Attachment 11 – Sustainable Futures P2 Assessment for {PPG021}

This chemical is the subject of a P2 Assessment for participation in the Sustainable Futurestm Initiative. 

The P2 assessment of {1 Hexanedioic acid, polymer with 2-ethyl-2-(hydroxymethyl)-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 assessment 

of the chemical. 

{PPG021} is predicted to have a high overall concern for persistence, with an environmental half-life of 

>180 days. 

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

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

{PPG021} is predicted to have low hazard concerns for acute human health effects, as well as cancer 

hazard concerns. {PPG021} is predicted to have a moderate overall human health non-cancer chronic 

hazard concern level, based on systemic and reproductive effects. It should be noted that {PPG021} is 

also predicted to have the potential to cause irritation 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 hazard, there is a low 

potential for risk. 

The conclusions of the {PPG021} human health risk assessment is that there is a low potential for acute 

or cancer hazard risk, as well as chronic risk to the general population from exposure to the substance. 

However, based on the potential human health chronic hazard concerns identified for the {PPG021} and 

possible occupational dermal exposure modeled for the substance, the potential for occupational 

dermal risk exists. There is potential for inhalation 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 not take PPE and other exposure controls into account 

for this risk assessment. The {PPG} MSDS, which is included with this substance, indicates that workers 

should wear gloves and use other personal protective measures when handling {PPG021} or when 

exposure may occur. Further, the use of this substance involves robotic spraying and other exposure 

controls, which is likely to significantly reduce potential 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 of gloves and appropriate exposure controls, 

{PPG021} will not pose an unreasonable risk to human health or the environment.
Sustainable Futures 

Summary Assessment 

Using 

P2 Framework Models

Chemical Assessed: 

{Hexanedioic acid, polymer with 2-ethyl-2-(hydroxymethyl)-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 estimation 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 asked 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 Profiler? 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: Low 

 
4 

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 (professional 

judgment)

Water Solubility <10 mg/L (professional judgment)

Log Kow Not evaluated 

ENVIRONMENTAL TRANSPORT AND FATE: 

Transport 

Henry’s Law Constant – HLC (atm-m3/mol) <10-8 (professional judgment)

Soil Adsorption Coefficient – Log Koc 

Strong 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 judgment)

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 

Metabolites 

 
5 

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

ECOTOXICITY: 

ECOSAR Class ECOSAR 

Acute Toxicity 

Fish LC5O NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Daphnid LC5O NES for Oligomers or Polymer (ECOSAR; PGD 2010)

Green Algae EC5O 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)}, LD50 of 

1960 mg/kg in rats (IUCLID 2000) or {trimethylol propane (CAS 

RN 77-99-6)},LD50 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 (IUCLID 

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 exchange assay for 

{nitrobenzoic acid} (NTP 1994) 

Mutagenicity Positive based on positive Ames test with and without 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 evaluation 

of oligomeric structures 

Overall Human Carcinogenicity Hazard Concern Low

 
6 

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 Chronic 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 Predicted

 
7 

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 Chronic 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 Predicted
8 

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 Chronic 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 Occupational 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 Population: Low based on low hazard

Risk of Non-Cancer Chronic Effects to General Population: 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 (LMW) 

oligomers in the polymeric mixture. GPC analysis of the polymer shows two major peaks, one for the polymer and 

one believed to arise from residual monomer. The polymeric peak shows 36% of material with MW of <1,000 and 

15% of material with MW of <500. This amount of LMW materials is significant and will be taken into account in the 

P2 Assessment. 

Representative structures based on these LMW oligomers will be evaluated with EPI Suite and ECOSAR, and these 

predictions taken into account for assigning the persistence, bioaccumulation potential, and ecotoxicity hazard 

concerns for the substance. In addition, smaller oligomers and monomers will be taken into account for the human 

health hazard assessment portion as well. The individual assessment methodology will be discussed in each relevant 

section. 

Physical/Chemical Properties

No measured physical property data were available for {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 point, estimated at >400 °C at 760 mm Hg, with decomposition 

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 soluble in water, with water solubility 

estimated at <10 mg/L. {PPG021} is a polymeric substance and will contain a mixture of many different structures. 

The substance contains monomers that are expected to 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 polymeric substance. 
Record ID: {PPG021} Submitter: {PPG Industries, Inc.} 

10 

Bioconcentration Factor

{PPG021} is a polymer with Mn of >1,000 and significant LMW component content. The high MW portions are 

expected to be non-bioavailable and have a low concern for bioaccumulation or bioconcentration (PGD 2010). EPI 

Suite was used to evaluate several smaller, oligomeric 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 level as well. 

Overall, {PPG021} is predicted to have a low BCF concern. E-FAST requires a numeric BCF for the purpose of 

calculations and a BCF of 10, which is consistent with 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 <1,000. 

The environmental fate assessment of {PPG021} will focus on the polymer itself, rather than lower 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 removed during waste water 

treatment at a POTW; 50% removal will be used for modeling purposes as necessary (PGD 2010). Removal will occur 

primarily through physical processes, such as sludge adsorption. {PPG021} is expected to exist solely as a particulate 

in the atmosphere (air) and settling of the chemical 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, with an estimated half-life for volatilization from the model lake or 

river of >1 year. Based on the above considerations, {PPG021} is expected to partition mainly to soil and sediment in 

the environment.

{PPG021} is predicted to partition mainly to soil and sediment in the environment and degradation in these media 

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 susceptible to hydrolysis; however, due to poor solubility and 

the general stability of ester groups at an environmentally 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 significant 

extent and atmospheric oxidation is not expected to be a major route of degradation. Due to partitioning 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 predicted to bind very strongly to soil and sediment, and partition 

significantly to those media. These factors indicate that the chemical is likely to biodegrade slowly, with a half-life for 

biodegradation of >180 days; this is consistent with a high concern level for persistence. 

Overall, {PPG021} is expected to partition mainly to soil and sediment, 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 methods were used to 

establish the ecotoxicity hazard concerns for the substance. {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; GPC analysis 

shows 36% of material with MW of <1,000 and 15% of material with MW of <500. Evaluation of the ecotoxicity 

hazard concerns will include both the polymer itself, as well as considerations for LMW material. The {PPG021} 

polymer contains anionic groups, both as possible unreacted {carboxylic acid moieties} on the polymer chain and 

{phosphoric acid groups} pendant to the chain. Repeating anionic groups can be associated with ecotoxicity hazard 

concerns; however, based on the configuration of these 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 ecotoxicity hazard concern level of low (PGD 2011; Boethling et al. 

1997). The polymer contains significant LMW components, which were also evaluated with for ecotoxicity concern. 

A review of potential oligomeric structures by ECOSAR 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 case, all of the 

predicted effects levels for each species for acute and chronic effects were more than 10 x greater than the water 

solubility. This is consistent with a prediction of no effects at saturation (NES) for these oligomeric 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 hazard concern level for {PPG021}. 

Overall, based on evaluation of the polymer and potential 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 the absence of an adequate 

analog, the human health hazard will be based partially on review of data available for the monomers. This is 

considered an adequate assessment strategy because there may be significant levels of unreacted monomer in the 

polymeric mixture. In addition, there are significant amounts of low molecular weight materials in the {PPG021} 

polymer, including material with MW of <1,000 and <500. This LMW material may be subject to metabolism that 

could release monomers; in particular cleavage of ester bonds could release individual monomers from smaller 

bioavailable oligomers. However, it should be noted 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 LD50 of 1,960 mg/kg in rats via oral dose (IUCLID 2000). 

{Trimethylol propane} has an LD50 of 14,100 mg/kg in rats and 13,700 mg/kg in mice (OECD 1995) via oral dosing. The 

inhalation LD50 is greater than the highest dose tested, 0.85 mg/L/4 h in rats, and the dermal LD50 was greater than 

500 mg/kg. Based on this, {PPG021} is expected to have low concern for acute toxicity. 

{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 tested, 800 

mg/kg-days (OECD 1995). In a two generation study in 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). Based 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, repeated 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 fragmentation at 667 

mg/kg-day. At 67 mg/kg-day, there was decreased activity of SGPT and of serum alkaline phosphatase only 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 organ 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 dose at 17 weeks, but weights of all treated males matched controls 

by the end of the study. Females at the highest tested dose had a reduction in weight at the conclusion of the study. 

A two-year chronic study in rats with doses up to 210 mg/kg-day (males) and 250 mg/kg-day (females) found no 

increase in mortality, but a significant decrease in body weight for males at the highest dose tested and females 

beginning with a dose of 100 mg/kg-day. At the 15-month evaluation, female rats in the highest tested dose showed 

clinically significant changes in hematology parameters consistent with observations at higher dose testing in 

subchronic studies. (NTP 1994). Based on the limited systemic toxicity for {nitrobenzoic acid} and {trimethylol 

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

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

{Trimethylol propane} has consistently tested negative as a mutagen (OECD 1995). {Nitrobenzoic acid}, on the other 

hand, has tested positive on an Ames test with and without activation, and positive in a sister chromatid 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 monomers, {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 evaluated 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 the substance. This resulted in a predicted cancer hazard 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, there was a not a specific SAR that was able to adequately 

describe and evaluate the LMW materials and the evaluations of these are based on the monomers. 

Although {nitrobenzoic acid} has a positive Ames test, it appears to be only weakly 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 cancer. A twoyear study in rats found no cancer in males and only a slight increase in clitoral adenomas in the highest dose group 

(250 mg/kg-day) compared to historical controls. (NTP 1994) Based on this, the TD50 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 variety 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 cancer. 

As {nitrobenzoic acid} may be weakly carcinogenic, the carcinogenic potential for {PPG021} cannot be ruled out. 

However, as {nitrobenzoic acid} is not expected to be present in the mixture at high concentration and is not likely a 

product of metabolism, use of this substance for prediction 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 potential 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 assessment; 

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 level (10-3 mm Hg) 

where exposure of workers to vapors at room temperature is a concern; exposure to particulate matter and/or mists 

is predicted for the {PPG021} during the Use operation modeled for the substance. 

{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 below 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 and, while disposal of solid materials from the Use operation to 

landfill will occur, no general population exposure is predicted for this disposal route. 

{PPG021} is manufactured as a 61% liquid in solvent and packaged into drums and 5 gallon pails for transport and 

storage (manufacture). The substance is then blended with other components of the coating mixture to a total 

volume of 0.16% by weight and packaged into 400 gallon totes and drums for transport and storage for use 

(processing). Use occurs at 11 customer sites identified in the PMN in coatings for {automobiles }(use). 

{PPG Industries, Inc.} maintains “zero discharge” facilities at the sites at which {PPG021} will be manufactured and 

processed. At these sites all cleaning residuals are recycled into the process, landfilled, or incinerated. In the case of 

{PPG021}, all rinsate from cleaning activities is collected and incinerated. Filter media is also incinerated and any ash 

is disposed of in a RCRA approved landfill. Based on these considerations, no releases to surface water from 

manufacture or processing have been estimated for manufacture 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 single 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 and 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 to 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. For surface 

water releases, 50% POTW removal, and BCF of 10 were used for E-FAST modeling. No general population exposure 

from landfill leaching, fugitive emissions, or incineration emissions has been estimated due to the groundwater 

migratory potential and vapor pressure predictions for {PPG021}. 

Predicted releases, occupational, general population, and aquatic environmental exposure from operations modeled 

for {PPG021} are listed on the pages above.

Environmental (Aquatic) Risk Assessment

Assessment of aquatic risk is based on comparison of the concentration of the chemical in the environment, referred 

to as the predicted environmental concentration (PEC), to any acute and/or chronic concentrations of concern (COCs) 

established for the chemical. Acute risk potential is determined by direct comparison of the PEC to an 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 to the acute risk assessment, and by E-FAST estimation of the 

number of days the PEC will exceed the chronic COC, with risk potential indicated if the PEC exceeds the chronic COC 

for 20 days or more. 

Risk is a function of hazard and exposure; if the hazard concern level is low, than the risk will generally also be low. In 

the case of {PPG021}, the chemical is estimated to pose a low ecotoxicity hazard based evaluation of the polymer and 

LMW oligomers. Based on this, the risk is also predicted to be low. 

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

15 

Human Health Risk Assessment 

Human health risk potential is established by comparison of the potential health effect levels to the occupational and 

general population dose rates estimated for the chemical. 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 LD50 is found to be <50 mg/kg. Chronic risk is evaluated for each effect level identified in the human 

health hazard assessment that has a moderate or greater hazard concern. The magnitude of the MOE determines if 

the potential for risk exists; when based on a LOAEL (lowest observed adverse effect level) a MOE of <1,000 indicates 

the potential for human health risk exists, and when based on a NOAEL (no observed adverse effect level) a MOE of 

<100 indicates the potential for risk exists. 

{PPG021} has been predicted to have a low hazard concern for 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 potential for risk. 

Based on this, the acute human health and cancer risk 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 NOAEL of 500 mg/kg-day for reproductive effects. These values were 

evaluated, with the occupational and general population exposure levels predicted for the substance, for 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 operation also has potential inhalation exposure. For systemic effects, 

the MOE calculated for each of the operations is <1,000, which indicates that the potential for risk to workers 

exposed to {PPG021} exists for all thee modeled operations. It should be noted that the MOE established just for 

occupational inhalation risk associated with the use operation would be >1,000 indicating a low potential for risk for 

that exposure route alone. The MOE established for developmental effect is >100 for manufacture and use, 

indicating a low potential for risk for those operations, regardless of exposure route. However, the MOE is <100 for 

the processing operation (dermal exposure only), indicting the potential for risk for that operation. In general, 

{PPG021} may have the potential for risk to workers exposed dermally. 

For the {PPG021} general population risk assessment, there is potential general population exposure from the use 

operation only. For the manufacture and processing operations, no general population exposure is predicted and 

this would lead to a low potential for risk for these operations. The use operation does have potential exposure from 

releases to surface water; the MOE calculated for this exposure is 350,000, which is indicative of a low potential for 

risk. {PPG021} is predicted to pose a low risk to the general population from the modeled operations. 

Overall, based on the MOEs calculated in the general 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 

Nitrobenzoicacid (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 LD50 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 clitoral 

adenomas in rats at 250 mg/kgday 

1) Low

2) Irritant 

3) Skin 

sensitizer 

4) Moderate 

5) Genotoxic 

6) Mutagenic 

7) Low 

8) Low 

Trimethylol 

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 LD50 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 Sustainable Futures Assessment of Polymers, an EPA Sustainable 

Futures/P2 Guidance Document, revised 2010. Available online at: http://www.epa.gov/oppt/sf/. 

(Boethling et al. 1997) Boethling, Robert S. and Nabholz, J. Vincent “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.), (1997) Van Nostrand Reinhold. 

(CPD 2007) Cancer Potency Database.{ http://potency.berkeley.edu/chempages/p-NITROBENZOIC%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.pdf}

(NTP 1994) National Toxicology Publication {TR-442, NIH Publication No. 95-3358. 

http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr442.pdf}
17 

Appendix 1: Determination of Human Health Risk from Occupational Exposure 

Chemical Identifier: {PPG021} CAS Number: N/A 

Exposure Activity 1: Manufacture Site Information: {PPG Circleville, OH} 

Endpoint 

(Concern Effect) 

NOAEL 

(mg/kg-d) 

LOAEL 

(mg/kg-d) 

Exposure Dose and 

Source 

(mg/kg-d) MOE* 

Occupational 

Exposure 

Systemic Effects 67 mg/kg-day 0.083 mg/kg-day (dermal ADD) 810 

Reproductive Effects 500 mg/kg-day 0.083 mg/kg-day (dermal ADD) 6,000 

Exposure Activity 2: Processing Site Information: {PPG Cleveland, OH}

Endpoint 

(Concern Effect) 

NOAEL 

(mg/kg-d) 

LOAEL 

(mg/kg-d) 

Exposure Dose and 

Source 

(mg/kg-d) MOE* 

Occupational 

Exposure 

Systemic Effects 67 mg/kg-day 9.5 mg/kg-day (dermal ADD) 7.1 

Reproductive Effects 500 mg/kg-day 9.5 mg/kg-day (dermal ADD) 52 

Exposure Activity 2: Use Site Information: {Motor Vehicle} Manufacture SIC Code 

Endpoint 

(Concern Effect) 

NOAEL 

(mg/kg-d) 

LOAEL 

(mg/kg-d) 

Exposure Dose and 

Source 

(mg/kg-d) MOE* 

Occupational 

Exposure 

Systemic Effects 67 mg/kg-day

1.4 mg/kg-day 

(combined dermal 

and inhalation ADD)

48 

Reproductive Effects 500 mg/kg-day

1.4 mg/kg-day 

(combined dermal 

and inhalation ADD)

360 

*MOE < 100 indicates potential for risk when using a NOAEL value; MOE < 1000 indicates potential for risk when using a L
18 

Appendix 2: Determination of Human Health Risk to the General Population 

Chemical Identifier: {PPG021} CAS Number: N/A 

Exposure Activity 1: Manufacture Site Information: {PPG Circleville, OH}

No general population exposure predicted for this operation Exposure Activity 2: Processing Site Information: {PPG Cleveland, OH}No general population exposure predicted for this operation Exposure Activity 2: Use Site Information: {Motor Vehicle} Manufacture SIC Code 

Endpoint 

(Concern Effect) 

NOAEL 

(mg/kg-d) 

LOAEL 

(mg/kg-d) 

Exposure Dose and 

Source 

(mg/kg-d) MOE

General 

Population 

Exposure 

Systemic Effects 67 mg/kg-day 1.9 x 10-4 mg/kg-day (combined ADD) 350,0

Reproductive Effects 500 mg/kg-day 1.9 x 10-4 mg/kg-day (combined ADD) 2,600,0

*MOE < 100 indicates potential for risk when using a NOAEL value; MOE < 1000 indicates potential for risk when using a L