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,. G' AND POLLllTlOS' PREVENTION ,,(**PRO~** March 11,2011

MEMORANDUM

SUBJECT: Summary of Product Chemistry, Environmental Fate, and Ecotoxicity Data for the p-Chloro-m-Cresol and Sodium p-Chloro**m~Cresolate** Registration Review Decision Document.

Active Ingredients p-Chloro-m-Cresol

Sodium p-Chloro-m-Cresolate

DP Barcode: 383014 PC Code

064206

064205 CAS No.

59-50-7

15733-22-9 Case#

3046

50 II

FROM:

TO:

THRU:

Introduction Srinivas Gowda, Microbiologist 

## S"1ri**~vo.S** Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (751 OP)

Seiichi Murasaki, Chemical Review Manager Regulatory Management Branch II

Antimicrobials Division (7510P)

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Nader Elkassabany, Branch Chief / 

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Siroes Mostaghimi, Peer**Reviewer~_** 1/I,A<Yd_

Risk Assessment and Science Support Branch (RAS

Antimicrobials Division (751 OP) (

The first product containing p-chloro-rn-cresol as an active ingredient was registered in the United States in 1968 for use as an industrial preservative. Currently

there are three products registered with p-chloro-m-cresol as an active ingredient for the

material preservative uses listed in Table I. A manufacturing use product is registered

for fonnulation as a preservative against bacteria or as an antimicrobial for the following

uses: industrial adhesives, general preservatives for leather, paper products, textiles,

fibers and cordage, metalworking (cuning) fluids, industrial coatings and resin or latex or polymer emulsions; and for general hard non-porous surface use in residential,
commercial, industrial and institutional. End-use products are registered for use as a
material preservative for the protection of chrome or vegetable tanned leather, glues,



### Page I of24adhesives, pigment slurries, building materi als such as joint cements and concrete additives, metalworking fluids, materials in the textile indus try, paper, polishes, waxes, protein solutions, ceramic glazes, fire exti nguishing materials, cl eaning solutions and detergents. A Reregistration Eligibility D ecision (RED) was issued by EPA in January

1997.

The first product containing Sodium p-chlo ro-m-cresolate as an active ingredient was registered in the United States in 2000 fo r use as an industrial preservative and disinfectant. Currently there ar e six products registered with sodium p-chloro-m-cresolate as an active ingredient for the material pr eservative and disinfectant uses listed in Table 2.

Table 1. Registered Active Product of p-Chloro-m-Cresol

Registration # Registration Name Company

Name Formulation Type % of

Active Ingredient

39967-8 Preventol ® CMK

P ara c hloro m eta c resol (PCMC) LANXESS Corporation Technical

Chemical

Solid 99.9

39967-9 Preventol ® WB LANXESS Corporation Soluble

Concentrate 29.6

39967-12 Preventol ® CMK Preservative LANXESS Corporation End Use Product

Pellets 99.9

EPA Reg. No. 39967-8

Preventol® CMK For Manufacturing Use

Technical Chemical

p -Chloro- m -cresol 99.9%

For formulation as a preservative against bact eria or as an antimicrobial for the following

uses: (1) Only for formulation into microbiocide fo r the following use(s): industrial adhesives, general preservatives for leather, paper products, textiles, fibers and cordage, metalworking (cutting) fluids, industrial co atings and resin or latex or polymer

emulsions. (2) General hard non-porous surface use in residential, commercial, industrial and

institutional.

EPA Reg. No. 39967-9

Preventol® WB

Soluble Concentrate

Industrial Microbiocide (Dilutable Concentrate)

p -Chloro- m -cresol 29.6% o-Phenylphenol 12.5%

Page 2 of 24Preservative for the Leather Industry.

Preservative for the Protection of Chrome or Vegetable Tanned Leather, Glues, Adhesives, Pigment Slurries, Building Materi als such as Joint Cements and Concrete Additives, Metalworking Fluids, Materials in the Textile Industry, Paper, Polishes, Waxes, Protein Solutions, Ceramic Glazes , Fire Extinguishing Materials, Cleaning Solutions and Detergents.

Preventol ® WB Technical Information Sheet

Preventol WB prevents damage and deteriora tion caused by mold and bacteria to leather, glues, adhesives, pigment slurries, buildi ng materials (e.g. concrete additives, joint cements), metal working fluids, materials in the textile industry, materials in the paper industry, oil field materials (e.g. drilling m uds), polishes, waxes; protein solutions, ceramic glazes, fire extinguishing materials, cleaning solutions and de tergents. Due to its special combination of active ingredients, Pr eventol WB has a wide spectrum of activity, including mold, fungi, bacteria and yeasts. It is re adily soluble in water and easy to use.

Uses:

LEATHER Storage of raw hides - Protecti on against preservation damage. Soaking of hides, particularly dried hides - No damage caused by soaking. Pickled pelts - Protection of pelts against mold, even during shippi ng over long distances.

Wet Blues - Prevention of mold formation and damage from bacteria, even during prolonged storage and shipping. Vegetable tanning floats - No tanning ma terial loss due to mold formation, decomposition or acid formation. All types of finished leather - Gives long-lasting leather protection against the formation

of mold.

ADHESIVES AND GLUES Bone glues Skin glues Casein containing glues Other animal glues Starch based glues (liquid) Starch based glues (solid)

Dextrin adhesives

Cellulose adhesives Other plant based adhesives Polyvinyl acetate adhesives Acrylic adhesives Styrene butadiene adhesives

Other adhesive emulsions

Gumarabic and similar adhesives

Page 3 of 24PIGMENT SLURRIES Kaolin slurry Calcium carbonate slurry Talcum slurry Iron oxide slurry

MATERIALS IN THE BUILDING INDUSTRY

Joint cements

Concrete additives

Other materials and auxiliaries

METALWORKING FLUIDS Metalworking fluids-Mineral Oil Based Metalworking fluids (concentrates) Metalworking fluids (ready for use) Metalworking fluids-Non-Mineral Oil Based Metalworking fluids (concentrates) Metalworking fluids (ready for use)

MATERIALS IN THE TEXTILE INDUSTRY Printing thickeners (liquid) Printing thickeners (solid) Sizes and finishing agents

Yam humidifiers Printing thickeners (liquid)

Other materials and auxiliaries

MATERIALS IN THE PAPER INDUSTRY Filler suspensions and coating compounds Rosin paper sizes

Starch slurries

Other materials and auxiliaries

ADDITIONAL MATERIALS Polishing and wax material

Protein solutions Ceramic glazes Fire extinguishing materials Cleaning solutions, detergents

EPA Reg. No. 39967-12

Preventol® CMK Preservative

p -Chloro- m -cresol 99.9% For the Preservation of Adhesives, Glues, Joint Cements, Polymer Dispersions and Emulsions, Metalworking/Cutting Fluids, Dyes , Industrial Lubrican ts, Pigments And Filler Suspensions, Materials in the Building Industry (e.g., Concrete Additives, Joint

Page 4 of 24Cements), Paint and Coatings; Paper, Textile, Photo, Oil Industries And Leather at all Stages of Production.

Technical Information Sheet.

PREVENTOL CMK Preservative is a high purity chemical suggested as a preservative against bacteria, mold fungi and yeast deterioration for industrial water based compositions, such as adhesives, joint cemen ts, and latex emulsions to impart package stability, leather at all stages of producti on and metalworking flui ds and cutting oils.

Recommended use:

ADHESIVES AND GLUES: Bone glues Skin glues Fish glues Leather glues Gelatin based glues Casein containing adhesives Other animal glues Starch based glues (liquid) Starch based glues (solid)

Dextrin adhesives Hydroxyethyl cellulose adhesives Methyl cellulose adhesives Other plant based adhesives Polyvinyl acetate adhesives Polyvinyl alcohol adhesives Acrylic adhesives Styrene butadiene (SBR latex) adhesives

Other adhesive emulsions Gumarabic and similar gums Rosin paper sizes

JOINT CEMENTS: Vinyl latex based

Protein based Other joint cement materials

POLYMER DISPERSIONS:

AND EMULSIONS Acrylic Polyvinylacetate (PVA) Vinyl/Acrylic Styrene Butadiene (SBR Latex) Other Polymer emulsions

Page 5 of 24LEATHER: Pickle solutions and pickled hides Chrome leather (calculated on pelt weight) Leather pasting adhesives Leather pigment finishes

LUBRICOOLANTS AND MINERAL OIL BASED PRODUCTS: Straight oils (Mineral-oil based) (Concentrates) (ready for use) Soluble oils (oil emulsions, aqueous) (concentrates) (ready for use) Semi-synthetic (emulsions, aqueous) (concentrates) (ready for use) Synthetic (solutions) (concentrates) (ready for use)

MATERIALS IN THE PRINTING INDUSTRY:

Inks

Fount solutions Printing pastes Other printing materi als and auxiliaries

MATERIALS IN THE BUILDING INDUSTRY:

Bitumen emulsions

Concrete additives Other building materi als and auxiliaries

MATERIALS IN THE

COATINGS INDUSTRY: Dyestuff paste, knifing fillers and plastic putty Casein based coatings

Paints Other auxiliaries and coating materials Synthetic resin dispersions

MATERIALS IN THE PAPER INDUSTRY: Rosin paper sizes Filler suspensions and coating compounds

Starch slurries Pigment slurries

Other materials and auxiliaries

Page 6 of 24MATERIALS IN THE TEXTILE INDUSTRY: Spinning Preparations Sizes and finishing agents

Yarn humidifiers Printing thickeners (solid) Printing thickeners (liquid)

Other materials and auxiliaries

MATERIALS IN THE PHOTO INDUSTRY:

Gelatin

Other materials and auxiliaries

MATERIALS IN THE OIL INDUSTRY: Biopolymers, solid (xanthan, starch, galactoma nnan, etc.) Biopolymers, liquid (drilling muds)

Other materials and auxiliaries

ADDITIONAL MATERIALS: Polishing and wax material

Protein solutions Cleaning solutions, detergents Ceramic glazes Fire extinguishing materials

Materials and auxiliaries in the leather industry Cosmetic and toiletry raw materials

Industrial Lubricants

Table 2. Registered Active Produc t of Sodium p-Chloro-m-Cresolate

Registration # Registration Name Company

Name Formulation Type % of

Active Ingredient

39967-21 Preventol CMK-NA LANXESS Corporation Formulation

Intermediate Solid

MUP 71

39967-22 Preventol CMK-NA

Preservative LANXESS Corporation Ready-to-Use Solid

MUP 71

39967-25 Preventol CMK 40 LANXESS Corporation Soluble

Concentrate

MUP 46.13

39967-26 Preventol WB Plus LANXESS Corporation Soluble

Concentrate 31.9

39967-27 Preventol CMK-NA

Preservative Solution LANXESS Corporation Soluble

Concentrate

MUP 34.5

Page 7 of 24% of Company Formulation Registration # Registration Name Active Name Type Ingredient

39967-46 Preventol CT-L LANXESS Corporation Soluble

Concentrate 37.3

EPA Reg. No. 39967-21

Preventol® CMK-Na

Formulation Intermediate Sodium p-chloro-m-cresolate 71.0%

Only for formulation as a disinfectant, fungi cide, bactericide, or preservative for the following uses: (a) Disinfectant uses: Industrial, Hospital, Household, Institutional, and Hard Surface

Disinfection. (b) Preservation uses: Indus trial Preservatives for Leather/Leather Products, Polymer/Resin/Latex Emulsions, Coatings , Paints, Specialty Industrial Products, Materials in the Building Industry (concret e additives/masonry and joint cements), Adhesives, Glues, Metalworki ng/Cutting Fluids, Materials in the Paper Industry (wet end additives, industrial processing chemicals) , Textiles, Materials in the Photographic Industry, Thickeners (sta rch, cellulose, guar, etc.), Air Filt er Oils, Starches, Clay Slurries, Slurries, Printing Inks, Graphite, and Hard Surface Treatment Products (polishes, waxes, ceramic glazes).

EPA Reg. No. 39967-22

Preventol CMK-NA Preservative Sodium p-chloro-m-cresolate 71.0%

For Use in the Manufacture of Adhesives and Glues, Polymer Dispersions and Emulsions, Leather, Lubricoolants and Mine ral Oil Based Products, Materials in the Printing Industry, Materials in the Building Industry (E.G., Concrete Additives, Joint Cements), Paint and Coatings, Materials in the Oil Industry, Pigment Slurries (Kaolin, Calcium Carbonate, and others), Polishes, Waxes, Protein Solutions, Ceramic Glazes, Fire Extinguishing Materials, Cl eaning Solutions and Detergents.

Technical Information Sheet

See under EPA Reg. No. 39967-12

EPA Reg. No. 39967-25

Preventol CMK 40 Sodium p-chloro-m-cresolate 46.13%

Industrial Microbiocide : Preservative For Use In The Manufacture Of Adhesives And Glues, Polymer Dispersions And Emulsions, Ma terial In The Leather Industry (For The Protection Of Chrome Or Vegetable Tanne d Leather), Lubricool ant And Mineral Oil-

Page 8 of 24Based Products, Materials In The Printing I ndustry, Building Materials Such As Joint Cements And Concrete Additives, Materials In The Oil Industry, Pigment Slurries, Materials In The Textile Industry, Paper, Po lishes, Waxes, Protein Solutions, Ceramic Glazes, Fire Extinguishing Materials, Clean ing Solutions And Detergents, Industrial

Lubricants.

Technical Information Sheet

ADHESIVES AND GLUES Bone glues Skin glues Casein containing glues Other animal glues Starch based glues (liquid) Methyl Cellulose adhesives Other plant based adhesives Polyvinyl alcohol adhesives Acrylic adhesives Styrerie butadiene adhesives

Other adhesive emulsions

Gumarabic and similar adhesives

POLYMER DISPERSIONS AND EMULSIONS Acrylic Polyvinylacetate (PVAc) Styrene Sutadiene (SBR Latex) Other polymer emulsions

LEATHER Pickle solutions and pickled hides Chrome leather (on pelt weight) Leather pasting adhesives Leather pigment finishes

METAL WORKING FLUIDS Straight oils (Mineral-oil based) Soluble oils (oil emulsions, aqueous) Semi-synthetic (emulsions, aqueous) Synthetic (solutions)

MATERIALS IN THE PRINTING INDUSTRY

Inks

Fount solutions Printing pastes Other printing materi als and auxiliaries

Page 9 of 24MATERIALS IN THE BUILDING INDUSTRY

Joint cements materials

Bitumen emulsions

Concrete additives

Other materials and auxiliaries

MATERIALS IN THE COATINGS INDUSTRY Dyestuff paste, knifing fillers and plastic putty Casein based coatings Synthetic resin dispersions Other auxiliaries and coating materials

MATERIALS IN THE PAPER INDUSTRY Filler suspensions and coating compounds Rosin paper sizes

Starch slurries

Other materials and auxiliaries

MATERIALS IN THE TEXTILE INDUSTRY Printing thickeners (liquid) Sizes and finishing agents

Yarn humidifiers

Other materials and auxiliaries

MATERIALS IN THE OIL INDUSTRY Biopolymers, liquid (drilling muds)

Other materials and auxiliaries

PIGMENT SLURRIES Kaolin slurry Calcium carbonate slurry Talcum slurry Iron oxide slurry

ADDITIONAL MATERIALS Polishing and wax materials

Protein solutions Ceramic glazes Fire extinguishing materials Cleaning solutions, detergents

Industrial Lubricants

Industrial Lubricants with incidental food contact

EPA Reg. No. 39967-26

Preventol WB Plus

Industrial Microbiocide

Page 10 of 24Sodium p-chloro-m-cresolate 31.9% Sodium 0-phenylphenol 13.1% Sodium pyridine-2- thiol 1-oxide 1.2%

Preservative For The Leather Industry, For The Protection Of Chrome Or Vegetable Tanned Leather, Glues, Adhesives, Pigment Slurries, Building Materials Such As Joint Cements And Concrete Additives, Metal Work ing Fluids, Materials In The Textile, Paper, Polishes Waxes, Protein Solutions, Ce ramic Glazes, Fire Extinguishing Materials, Cleaning Solutions And Detergents.

Preventol WB Technical Information sheet

EPA Reg. No. 39967-27

Industrial Microbiocide

Preventol CMK-NA Preservative Solution Sodium p-chloro-m-cresolate 34.5%

Industrial Microbiocide; For Use As A Preservative In Th e Manufacture Of Adhesives And Glues, Polymer Dispersions And Emulsi ons, Leather Industry (For The Protection Of Chrome Or Vegetable Tanned Leathe r), Lubricoolant And Mineral Oil-Based Products, Materials In The Printing Industry, Building Materials Such As Joint Cements And Concrete Additives, Materials In The O il Industry, Pigment Slurries, Materials In The Textile Industry, Paper, Polishes, Waxe s, Protein Solutions, Ceramic Glazes, Fire Extinguishing Materials, Cleani ng Solutions, And Detergents.

Technical Information Sheet

For Use As A Preservative In The Manufact ure Of Adhesives And Glues, Polymer Dispersions And Emulsions, Leather Industr y (For The Protection Of Chrome Or Vegetable Tanned Leather), Lubricoolant A nd Mineral Oil-Based Pr oducts, Materials En The Printing Industry, Building Materials Such As Joint Cements And Concrete Additives, Materials In The Oil Industry, Pi gment Slurries, Materials In The Textile Industry, Paper, Polishes. Waxes, Protein Solutions, Ceramic Glazes, Fire Extinguishing Materials, Cleaning Solu tions, And Detergents.

ADHESIVES AND GLUES Bone glues Skin glues Casein containing glues Other animal glues Starch based glues (liquid) Starch based glues (solid) Methyl Cellulose adhesives Other plant based adhesives Polyvinyl alcohol adhesives Acrylic adhesives Styrene butadiene adhesives

Page 11 of 24Other adhesive emulsions

Gumarabic and similar adhesives

POLYMER DISPERSIONS AN]) EMULSIONS Acrylic Polyvinylacetate (PVAc) Styrene Butadiene (SBR Latex) Other polymer emulsions

LEATHER Pickle solutions and pickled hides Chrome leather (on pelt weight) Leather pasting adhesives Leather pigment finishes

METAL WORKING FLUIDS Straight oils (Mineral-oil based) Soluble oils (oil emulsions, aqueous) Semi-synthetic (emulsions, aqueous) Synthetic (solutions)

MATERIALS IN THE PRINTING INDUSTRY

Inks

Fount solutions Printing pastes Other printing materi als and auxiliaries

MATERIALS IN THE BUILDING INDUSTRY

Joint cements materials

Bitumen emulsions

Concrete additives

Other materials and auxiliaries

MATERIALS IN THE COATINGS INDUSTRY Dyestuff paste, knifing fillers and plastic putty Casein based coatings Synthetic resin dispersions Other auxiliaries and coating materials

MATERIALS IN THE PAPER INDUSTRY Filler suspensions and coating compounds Rosin paper sizes

Starch slurries

Other materials and auxiliaries

MATERIALS IN THE TEXTILE INDUSTRY

Page 12 of 24Printing thickeners (liquid) Sizes and finishing agents

Yarn humidifiers

Other materials and auxiliaries

MATERIALS IN THE OIL INDUSTRY Biopolymers, liquid (drilling muds)

Other materials and auxiliaries

PIGMENT SLURRIES Kaolin slurry Calcium carbonate slurry Talcum slurry Iron oxide slurry

ADDITIONAL MATERIALS Polishing and wax materials

Protein solutions Ceramic glazes Fire extinguishing materials Cleaning solutions, detergents

EPA Reg. No. 39967-46

Preventol CT-L Sodium p-chloro-m-cresol -3 7.3% 2-n-octyl-4-isothiazolin-3-one - 2.0%

Industrial Microbiocide : Preservative For The Leather Industry, For The Protection Of Chrome Or Vegetable Tanned Leather.

For the Preservation of Pickled Pelts a nd Preservation during Chrome Tannage.

Science Findings

The Agency has conducted a review of the available product chemistry, environmental fate, and ecotoxicity data for p-chloro-m-cresol and sodium p-chloro-mcresolate. The findings are summarized below.

Product Chemistry Summary of p-Chloro-m-Cresol (99.9% TGAI)

Common Name: p-Chloro-m-cresol (PCMC); Parachlorometacresol; 4-Chloro-3-methylphenol

Chemical Name: 4-Chloro-3-cresol

Trade and Other Names: Preventol, Preventol CMK, Raschitk, Aptal

OPP Chemical Code: 064206 CAS Registry Number: 59-50-7

Page 13 of 24Case: 3046 Chemical Family: Phenol

Molecular Formula: C 7 H 7 OCl Molecular weight: 142.58

Molecular Structure:

Color: White/colorless

Physical State: Crystalline solid

Odor: Phenolic

Stability: Stable at normal and elevated temperature over a period of 14-day period. Corrosive to metals and forms complex compounds with transition meta l ions. Slow discoloration of the chemical occurs in the presence of sunlight.

Oxidation/Reduction: N/A

Flammability-Flash Point: 224.4oF (118oC)

Explodability: N/A

Storage Stability: Stable for 12 months.

Miscibility: N/A

Corrosion Characteristics: Not corrosive to its packaging (plastic woven bag).

Dielectric breakdown voltage: N/A

pH: 5.6 (saturated aqueous solution) at 25 oC

UV/Visible absorption: Not provided.

Viscosity: N/A. Product is not liquid.

Melting point: 63-65 oC (measured)

Boiling Point: Approximately 235-239 oC

Page 14 of 24Density: 49.93 lbs/ft 3 (800 kg/m 3 )

Dissociation Constant: 9.4 ± 0.1 at 25 oC

Log K o/w or log P : 3.02 (measured)

Solubility: Water: 4 g/L at 25oC Ethanol: 500 g/L Toluene 300 g/L 10% aqueous NaOH solution 320 g/L

Soluble in alkalies, organic solvents, fats, and oils. More soluble in hot than in cold water; freely soluble in alcohol, benzene, chloroform, ether, fixed oils, terpenes, acetone, aqueous alkaline solution, and petroleum ether.

Vapor Pressure: < 0.2 mm Hg at 25o C (estimated from the boiling point using PC-nomo-5). 5 mm Hg at 100 oC Henry's Law Constant: 2.45E-06 atm-m3/mole 25 o C (Source: EPI Suite).

Enf. Analytical Method: Gas Chromatography

Product Chemistry Summary of Sodium p-Chloro-m-Cresolate (71% Technical)

Common Name: p-Chloro-m-cresol, sodium salt; Sodium p-chloro-mcresolate; Parachlorometacresolate, sodium salt; Sodium Parachlorometacresolate;

Chemical Name: Sodium 4-chloro-3-cresolate; Sodium 4-chloro-3- methylphenolate; Sodium p-chloro-m-methylphenate; Sodium p-chloro-m-cresolate

Trade and Other Names: Preventol, Preventol CMK, Raschitk, Aptal

OPP Chemical Code: 064205 CAS Registry Number: 15733-22-9

Case: 5011 Chemical Family: Phenol

Molecular Formula: C 7 H 6 OCl·Na Molecular weight: 164.56 g/mol

Molecular Structure:

Color: White to pale yellow

Page 15 of 24Physical State: Solid

Odor: Nearly odorless or slightly phenolic

Stability: This is a stable material.

Oxidation/Reduction: N/A. Product contains no oxidizer or reducing action.

Flammability-Flash Point: >185 oC (365 °F)

Explodability: N/A

Storage Stability: Stable for >24 months.

Miscibility: N/A

Corrosion Characteristics: Not corrosive to its packaging.

Dielectric breakdown voltage: N/A

pH: Approx. 10.5-11.5 at 1 g/L water

UV/Visible absorption: Not reported.

Viscosity: N/A Product is not liquid

Melting point/ Freezing Point: 94oC (201.2°F)

Boiling Point: Not applicable. Product is solid.

Density: 1.36 g/cm 3 at 20 oC

Bulk Density: Approx. 700 kg/m 3

Specific Gravity: Approx. 1.36

Dissociation Constant: 9.4 ± 0.1 at 20 oC

Log K o/w or log P : 2.86 at a concentration of 1 g/L

Solubility: Water: 580 g/L at 20 oC Water: 700 g/L at 50 oC Ethanol: approx. 2000 g/L Toluene <0.5 g/L

Page 16 of 24Acetonitrile: 2400 g/L Ethyl acetate: approx. 10 g/L (0.9%)

Vapor Pressure: 1.6 x 10 -4 hPa (at 21 oC) (0.00012 mm Hg or 1.2 x 10 -4 mm Hg)

Henry's Law Constant: 8.17E-007 atm-m3/mole at 25 oC (Source: EPI Suite)

Enf. Analytical Method: Gas Chromatography

All product chemistry data requirements have been satisfied for the active ingredients p-chloro-m-cresol and sodium p-chloro-m-cresolate.

Environmental Fate Summary

The Agency has not received any guide line environmental fate studies on pchloro-m-cresol or sodium p-chloro-m-cresolate, and fate studies are required to conduct

an environmental fate assessment for material preservatives (including p-chloro-m-cresol and sodium p-chloro-m-cre solate) that may potentially pass through waste water treatment plants (WWTPs) and may be discharged into terrestrial and aquatic environments. For this assessment the Agency anticipates needing those data outlined on page 19 of this document.

Water Quality

Neither p-Chloro-m-cresol nor sodium p-chloro-m-cresolate are identified as a cause of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_na tion_cy.cause_detail _303d?p_cause_group_id

=885 . In addition, no Total Maximum Daily Loads (TMDL) have been developed for pchloro-m-cresol and sodium p-chloro-m-cresolate , based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_na tion.tmdl_pollutant_detail?p_pollutant_group _id=885&p_pollutant_group_name=PESTICIDES . More information on impaired water

bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/ . The Agency invites submission of water quality data for this pesticide. To the extent possible, data should conform to the quality standards in Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP’s Registration Review Risk Assessment and Management Process (see: http://www.epa.gov/oppfead1/cb/ppdc/2006/november06/session1-sop.pdf ), in order to ensure they can be used quantitatively or qualitatively in pesticide risk assessments.

Ecological Effects Summary

The registrant has submitted ecological effects studies for both terrestrial and aquatic animals. These data are adequate to provide the Agency with sufficient information to determine appropriate labe l precautions, and may be seen in Table 2

below.

Page 17 of 24a. Toxicity to Terrestrial Animals

Birds, Acute and Subacute

p-Chloro-m-cresol is slightly toxic to avian species on an acute oral and subacute dietary basis.

b. Toxicity to Aquatic Animals

Freshwater Fish and Invertebrates

p-Chloro-m-cresol is highly toxic to cold water fish and moderately toxic to aquatic invertebrates.

c. Toxicity to Aquatic Plants

(1) Freshwater Algae

No algal toxicity data have been submitted. For the ecological risk assessment, including an endangered species assessment for all uses, the Agency anticipates needing the algal t oxicity data outlined on page 19 of

this document.

Table 2. Ecotoxicity Data Summary for p-Chloro-m-cresol

GUIDE

LINE COMMON

NAME TAXONOMIC

NAME TEST

TYPE %

AI STUDY

TIME DOSE

TYPE TOXI

CITY TOX

LEVEL NOEL STUDY

STATUS TOX

CATEGORY MRID

Avian Acute Oral Toxicity

850.2100 Bobwhite quail Colinus virginianus O 99.9 14 D LD 50 1540 MGK 250 Acceptable Slightly

toxic 42692401

Avian Subacute Dietary Toxicity

850.2200 Bobwhite quail Colinus virginianus D 99.9 8 D LC 50 >3180 PPM 3180 Acceptable Slightly

toxic 42692402

Freshwater Fish Acute Toxicity

850.1075 Rainbow

trout Oncorhynchus mykiss SR 99.9 96 hr LC 50 917 PPB 366 Acceptable Highly

toxic 42692403

Freshwater Invertebrate Acute Toxicity

850.1010 Water

flea Daphnia

magna S 99.9 48 hr EC 50 2300 PPB 1730 Acceptable Moderately

Toxic 42692404

Adverse Ecological Incidents

There are no reported incidents in the Ag ency' s Ecological Incident Information System (EIIS) regarding p-chloro-m-cresol and sodium p-chloro-m-cresolate. The

absence of documented incidents does not nece ssarily mean that such incidents did not

occur.

Page 18 of 24Ecological Effects Risk Assessment

An ecological risk assessment was not conducted on the p-chloro-m-cresol and sodium p-chloro-m-cresolate use patterns described in this document. p-Chloro-m-cresol and sodium p-chloro-m-cresolate uses that have potential fo r environmental exposure are material preservatives discharges. The Agen cy needs to conduct environmental fate and ecological risk assessments for material pres ervatives that potentia lly pass through waste water treatment plants (WWTPs) and may be discharged into terrestrial and aquatic environments. For this ecological risk assessment, including an endangered species assessment for all uses, the Agency anticipates needing the algal toxi city data outlined on page 19 of this document.

The Agency has not conducted a risk assessment that supports a complete endangered species determination. The eco logical risk assessment planned during registration review will allow the Agency to determine whether p-chloro-m-cresol’s and sodium p-chloro-m-cresolate’s use has “no effect or “may affect” federally listed threatened or endangered species (listed species) or their desi gned critical habitats. When an assessment concludes that a pesticide’s use “may affect” a lis ted species or its designated critical habitat, the Agency w ill consult with the U.S. Fish and Wildlife

Service and/or National Marine Fisheries Se rvices (the Services), as appropriate.

Environmental Fate and Ecotoxicity Data Gaps and Anticipated Work

Environmental fate and ecological risk assessments have not been conducted for pchloro-m-cresol and sodium p-chloro-m-cresolate . The Agency needs to conduct environmental fate and ecological risk assessme nts for material preservatives that potentially pass through waste water treatment plants (WWT Ps) and may be discharged into terrestrial and aquatic environments. Therefore, the Agency anticipates needing the proposed

environmental fate and ecotoxicity data for p-chloro-m-cresol and sodium p-chloro-mcresolate and/or any of its major degradation products that are of potential concern for all registered uses of p-chloro-m-cresol and sodium p-chloro-m-cresolate . The following environmental fate and ecotoxicity data are needed to conduct an environmental fate and ecological risk assessment:

• The Agency anticipates needing the following data to conduct a complete environmental fate assessment for material preservative uses:

o (GLN 835.2120) Hydrolysis;

o (GLN 835.2240) Photodegradation in water;

o (GLN 850.6800) Modified Activated Sludge Respiration Inhibition;

o (GLN 835.1110) Activated Sl udge Sorption Isotherm; and

o (GLN 835.3110) Ready Biodegradability.

• The Agency anticipates needing the following algal toxicity data in order to conduct a complete ecological risk assessment, including an endangered species assessment:

o (GLN 850.5400) algal toxicity (Tier II) using freshwater green alga, Selenastrum capricornutum.

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### Appendix A. Environmental Fate Guideline Study Justifications

Guideline Number: 835.2120 Study Title: Hydrolysis
Practical Utility of the Data 1) What is the value of the study? Data characterizing the rate of hydrolytic degrada tion of p-chloro-m-cresol and/or the formation and decline of degradates is important in determining the persistence and concentrations of p-chloro-m-cresol and potential degradates over time in various aquatic environments. For outdoor uses, p-chloro-m-cresol can reach surface water through direct contact or disch arge to WWTPs. P-chloro-m-cresol may also reach surface water or groundwater through run-off or l eaching processes. The Agency will evaluate the potential risks of concern.

2) How would the data be used? The data would establish the significance of chemical hy drolysis as a route for degradation and identify, if possible, the hydrolytic transformation products formed that may adversely affect non-target organisms and may contaminate water and food source of aquatic or ganisms. The data would also help establish the hydrolytic half-life of p-chloro-m-cresol and possibl y degradates, and assist in developing a degradation pathway.

3) How could the data affect the risk assessment? The results of hydrolysis data would indicate if p-chlo ro-m-cresol is persistent or if it degrades into other products that may adversely affect nontarget organisms and may contaminate their food and water and possibly soil.

4) What is triggering the need for this data? Hydrolysis data is needed to c onduct the fate assessment to support material preservatives uses for pchloro-m-cresol.

Guideline Number: 835.2240 Study Title: Photodegradation in water
Practical Utility of the Data 1) What is the value of the study? Biocides introduced into aqueous systems in the e nvironment can undergo photolytic transformation by sunlight. Results from the photolysis study will indicate the stability and persistence of p-chloro-m-cresol and potential degradates in an aquatic environment when exposed to sunlight. The Agency will evaluate the potential risks of concern.

2) How would the data be used? The data would establish the significance of chemical photolysis as a route for degradation and identify, if possible, the photolytic degradation products formed that may adversely affect non-target organisms and may contaminate water and food source of aquatic or ganisms. The data would also help establish the photolytic half-life of p-chloro-m-cresol and possibly degradates, and assist in developing a degradation pathway.

3) How could the data affect the risk assessment? The results of photolysis data would indicate if p-chloro-m-cresol is persistent or if it degrades into degradation products that may adversely affect nontar get organisms and may contaminate their food. The results of the photolysis data would expand the unders tanding of the results of the hydrolysis data since environmental aquatic conditions usua lly involve exposure to sunlight.

Page 20 of 24Guideline Number: 835.2240 Study Title: Photodegradation in water 4) What is triggering the need for this data? Aqueous photodegradation data is n eeded to conduct the fate assessment to support material preservative uses for p-chloro-m-cresol.

Guideline Number: 835.1110 Study Title: Activated Sludge Sorption Isotherm
Rationale for Requiring the Data Data from this study are needed to determine the sorption potential of activated sludge for the removal of specific chemical compoun ds in biological wastewater treatment plants (WWTPs). If the chemical is not sorbed or biodegraded, then it would pass th rough a biological treatment system unaffected, potentially contaminating surface and drinking waters where it may then have the potential to adversely

affect nontarget organisms. EPA needs activated sludge sorption stu dy data to assess the distribution of the antimicrobial chemical among the solid, aqueous, and vapor phases of WWTPs. Specifically, this study identifies those chemicals which sorb to sludge biomass. Practical Utility of the Data

1. How will the data be used? The data will be used to assess exposure and risk to non-target endangered and non-endangered species. Exposure data are integral parts of the risk equation fo r determining the impact of pesticides to beneficial nontarget organisms through direct exposure from their food sources and habitat.

In addition, the data will be used to determine whethe r or not additional studies and/or label restrictions are

needed. If the data indicate that the chemical does not sorb to sludge and instead partitions more readily to water, then the chemical has the potential to pass through the WWTP and therefore could be discharged in to the aquatic environment. This determination c ould trigger further data requirements to assess the chemical’s impact upon release.

2. How could the data impact th e Agency’s future decision-making? If the data show that the chemical negatively impacts the aquatic environment or the effectiveness of the WWTP, then the risk assessments for this chemical may need to be revised to reflect the magnitude of potential risk derived from the new data. The risk assessment may result in the Agency requiring label restrictions that would be necessary for the produc ts to meet the “no unreasonable adverse effects” requirements of FIFRA (e.g., changes to the directions for disposal).

In addition, EPA is required by section 7(a)(2) of the ESA to ensure that any action it authorizes or takes “...is not likely to jeopardize the continued existence of any endangered or threatened species or result in

the destruction or adverse modification of critical habita t” and to use the best scientific data available” in carrying out this obligation. The data EPA intends to call in are necessary to inform the determination required by the ESA as to whether continued registra tion of a pesticide is not likely to jeopardize the species or its critical habitat. Absent this data EPA may not be able to conclude that this pesticide will not harm endangered species and may theref ore need to consider other limitati ons on the use of the pesticide in order to fulfill the Agency’s statutory obligations under the ESA. The lack of these data will limit the flexibility that the Agency and registrants have in co ming into compliance with the ESA and could result in use restrictions which are unnecessarily severe.

Page 21 of 24Guideline Number: 835.1110 Study Title: Modified Activat ed Sludge Respiration Inhibition
Rationale for Requiring the Data The modified activated sludge, respiration inhibition test is needed to identify whether this pesticide could harm microorganisms found in biol ogical wastewater treatment systems. The Agency will utilize

these data to conduct the environmental fate assessment and to determining the potential impact of this

chemical on waste water treatment plants ( WWTPs) via effects on WWTP microbes. This test is also necessary to enable EPA to establish correct concentrations for use in the ready biodegradability test. Practical Utility of the Data

1. How will the data be used? The data will be used to assess exposure and risk to non-target endangered and non-endangered species. Exposure data are integral parts of the risk equation fo r determining the impact of pesticides to beneficial non-target organisms through direct expos ure from their food sources and habitat.

In addition, the data will be used to determine whether or not additional studies and/or label restrictions are needed. The study will identif y the inhibitory effect of this chemical on the treatment plant’s microorganisms’ respiration at a particular con centration and will identify the EC50, the effective concentration at which the respiratory rate is reduced by 50%. EPA will use the data to determine the chemical’s potential to directly harm the non-target organisms and/or the microbial treatment processes present in a WWTP. The data will also determine suita ble non-inhibitory concentrations to be used in biodegradability tests.

2. How could the data impact th e Agency’s future decision-making? If the data show a high degree of respiratory inhibiti on, higher-tiered environmental fate studies may be required and the risk assessments for this chemical may need to be revised to address the impact of the potential risk. The risk assessment may result in the Agency requiring label restrictions that would be necessary for the products to meet the “no unreasona ble adverse effects” requirements of FIFRA (e.g., changes to the directions for disposal).

In addition, EPA is required by section 7(a)(2) of the ESA to ensure that any action it authorizes or takes “...is not likely to jeopardize the continued existence of any endangered or threatened species or result in

the destruction or adverse modification of critical habita t” and to use the best scientific data available” in carrying out this obligation. The data EPA intends to call in are necessary to inform the determination required by the ESA as to whether continued registra tion of a pesticide is not likely to jeopardize the species or its critical habitat. Absent this data EPA may not be able to conclude that this pesticide will not harm endangered species and may theref ore need to consider other limitati ons on the use of the pesticide in order to fulfill the Agency’s statutory obligations under the ESA. The lack of these data will limit the flexibility that the Agency and registrants have in co ming into compliance with the ESA and could result in use restrictions which are unnecessarily severe.

Page 22 of 24Guideline Number: 835.3110 Study Title: Ready Biodegradability
Rationale for Requiring the Data For antimicrobial chemicals that go down-the-drain and reach a WWTP, as part of its screening-level environmental fate assessment, EPA will analyze the pote ntial impact of the antimicrobial chemical on the microorganisms in the biological treatment pro cesses of a WWTP. Biodegradation is an important environmental pathway in which the antimicrobial is broken down by bacteria. This study supplies information on the rate of breakdown and the complete ness of the degradation to carbon dioxide and water. A ready biodegradability study woul d allow the Agency to determine whether the chemical achieves ‘‘pass levels’’ for ready biodegradability (e.g., 70% removal of dissolved organic carbon). Practical Utility of the Data

1. How will the data be used? The data will be used to assess exposure and risk to non-target endangered and non-endangered species. Exposure data are integral parts of the risk equation fo r determining the impact of pesticides to beneficial non-target organisms through direct expos ure from their food sources and habitat.

In addition, the data will be used to determine whether or not additional studies and/or label restrictions are needed. If the chemical does not achieve a ‘‘pass level’’ for ready biodegradability, then the Agency would determine that the chemical has the potential to pass through the WWTP and therefore may be discharged in to the aquatic environment potentially resulting in exposure to non-target species. This determination would trigger furthe r data requirements to assess the chemical’s impact on the aquatic environment upon release.

2. How could the data impact th e Agency’s future decision-making? If the chemical is found to be readily biodegraded, then impact on WWTP would be identified as minimal and most likely no further studies or label restrictions would be required. If a low rate of biodegradability is identified, then higher-tiered e nvironmental fate studies may be triggered and the risk assessments for this chemical may need to be revised to reflect the magnitude of poten tial risk derived from the chemical’s lack of biodegradability. The risk assess ment may result in the Agency requiring label restrictions that would be necessary for the products to meet the “ no unreasonable adverse effects” requirements of FIFRA (e.g., changes to the directions for disposal).

In addition, EPA is required by section 7(a)(2) of the ESA to ensure that any action it authorizes or takes “...is not likely to jeopardize the continued existence of any endangered or threatened species or result in

the destruction or adverse modification of critical habita t” and to use the best scientific data available” in carrying out this obligation. The data EPA intends to call in are necessary to inform the determination required by the ESA as to whether continued registra tion of a pesticide is not likely to jeopardize the species or its critical habitat. Absent this data EPA may not be able to conclude that this pesticide will not harm endangered species and may theref ore need to consider other limitati ons on the use of the pesticide in order to fulfill the Agency’s statutory obligations under the ESA. The lack of these data will limit the flexibility that the Agency and registrants have in co ming into compliance with the ESA and could result in use restrictions which are unnecessarily severe.

Page 23 of 24Page 24 of 24 

## Appendix B: Ecological Guideline Study Justifications

Guideline Number: 850.5400 Study Title: Algal toxicity (Ti er II) using freshwater green alga, Selenastrum capricornutum
Practical Utility of the Data 1) What is the value of the study? As part of an initial risk assessment, one indicator pl ant species is tested for ph ytotoxicity. This study would allow the Agency to categorize p-chloro-m-cresol as toxic or non-toxi c to plants. If toxic, additional higher tier plant tests would be needed. An endange red species assessment for endangered or threatened plants is not possible without this study.

2) How would the data be used? This study would be used to evaluate the toxicity of p- chloro-m-cresol to non-target plants in terrestrial and aquatic ecosystems.

3) How could the data affect the risk assessment? Adverse effects to non-target plants in terrestrial a nd aquatic ecosystems may result in mitigation to protect species at risk. Mitigation might include reduced label dosages, neutralization of effluents prior to discharge into water, restrictions on use in sensitive ecosystems or where endangered species are present, or other mitigation measures.

4) What is triggering the need for this data? Increased concern from state regulators and the public to evaluate impacts on WWTP operations, endangered species, and persistence in the environment, since initial registration, have triggered the need for this study. Green algae are critical to ecosystem health and productivity.