations, 

including the Agency for Toxic Substances and Disease Registry (ATSDR), Health Canada, and 

the International Programme on Chemical Safety (IPCS) include some or all of these 

considerations. For example, Health Canada includes an uncertainty factor of 1-1 00 for 

inadequacies of the database, including lack of adequate data on developmental, chronic or 

reproductive toxicity, use of a LOAEL, and inadequacies of the critical study (Meek et al., 1994). 

While these specific adjustments may not always have a significant impact on the overall 

assessment, use of these values, where possible and feasible within resource limitations, tends to 

improve the scientific basis for the assessment. 

In this spirit of harmonization, Table 1 presents risk values for the FR chemicals developed by 

other organizations and the bases for these values. The data are from the NAS review of flame 

retardants (NRC, 2000), and IRIS data from EPA (http://www.epa.gov/iris/ ), and supplemented 

by data fiom ATSDR. Key differences from other organizations are bolded. The ITER database 

(available at http://www.tera.org/iter/ and http://toxnet.nlm.nih.gov/) provides key information 

about risk values developed by U.S. and international agencies, as well as independentlydeveloped and peer-reviewed values, and can be a resource for such information." 

Response: 

The risk assessment, including the use of uncertainty factors, was conducted according to the 

CPSC Chronic Hazard Guidelines, which were issued in 1992. The guidelines do not provide for 

additional uncertainty factors to account for inadequacies of the data base or for the potential 

sensitivity of children relative to adults. However, the guidelines allow the use of chemicalspecific adjustment factors on a case-by-case basis, provided there are sufficient data to deviate 

firom the default factors. In the present case, the CPSC staff did not consider that there were 

adequate data to justify the use of chemical-specific uncertainty factors. The differences 

* "Note that harmonization is not standardization. Harmonization involves (1) understanding the methods and 0 practices used by various organizations; (2) developing confidence in, and acceptance of, assessments using 

different approaches; and (3) willingness to work toward a convergence of methodologies as a long-term goal 

(Sonich-Mullin, 1997)." 

Table 1, provided by the peer reviewers, appears on page 14 of this document. 
Table 1. Comparison of Toxicity Values of FR Chemicals Developed by Various organizationse 

Chemical 

Tris (1,3-Dichloro-2- 

Propyl) Phosphate 

(TDCP) 

Triphenyl Phosphate 

(TPP) 

lsopropylated Triaryl 

Phosphate (ITP) 

Brominated Aryl 

Esters (BAE'S) 

Tris (1,3-Dichloro-2- 

Propyl) Phosphate 

(TDCP) 

CPSC 

AD1 = 0.005 mglkg-day 

LOAEL = 5 mglkg-day (Biodynamics 

1981) 

UF = 1000 (1 OA, 1 OH, 10L) 

Oral cancer unit risk = 0.031lmglkgday (based on ql from BMD modeling 

for kidney and liver tumors combined) 

Date: 2006 

Possibly toxic in humans. lnsufficient 

information to derive an AD1 directly. 

NOAEL = 160 mglkg-day (Sobotka et 

al., 1986) 

Possibly toxic in humans. lnsufficient 

information to derive an AD1 

lnsufficient information to determine 

whether the BAE1s'are "toxic" in 

humans or to derive an ADI. 

NAS 

RfD = 0.005 mglkg-day 

LOAEL = 5 mglkg-day (Biodynamics 

1981) 

UF = 1000~(10A, 3H, IOL, 3D) 

RfC = 0.018 mg/m3 (based on route-toroute extrapolation from RfD) 

Oral unit risk = 0.06 lmglkg-day (based 

on BMDL extrapolation to zero for 

testicular tumors) 

Inhalation unit risk = 1.71 x 10"/ug/m3 

(based on route-to-route extrapolation 

from oral unit risk) 

Date: 2000 

No assessment 

No assessment 

No assessment 

EPA 

No RfDIRfC 

No RfDIRfC 

No RfDlRfC 

UF ='lo00 (IOA, IOH, 10L) 

Oral cancer unit risk = 0.03llmglkgday (based on ql from BMD modeling 

for kidney and liver tumors combined) 

Date: 2006 

AD1 = 0.005 mglkg-day - 

LOAEL = 5 mglkg-day (Biodynamics 

1981 1 

* Table provided by the peer reviewers. 

UF ='I 000 (IOA, 3H, 1 OL; 3D) 

RfC = 0.018 mglm3 (based on route-toroute extrapolation from RfD) 

RfD = 0.005 mglkg-day 

LOAEL = 5 mglkg-day (Biodynamics 

1981 

Oral unit risk = 0.06 lmglkg-day (based 

on BMDL extrapolation to zero for 

testicular tumors) 

Inhalation unit risk = 1.71 x 10-~1u~lm~ 

(based on route-to-route extrapolation 

No RfDIRfC 

ATSDR 

No assessment 

No assessment 

No assessment 

No assessment 
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between CPSC's risk assessment practices and those of other U.S. agencies are minor and have 

been discussed elsewhere in detail (Babich 1998; Rhomberg 1997). 

Comment: 

"It would be usefil for the documentation in the quantitative assessment to provide sufficient 

rationale for the readers to understand the reasons for the key decision points, particularly where 

CPSC decisions differed from those of other organizations. While the reader can be referred to 

the qualitative assessment for additional details (where such details are provided in that 

assessment), it can be usefil to have all of the key exposure and toxicity decisions documented 

in one place. It would be desirable for each chemical summary to include an overall picture of 

available database, even in light of the brief summary in the risk assessment document. For 

example, although the two-year chronic study for TDCP was judged to be the critical study, the 

findings from this study are supported by other studies, such as acMe and subchronic studies, 

developmental and reproductive studies, and neurotoxicity studies. The current version of the 

summary document (risk assessment document) does not mention the existing developmental 

and reproductive studies, probably due to the lack of positive findings from these studies. 

Without such supporting information, the confidence for the derived ADIs would be significantly 

compromised. The differences in the methods used by different regulatory agencies in risk 

assessment highlight the importance of clear documentation of the key decision points in 

deriving risk values." {see Table 1 ) 

Response: 

The staff agrees with the reviewer, and has substantially expanded the suinmaries in the hazard 

identification and dose response sections in the revised riskassessment. 

Comment: 

"The summary document does not mention any information about potential skin and eye 

irritation effect. In addition, there was no mention of any information about inhalation toxicity. 

Since such data may be available, it would be helpfil to briefly mention the results even though 

they showed negative responses." 

Response: 

This information has been added to the hazard identification section of the risk assessment. 

Comments on Specific Chemical Assessments 

"These comments are based on review of the qualitative and quantitative assessments for the 

chemicals of interest provided by CPSC, supplemented by other documentation provided by 

authoritative reviews by other organizations or agencies. Since TDCP is the only one among the 

four chemicals summarized in'the CPSC review document that has enough data for deriving an 

ADI, a more detailed discussion is provided for TDCP." 
Comment: 

Tris(l,3-Dichloro-2-Pro~7/1) Phosphate (TDCP) . 

"We recognize that the purpose of the primary document being reviewed (the risk assessment 

document) is to focus on the overall risk assessment, rather than the details of the studies. 

However, as mentioned in the general comments, it is much easier for the reader, and improves 

the overall credibility of the assessment, if the key toxicity information is presented. While it is 

appropriate to reference the supporting documents for the study details, it is recommended that 

CPSC include a list (either text or tabular) of other relevant studies (including the neurotoxicity, 

developmental, and reproductive toxicity studies). It would be useful for this list to identifj the 

effects observed and NOAELsILOAELs. For example, neurological effects were mentioned in 

the summary of acute studies, but the risk assessment document did not address the follow-up 

neurotoxicity studies conducted in hens treated with repeated doses of TDCP (Stauffer Chemical 

Co., 1981; Celanese Corp., 1960). Description of the findings from these latter studies would 

present a complete picture of the potential neurotoxicity of TDCP. In addition to data on toxicity 

from oral exposure, the summary should also include information on available toxicity 

information from dermal and inhalation exposure. At the least, it would be useful to note that 

few data are available for these routes. In addition, as noted below, it would be useful for CPSC 

to do some rough analyses to evaluate the importance (or lack thereof) of these data gaps." 

Response: 

Additional information has been added to the hazard identification, dose response, and 

discussion sections. 

Comment: 

"As an important component of hazard characterization, information regarding reproductive and 

development toxicity should always be mentioned. Even though the detailed information is 

presented in the earlier supporting documents, summarizing the results of the reproductive and 

developmental toxicity studies in the risk assessment document would address a potential data 

gap in the reader's mind, even if these studies show negative results (e.g., for TDCP, 

developmental toxicity only in the presence of maternal toxicity or no reproductive effects in 

rabbits). Three developmental and reproductive studies have been conducted in two different 

animal species, rabbit and rat (Wilczynski et al., 1983; Stauffer Chemical Co., 1977-1978; 

Kawashima et al., 1983; Akzo Nobel Functional Chemicals LLC, 2001). Results of these studies 

are of particular relevance for TDCP, since the critical effect for the noncancer assessment is a 

male reproductive endpoint. It would be useful to address consistency between the negative 

results in these studies and the use of a male reproductive effect as the critical effect. We agree 

that this inconsistency is not necessarily problematic, since the two-year bioassay was in rats and 

the male reproductive toxicity study was in rabbits, and different endpoints were evaluated, but 

these differences should be noted. Overall, further consideration of endpoints evaluated and 

relative sensitivity of the species would be useful, since the rabbit NOAEL of 200 mgkg-day for 

male reproductive function was 40x the rat LOAEL of 5 mglkg-day." 
Response: . . 

Additional explanation has been provided. 

Comment: 

"It would be useful to state more explicitly in the risk assessment document what the 

experimental protocol was for the chronic two-year study in rats (e.g. "animals were exposed.. . in diet for 2 years). Because this document only mentions the interim sacrifice, but does not 

mention the terminal sacrifice, the reader may wonder whether the dosing in this study continued 

for two years or just one year followed by a 12-month recovery. The text could also be clarified 

if the terminal sacrifice and number were noted after the mention of the interim sacrifice. More 

significantly, it is not clear fiom the text whether the reported effects were observed at the 

interim or terminal sacrifice, and whether there was any progression with additional exposure. In 

addition, the identification of doses tested should include the dose of 0 mgkg-day, to make it 

clear that the study did include the appropriate control. 

Although the summary identifies the lowest treatment dose of 5 mgkg-day as a free-standing 

LOAEL, it does not identify the effects on which this judgment was based. It would be useful to 

remind the reader that the LOAEL is based on seminal vesicle lesions, and to more specifically 

identify the observed lesion(s)." 

Response: 

Additional information has been included in the revised risk assessment. 

Comment: 

"While it appears that the focus of the genotoxicity summary is strictly in support of the 

carcinogenicity assessment, it would be useful to provide some additional information. In 

particular, more information and/or further analyses would be useful regarding the "mixed 

results" in mammalian systems. Were consistent results observed within a study type (e.g., DNA 

damage, gene mutation, chromosome aberration)? The more detailed evaluation by CPSC in 

Ferrante (1999b), describes "weak or variable" results in mammalian systems. It would have 

been useful to provide more information in that document regarding the "variable" results, and 

interpretation of those studies. In particular, it was not clear whether Ferrante (1 999b) 

considered all of the relevant studies evaluated by NRC (2000). Ferrante (1999b) also presented 

a nice review of studies investigating different microsome activation systems. However, it 

would have been useful for CPSC to conduct a more critical evaluation of the overall conclusion 

regarding the impact of the S9 systems, such considerations may provide information regarding 

the enzymes that metabolize TDCP to a genotoxic form. Regardless of the conclusions of this 

analysis of the impact of S9, a brief statement should be included in the final risk assessment, 

noting the variety of S9 systems tested and the results and implications of such testing. 

, Most of the tumor response data showed a dose-response trend. Nevertheless, adenomas of the 

adrenal cortex were significantly elevated only in mid-dose males and were reduced in mid-dose 
females, with no significant changes in the high dose groups. These observations raise an issue 

about whether the increase in this tumor observed in mid-dose animals was chemical treatrnentrelated, and if so, whether it was biologically significant. Adding an analysis of these 

considerations would facilitate the reader's understanding of the significance of these 

observations." 

Response: 

Additional information was included in the hazard identification and discussion sections of the 

revised risk assessment. 

~ose-respons'e assessment 

Comment: 

"As stated in the general comments, it would be useful for the documentation in the quantitative 

assessment to provide sufficient rationale for the readers to understand the reasons for the key 

decision points, particularly where CPSC decisions differed from those of other organizations. 

For example, in noncancer assessment, a composite uncertainty factor of 1000 was used to 

account for interspecies and intraspecies differences, and for LOAEL to NOAEL extrapolation. 

However, NRC used an uncertainty factor of 1000 to account for interspecies and intraspecies 

differences, LOAEL to NOAEL extrapolation, and database deficiency. Thus, although both 

organizations calculated the same final value, the approach used (and presumable the rationale 

used), differed. It would be useful for CPSC to present the rationale for the uncertainty factors in 

a bit more detail, explaining how and why its values differ fiom those of NRC." 

Response: 

Additional explanation was included in the dose response section of the revised risk assessment. 

The CPSC staff applied an overall uncertainty factor of 1,000 to the LOAEL, including 10-fold 

for animal to human extrapolation, 10-fold for inter-individual variability, and 10-fold because a 

no-observed-adverse-effect level (NOAEL) was not established. This results in an AD1 level of 

0.005 mglkg-d. These are the default uncertainty factors described in the CPSC chronic hazard 

guidelines (CPSC 1992). 

The NRC subcommittee derived a reference dose (RfD)* of 0.005 mglkg-d (NRC 2000). 

However, the NRC subcommittee applied uncertainty factors of 10-fold for animal to human 

extrapolation, 3-fold for inter-individual variability, 10-fold because a NOAEL was not 

established, and 3-fold for an incomplete database. The CPSC chronic hazard guidelines do not 

provide for an additional uncertainty factor for an incomplete database (CPSC 1992). The 

default factor for inter-individual variability used by the CPSC staff and others is 10-fold. The 

NRC subcommittee applied a 3-fold factor for inter-individual variability in this case, because 

* Both the acceptable daily intake (ADI) and reference dose (RfD) are estimates of the amount of a chemical a 

person can be exposed to on a daily basis over an extended period of time (up to a lifetime) with a negligible risk 

of suffering deleterious effects. , 

185 i 
there was no evidence of increased sensitivity of juvenile animals from developmental toxicity 

studies (NRC 2000). They did not indicate what studies were lacking fiom the database. 

Comment: 

"The summary document states that benign tumors of the testes and adrenal cortex were not 

included in the calculation of cancer unit risk, but the summary provides no rationale why these 

endpoints were not used. The rationale for this decision should be presented." 

Response: 

Additional explanation was included in the dose response section of the revised risk assessment. 

P 

Benign tumors of the testes and adrenal cortex were not included, because no malignancies were 

present in the organ sites. Thus, it does not appear that these particular tumors would progress to 

malignancy. In addition, testicular interstitial cell adenomas have a high background rate in rats, 

and their relevance to human cancer risk is uncertain (CPSC 1992, p. 46636). 

Comment: 

"The CPSC approach of combining incidence data for males and females when the separatelycomputed unit risks differ by less than a factor of two is a reasonable approach in general, 

although it is not identical to the approach of other international regulatory agencies. However, 

the approach of calculating the human equivalent dose (HED) when data are combined should be 

'considered further. Because the body weight to the % conversion is designed to adjust for 

differences in tissue dose between species, it seems that a preferred approach for combining risk 

would be to calculate the risk for each sex separately, calculate the HED, and then combine risk, 

rather thanincidence. This accounts (at least roughly - considering scaling but not sex-specific 

differences in enzyme expression) for sex-specific differences in tissue dose for a given mg/kgday (which could affect the resulting tumor incidence), as well as accounting for differences in 

background response." 

Response: 

In this particular case, both the background tumor levels and dose-dependent tumor incidences 

were roughly similar. The alternative approach of calculating sex-specific unit risks separately 

and then averaging them would have a negligible effect. 

Comment: 

"Using the maximum likelihood estimate of extra risk (ql) as the basis for the unit risk is a 

reasonable choice that is consistent with the approach used by some organizations, but different 

from that used by others. However, CPSC should explicitly note this decision in the section on 

risk calculations (comparison to exposure), in addition to the current identification of this choice 

in the dose-response assessment. Consideration of bounds could also provide useful input to the 

nice uncertainty discussion in the document. While the software used by CPSC does not 
calculate the lower confidence limit for the estimated ql (i.e., the ql*), other software can do so. 

Alternatively, CPSC could use the approach used by the USEPA, calculating the BNIDL10, and 

then using linear extrapolation to zero. While comparing these results with that using the ql 

would not capture all of the uncertainties relating to cancer risk, the comparison would capture at 

least some of the uncertainties related to model choice and experimental variability." 

Response: 

The staff has added a discussion of the effect of model choice to the discussion section of the 

revised risk assessment. 

The risk assessment was conducted in accordance with the CPSC chronic hazard guidelines. The 

software used by the CPSC staff does, in fact, calculate ql*. We use ql* when ql is zero to 

ensure a linear dose response. The uncertainty in the estimate of ql (generally within 3-fold) is 

small in comparison to the uncertainty associated with the choice of mathematical model. 

The current EPA approach-benchmark dose combined with linear extrapolation-would give a 

unit risk that is very similar to that calculated by the CPSC staff. The primary difference is that 

the CPSC staff prefers to use the best estimate of risk, rather than the upper confidence limit. 

The use of a non-linear model, however, would result in a much lower estimate of risk. 

Comment: 

"It would be helpful if the mathematical equation for calculation of the unit risk for humans from 

the rat data (based on the unit risk is proportional to body weight to the three-quarters power) 

were presented. While this calculation is fairly standard, presentation of the equation enhances 

transparency, especially since some aspects of the conversion can lead to confusion." 

Response: 

The equation was added to the dose-response section. 

Comment: 

"Another method used in the dose-response analysis that is different from that used by other 

agencies is the addition of unit risks for different endpoints (liver and renal tumors). Again, 

while cogent arguments can be made for this approach, it would be useful to provide additional 

information regarding its rationale." 

Response: 

The risk assessment was performed in accordance with the CPSC chronic hazard guidelines. 

The differences between CPSC staffs risk assessment practices and those of other U.S. agencies 

are minor and have been discussed elsewhere in detail (Babich 1998; Rhomberg 1997). 
The cancer risks for different tumor sites are calculated separately, because they are considered 

to arise independently. This practice could result in a slightly greater unit risk, relative to using 

total tumor incidence, if there are individual animals in the bioassay with, tumors at both sites. 

Comment: 

"Although there are only very limited data from inhalation studies, a robust database from oral 

exposure studies could provide valuable information for deriving inhalation ADI. Since TDCP is 

not water soluble, and not a reactive compound, it is expected to produce similar systemic 

toxicity as by oral route exposure. This means that the approach used by CPSC in the calculation 

of risk (using only the systemic dose rather than considering portal of entry effects from 

inhalation exposure) is appropriate as an initial calculation. However, it should be noted that 

chemicals absorbed from the gastrointestinal tract have to go through first-pass metabolism 

before they reach the systemic circulation, while parent compound absorbed from the respiratory 

tract can be directly distributed throughout the body before it is metabolized. Therefore, routeto-route extrapolation from oral data to inhalation exposure needs to present any available 

information regarding the potential impact of first-pass metabolism on effects or on internal 

dose. In particular, it would be useful for CPSC to further consider whether the noncancer 

toxicity of TDCP is due to the parent compound or to a metabolite. First-pass metabolism would 

decrease the tissue dose (for the reproductive tract, but not necessarily for the liver) of the parent 

compound from the oral route, compared to the tissue dose of the parent from inhalation 

exposure to the same amount. This means that a given "dose" from inhalation exposure may 

have greater toxicological consequences than the same dose from oral exposure. Conversely, 

inhalation exposure may result in lower tissue doses to a metabolite than the "equivalent" oral 

exposure, again depending on the target and mode of action. Further consideration of this issue 

by CPSC would be important. In addition, the discussion of uncertainty should capture this 

issue, since it could result in inhalation exposure contributing a different, and possibly higher, 

percentage of total dose than is apparent from Table 4." 

Response: 

A discussion of the reviewer's points has been included in the discussion section of the revised 

risk assessment. 

Comment: 

"An alternative approach to the route-to-route extrapolation would be to estimate an inhalation 

AD1 from the oral ADI, and then combine the hazard quotients and cancer risk." 

Response: 

While this alternative approach is valid, the staff did notf apply it because it is not clear how this 

approach would reduce the uncertainty. 
Comment: 

"The CPSC assessment included a nice sensitivity analysis in the exposure assessment, as well as 

a nice discussion of'the exposure uncertainties in the discussion. In contrast, the consideration of 

toxicological uncertainties for TDCP in the discussion addresses only the sufficiency of data to 

calculate the AD1 and cancer slope factor. A more complete consideration of toxicological 

uncertainty (qualitative, and, to the degree possible, quantitative), would be useful. This 

discussion could include uncertainties in the cancer calculation and in the route-to-route 

extrapolation fiom oral to inhalation data, as described above. In addition, consideration of the 

uncertainties addressed by the uncertainty factors and the implications of the overall uncertainty 

factor would be informative." 

Response: 

The staff agrees that these are significant sources of uncertainty that merit fbrther discussion, but 

many are also difficult to quantify. For example, it is not possible to estimate the probability that 

a given dose response model is correct. However, the discussion section of the revised risk 

assessment has been expanded to include a more thorough discussion of these sources of 

uncertainty. 

Comment: 

"Finally, overall confidence in the derived AD1 value can be presented. Such discussion would 

facilitate readers' understanding of the overall confidence in the estimated AD1 and calculated 

cancer risk. In addition, deeper consideration of uncertainties is consistent with the OMB 

proposed Risk Assessment Bulletin, although the approaches suggested here are less detailed 

than many of the approaches recommended in the OMB proposed Bulletin." 

Response: 

In deriving AD1 values, the CPSC staff reviews all of the available data and considers whether 

the studies were well designed and well executed, as described in the CPSC chronic hazard , 

guidelines (CPSC 1992). Studies are classified as providing inadequate, limited, or sufficient 

evidence of toxicity. The CPSC staff also discusses sources of uncertainty, such as the 

completeness of the database. 

Triphenyl Phosphate (TPP) 

Comment: 

"Based on EPA's review of TPP (EPA 2005), the available data on delayed neurotoxicity, adult 

neurotoxicity, developmental toxicity, and immunotoxicity were judged as negative responses. 

, However, this information is not presented in the current summary document, and much was not 

presented in the more detailed evaluation' by Ferrante (1999a), even though the studies were 

published prior to that evaluation. While the risk assessment summary document does not 

necessarily need to include a critical evaluation of all of these studies, it is critical that the 
summary document present a clear overview of the entire database, so that the endpoints of 

interest and data gaps are clear." 

Response: 

The hazard identification section has been expanded, and includes all the available data. 

Comment: 

"It is indicated in the summary document that the lowest NOAEL reported for TPP was 160 

mgfkg-d for effects on body weight gain in male SD rats fed TPP for 90 days in a neurotoxicity 

screening study (Sobotka et al., 1986). In their publication, Sobotka et al. (1 986) stated that their 

study was a part of a larger subchronic feeding study designed to assess the general toxicity, 

teratologic effects and immunotoxicity of TPP. In addition, the published part of 

irnmunotoxicity report by Hinton et al. (1 987) also suggested that the only effects noted were a 

decreased rate of growth rate and increases in the levels of alpha- and beta-globulins suggestive 

of increased hepatic activity. All these reports indicated that there might be sufficient doseresponse information from the original large subchronic study, and decreased body weight gain 

is a potential critical effect. Since a well-conducted subchronic study can constitute a minimum 

database for deriving a safe dose, and decreased'body weight is routinely considered as a 

. benchmark in evaluation of whether administrated doses used in a long term experiment reach a 

maximum tolerable dose, it is recommended that CPSC review the original subchronic study for 

general toxicity. If possible, CPSC couId also contact the authors of that study for relevant 

unpublished data. The final conclusion and dose response assessment should be based on this 

additional review and consideration of any additional data." 

Response: . . 

The CPSC staff contacted one of the authors of the FDA studies. ~nfortun&ely, the "larger 

study" was never completed and there are no additional'data. 

Comment: 

Isopropylated Triaryl Phosphate (ITP) 

"The CPSC approach to the toxicity evaluation of ITP, and conclusions of that evaluation appear 

to be reasonable." 

Brominated Arvl Esters (BAE's) 

"The CPSC approach to the toxicity evaluation of BAE's, and conclusions of that evaluation 

appear to be reasonable." 

Response: 

No response required. 
Risk Calculations and Other Considerations 

Comment: 

"Since there was insufficient information to derive AD1 values for TPP and ITP, AD1 values for 

other aromatic phosphates, including mixtures, were used as surrogates for TPP and ITP. While 

the structural analogy among these chemicals suggests that the other aromatic phosphates were 

appropriate surrogates, it would be useful to present any additional supporting evidence. In 

particular, a comparison of the available (albeit limited) toxicity data for TPP and ITP compared 

to other aromatic phosphates would be useful. The Ferrante (1 999a) document does a nice job of 

presenting the data, but it would be useful to present tables directly comparing the toxicity results 

for the different aromatic phosphates, to aid in the extrapolation. For example, a quantitative 

comparison between effective doses, (e.g., ED10 or NOAEL), for causing the same toxic effect, 

(e.g., decrease in body weight), by TPP and other aromatic phosphates in repeated dosing studies 

would provide strong support for using other data as the surrogate for TPP and other similar 

compounds in risk assessment." 

Response: 

The staff expanded the hazard identification to include a brief review of all of the aromatic 

phosphates. 

Comment: 

"While the calculation of the LADD for children is correct; it would be useful to explain the 

calculation a bit more, noting that the child LADD is the exposure as a child, averaged over a 

lifetime. Conversely, calculation of the HI for the child is conservative (assuming that the 

exposure and toxicity benchmarks are appropriate and appropriately consider the potential for 

child sensitivity), since the AD1 assumes lifetime exposure, rather than exposure for 2 years." 

Response: 

Additional explanation was added to the revised risk assessment. 

MinorLEditorial Comments 

Comment: 

"Page 3, the 3rd line from the bottom: A statistical P value of 0.05 is usually used as the criterion 

in judging whether a observed response is significantly different from the control. The P value 

for the hepatocellular carcinoma at high dose is less than 0.03 (less than 0.05) as shown in the 

Table 1 in the summary document. It is not clear why it is still considered: '. . . non-significantly 

elevated.. . ' " 
Response: 

This was a typographical error. The text should have said that the response in females, not 

males, was non-significantly elevated. The response in the males was indeed statistically 

significant. The text has been revised. 

. . 

Comment: . ' 

"Page 3, the last line: should ' . . . significantly elevated at the high dose in males and the midand high dose in females' be '. . . significantly elevated at the high dose in males and the midand high doses in females?' " 

Response: 

The change has been made. 

Comment: 

"P. 1 1 (line just before equation lo): Schwope et al. (1999) should be Schwope et al. (1989). 

P. 11 (2nd line just after equation 13): It appears that the units for Mp should be mg, not ug. This 

both keeps the units consistent for equation 13, and appears to be the units used in the 

spreadsheets." 

Response: 

The changes were made. 

Comment: 

"The EPA cancer guidelines are now final (as of 2005). The correct citation is: 

U.S. EPA (Environmental Protection Agency). (2005) Guidelines for carcinogen risk assessment. 

Risk Assessment Forum, Washington, DC; EPA1630P-03/001B. Available from: 

<http ://www.epa.gov/iris/backgr-d. htm>. 

U.S. EPA (Environmental Protection Agency). (2005) Supplemental guidance for assessing 

susceptibility from early-life exposure to carcinogens. Risk Assessment Forum, Washington, 

DC; EPAl63OiR-031003F. Available from: <http://www.epa.gov/iris/backgr-d.htm>." 

Response: 

The reference has.been updated. 
Reference Listed by the Reviewers 

Nobel Functional Chemicals LLC, 200 1. High Production Volume (HPV) Challenge Program. 

Test plan for FYROL FR-2 (Tris[l,3-dichloro-2-propyl] Phosphate. 

References Cited by the CPSC Staff 

Babich MA (1 998) Risk assessment of low-level chemical exposures fiom consumer products 

under the U.S. Consumer Product Safety Commission chronic hazard guidelines. Environmental 

Health Perspectives, 106, Supplement 1 : 387-390. 

Babich MA (2006) CPSC Staff Preliminary Risk Assessment of Flame Retardant (FR) 

Chemicals in Upholstered Furniture Foam. U.S. Consumer Product Safety Commission, 

Bethesda, MD 20814. September 2006. Revised draft. 

Babich MA, Thomas TA, Ha-tlelid K (2006) CPSC Staff Preliminary Risk Assessment of Flame 

Retardant (FR) Chemicals in Upholstered Furniture Foam. U.S. Consumer Product Safety 

Commission, Bethesda, MD 20814. January 2006. Peer review draft. 

Cobb D, Bhooshan B (2005) Migration of flame retardant chemicals in upholstered furniture 

foam. U.S. Consumer Product Safety Commission, Bethesda, MD 208 14. December 10,2005. 

Consumer Product Safety Commission (CPSC) (1 992) Labeling requirements for art materials 

presenting chronic hazards; guidelines for determining chronic toxicity of products subject to the 

FHSA; supplementary definition of "toxic" under the Federal Hazardous Substances Act; final 

rules. Federal Register 57:46626-46674. 

Hughes MF, Edwards BC, Mitchell CT, Bhooshan B (2001) In vitro dermal absorption of flame 

retardant chemicals. Food and Chemical Toxicology 39: 1263: 1270. 

Kiss C (2002) A Mouthing Observation Study of Children Under 6 Years. U.S. Consumer 

Product Safety Commission, Bethesda, MD 20814. June 2002. 

National Research Council (NRC) (2000) Toxicological Risks of Selected Flame-Retardant 

Chemicals. Subcommittee on Flame Retardant Chemicals, National Research Council, National 

Academy of Sciences. National Academy Press, Washington, DC. 

Rhomberg LR (1 997) A survey of methods for chemical health risk assessment among federal 

regulatory agencies. Presidential/Congressional Commission on Risk Assessment and Risk 

Management. Washington, DC. 

Smith TP, Kiss CT (1 998) Empirical observations of children's mouthing behaviors: 

Frequencies and durations. U.S. Consumer Product Safety Commission, Bethesda, MD 20814. 

Submitted for publication. 
Memorandum 

Date: December 21,2006 

TO : Dale Ray, Project Manager for Upholstered Furniture, Directorate for 

Economic Analysis 

vr 

THROUGH: ary Ann Danello, Ph.D., Associate Executive Director for Health Sciences 

eri E. Saltzman. M.S.. Director. Division of Health Sciences Lr/ 

FROM ld' ichael A. Babich, Ph.D., Chemist, Division of Health Sciences 

SUBJECT : :v Response to Public Comments on the CPSC Staff Preliminary Risk Assessment 

of Flame Retardant (FR) Chemicals in upholstered Furniture ~oam* 

. . 

The CPSC staff completed a draft risk assessment on the use of flame retardant (FR) chemicals 

in upholstered furniture foam in January 2006 (Babich et al. 2006). The risk assessment was part 

of the January 2006 Briefing Package on Upholstered Furniture. Supresta LLC, a manufacturer 

of FR chemicals, submitted technical comments on the risk assessment. No other public 

comments were received. The staff has made appropriate revisions to the risk assessment 

(Babich 2006), based on comments from peer reviewers and Supresta LLC. Below are the 

staffs responses to the public comments submitted by Supresta LLC. 

Many of the comments submitted by Supresta LLC involved the factors used to estimate 

exposure, such as the surface area exposed and the fabric to skin transfer factor. The CPSC staff 

made several of the suggested changes, which reduced the estimated dermal exposure somewhat. 

Supresta also commented on the staffs methods for assessing the dose response of TDCP, and 

suggested changes that would significantly reduce TDCP's cancer potency. The staff disagreed 

with these comments and did not make the suggested changes. As a result of the changes made 

in response to the public and peer review comments, the relative contribution of inhalation to 

total exposure increased. However, the overall conclusions of the risk assessment did not 

change. 

* These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily 

reflect the views of, the Commission. 

Comments, including tables, references, and appendices, are reported verbatim. 

CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http:llwww.cpsc.gov 
Comment: 

"The draft CPSC report compares the health risks associated with two commercial flame 

retardant products, tris(l,3-dichloro-2-propyl) phosphate (TDCP) and FiremasterTM 550 

(FM-550) which consists of a mixture of triphenyl phosphate (TPP), isopropylated triaryl 

phosphate (ITP), and a proprietary brominated aryl phosphate ester (BAEs)." * 

Response: 

The CPSC staff risk assessment considered flame retardant (FR) chemicals present in foam 

samples that were available to the staff. This work was not performed solely as a comparison of 

two products. 

Comment: 

"On page 3 of the draft report, the first paragraph under Hazard Identification states "TDCP is 

acutely toxic by oral administration." This implies that TDCP's oral LD50 is significantly 

different from that of ITP, melamine, and other flame retardants. The oral LD50 for almost all of 

the phosphate ester flame retardants is above 2000 mgkg, indicating low acute oral toxicity. In 

a 1999 CPSC review of TDCP, Ferrante listed rat acute oral LD50 values of 2.83 gkg (Celanese 

study), 3.6 gkg (Stauffer study) and 2.36 gkg (CPSC study) (1). An acute oral LD50 test 

conducted in 1985 in full GLP compliance provides a TDCP oral LD50 of 2.36 g/kg (2). I thus 

suggest CPSC change the "acutely toxic" language for TDCP." 

Response: 

As stated by the comrnenter, TDCP has an oral LDso less than 5,000 mgkg. Therefore, it is 

"toxic," as defined by Federal Hazardous Substances Act (FHSA) regulations. 

16 CFR 1500.3 (c)(l). 

Comment: 

"Also in that paragraph, fatty degeneration was described as the only histological lesion in an 

acute study. Diagnostic pathology is not usually performed in acute tests. I suggest this 

statement be removed, as the study described by Ferrante is not an acute toxicity test, but rather a 

repeated dose toxicity test, a copy of which is unattainable for confirmation of the findings." 

Response: 

The wording has been changed in the revised risk assessment. 

* Some of the abbreviations were changed to reflect new information that identifies certain chemicals more 

specifically. BAE (brominated aryl ester) was changed to OTB (octyl tetrabromobenzoate) and ITP (isopropylated 

triphenyl phosphate) was changed to PIP (phenol isopropylated phosphate). 
Comment: 

"On page 3, TDCP is alleged to have reproductive toxicity and is "considered probably toxic to 

humans" based solely on changes observed in the testes of aging rats in a chronic cancer 

bioassay. I believe the available data do not support classification as a possible reproductive 

toxin. In a GLP-compliant fertility study, male rabbits received daily doses of up to 200 

mglkglday for 12 weeks prior to mating (3,4)." 

Response: 

The AD1 was based on histopathological effects in the testes, not reproductive function. This is 

better described as general organ toxicity, rather than reproductive toxicity. This is the same 

endpoint used by the NRC subcommittee (NRC 2000). The testicular effects were seen in a 

chronic study in rats, while the reproductive study was of short duration and in a different 

species. The revised risk assessment explains this point more clearly. 

Comment: 

"It is known that various changes in the testes of aging rats occur spontaneously and this is 

confirmed by the 12 month pathology results from the chronic rat bioassay. Rather, TDCP 

exacerbated the various changesGthat normally occur in the testes of aging male rats during their 

second year. Since significant treatment-related changes did not occur in the testes during the 

first full year of treatment, TDCP should not be considered a reproductive toxin. Rather, I 

suggest the CPSC utilize the carefully conducted rabbit reproduction study and the pathology 

report for the 12 month sacrifice in the chronic study as a basis for concluding that TDCP is not a 

reproductive toxin." 

Response: 

While these effects did not appear until late in the chronic study, they are still a chronic, 

degenerative lesion. While these may occur spontaneously, the increased incidence was 

treatment-related and statistically significant. Therefore, we regarded this as evidence of chronic 

organ toxicity. 

Comment: 

"Further, it is clear that the CPSC applied the uncertainty factors published in the NRC 2000 

report without due consideration of the science. Since the changes that occurred in the seminal 

vesicles in the aging male rats do not represent treatment-related testicular toxicity, because they 

occurred with similar incidence in the control animals, the 5 mglkglday dose is, in fact, an 

NOAEL. Thus, the uncertainty factor of 10 for extrapolating from an LOAEL to an NOAEL 

should be deleted, as should the factor of 3 for a limited database. This would result in a 

significantly lower human health risk. The hazard index (HI) would be 0.05 mglkg-d 

(uncertainty factors UFA= 10 for extrapolation from rats to humans; UFH= 3 intraspecies 

variability; UFD= 3 for adequacy of toxicity database)." 
Response: 

The staff did not apply the same safety factors as the NRC subcommittee. While we regard the 

NRC report as authoritative and representing the best available science, we evaluated the data 

and derived the AD1 in accordance with the CPSC chronic hazard guidelines (CPSC 1992). This 

point is discussed in the revised risk assessment. We disagree with the reviewer's conclusion 

that the increase in incidence was not statistically significant. Our own statistical tests (onetailed Fisher's exact test) show that these effects are statistically significant (Babich 2006, 

Table 3). 

Comment: 

TDCP - Genotoxicity/Carcinogenicity 

"In the cancer bioassay, TDCP appears to exacerbate the incidence of benign tumors that 

normally occur in older rats. There was no significant increase in malignant tumors in any organ 

in the two-year cancer bioassay. The presence of a non-DNA-reactive, epigenetic mechanism 

for the induction of the benign tumors is supported by the results of the many genotoxicity tests 

which, on a weight of evidence basis, confirm that TDCP does not express genotoxicity. While 

certain Ames Tests showed positive responses, the majority of the microbial mutagenicity tests 

were negative. TDCP was without genotoxic activity in almost all of the in vitro tests using 

mammalian cells as test systems. More important, TDCP was consistently without genotoxic 

activity in the several in vivo mutagenicity tests conducted. Ferrante lists the earlier negative in 

vivo tests. More recently, a GLP-compliant Mouse Micronucleus Test, conducted twice per 

OECD Guideline, was negative (5), as was a recently completed in vivo UDS Test, also 

conducted twice per OECD Guideline, which showed no evidence of UDS (6). While in vitro 

tests provide a quick, predictive evaluation of mutagenic potential, the more comprehensive in 

vivo tests provide conclusive indication as to.whether a substance has genotoxic activity in the 

living animal. TDCP was negative in all of the in vivo tests in which it was evaluated. I 

therefore suggest that the first paragraph on page 4 be revised to reflect the results of the recently 

conducted mutagenicity tests, and thus indicate that the weight of evidence strongly indicates 

that TDCP does not have genotoxic activity in the living animal. In that same paragraph, the 

statement that TDCP is a probable human carcinogen should be deleted, based on a lack of 

genotoxicity in vivo and a lack of a significant incidence of malignant tumors in any tissue. The 

exacerbation in the incidence of normally occurring benign tumors late in life should not be 

interpreted as carcinogenic activity. There is insufficient evidence to conclude that TDCP is a 

probable human carcinogen. " 

Response: 

The staff agrees that TDCP is only weakly genotoxic. However, this does not alter our 

conclusion that TDCP is a probable human carcinogen, as defined in the CPSC chronic hazard 

guidelines (CPSC 1992). Increased incidence or decreased time to occurrence of spontaneously 

occurring tumors is generally regarded as evidence of a carcinogenic effect (CPSC 1992). 
Comment: 

"Under Section 2, Dose Response Assessment, the LOAEL for non-cancer effects should be 

changed to NOAEL per the previous discussion on changes seen in the control animals at the 

twelve month interim sacrifice. This would eliminate the uncertainty factor of 10 applied for the 

extrapolation from an LOAEL to an NOAEL. The RfD would change to 0.05 mgtkglday." 

Response: 

The CPSC staff disagrees with this comment. The lack of changes at 12 months is not relevant 

to the LOAEL or NOAEL in a chronic study. 

Comment: 

"Examining further the risk calculations, we find that the CPSC calculated the cancer unit risks 

for adults and children using the linearized multistage model, which assumes a non-threshold 

genotoxic mechanism. This is consistent with the NRC 2000 report. However, now that new in 

vivo genotoxicity tests are available which show a lack of genotoxic activity, the determination 

of the RfD for non-genotoxic cancer effects should use the same calculations used for systemic 

toxicity. The cancer risk assessment developed by the CPSC without the benefit of the new 

genotoxicity tests should be deleted from the CPSC report. Based on the NOAEL of 5 mglkg for 

carcinogenicity, the RfD would be 0.05 mgikglday." 

Response: 

The lack of genotoxicty does not change the method for estimating cancer risk. Cancer risk is 

assumed to be linear at low dose unless there is convincing evidence to the contrary (CPSC 

1992), such .as an understanding of the mode of action (MOA). "Non-genotoxic" is not an 

MOA. It only means that the MOA does not involve direct mutations. Furthermore, TDCP is 

weakly genotoxic. It is not completely lacking in genotoxic effects. Therefore, as discussed in 

the revised risk assessment, a possible role for genotoxicity in tumorigenesis cannot be ruled out. 

Comment: 

TDCP - Dermal Exposure 

"I believe the CPSC basis for determining dermal exposure is overly conservative and uses 

unrealistic assumptions that result in highly exaggerated exposure and absorption determinations. 

For example, when estimating dermal exposure of consumers to TDCP from upholstered foam, 

the CPSC assumed that the consumer is lying on a sofa and wearing a short-sleeved shirt and 

short pants. The exposed body surface was calculated by adding the surface areas for the lower 

leg and arms, then dividing by two. This assumes that half of the uncovered body parts is in 

contact with the sofa. This is an unrealistic overestimation. For essentially circular structures 

(arms and legs), a more realistic and reasonable estimate would be 20-25% of the total surface 

are is in contact with the sofa. Even 25% is an exaggeration in that people do not lie stiff, with 
elbows and knees locked to provide the proposed contact area. Utilizing the worst case value of 

25% of the surface area would result in a 50% reduction in the estimated dermal absorption." 

Response: . 

The assumptions regarding the manner in which consumers interact with upholstered furniture 

were developed by staff from the CPSC Division of Human Factors. They are intended to be 

reasonably protective of public health. We agree that the assumption that 50% of the exposed 

skin contacts the furniture surface is probably an overestimate, due to the 3-dimensional nature 

(roughly cylindrical) of the legs and arms. However, it is difficult to characterize the contact 

surface more precisely, especially for a malleable surface such as upholstered furniture. In 

addition, the softness of upholstered furniture is variable. We chose 50% as a reasonable upper 

bound. The best estimate is probably between 25% and 50%. In the revised risk assessment, we 

assumed 33% as a best estimate. 

Comment: 

"The CPSC discusses exposure by children separately on page 14, using an estimation method 

developed by EPA many years ago. The body surface areas for children under the age of 2 

years were estimated from the median surface area-to-body weight ratio (age 0-2 years: 0.062 

[EPA 1997, Table 6-91). As is apparent from the table, this ratio is highly dependent on age. For 

example, for children aged 2.1 years the median ratio is 0.042. It is therefore assumed that for 

children with the selected body weight of 11 kg, using a ratio of 0.062 leads to overestimation of 

skin surface. In order to refine the estimated body surface area for the selected body weight, it 

has been suggested that the more refined formula for surface area in relation to length and weight 

be used (Gehan and George 1970 [in: EPA 1997, Exposure Factors Handbook, Appendix 6A]) 

instead. This highly regarded formula, SA = 0.02350 x H o 42246 Wo 51456 (SA in m2, H in cms, 

W in kg), provides a more accurate estimation of dermal exposure, and is applicable for adults 

and for children under the age of 5 years (n=229). The estimated body surface for children of the 

aselected weight category (1 1 kg, equivalent to an age of approximately 12 months and length of 

78 cm) is 0.5 m2. Using this more accurate formula would lead to a reduction of the estimated 

dermal exposure of children by about 25%." 

Response: 

The staff generally selected the methods and data recommended in the EPA Exposure Factors 

Handbook (EPA 1997). However, we agree that the approach suggested by the comrnenter has 

merit. Therefore, we adopted the approach suggested by the cornmenter with minor changes. 

We substituted parameters that were specific for the age range of interest (0-2 years). We also 

used the most recent available body weight and length data for infants from the CDC (CDC 

2000). Thus, we assumed an average body weight of 10 kg (rather than 11 kg) and a length of 75 

cm (rather than 78 cm). Using this method, the total surface area of 1 -year-olds was estimated to 

be 0.48 m2. 
Comment: 

"In the CPSC surface migration experiments, Cobb and Bhooshan used miniature furniture 

mock-ups, 9" x 9" consisting of plywood and foam with a cotton overlay. They applied 25 mL 

of saline solution directly to the mockup to simulate 8 hours of sweat. The CPSC states that 

using this wet mock-up and 8 hours of sweat will lead to an overestimation of exposure (page 

19, because they really believe daily contact time to be 4 hours. While this, alone, is 

problematic, there are additional deficiencies in the experimental design. The surface area of the 

circular filter paper in contact with the mockup measured 23.76 cm2 (diameter 5.5 cm). This 

means the moistened mockup (surface area: 523 cm2) is only partially covered, in contrast to the 

situation that the test aims to mimic, a person lying on a sofa. Further, there appears to be a 

calculation error in the draft report. The results from the surface migration experiments (Table 2 

in Cobb and Bhooshan 2005) are expressed as pg of flame retardant chemical. Apparently the 8- 

day average from foams S and Y (3.63 pg) was transferred to the CPSC risk assessment report as 

mg/cm2 (Table 3). I believe the 0.0036 mg extracted should be converted to mg/cm2. This 

results in a migration to liquid phase (M) value of 0.00015 mg/cm2 instead of the 0.0036 shown 

in Table 3 for TDCP. This would result in a substantially lower ADD and an HI of below 1.0." 

Response: 

The migration data were'the only data available. Both the estimate of the amount of liquid and 

'the contact time are average values with considerable variability. 

We agree that the saline solution was not evenly distributed across the surface of the mock-up. 

Rather, it was applied to a point on the surface of the mock-up and allowed to distribute by 

capillary action and hydrostatics. We do not agree, however, that this is inconsistent with 

consumer exposure. A consumer sitting on a sofa is not exposed to the entire surface. 

What appears to be a calculation error is actually a typographic error in the table. This has been 

corrected in the revised risk assessment. 

Comment: 

"Furthermore, for estimating the transfer from fabric to skin, the CPSC selectively uses the 

available information from Wester et al. 1996 and ignores the data for a second substance, 

glyphosate, for which transfer factors from fabric to skin were determined. Unlike malathion 

which was dissolved in 50% ethanol, glyphosate was dissolved in water, which more closely 

resembles sweat. The percutaneous absorption for glyphosate was 1.42%, for immediate 

exposure to treated fabric 0.74%, declining to 0.08% after one or two days of drying. 

Remoistening with water resulted in a percutaneous absorption of 0.36%. These figures lead to 

transfer efficiencies of 0.52 for direct exposure to treated fabric and 0.25 for remoistened fabric. 

In view of the more relevant solvent, this part of the Wester et a1 study is more applicable for 

transfer from upholstered furniture to skin. Even the 0.25 transfer efficiency ratio for 

glyphosate from the Wester et a1 study should be considered an exaggeration, as confirmed by a 

study by Snodgrass (7). He showed that the transfer efficiency of permethrin from impregnated 

clothing to skin was only 0.005 and was independent of the presence of sweat or the type of 
clothing. I therefore believe that a worst case transfer efficiency of 0.25 be used by the CPSC 

which would result in a 37.5% reduction of the estimated dermal exposure." 

Response: 

As explained in the draft risk assessment, we selected malathion as a surrogate for FR chemicals 

because it is more hydrophobic than glyphosate, which is water soluble. The FR chemicals 

under consideration are hydrophobic. 

In considering this comment, we were prompted to search for additional studies on this subject. 

In addition to the data by Snodgrass, we identified other potential sources of data on the transfer 

of chemicals from textiles to skin. The data include hydrophobic and water-soluble chemicals 

and particles. These properties appear to have no effect on surface-to-skin transfer. Considering 

all of the data, we derived a new estimate of the transfer factor, as well as its upper and lower 

bounds (Babich 2006, Table 7). This change resulted in a 3-fold lower estimate of surface-toskin transfer. 

Comment: 

"The bioavailability of TDCP as a result of dermal absorption is calculated by the CPSC based 

on the in vitro studies conducted with hairless mouse skin (Hughes 2000; Hughes et al. 2001). 

The skin of hairless mice is very different from human skin and Hughes et a1 used acetone as a 

vehicle for the study. Acetone is known to substantially enhance the transfer of substances 

through the skin. Thus the use of the Hughes studies for determining bioavailability is 

inappropriate. Rather, the CPSC should use the results from an industry sponsored in vitro 

dermal absorption study using human skin and the structurally similar substance TCPP, 

dissolved in artificial sweat (8,9). We recognize that the results of this very recent study were 

not available to the CPSC when the draft report was written. This study was conducted in 

accordance with the 2004 OECD guidance document for conducting skin absorption studies (10). 

Accurate measurements were made using "c-TCPP. The 24-hour absorption after 8 hours 

contact time was 40 percent, a level that was relatively independent of the concentration. This is 

equivalent to a dermal absorption rate of 0.05 h-'. The study final report will be made available 

to the CPSC for consideration of extrapolation to TDCP. This would provide real data using 

human skin for a substance that has a very similar chemical structure. Using the more accurate 

dermal absorption rate of 0.05 h" will result in a 37.5 percent reduction of the internal exposure 

estimate." 

Response: 

Dr. Robert Bronaugh, Food and Drug Administration, is a recognized expert in the measurement 

of percutaneous absorption using in vitro methods. Dr. Bronaugh advised us in designing the in 

vitro studies performed by Hughes et al. (2001). The skin from hairless mice was chosen for the 

in vitro percutaneous absorption experiments because it is considered a reasonable surrogate for 

human skin (Bronaugh et al. 2005). Acetone was used to dissolve TDCP for skin application; 

then it was allowed to evaporate prior to conducting the experiment. This is a standard method 
for the study of extremely hydrophobic compounds. Acetone did not remain on the skin and, 

therefore, is not likely to affect the permeability of the skin. 

The study submitted by the cornrnenter was on the percutaneous absorption of an analog of 

TDCP, tris(chloropropy1)phosphate (TCPP), using human skin in vitro. The comrnenter cited the 

results from experiments in which TCPP was present in limiting concentrations. Thus, the 

absorption rate declined over time, probably following first-order kinetics, as the TCPP on the 

skin surface was depleted (Bronaugh et al. 2005). The comrnenters erroneously concluded that 

TCPP was absorbed at a lower rate through human skin than TDCP was absorbed through mouse 

skin. Other experiments in the same report applied a larger total volume of TCPP to the skin. In 

these experiments, the TCPP was not depleted and the absorption rate remained constant 

throughout the course of the experiment. In these experiments, TCPP was absorbed at roughly 

the same rate as TDCP. 

Comment: 

TDCP - New Input Parameters. New Exposure Values and Risk Assessments 

"The attached Appendices 1,2, and 3 contain the CPSC Tables 2,3, and 4 with corrected fabric 

to skin transfer, surface area of exposed skin, migration to liquid phase, measured vapor pressure 

(1 I), dermal absorption, and acceptable daily intake (ADI) values which have been used to 

calculate new, more accurate acceptable daily dose (ADD) values and a new hazard Index (HI). 

Using the new values in Tables 2 and 3, the HI is determined to be 0.01 for adults and 0.02 for 

children. Certainly the documentation provided in this letter and the articles referenced in the 

table footnotes support the accuracy of these new values." 

Response: 

The staff considered each parameter and made changes in the revised risk assessment as 

appropriate. We reevaluated the fabric-to-skin transfer factor, total skin surface area of children, 

fraction of skin surface in contact with furniture, and TDCP vapor pressure. These changes are 

discussed above in more detail. The net effect of these changes reduced the estimated dermal 

and oral exposure, but increased inhalation exposure. However, the conclusion that TDCP might 

present a hazard to consumers is unchanged. 

Comment: 

Melamine - Some Reasons for Concern 

"I believe melamine does meet the FHSA definition of toxic, and thus should be reviewed along 

with TDCP and FM-550. In national Toxicology Program chronic cancer bioassay, melamine ' 

caused transitional cell carcinomas in the urinary bladders of male rats (1 2). Although bladder 

stones were found in most of the male rats that expressed bladder cancer, suggesting a 

correspondence between the presence of stones and bladder tumors, bladder stones were also 

observed in female rats and in both male and female mice, which did not express bladder tumors. 

The NTP concluded that melamine is carcinogenic in male rats. The International Agency for 

202 
Research on Cancer confirmed that melamine exposure resulted in bladder and urethral 

carcinomas in male rats and urinary bladder hyperplasia in male mice (13). They indicate that 

while the tumors "appear to be produced by a non-DNA-reactive mechanism involving epithelial 

hyperplasia," there was insufficient genotoxicity data available to reach a firm conclusion." 

, , Response: 

The bladder tumors induced by melamine are considered to be induced by a mechanism that is 

not relevant in humans. Therefore, the CPSC staff considers melamine as a possible carcinogen, 

due to limited evidence in animal studies. This does not satisfy the FHSA definition of "toxic." 

The discussion on this point has been expanded in the revised risk assessment. 

Comment: 

"Teratogenic effects of melamine have been reported in toads, where it caused anomalies in the 

. mouth, gills, gonads, and renal tubules (14). In a non-guideline rodent developmental toxicity 

study, melamine was injected intraperitoneally on two gestation days, with no gross 

malformations observed. During combustion, melamine decomposes with evolution of 

poisonous hydrogen cyanide (1 5). Will this not pose a potential health risk to humans? With the 

causation of cancer in a rodent bioassay, no reproductive toxicity tests available, and no in vivo 

mammalian mutagenicity tests, I believe melamine could be considered "toxic" and included in 

the CPSC review." 

Response: 

The developmental effects in toads are of uncertain relevance to humans. Smoke toxicity is 

beyond the scope of this risk assessment. . 

Comment: . . 

FM-550 - New Toxicity Data 

"The report states that because there has been very little testing of two of the three components, 

ITP and the BAEs, the CPSC used surrogate data to calculate a hazard index, "assuming that 

TPP and ITP are no more toxic than the other aromatic phosphates." I believe this is an 

erroneous asshption for ITP, based on toxicology test results recently made public. In a May 5, 

2004 TSCA 8(e) substantial risk notification to the U.S. EPA, the manufacturer of FM-550 

reported that their commercial ITP caused significant reproductive toxicity in rats. Decreased 

fertility was observed at all doses, so an NOAEL was not identified. Further, it is not known 

whether the effect is in the males, females', or in both sexes. Reversibility of the effect was not 

shown. Litter size and pup survival were also affected. Since FM-550 consists of 24-5 1% ITP, 

there could be a significant human reproductive risk associated with exposure to foam containing 

this flame retardant. In a June 9,2004 TSCA 8(e) notification, the manufacturer reported 

significant adverse effects observed in an ITP developmental toxicity study, further justifying 

concern that both the human fetus and adult may be at risk. I urge the CPSC to carefully 
consider the results of these recently conducted studies and not rely on data from surrogate 

chemicals." 

Response: . . 

The May 5,2004 notice (8e-HQ-0504-15566) provides minimal details. The actual report is not 

yet available. The same information was described in a recent EPA report (EPA 2005) that we 

cited in the draft risk assessment. The June 9,2004 notice (8e-HQ-0604-15587) is for tricresyl 

phosphate, not ITP (PIP). These reports provide no new information and no changes in the risk 

assessment are needed. 

Comment: 

"Page 6 states that there is insufficient information to derive an AD1 for isopropylated triaryl 

phosphate. I believe the lowest dose fiom the recently conducted reproductive toxicity study, 25 

mgkgtday, can be used as it caused significant reproductive toxicity in that GLP-compliant 

study. Now there is sufficient information available for the CPSC to conclude that ITP is 

possibly toxic to humans. The statement on page 7, that there is insufficient data for ITP to 

derive AD1 values, is also no longer accurate." 

Response: 

, As the commenter states, the study is not currently available. We will review the new data when 

they become available. However, depending on the study design, a reproductive study alone is 

not necessarily sufficient to derive an ADI. Generally, a 90-day subchronic study with full 

pathology is needed to provide minimal information for an ADI. . 

comment: 

"Page 7, Section C implies that since there is insufficient toxicology information to determine 

whether the BAEs are toxic, they will be treated as non-toxic until shown to be toxic. How does 

this afford protection for workers and consumers who may be exposed to the BAEs? Shouldn't 

the OECD Base Set of tests be required of a substance to which infants, children, and adults may 

have daily contact?" 

Response: i 

Under the FHSA, data showing a toxic effect, i.e., "causing substantial illness or injury," are 

needed to conclude that a substance is "toxic." 15 USC 1261 (f)(l)(A). In the absence of data, 

CPSC cannot promulgate a mandatory regulation. The OECD set of tests are not required under 

the FHSA or the Toxic Substances Control Act (TSCA), which is administered by EPA. 

Comment: 

"1 believe there are several publications that show brominated flame retardants express 

significant toxicity. For example, recent studies have shown that the polybrominated diphenyl 
ether flame retardants adversely affect the central nervous system. They disrupt behavior and 

impair learning and memory, especially after neonatal exposure (1 6, 17). The brominated 

phosphate esters cause genetic recombination in mammalian cells, which can result in various 

forms of mutation (1 8). A recent publication by EPA scientists expresses concern over the use 

of brominated flame retardants after finding significant levels in human tissues and in the 

environment (19). Recognizing that several brominated flame retardants have neurotoxic and 

mutagenic activity, how can the CPSC conclude they do not fit the definition of toxic? If 

FM-550 is to be considered one of the major flame retardants approved for furniture, a 

responsible course of action would be to require the manufacturer to provide base set toxicity 

data on the BAEs, either via a SNUR or a consent agreement." 

Response: 

Brominated FR chemicals (BFR's) are a broad class of compounds with varying toxicological 

effects. The chemical structure of the BAEYs is not closely related to other BFR's for which data 

are available. FM-550TM was reviewed by EPA under its new chemicals program (EPA 2005). 

Thus, it has already gone through the same process that would be imposed by a significant new 

use rule (SNUR). Under the FHSA, CPSC does not have the authority to require additional 

toxicity tests. However, CPSC can request studies through the EPA Interagency Testing 

Committee (ITC) or the National Toxicology Program (NTP). The CPSC staff recently 

requested additional testing of selected FR chemicals, including triaryl phosphates, by NTP. 

Comment: 

"The statement on page 20 "assuming that TPP and ITP are no more toxic than other aromatic 

phosphates.. ." is no longer valid, due to the significant reproductive toxicity reported for ITP. 

Since there is no NOAEL in the ITP reproduction study, an additional factor should be included 

in the calculation of risk. The Discussion section begins by exclaiming that there is no toxicity 

data on FM-550, and insufficient information for ITP, TPP, and BAEs to calculate an AD1 value. 

Yet the toxicity of the three components may be additive or synergistic. It therefore seems 

reasonable to include an additional 10-fold or 100-fold safety factor in the calculation of risk, 

rather than making the dangerous and unsupported assumption that the components of FM-550 

are no more toxic than other aromatic phosphates." 

We assumed that TPP and ITP were no more toxic than the other members of the class. This is 

only an assumption and must be supported by data. We have requested additional testing by 

NTP. We correctly reported that'there are limited data for OTB (BAE). 

Comment: 

"On page 26, the CPSC points out that the estimated upper bound for TPPIITP exposures would 

exceed the AD1 value for the most toxic aromatic phosphate, then goes on to exonerate FM-550 

by stating that doesn't matter because of the inclusion of "several assumptions that tend to 

overestimate exposure." Doesn't the exposure scenario used for TDCP also include many 
conservative assumptions that overestimate exposure? Why is the lack of toxicity data for FM550 and its components and an inability to measure TPP and ITP not cause for concern?" 

Response: 

The lack of data in this risk assessment is a significant limitation of the risk assessment, as 

discussed in the report. The staff did not intend to imply that FM-550TM should be "exonerated." 

Rather, we pointed out the limitations of the risk assessment. 

Comment: 

"I believe that a reexamination of the available genotoxicity data, the reproductive toxicity study 

conducted in rabbits, the 12 month chronic bioassay pathology results, the more accurate 

dermal absorption values, and the corrected CPSC calculations will result in a conclusion that 

furniture containing TDCP-treated foam will not present an appreciable health risk to consumers. 

For FM-550, the results of the reproductive toxicity test should negate the conclusion at the top 

of page 27 that states "there is no evidence that upholstered furniture containing foam treated 

with FM-550 would pose an appreciable health risk to consumers." Having no toxicity data 

should not make a product safer in a health risk assessment than one with considerable data, even 

if certain of the data indicate a degree of toxicity associated with the product." 

Response: 

The CPSC staff evaluated these comments in detail and made appropriate changes to the revised 

risk assessment, as discussed in detail above. 

Briefly, we re-evaluated several exposure parameters including the fabric-to-skin transfer 

coefficient, the estimated total surface area of children, and the fraction of skin surface in contact 

with upholstered furniture. These revised parameters are close to the values recommended by 

the cornrnenter, though not identical. These changes reduced the estimated dermal exposure -. 

from TDCP. , . 

We considered the in vitro percutaneous absorption study with a related FR chemical, 

tris(chloropropy1) phosphate (TCPP) submitted by the cornmenter. We disagree with the 

commenter's interpretation of this study, as well as the commenter's interpretation of the TDCP 

study that we used (Hughes et al. 2001). We conclude that both studies were of high quality. 

The data suggest to us that the time course of absorption of TCPP is approximately the same as 

that of TDCP. There is no justification for using percutaneous absorption data for a surrogate 

chemical (TCPP) when data from a well-conducted study with the compound of interest (TDCP) 

are available. If we were to use the TCPP data, the results would not be affected significantly. 

The new genotoxicity data submitted by the commenter provide additional evidence that TDCP 

is probably not genotoxic in animals. However, as explained above, this is not sufficient to 

change the dose response model that we used to estimate cancer risk. 
We also reconsidered the available information on the vapor pressure of TDCP. We chose to use 

an empirical value obtained in the CPSC Chemistry Laboratory using TDCP-treated foam. We 

consider that this is more relevant to the current risk assessment than empirical or calculated 

values for pure TDCP. This change has the effect of increasing the estimated inhalation 

exposure. However, we recognize that there is considerable uncertainty in estimating inhalation 

exposure and recommend obtaining additional data. 

We disagree with the conclusion of the commenter that the 12-month interim pathology results 

should be used to derive the ADI. We consider that the lifetime exposure study is more 

appropriate for assessing chronic toxicity. However, we clarified that the non-cancer AD1 is 

based.on chronic organ toxicity, in which the testes were the most sensitive organ site. We do 

not conclude that TDCP affects reproductive function. 

In addition to the public comments discussed here, we also received'comments from independent 

peer reviewers. As a result of all of the comments, the relative contributions of oral &d dermal 

exposure have been reduced, while the relative contribution of inhalation exposure has increased. 

The conclusion that TDCP might present a hazard to consumers and,therefore, additional data 

are needed, has not changed. ; 

The reproductive study with FM-550TM described by the commenter is not yet available to us. 

Therefore, we cannot consider it in our evaluation of FM-550TM. We must thoroughly review the 

study before we can draw any conclusions and evaluate whether it is appropriate for deriving an 

ADI. 

We agree with the commenter that the lack of toxicity data for FM-550TM is not evidence of its 

safety. We considered all of the available data on the FR chemicals of interest in assessing their 

potential risks, as described in the chronic hazard guidelines (CPSC 1992). We concluded that 

basic toxicity and physico-chemical data are needed to assess the potential risks associated with 

the use of FM-550TM in upholstered furniture. 
References Listed by the Commenter 

1. Ferrante, J. Toxicity Review of Tris(l,3-dichloropropyl-2)phosphate (Fyrol FR-2 or TDCP), 

U.S. CPSC, Bethesda, MD. 1999. 

2. Safepharm Laboratories. Acute Oral Toxicity Test in Rats. 1985. 

3. Stauffer Chemical Company. Fertility Study of Fyrol FR-2 in Male Rabbits. 1982. 

4. Wilczynski, S., Kilinger, J., and Zwicker, G. Fyrol FR-2 Fertility Study in Male Rabbits. 

Toxicologist 3:22, 1983. 

5. Safepharm Laboratories. OECD 474 Micronucleus Study in the Mouse. 1985. 

6. Covance Laboratories. OECD 486 In Vivo/In Vitro Wnscheduled DNA Synthesis in Rat 

Primary Hepatocyte Cultures at Two Time Points. 2005 

7. Snodgrass, H.L. Permethrin Transfer from Treated Cloth to the Skin Surface: Potential for 

Exposure in Humans. J. Toxicol. Environ. Health 35:91-105, 1992. 

8. Maas, W.J.M. Release test for tris(2-chloro-1-methylethy1)-phosphate (TCPP) from a 

flexible foam - pilot study. TNO Quality of Life report V6578/01, 9 December 2005. 

9. Maas, W.J.M. In vitro percutaneous absorption of [14~]tris(2-chloro- 1 -methylethyl)- 

phosphate (TCPP) through human skin membranes using flow-through diffusion cells. TNO 

Quality of Life report V6578/02, 8 December 2005. 

10. OECD Guidance Document for the Conduct of Skin Absorption Studies. OECD 

Environmental Health and Safety Publications. No. 28, March 5,2004. 

1 1. Tremain S.P. TDCP: determination of vapour pressure. Safepharm Laboratories project 

16 13/003,7 March 2002. 

12. National Institutes of Health, National Toxicology Program Technical Report No. 245, 1983. 

13. IARC Monograph No. 73. The Evaluation of the Carcinogenic Risk of Chemicals to 

Humans, 1999. 

14. Rengel, D. and Pisano, A. Teratogenic Effects and Cannibalism Caused by Melamine on 

Bufo arenarum Larvae. Jnl Lab. Invest. Embryiologicas 126:4-9, 1994. 

15. Morikawa, T. The Evolution of Hydrogen Cyanide During Combustion and Pyrolysis of 

Melamine. J. Combust. Toxicol. 5:3 15-319, 1978. 

16. Viberg, H. et al. Neonatal Exposure to Polybrominated Diphenyl Ether Disrupts 

Spontaneous Behavior, Impairs Learning and Memory, and Decreases Hippocampal 

Cholinergic Receptors in Adult Mice. Toxicol. Appl. Pharmacol. 192:95-106,2003 

17. Branchi, I., Capone, F., Alleva, E. and Costa, L. Polybrominated Diphenyl Ethers: 

Neurobehavioral Effects Following Developmental Exposure. Neurotoxicol. 24:449-462, 

2003 

18. Helleday, T., et al. Brominated Flame Retardants Induce Intragenic Recombination in 

Mammalian Cells. Mutat. Res. 439: 137- 147, 1999. 

19. Birnbaum, L. and Staskal, D. Brominated Flame Retardants: Cause for Concern? Environ. 

Health Perspect. 112:9-14,2003. 
References, Cited by the CPSC Staff 

Babich MA, Thomas TA, Hatlelid K (2006) CPSC Staff Preliminary Risk Assessment of Flame 

Retardant (FR) Chemicals in Upholstered Furniture Foam. U.S. Consumer Product Safety 

Commission, Bethesda, MD 208 14. January 2006. Peer review draft. 

Babich MA (2006) CPSC Staff Preliminary Risk Assessment of Flame Retardant (FR) 

Chemicals in Upholstered Furniture Foam. U.S. Consumer Product Safety Commission, 

Bethesda, MD 20814. September 2006. Revised draft. 

Bronaugh RL, Kraeling MEK, Yourick JJ (2005) ~eterrnination of percutaneous absorption by 

in vitro techniques. In, "Percutaneous Absorption," 4" Edition, Bronaugh RL, Maibach HI, 

editors. Taylor and ran cis Group, New York. Chapter 18. Pages 265-269. 

Centers for Disease Control (CDC) CDC Growth Charts: United States. National Center for 

Health Statistics, Centers for Disease control and Prevention, Hyattsville, MD. December 4, 

2000. 

Consumer Product Safety Commission (CPSC) (1992) Labeling requirements for art materials 

presenting chronic hazards; guidelines for determining chronic toxicity of products subject to the 

FHSA; supplementary definition of "toxic" under the Federal Hazardous Substances Act; final 

rules. Federal Register 57:46626-46674. 

Environmental Protection Agency (EPA) (1997) Exposure Factors Handbook. Office of 

Research and Development, U.S. Environmental Protection Agency, Office of Toxic Substances, 

Washington, D.C 20460. August 1997. EPA 600P-951002F. 

Environmental Protection Agency (EPA) (2005) "Furniture Flame Retardancy Partnership: 

Environmental Profiles of Chemical Flame-Retardant Alternatives for Low-Density 

Polyurethane Foam." Design for the Environment Program, U.S. Environmental Protection 

Agency, Washington, D.C. September 2005. 

National Research Council (NRC) (2000) Toxicological Risks of Selected Flame-Retardant 

Chemicals. Subcommittee on Flame Retardant Chemicals, National Research Council, National 

Academy of Sciences. National Academy Press, Washington, D.C. 
Appendices Attached to the Comments 

Appendix 1': 

Table 2. General In~ut Parameters 

I Dermal 1 

Parameter 

Fabric to skin transfer, F 1 0.25 1 0.005 1 0.52 1 Wester et al. 1996; 

Snodgrass 1992; see text 

Best 

Estimate 

/ Surface area of exposed skin, S, cm2 ' I I I I 

1,250 1 500 1 4,500 1 EPA 1997; Smith 2000 

1 - 

Children esf 1 275 1 150 1 1250 1 EPA 1997; Smith 2000 1 

Lower 

Bound 

Wester et al. 1996, transfer based on experiments with glyphosate in water 

25% of total surface of relevant body parts is in contact with upholstered hiture . 'using body surface of 0.5 m2 for children weighing 11 kg (aged 12 months; length 78 cm) 

* The citations in this table refer to the CPSC risk assessment [Note added by the CPSC staff]. 

Upper 

Bound Reference 
Appendices Attached to the Comments 

Table 3. Chemical-Specific Input Parameters 

corrected for contact surface area in Cobb and Bhooshan 2005 study 

, hTremain2002 

' Calculated from vapor pressure and molecular mass ' Based on in vitro dermal absorption study with TCPP and human skin 

NOAEL for systemic toxicity is 5 mglkg-d ' Threshold model because of non-genotoxic mechanism of tumor formation (NOAEL is 5 mgtkg-d) 

Parameter Symbol 

Vapor pressure 

, Saturation concentration in air 

Dermal absorption rate 

Acceptable daily intake 

Cancer RfD 

Units 

VP 

Gat 

KT 

AD1 

RfD 

TDCP 

ton 

mg/d 

hmgfl<g-d 

mgkg-d 

TPPATP BAE 

4.2 x lo-' 

0.001 ' 

0.05' 

0.05 

0.05 ' 

6.3 x 

0.1 1 

0.1 

0.01 - 1.0 

<1 x lo-6 

0.015 

0.01 

ND 
Appendices Attached to the Comments . 

Appendix 3 

Table 4. Exposure and Risk 

" AD1 for systemic effects proposed change f?om 0.005 to 0.05 mglkg-d 

Parameter 

ADD (mgkg-d) 

Percent of total: 

Dermal 

Oral, indirect 

Oral, direct 

Inhalation, vapor 

Inhalation, particles 

HI " 

LADD (mglkg-d) 

TDCP BAE 

Adults 

1.8x10J 

8 0 

14 

0 

6 

0 

ND 

1.8~10" 

TPPATP 

Adults 

2.4x10-~ 

56 

40 

0 

3 

0 

0.005 

2.4x10-~ 

Children 

3.2~10'~ 

65 

23 

3 

9 

0 

ND 

8.6x10-~ 

Adults 

2.7~10" 

53 

9 

0 

38 

0 

0.003 - 0.3 

2.7x10-~ 

Children 

5.0x10-~ 

29 

56 

11 

5 

0 

0.010 

1.3x10-~ 

Children 

5.8~10~~ 

3 6 

13 

2 

50 

0 

0.006 - 0.6 

1.6~10'