### Attachment 11 – Sustainable Futures P2 Assessment f or { PPG021 }

This chemical is the subject of a P2 Assessment for participation in the Sustainable Futures tm Initiative. The P2 assessment of { 1 Hexanedioic acid, polymer with 2-ethyl-2-(hydroxy methyl)-1,3-propanediol, dihydrogen phosphate 4-nitrobenzoate }, referred to as { PPG021 } in the assessment, directly follows this
cover letter.

Incomplete data were available for { PPG021 } and predictive methods were employed in the asses sment of the chemical.

{ PPG021 } is predicted to have a high overall concern for p ersistence, with an environmental half-life of >180 days.

{ PPG021 } is predicted to have a low concern for bioaccumul ation.

{ PPG021 } is predicted to have a low hazard concern for aqu atic toxicity.

{ PPG021 } is predicted to have low hazard concerns for acut e human health effects, as well as cancer hazard concerns. { PPG021 } is predicted to have a moderate overall human hea lth non-cancer chronic hazard concern level, based on systemic and reprodu ctive effects. It should be noted that { PPG021 } is also predicted to have the potential to cause irrit ation and/or sensitization, but these are not used for assessment purposes to determine overall hazard or risk concern.

The conclusion of the { PPG021 } aquatic risk assessment is that, based on low haz ard, there is a low potential for risk.

The conclusions of the { PPG021 } human health risk assessment is that there is a l ow potential for acute or cancer hazard risk, as well as chronic risk to t he general population from exposure to the substanc e. However, based on the potential human health chroni c hazard concerns identified for the { PPG021 } and possible occupational dermal exposure modeled for t he substance, the potential for occupational dermal risk exists. There is potential for inhalat ion exposure from the use operation only and there is a low potential for risk when the inhalation route is used to determine risk alone.

It should be noted that this risk assessment does n ot take PPE and other exposure controls into accoun t for this risk assessment. The { PPG } MSDS, which is included with this substance, indi cates that workers should wear gloves and use other personal protectiv e measures when handling { PPG021 } or when exposure may occur. Further, the use of this subst ance involves robotic spraying and other exposure controls, which is likely to significantly reduce p otential inhalation exposure. These measures would likely mitigate any risk to human health posed by { PPG021 }.

It is our opinion that based on this assessment of the chemical and information included in the PMN submission and manufacturer’s MSDS, including use o f gloves and appropriate exposure controls, { PPG021 } will not pose an unreasonable risk to human healt h or the environment.

# Sustainable Futures

Summary Assessment

Using

P2 Framework Models

Chemical Assessed: { Hexanedioic acid, polymer with 2-ethyl-2-(hydroxyme thyl)-1,3- propanediol, dihydrogen phosphate 4-nitrobenzoate }

CAS Registry Number: N/A

Participant Name: { PPG Industries, Inc. }

Date of Assessment: 03/14/2011 This document was developed to help compile estimatio n results from U.S. EPA OPPT’s P2 Framework Models www.epa.gov/oppt/p2framework/ and is used by OPPT during Sustainable Futures (SF) training described at www.epa.gov/opptintr/newchems/sustainablefutures.htm

. Participants in the voluntary SF Pilot Project are a sked to submit the information contained in this assessment along with their SF PMNs in their choice of format. Use of this specific format is not mandatory.3 Record ID:{ PPG021 } Submitter:{ PPG Industries, Inc.}

Chemical Structure

Is this a representative structure? yes Mn: 1,032 Dalton

% <1,000: 36%; % <500: 15%

Physical Form: Solid (neat)

CAS RN: N/A

Trade Name: 5062

Use: { Automobile } Coatings

Production Volume: 29,200 kg/yr

SMILES: N/A

Name: { Hexanedioic acid, polymer with 2

- ethyl

- 2

- (hydroxymethyl)

- 1,3

- propanediol, dihydrogen phosphate 4

- nitrobenzoate }

Synonyms: 5062

SUSTAINABLE FUTURES SUMMARY:

Concern Level HIGH MODERATE LOW

Persistence X

Bioconcentration X

Non-Cancer Health Hazard X

Cancer Health Hazard X

Aquatic Toxicity Hazard X

Is the chemical predicted to be a PBT by PBT Profil er? Not Run in PBT Profiler

Overall Hazard Concern Human Health Hazard: Moderate Aquatic Hazard: Low

Overall Risk Human Health Risk: The Potential for Occupational Risk

Exists Aquatic Risk: Low4 Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

PHYSICAL/CHEMICAL PROPERTIES:

Melting Point (deg C) >20 for neat substance (professional judgment)

Boiling Point (deg C) >400 for neat substance (professional judgment)

Boiling Point Pressure (mm Hg) 760

Vapor Pressure (mm Hg) <10 - 8 ; increases with decreases oligomer size (professio nal judgment)

Water Solubility <10 mg/L (professional judgment)

Log K ow Not evaluated

ENVIRONMENTAL TRANSPORT AND FATE:

Transport

Henry’s Law Constant – HLC (atm-m 3 /mol) <10 -8 (professional judgment)

Soil Adsorption Coefficient – Log K
oc Str o ng sorption to soil ; slow to negligible groundwater migratory potential (professional judgment)

Bioconcentration Factor – BCF Low concern for polymer and LMW materials ; 10 used for E-FAST (EPI Suite and professional judgment)

Persistence

Experimental Biodeg Tests Slow degradation with a half

- life of >60 days (professional judgment)

Probability of Rapid Biodegradation Will not biodegrade fast (professional judgment)

Ultimate Biodeg Model

Primary Biodeg Model

Ready Biodegradability Not ready biodegradable (professional judgment)

Atmospheric Half-life N/A due to lack of partitioning (professional judgm ent)

Hydrolysis Half-life Slow hydrolysis (professional judgment)

Volatilization Half-life for Model River > 1 year (professional judgment)

Volatilization Half-life for Model Lake >1 year (professional judgment)

Removal in Sewage Treatment Plant 50 – 90% (professional judgment)

Byproducts

Degradation Products

Metabolites5 Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

ECOTOXICITY:

ECOSAR Class ECOSAR

Acute Toxicity

Fish LC 5O NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Daphnid LC 5O NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Green Algae EC 5O NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Chronic Toxicity

Fish ChV NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Daphnid ChV NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Green Algae ChV NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Overall Aquatic Toxicity Hazard Concern Low

NON-CANCER HEALTH EFFECTS:

Acute Toxicity Low, based on { nitrobenzoic acid (CAS RN 62

- 23

- 7) }

, LD 50 of 1960 mg/kg in rats (IUCLID 2000) or { trimethylol propane (CAS RN 77-99-6) },LD 50 of 13700 mg/kg in mice (OECD 1995)

Irritation Skin and eye irritant based on { nitrobenzoic acid } (IUCLID 2000)

Skin Sensitizer Skin sensitizer based on { nitrobenzoic acid } (IUCLID 2000)

Reproductive Effects Moderate based on { nitrobenzoic acid } , increase in stillbirths NOAEL of 500 mg/kg-day, LOAEL of 1,100 mg/kg-day (I UCLID 2000) Developmental Effects No data identified for { PPG021 } or analogs

Immune System Effects No data identified for { PPG021 } or analogs

Neurotoxicity No data identified for{ PPG021 } or analogs

Genotoxicity Positive based on positive sister chromatid exchang e assay for { nitrobenzoic acid } (NTP 1994)

Mutagenicity Positive based on positive Ames test with and witho ut activation for { nitrobenzoic acid } (NTP 1994)

Systemic Effects Moderate based on LOAEL of 67 mg/kg

- day for { trimethylol

propane } (OECD 1995)

Overall Human Health Non-Cancer Hazard Concern Moderate

CANCER HEALTH EFFECTS:

Experimental data Low based on { nitrobenzoic acid } (NTP 1994)

OncoLogic Results Low based on Polymers SAR; now SAR for adequate eva luation of oligomeric structures
Overall Human Carcinogenicity Hazard Concern Low6 Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Manufacture Number of Sites 1

Location { PPG, Circleville, OH } Operating Days Per Year 6

INDUSTRIAL RELEASE SUMMARY:

Media Daily Release

(kg/site-day) Release Days

per Year No. of Sites

of Release Total Annual Releases

(kg/year -all sites) Release Site Information and Control Efficiency

Incineration or recycled into

process 146 2 1 292 Incineration; 99% Efficient

OCCUPATIONAL EXPOSURE SUMMARY:

Route Dose Rate Days/yr No. Workers Cancer LADD Ch ronic ADD Acute APDR

Dermal 1,060 mg/day 2 2 0.047 mg/kg-day 0.083 mg/kg-day 15 mg/kg-day

Inhalation N/A

Total number of Workers – All Sites 3

GENERAL POPULATION EXPOSURE SUMMARY:

Cancer LADDpot Chronic ADDpot Acute ADRpot Drinking Water Fish Ingestion Fugitive Emissions

Incineration Emissions 0 mg/kg

- day (VP <10 - 6 mm Hg) 0 mg/kg

- day (VP <10 - 6 mm Hg) 0 mg/kg

- day (VP <10 - 6 mm Hg) Landfill Leaching

Dermal – Consumer Use

Inhalation – Consumer Use
AQUATIC EXPOSURE SUMMARY:

Lowest Acute COC

– Aquatic Exposure N/A

– Low Hazard

Lowest Chronic COC

– Aquatic Exposure N/A

– Low Hazard Predicted Environmental Concentration (PEC) 0 ppb PEC Exceeds Chronic COC (days / year) 0

RISK ASSESSMENT CALCULATIONS: MOE – Acute Occupational Exposure N/A – Low Hazard MOE – Chronic Occupational Exposure 810 (systemic effects) MOE – Acute General Population Exposure N/A – Low Hazard MOE – Chronic General Population Exposure N/A – No Exposure Predicted7 Record ID: { PPG021 } Submitter:{ PPG Industries, Inc. }

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Processing Number of Sites 1

Location { PPG, Cleveland, OH} } Operating Days Per Year 365

INDUSTRIAL RELEASE SUMMARY:

Media Daily Release

(kg/site-day) Release Days

per Year No. of Sites

of Release Total Annual Releases

(kg/year -all sites) Release Site Information and Control Efficiency

Incineration or recycled into

process 220 1 1,168 (combined release) Incineration; 99% Efficient

OCCUPATIONAL EXPOSURE SUMMARY:

Route Dose Rate Days/yr No. Workers Cancer LADD Ch ronic ADD Acute APDR

Dermal 1,060 mg/day 229 4 5.4 mg/kg-day 9.5 mg/kg-day 15 mg/kg-day

Inhalation N/A

Total number of Workers – All Sites 7

GENERAL POPULATION EXPOSURE SUMMARY:

Cancer LADDpot Chronic ADDpot Acute ADRpot Drinking Water Fish Ingestion Fugitive Emissions

Incineration Emissions 0 mg/kg

- day (VP <10 - 6 mm Hg) 0 mg/kg

- day (VP <10 - 6 mm Hg) 0 mg/kg

- day (VP <10 - 6 mm Hg) Landfill Leaching

Dermal – Consumer Use

Inhalation – Consumer Use
AQUATIC EXPOSURE SUMMARY:

Lowest Acute COC

– Aquatic Exposure N/A

– Low Hazard

Lowest Chronic COC

– Aquatic Exposure N/A

– Low Hazard
Predicted Environmental Concentration (PEC) 0 ppb PEC Exceeds Chronic COC (days / year) 0

RISK ASSESSMENT CALCULATIONS: MOE – Acute Occupational Exposure N/A – Low Hazard MOE – Chronic Occupational Exposure 7.1 (systemic effects) MOE – Acute General Population Exposure N/A – Low Hazard MOE – Chronic General Population Exposure N/A – No Exposure Predicted8 Record ID: { PPG021 } Submitter: { PPG Industries, Inc .}

INDUSTRIAL OPERATIONS INFORMATION:

Operation Name Use Number of Sites 11

Location Multiple Operating Days Per Year 365

INDUSTRIAL RELEASE SUMMARY:

Media Daily Release

(kg/site-day) Release Days

per Year No. of Sites

of Release Total Annual Releases

(kg/year -all sites) Release Site Information and Control Efficiency

Air 0.13 250 11 350 N/A – VP <10 -6 mm Hg

Water (combined) 0.51 250 11 1,400 { Motor Vehicle } SIC Code; 50% Removal Efficiency

Landfill 2.8 250 11 7,600 RCRA Landfill; Negligible Migration Potential

OCCUPATIONAL EXPOSURE SUMMARY:

Route Dose Rate Days/yr No. Workers Cancer LADD Ch ronic ADD Acute APDR

Dermal 138 mg/day 250 187 0.78 mg/kg-day 1.4 mg/kg-day 2.0 mg/kg-day

Inhalation 1.47 250 187 0.0082 mg/kg-day 0.014 mg/kg-day 0.021 mg/kg-day

Total number of Workers – All Sites 231

GENERAL POPULATION EXPOSURE SUMMARY:

Cancer LADDpot Chronic ADDpot Acute ADRpot Drinking Water 9.8 x 10 - 5 mg/kg-day 1.8 x 10

- 4 mg/kg-day 2.5 x 10

- 3 mg/kg-day Fish Ingestion 4.2 x 10 - 6 mg/kg-day 7.9 x 10

- 6 mg/kg-day 3.3 x 10

- 4 mg/kg-day

Fugitive Emissions 0 mg/kg

- day (VP <10 - 6 mm Hg) 0 mg/kg

- day (VP <10 - 6 mm Hg) 0 mg/kg

- day (VP <10 - 6 mm Hg)

Incineration Emissions

Landfill Leaching 0 mg/kg

- day (negligible migratory potential) 0 mg/kg

- day (negligible migratory potential) 0 mg/kg

- day (negligible migratory potential)

Dermal – Consumer Use

Inhalation – Consumer Use
AQUATIC EXPOSURE SUMMARY:

Lowest Acute COC

– Aquatic Exposure N/A

– Low Hazard
Lowest Chronic COC

– Aquatic Exposure N/A

– Low Hazard Predicted Environmental Concentration (PEC) PEC Exceeds Chronic COC (days / year) 0

RISK ASSESSMENT CALCULATIONS: MOE – Acute Occupational Exposure N/A – Low Hazard MOE – Chronic Occupational Exposure 48 (systemic effects) MOE – Acute General Population Exposure N/A – Low Hazard MOE – Chronic General Population Exposure 350,000 (systemic effects)Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

9 SUMMARY CONCLUSIONS:

Occupational Risk: Risk of Non-Cancer Acute Effects from Occupational Exposure: Low based on low hazard Risk of Non-Cancer Chronic Effects from Occupationa l Exposure: The potential for risk exists based on calculated

MOEs
Risk of Cancer Effects from Occupational Exposure: Low based on low hazard

General Population Risk: Risk of Non-Cancer Acute Effects to General Populat ion: Low based on low hazard Risk of Non-Cancer Chronic Effects to General Popul ation: Low based on calculated MOEs Risk of Cancer Effects to General Population: Low based on low hazard

Aquatic Risk: Acute Risk to the Aquatic Environment: Low based on low hazard Chronic Risk to the Aquatic Environment: Low based on low hazard

Notes on Polymer Size and Assessment Strategy

{ PPG021 }is a polymer with a Mn of >1,000; however, there are significant amounts of low molecular weight (LM W) oligomers in the polymeric mixture. GPC analysis o f the polymer shows two major peaks, one for the po lymer and one believed to arise from residual monomer. The p olymeric peak shows 36% of material with MW of <1,0 00 and
15% of material with MW of <500. This amount of LM W materials is significant and will be taken into a ccount in the

P2 Assessment.

Representative structures based on these LMW oligom ers will be evaluated with EPI Suite and ECOSAR, an d these predictions taken into account for assigning the pe rsistence, bioaccumulation potential, and ecotoxici ty hazard concerns for the substance. In addition, smaller o ligomers and monomers will be taken into account fo r the human health hazard assessment portion as well. The indi vidual assessment methodology will be discussed in each relevant

section.

Physical/Chemical Properties

No measured physical property data were available f or { PPG021 } and predictive methods were used to evaluate the substance. As noted above, { PPG021 } may contain significant amounts of LMW components ; however, the physical property evaluation will focus on the mixture as a whole. { PPG021 } is predicted to be a solid at room temperature. The substance is expected to have a high boiling po int, estimated at >400 °C at 760 mm Hg, with decomp osition possibly occurring prior to boiling. The chemical is expected to have very low vapor pressure, due to both size and ionic nature, estimated at <10 -8 mm Hg. The substance is not expected to be solubl e in water, with water solubility estimated at <10 mg/L. { PPG021 } is a polymeric substance and will contain a mixtu re of many different structures. The substance contains monomers that are expected t o be hydrophobic and monomers that will tend to be hydrophilic; further, the substance is not expected to be highly soluble in either water or octanol. Due to these factors, the log Kow was not predicted for the poly meric substance.Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

10 Bioconcentration Factor

{ PPG021 } is a polymer with Mn of >1,000 and significant LM W component content. The high MW portions are expected to be non-bioavailable and have a low conc ern for bioaccumulation or bioconcentration (PGD 20 10). EPI Suite was used to evaluate several smaller, oligome ric structures that may be present on { PPG021 }, with MWs of 489 Daltons, 608 Daltons, 757 Daltons, and 852 Daltons, for BCF. These oligomers showed a low concern lev el as well. Overall, { PPG021 } is predicted to have a low BCF concern. E-FAST r equires a numeric BCF for the purpose of calculations and a BCF of 10, which is consistent w ith a low concern, was used.

Environmental Fate

{ PPG021 } is a polymer with Mn of >1,000; however there is significant amounts of LMW material with MW of <1,0 00. The environmental fate assessment of { PPG021 } will focus on the polymer itself, rather than low er molecular materials, as this will likely pose the worst case scenario.

Based on the size and structure of { PPG021 }, 50 - 90% of the polymer is predicted to be remov ed during waste water treatment at a POTW; 50% removal will be used for m odeling purposes as necessary (PGD 2010). Removal will occur primarily through physical processes, such as sludg e adsorption. { PPG021 } is expected to exist solely as a particulate in the atmosphere (air) and settling of the chemica l to surfaces may occur. The chemical is expected to bind strongly to soil and sediments and have negligible potential to migrate to groundwater. { PPG021 } is not expected to volatilize from water or moist soil at an appreciable rate, wi th an estimated half-life for volatilization from t he model lake or river of >1 year. Based on the above consideration s, { PPG021 } is expected to partition mainly to soil and sedim ent in
the environment.

{ PPG021 } is predicted to partition mainly to soil and sedi ment in the environment and degradation in these me dia will be most relevant to the overall persistence of the chemical. { PPG021 } contains { carboxylic acid } and { phosphate
ester groups } within the polymer. Ester moieties are susceptib le to hydrolysis; however, due to poor solubility a nd the general stability of ester groups at an environ mentally relevant pH, hydrolysis is not expected to be a significant route of environmental degradation for these groups . { PPG021 } will not partition to the atmosphere to a signifi cant extent and atmospheric oxidation is not expected to be a major route of degradation. Due to partition ing and stability, the main route of environmental removal of the chemical is expected to be biodegradation. { PPG021 } is a polymer with Mn of >1,000, the substance is predict ed to bind very strongly to soil and sediment, and partition significantly to those media. These factors indica te that the chemical is likely to biodegrade slowly , with a half-life for biodegradation of >180 days; this is consistent wit h a high concern level for persistence.

Overall, { PPG021 } is expected to partition mainly to soil and sedim ent, where it will have a high concern for persistence.Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

11 Aquatic Hazard

No measured data were available for { PPG021 } or close structural analogs and predictive method s were used to establish the ecotoxicity hazard concerns for the s ubstance. { PPG021 } is a polymer with Mn of >1,000. There is also the potential for significant low molecular weight (LMW) material present in the polymeric mixture; GP C analysis shows 36% of material with MW of <1,000 and 15% of material with MW of <500. Evaluation of the ecotox icity hazard concerns will include both the polymer itsel f, as well as considerations for LMW material. The { PPG021 } polymer contains anionic groups, both as possible u nreacted { carboxylic acid moieties } on the polymer chain and { phosphoric acid groups } pendant to the chain. Repeating anionic groups c an be associated with ecotoxicity hazard concerns; however, based on the configuration of th ese groups, the anionic nature of { PPG021 } is not expected to contribute to ecotoxicity (PGD 2011; Boethling et al . 1997). Overall, based on the polymeric structure of { PPG021 } the polymer itself is expected to have an overall e cotoxicity hazard concern level of low (PGD 2011; B oethling et al

. 1997). The polymer contains significant LMW compon ents, which were also evaluated with for ecotoxicit y concern. A review of potential oligomeric structures by ECOS AR was undertaken. Four structures were evaluated with the software corresponding to a MW of 489 Daltons, 608 Daltons, 757 Daltons, and 852 Daltons. In each cas e, all of the predicted effects levels for each species for acute and chronic effects were more than 10 x greater th an the water solubility. This is consistent with a prediction o f no effects at saturation (NES) for these oligomer ic structures and a low ecotoxicity hazard for the LMW components. The evaluations of the polymeric substance, as well as the LMW components, are suggestive of a low ecotoxicity haz ard concern level for { PPG021 }.

Overall, based on evaluation of the polymer and pot ential oligomeric structure, { PPG021 } is predicted to have an aquatic toxicity hazard concern level of low.

Human Health Non-Cancer Hazard

No test data were identified for { PPG021 } itself or structurally similar analogs, and in th e absence of an adequate analog, the human health hazard will be based parti ally on review of data available for the monomers. This is considered an adequate assessment strategy because there may be significant levels of unreacted monome r in the polymeric mixture. In addition, there are signific ant amounts of low molecular weight materials in th e { PPG021 } polymer, including material with MW of <1,000 and < 500. This LMW material may be subject to metabolis m that could release monomers; in particular cleavage of e ster bonds could release individual monomers from s maller bioavailable oligomers. However, it should be note d that this approach may overstate the toxicity of both the parent compound and, to a lesser extent, the low molecular weight polymers.

The particular monomers on which this assessment is based will primarily include { nitrobenzoic acid (CAS RN 62-23- 7) } and { trimethylol propane (CAS RN 77-99-6) }.

{ Nitrobenzoic acid } has limited acute toxicity, with an LD 50 of 1,960 mg/kg in rats via oral dose (IUCLID 2000)

. { Trimethylol propane } has an LD 50 of 14,100 mg/kg in rats and 13,700 mg/kg in mice ( OECD 1995) via oral dosing. The
inhalation LD 50 is greater than the highest dose tested, 0.85 mg/ L/4 h in rats, and the dermal LD 50 was greater than 500 mg/kg. Based on this, { PPG021 } is expected to have low concern for acute toxicit y.

{ Trimethylol propane } tested negative both as a skin irritant and skin sensitizer (OECD 1995). { Nitrobenzoic acid } was slightly irritating in a Draize test and moderately irritating in a skin sensitization test in Guinea pigs (IUCLID 2000). Based on this, { PPG021 } has moderate concern as skin and eye irritant.Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

12 Human Health Non-Cancer Hazard (continued)

In reproductive toxicology assays, { trimethylol propane } showed no toxicity in rats at the highest dose te sted, 800 mg/kg-days (OECD 1995). In a two generation study i n mice, { nitrobenzoic acid } caused a dose-related suppression of weight gain, and a reduction in offspring survival at a dose of .75 % of the diet (IUCLID 2000). Base d on the toxicity of { nitrobenzoic acid }, { PPG021 } has a moderate concern as a reproductive toxicant

.

{ Trimethylol propane } has shown no systemic toxicity in a 5-month, repe ated dose toxicity study at doses up to 3000 mg/kg-day in rats. A 90-day study in rats showed a reduction in liver weight and increase in cell frag mentation at 667 mg/kg-day. At 67 mg/kg-day, there was decreased act ivity of SGPT and of serum alkaline phosphatase onl y in males; based on this endpoint, the LOAEL was estimated as 67 mg/k-day. (OECD 1995)

A two-year daily dose study of { nitrobenzoic acid } in mice showed no increase in mortality and no or gan specific toxicity at doses up to 675 mg/kg-day for males and 975 mg/kg-day for females. There was a treatment related reduction in weight gain for males at the highest d ose at 17 weeks, but weights of all treated males m atched controls by the end of the study. Females at the highest tes ted dose had a reduction in weight at the conclusio n of the study. A two-year chronic study in rats with doses up to 2 10 mg/kg-day (males) and 250 mg/kg-day (females) fo und no increase in mortality, but a significant decrease i n body weight for males at the highest dose tested and females beginning with a dose of 100 mg/kg-day. At the 15-m onth evaluation, female rats in the highest tested dose showed clinically significant changes in hematology parame ters consistent with observations at higher dose te sting in subchronic studies. (NTP 1994). Based on the limite d systemic toxicity for { nitrobenzoic acid } and { trimethylol

propane }, { PPG021 } has a moderate concern for systemic toxicity.

There is no immunotoxicity or neurotoxicity data fo r { nitrobenzoic acid } or { trimethylol propane }.

{ Trimethylol propane } has consistently tested negative as a mutagen (OE CD 1995). { Nitrobenzoic acid }, on the other hand, has tested positive on an Ames test with and without activation, and positive in a sister chroma tid exchange assay in CHO cells, but negative when tested via an in vivo mammalian bone marrow cytogenetic assay at an oral dose of up to 5000 mg/kg-day. (NTP 1994). Based on this, { PPG021 } has a moderate concern as a mutagenicity and genotoxic effects.

Overall, based on evaluation of the selected monome rs, { PPG021 } is predicted to have an overall human health noncancer hazard concern level of moderate.

Human Health Cancer Hazard

No data on the carcinogenicity of { PPG021 } were available. The cancer hazard has been evalua ted using OncoLogic
and review of data on the monomers discussed above. OncoLogic was used to evaluate { PPG021 } as a polymer, based on the polymers SAR and data available for th e substance. This resulted in a predicted cancer h azard concern level of low. Due to the presence of low molecular weight material and residual monomers, it was also suggested that these be evaluated with OncoLogic; however, th ere was a not a specific SAR that was able to adequ ately
describe and evaluate the LMW materials and the eva luations of these are based on the monomers.

Although { nitrobenzoic acid } has a positive Ames test, it appears to be only w eakly carcinogenic in vivo . A two-year study in mice at doses up to 675 mg/kg-day (males) and 950 mg/kg-day (females) found no increase in ca ncer. A twoyear study in rats found no cancer in males and onl y a slight increase in clitoral adenomas in the hig hest dose group (250 mg/kg-day) compared to historical controls. (N TP 1994) Based on this, the TD 50 has been estimated as 287 mg/kg-day. (CPD 2011).Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

13 Human Health Cancer Hazard (continued)

{ Trimethylol propane } has been tested for mutagenicity in a wide variet y of in vitro assays, and the results have been consistently negative. { Trimethylol propane } has not been tested in vivo for carcinogenicity, however, it is not a mutagen, does not cause inflammation, and there is no evidence it could act as a growth factor. (OECD 1995) Therefore, based on this, it is unlikely to cause c ancer.

As { nitrobenzoic acid } may be weakly carcinogenic, the carcinogenic pote ntial for { PPG021 } cannot be ruled out. However, as { nitrobenzoic acid } is not expected to be present in the mixture at h igh concentration and is not likely a product of metabolism, use of this substance for pr ediction of { PPG021 } may overstate the toxicity of the parent compound, and the potential for { PPG021 } to cause cancer is likely very small.

Overall, based on evaluation of the polymer and pot ential residual monomers, { PPG021 } is predicted to have a low
cancer hazard concern level.

Release and Exposure Sources

There are three operations associated with { PPG021 } that are the subject of the PMN and this assessme nt; Manufacture, Processing, and Use in { Automobile } Coatings. { PPG021 } will be in a liquid formulation or suspension form during all activities that require handling of the chemical. The vapor pressure is below the lev el (10 -3 mm Hg) where exposure of workers to vapors at room tempera ture is a concern; exposure to particulate matter a nd/or mists is predicted for the { PPG021 } during the Use operation modeled for the substanc e.

{ PPG021 } has been predicted to have 50% removal via POTW, BCF of 10, and negligible potential for groundwater migration from landfills. The vapor pressure is be low the level for which EPA generally has concerns for general population exposure (10 -6 mm Hg) from fugitive emissions or incinerator blow by and no downstream general population exposure has been predicted for fugitive or incineration emissions. Finally, { PPG021 } is predicted to have a negligible potential to migrate to groundwater an d, while disposal of solid materials from the Use o peration to landfill will occur, no general population exposure is predicted for this disposal route.

{ PPG021 } is manufactured as a 61% liquid in solvent and pa ckaged into drums and 5 gallon pails for transport and storage (manufacture). The substance is then blend ed with other components of the coating mixture to a total volume of 0.16% by weight and packaged into 400 gal lon totes and drums for transport and storage for u se (processing). Use occurs at 11 customer sites iden tified in the PMN in coatings for { automobiles }(use).

{ PPG Industries, Inc. } maintains “zero discharge” facilities at the site s at which { PPG021 } will be manufactured and processed. At these sites all cleaning residuals a re recycled into the process, landfilled, or incine rated. In the case of { PPG021 }, all rinsate from cleaning activities is collecte d and incinerated. Filter media is also incinerate d and any ash is disposed of in a RCRA approved landfill. Based on these considerations, no releases to surface wat er from manufacture or processing have been estimated for m anufacture or processing of { PPG021 }.Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

14 Release and Exposure Sources (continued)

The Use operation will occur at 11 identified singl e customer sites not controlled by { PPG. }. It should be noted that, once incorporated into the coatings, { PPG021 } will be covalently bonded in the polymer matrix a nd no longer available for release and exposure. The ChemSTEER { Automobile OEM } Spray Coating operation was selected for modeling the use of { PPG021 }. Transfer efficiency for the coating process has been estimated to be 70% and was changed for modeling purposes. Potential releases for the substance have been predicted to also occur from the cleaning of empty drums and 400 gallon totes used t o transport and store { PPG021 }. Releases to water were modeled using the {“Motor Vehicle } Manufacture” SIC Code available in E-FAST.

Unless otherwise noted, standard ChemSTEER default release or exposure assumptions have been used. Fo r surface water releases, 50% POTW removal, and BCF of 10 wer e used for E-FAST modeling. No general population exposure from landfill leaching, fugitive emissions, or inci neration emissions has been estimated due to the gr oundwater migratory potential and vapor pressure predictions for { PPG021 }.

Predicted releases, occupational, general populatio n, and aquatic environmental exposure from operatio ns modeled for { PPG021 } are listed on the pages above.

Environmental (Aquatic) Risk Assessment

Assessment of aquatic risk is based on comparison o f the concentration of the chemical in the environm ent, referred to as the predicted environmental concentration (PE C), to any acute and/or chronic concentrations of c oncern (COCs) established for the chemical. Acute risk potential is determined by direct comparison of the PEC to a n acute COC, with the potential for risk being indicated if the PEC is larger than the acute COC. Chronic risk is determined both by comparison of the PEC to the chronic COC, similar t o the acute risk assessment, and by E-FAST estimati on of the number of days the PEC will exceed the chronic COC, with risk potential indicated if the PEC exceeds t he chronic COC for 20 days or more.

Risk is a function of hazard and exposure; if the h azard concern level is low, than the risk will gene rally also be low. In the case of { PPG021 }, the chemical is estimated to pose a low ecotoxic ity hazard based evaluation of the polymer and LMW oligomers. Based on this, the risk is also pre dicted to be low.

Overall, based on low hazard, { PPG021 } is expected to pose a low potential for risk to t he aquatic environment.Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

15 Human Health Risk Assessment

Human health risk potential is established by compa rison of the potential health effect levels to the occupational and general population dose rates estimated for the che mical. The health effect is divided by the largest dose rate for either occupational or general population exposure to give a margin of exposure (MOE). Acute risk is only evaluated
if the acute LD 50 is found to be <50 mg/kg. Chronic risk is evaluat ed for each effect level identified in the human health hazard assessment that has a moderate or gre ater hazard concern. The magnitude of the MOE dete rmines if the potential for risk exists; when based on a LOAE L (lowest observed adverse effect level) a MOE of < 1,000 indicates the potential for human health risk exists, and whe n based on a NOAEL (no observed adverse effect leve l) a MOE of <100 indicates the potential for risk exists.

{ PPG021 } has been predicted to have a low hazard concern f or acute effects to human health and cancer hazard concern. In general, a chemical with a low hazard concern level is also considered to have a low pote ntial for risk. Based on this, the acute human health and cancer ri sk potential for { PPG021 } has been predicted to be low.

The overall chronic non-cancer human health hazard for { PPG021 } has been estimated to be moderate, based on a LOAEL of 67 mg/kg-day for systemic effects and NOAE L of 500 mg/kg-day for reproductive effects. These values were evaluated, with the occupational and general popula tion exposure levels predicted for the substance, f or overall risk

concern.

For the { PPG021 } occupational risk assessment, there are potential dermal exposures estimated for the substance for each operation modeled. In addition, the use opera tion also has potential inhalation exposure. For s ystemic effects, the MOE calculated for each of the operations is <1 ,000, which indicates that the potential for risk t o workers exposed to { PPG021 } exists for all thee modeled operations. It shoul d be noted that the MOE established just for occupational inhalation risk associated with the us e operation would be >1,000 indicating a low potent ial for risk for that exposure route alone. The MOE established for developmental effect is >100 for manufacture and u se, indicating a low potential for risk for those opera tions, regardless of exposure route. However, the MOE is <100 for the processing operation (dermal exposure only), in dicting the potential for risk for that operation. In general, { PPG021 } may have the potential for risk to workers expose d dermally.

For the { PPG021 } general population risk assessment, there is pote ntial general population exposure from the use operation only. For the manufacture and processing operations, no general population exposure is pred icted and this would lead to a low potential for risk for the se operations. The use operation does have potenti al exposure from releases to surface water; the MOE calculated for t his exposure is 350,000, which is indicative of a l ow potential for risk. { PPG021 } is predicted to pose a low risk to the general po pulation from the modeled operations.

Overall, based on the MOEs calculated in the genera l population and occupational risk assessments of { PPG021 }, the potential for occupational dermal risk exists.Record ID: { PPG021 } Submitter: { PPG Industries, Inc. }

16 Table I - Selected Analogs

Analog Structure Concern
Identified Basis of Concern Concern Level

Nitrobenzoic

acid (CAS RN 62- 23-7) (IUCLID 2000) 1) Acute toxicity 2) Skin and eye

irritant 3) Sensitization 4) Reproductive toxicity 5) Genotoxicity 6) Mutagenicity 7) Systemic Toxicity 8) Carcinogenicity 1) Oral LD 50 of 1960 mg/kg in rats

2) Positive Draize test, skin irritant
to rabbits 3) Skin sensitizer to rabbits 4) LOAEL of .75 mg/kg-day in mice 5) Positive sister chromatid exchange assay 6) Positive Ames test 7) LOAEL of 100 mg/kg-day in mice 8) Slight increase in clitoraladenomas in rats at 250 mg/kgday 1) Low 2) Irritant 3) Skin

sensitizer 4) Moderate 5) Genotoxic 6) Mutagenic 7) Low 8) Low

T rimethylol propane (CAS RN 77-99-6) (OECD 1995) 1) Acute toxicity 2) Skin and eye

irritant 3) Skin sensitizer 4) Reproductive toxicity 5) Mutagenicity 6) Systemic toxicity 1) Oral LD 50 of 13700 mg/kg in

mice 2) Negative skin and eye irritant
test in rabbits 3) Negative skin sensitization in
rabbits 4) NOAEL > 800 mg/kg-days 5) Negative Ames test, negative bacterial reversion assays 6) LOAEL of 67 mg/kg-days in rats due to elevated liver enzymes 1) Low 2) Not a skin and eye

irritant 3) Not a skin

sensitizer 4) Low 5) Not a
mutagen 6) Moderate

References

(PGD 2010) Interpretive Guidance Document for Susta inable Futures Assessment of Polymers, an EPA Susta inable Futures/P2 Guidance Document, revised 2010. Availa ble online at: http://www.epa.gov/oppt/sf/

.

(Boethling et al . 1997) Boethling, Robert S. and Nabholz, J. Vince nt “Environmental Assessment of Polymers under the U.S. Toxic Substances Control Act”, { pp. 187-234 }, in Ecological Assessment of Polymers Strategies for Product Stewardship and Regulatory Programs , Hamilton, John D. and Sutcliffe, Roger (eds.), (1 997) Van Nostrand Reinhold.

(CPD 2007) Cancer Potency Database.{ http://potency.berkeley.edu/chempages/p-NITROBENZOI C%20ACID.html }

(IUCLID 2000) IUCLID Dataset for Substance ID { 62-23-7 }, European Commission – European Chemicals Bureau, 02/18/2000. { http://ecb.jrc.ec.europa.eu/iuclid-datasheet/62237. pdf }

(OECD 1995) OECD – SIDS Report on { Trimethylpropane }. UNEP Publications, 1995. { http://www.chem.unep.ch/irptc/sids/OECDSIDS/77996.p df }

(NTP 1994) National Toxicology Publication { TR-442, NIH Publication No. 95-3358. http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr442.p df }17Appendix 1: Determination of Human Health Risk fromOccupational ExposureChemical Identifier: {PPG021}CAS Number:N/AExposure Activity 1:ManufactureSite Information: {PPG Circleville, OH}Endpoint(Concern Effect)NOAEL(mg/kg-d)LOAEL(mg/kg-d)Exposure Dose andSource(mg/kg-d)MOE*Potential for Risk?OccupationalExposureSystemic Effects 67 mg/kg-day0.083 mg/kg-day(dermal ADD)810 YesReproductive Effects 500 mg/kg-day0.083 mg/kg-day(dermal ADD)6,000 LowExposure Activity 2:ProcessingSite Information: {PPG Cleveland, OH}Endpoint(Concern Effect)NOAEL(mg/kg-d)LOAEL(mg/kg-d)Exposure Dose andSource(mg/kg-d)MOE*Potential for Risk?OccupationalExposureSystemic Effects67 mg/kg-day9.5 mg/kg-day(dermal ADD)7.1 YesReproductive Effects 500 mg/kg-day9.5 mg/kg-day(dermal ADD)52 YesExposure Activity 2:UseSite Information: {Motor Vehicle} Manufacture SIC CodeEndpoint(Concern Effect)NOAEL(mg/kg-d)LOAEL(mg/kg-d)Exposure Dose andSource(mg/kg-d)MOE*Potential for Risk?OccupationalExposureSystemic Effects67 mg/kg-day1.4 mg/kg-day(combined dermaland inhalation ADD)48 YesReproductive Effects 500 mg/kg-day1.4 mg/kg-day(combined dermaland inhalation ADD)360 Low*MOE < 100 indicates potential for risk when usinga NOAEL value; MOE < 1000 indicates potential for risk when using a LOAEL value.18Appendix 2: Determination of Human Health Risk to the General PopulationChemical Identifier: {PPG021}CAS Number:N/AExposure Activity 1:ManufactureSite Information: {PPG Circleville, OH}No general population exposure predicted for this operationExposure Activity 2:ProcessingSite Information: {PPG Cleveland, OH}No general population exposure predicted for this operationExposure Activity 2:UseSite Information: {Motor Vehicle} Manufacture SIC CodeEndpoint(Concern Effect)NOAEL(mg/kg-d)LOAEL(mg/kg-d)Exposure Dose andSource(mg/kg-d)MOE*Potential forRisk?GeneralPopulationExposureSystemic Effects 67 mg/kg-day1.9x 10-4mg/kg-day(combined ADD)350,000 LowReproductive Effects500 mg/kg-day1.9x 10-4mg/kg-day(combined ADD)2,600,000 Low*MOE < 100 indicates potential for risk when usinga NOAEL value; MOE < 1000 indicates potential for risk when using a LOAEL value.