MEMORANDUM

TO: Greg Macek, EPA/OPPT/CEB

FROM: Jason Sese, ERG

Kurt Rindfusz, ERG

DATE: May 31, 2013

SUBJECT: Potential Updates to Table 1 of the July 12, 2011 Proposed SNUR for the 

“Glymes” Category Chemicals

Through technical direction provided on December 6, 2012 and follow-up direction provided on 

December 12, 2012, December 20, 2012, April 9, 2013, and May 20, 2013, EPA tasked ERG 

with drafting a memorandum that proposes updates to the July 12, 2011 Proposed Significant 

New Use Rule (SNUR) for the Glymes Category Chemicals. Specifically, ERG was to update 

the known consumer uses for each glymes category chemical in Table 1 of the proposed SNUR: 

“Chemicals With Use in a Consumer Product as the Proposed Significant New Use and Proposed 

Excluded Consumer Uses.”

EPA directed ERG to reference 2012 submission data from the TSCA Chemical Data Reporting 

(CDR) rule, and comments on the proposed SNUR, which were provided by the following 

organizations:

 American Chemistry Council

 Alliance of Automobile Manufacturers

 American Coatings Association

 Boeing

 Global Automakers

 Novolyte Performance Materials

 PRBA – The Rechargeable Battery Association; and

 West Kern Water 

In the May 20, 2013 TD, EPA revised the scope of the Glymes SNUR from 14 glyme chemicals 

to seven glyme chemicals. EPA directed ERG to limit the analysis to the seven glyme chemicals 

of interest, as shown below:
CASRN Common Name

110-71-4 Monoglyme

111-96-6 Diglyme

629-14-1 Ethylglyme

112-36-7 Ethyldiglyme

112-49-2 Triglyme

112-73-2 Butyldiglyme

63512-36-7 Butyltriglyme

Based on the industry comments on the proposed SNUR and consumer uses listed in the NIH 

Household Products Database, ERG proposed updates in Table 1 of this memorandum. The table 

shows the consumer uses listed in the proposed SNUR and presents ERG’s recommended

updates and rationale. Note that Novolyte provided some comments that conflict with certain 

consumer uses listed in Table 1 of the proposed SNUR, which were originally based on ERG’s 

June 15, 2009 memorandum, “Revised Analysis of Potential Uses in the “Glyme” Chemical 

Category.” In these cases, ERG also provided the original basis for inclusion and recommends 

that EPA make the final determination on whether the consumer use should remain on Table 1 of 

the proposed SNUR.

ERG also reviewed the draft 2012 CBI submission data from the CDR rule. ERG provided a 

separate CBI addendum to this memorandum that outlined currently reported consumer uses for 

the glymes category chemicals on January 4, 2013. This memorandum does not contain TSCA 

CBI.
Table 1. Proposed Changes to the July 2011 List of Consumer Uses a

CASRN

Common 

Name

List of Consumer Uses in 

2011 Proposed SNUR List of Proposed Consumer Uses Rationale

110-71-4 Monoglyme In electrolyte solutions for 

sealed lithium batteries.

In electrolyte solutions for sealed 

lithium batteries.

Novolyte’s most recent comments on the proposed SNUR state 

monoglyme is currently used in electrolyte solutions for sealed 

lithium batteries, which is consistent with the products listed in the 

NIH Household Products Database (Novolyte, 2011; NIH, 2013). 

ERG does not propose any changes to the consumer uses currently 

listed.

111-96-6 Diglyme As a solvent in printing inks 

for consumer products

None Novolyte’s website previously listed a use as a solvent for printing 

inks (Novolyte, 2008a) and the Printers National Environmental 

Assistance Center (PNEAC) included diglyme on a listing of TRI 

chemicals possibly found in printing (but as a component in some 

cleaning solvents) (PNEAC, 1996). Joe Valcho of Novolyte also 

later stated that it was possible that printing inks containing 

between one and five percent glyme may be sold to consumers 

through distributors (Novolyte, 2009).

Novolyte’s most recent comments on the proposed SNUR state 

that there are no current consumer uses of diglyme (Novolyte, 

2011). 

Because Novolyte has provided an updated statement indicating 

that they do not use diglyme in consumer products, ERG 

recommends that EPA remove this consumer use from Table 1 of 

the proposed SNUR. The use described by PNEAC is for cleaning 

solvents and not for direct use in printing inks.

629-14-1 Ethylglyme None None ERG does not propose any changes to the consumer uses currently 

listed.

112-36-7 Ethyldiglyme None -As a component of consumer inks, 

coatings and adhesives.

-As a component of consumer 

paint/graffiti removers.

Novolyte’s comments on the proposed SNUR list the following 

current consumer uses: Consumer inks, adhesives, and coatings; 

and paint and graffiti removal (Novolyte, 2011). ERG proposes 

adding these consumer uses to Table 1 of the proposed SNUR.
CASRN

Common 

Name

List of Consumer Uses in 

2011 Proposed SNUR List of Proposed Consumer Uses Rationale

112-49-2 Triglyme As a solvent in consumer 

adhesives

[As a solvent in consumer 

adhesives]

b

Clariant and Novolyte’s websites previously listed use as a solvent 

for adhesives (Clariant, 2008a; Novolyte, 2008b). Terry Wells of 

Clariant could not specifically state that final adhesives containing 

triglyme would not be used by consumers (Clariant, 2009).

 Joe 

Valcho of Novolyte stated that it is possible that adhesives 

containing between one and five percent glyme may be sold to 

consumers through distributors (Novolyte, 2009).

AAM and Global Automakers also reported use as a solvent in 

adhesives for liquid display panels, but in the context of motor 

vehicle manufacturing (AAM, 2011; Global Automakers, 2011). 

Novolyte’s most recent comments on the proposed SNUR state 

that there are no current consumer uses for triglyme (Novolyte, 

2011). 

There is no definitive information that confirms the use of 

triglyme as a solvent in consumer adhesives. ERG recommends 

that EPA make the final determination on whether this use should 

remain on Table 1 of the proposed SNUR.

As a component of consumer 

brake fluids

[As a component of consumer brake 

fluids]

b

Clariant’s website listed a use as a component of brake fluids

(Clariant, 2008a) and a German MSDS listed triglyme as a 

component for a brake fluid (Continental Teves, 2006). No 

information was found limiting use of this brake fluid to industrial 

or commercial settings. Terry Wells of Clariant could not affirm 

that the final brake fluid would not be used by consumers

(Clariant, 2009); therefore it was previously assumed that triglyme 

may be present in brake fluid accessible by consumers.

AAM and Global Automakers also reported use in brake fluid, but 

in the context of motor vehicle manufacturing (AAM, 2011; 

Global Automakers, 2011). Novolyte’s most recent comments on 

the proposed SNUR state that there are no current consumer uses 

for triglyme (Novolyte, 2011). 

There is no definitive information that confirms the use of 

triglyme in consumer brake fluids. ERG recommends that EPA 

make the final determination on whether this use should remain on 

Table 1 of the proposed SNUR.
CASRN

Common 

Name

List of Consumer Uses in 

2011 Proposed SNUR List of Proposed Consumer Uses Rationale

As a component of consumer 

paint/graffiti removers

[As a component of consumer 

paint/graffiti removers]

b

Clariant’s website listed use as a component of paint/graffiti 

remover formulations and delacquers (Clariant, 2008a).

 No 

information was found limiting use of these removers to industrial 

or commercial settings. Terry Wells of Clariant could not affirm 

that the final paint/graffiti removers would not be used by 

consumers; therefore it was assumed that triglyme may be present 

in paint/graffiti remover accessible by consumers (Clariant, 2009).

Novolyte’s comments on the proposed SNUR state that there are 

no current consumer uses for triglyme (Novolyte, 2011). No other 

comments were received. 

There is no definitive information that confirms the use of 

triglyme in consumer paint/graffiti removers. ERG recommends 

that EPA make the final determination on whether this use should 

remain on Table 1 of the proposed SNUR.

in consumer paints [in consumer paints]

b Patent No. 5,919,851 indicates that triglyme may be used a solvent 

in a paint composition (Yamaguchi et al., 1999). Joe Valcho of 

Novolyte stated that it is possible that paint containing between 

one and five percent glyme may be sold to consumers through 

distributors (Novolyte, 2009).

Novolyte’s most recent comments on the proposed SNUR state 

that there are no current consumer uses for triglyme (Novolyte, 

2011). ACA also states that they have not identified any uses of 

glymes in the paints and coatings industry (ACA, 2011). 

There is no definitive information that confirms the use of 

triglyme in consumer paints. ERG recommends that EPA make the 

final determination on whether this use should remain on Table 1 

of the proposed SNUR.

112-73-2 Butyldiglyme None -As a component in consumer inks, 

adhesives, and coatings.

-As a component in soldering 

compounds

Novolyte’s most recent comments on the proposed SNUR report 

use of butyldiglyme in consumer inks, adhesives, and coatings; 

and soldering compounds (Novolyte, 2011). ERG proposes adding 

these consumer uses to Table 1 of the proposed SNUR.

63512-36-7 Butyltriglyme Not included in Table 1 Not included in Table 1 No comments were received. ERG does not propose any changes 

to the consumer uses currently listed.

a – Note that there may be additional proposed additions from the 2012 CDR (USEPA, 2012) that may be CBI and will be sent in a separate deliverable.

b – ERG recommends EPA review these uses to make a final determination for inclusion or exclusion in Table 1 of the proposed SNUR. 
REFERENCES

AAM, 2011 Alliance of Automobile Manufacturers. Comment 

response for Docket No. EPA-HQ-OPPT-2009-0767 Glymes; 

Proposed Significant New Use Rule 76 Fed. Reg. 40850. October 

12, 2011.

ACA, 2011 American Coatings Association. Comment response 

for Docket No. EPA-HQ-OPPT-2009-0767 Glymes; Proposed 

Significant New Use Rule 76 Fed. Reg. 40850. October 7, 2011.

Clariant, 2008a Clariant Corporation. Triglyme. Accessed, May 14, 2009,

http://www.glymes.com/C1257227004EED35/vwWebPagesByID/

2B3AC3AE3FD248E1C12571E900293AAE

Clariant, 2009 Clariant Corporation, ERG Conversation with Terry 

Wells, Clariant Corporation, June 4 and 15, 2009.

Continental Teves, 2006. Original ATE Brake Fluid DOT 3 (blue); 3m. Accessed, May 14, 

2009, http://www.contionline.com/generator/www/us/en/ate/ate/themes/20_ate_brake_pro

ducts/50_brake_fluid/download/ca_safetydata_dot3_blue_us.pdf

Global Automakers, 2011 The Association for Global Automakers. Comment response for 

Docket No. EPA-HQ-OPPT-2009-0767 Glymes; Proposed 

Significant New Use Rule 76 Fed. Reg. 40850. October 7, 2011.

NIH, 2013 National Institutes of Health Household Products 

Database.

http://householdproducts.nlm.nih.gov/cgibin/household/brands?tbl=chem&id=2925&query=110-71-

4&searchas=TblChemicals. Accessed April 12, 2013.

Novolyte, 2008a Novolyte Technologies, Diglyme – diethylene glycol 

dimethyl ether. Accessed, May 14, 2009, 

http://www.novolyte.com/page%20docs/Diglyme%20doc.html

Novolyte, 2008b Novolyte Technologies Triglyme – triethylene glycol 

dimethyl ether. Accessed, May 14, 2009, 

http://www.novolyte.com/page%20docs/Triglyme%20doc.html

Novolyte, 2009 Novolyte Technologies, ERG Conversation with Joe 

Valcho, Novolyte Technologies, June 11, 2009.

Novolyte, 2011 Novolyte Technologies. Comment response for Docket No. 

EPA-HQ-OPPT-2009-0767 Glymes; Proposed Significant New 

Use Rule 76 Fed. Reg. 40850. October 12, 2011.
PNEAC, 1996 Printers National Environmental Assistance Center 

(PNEAC), 1996. Appendix II – TRI Chemicals Possibly Found In 

Printing. Accessed, May 14, 2009,

http://www.pneac.org/sheets/all/printingtri.pdf

USEPA, 2012. U.S. Environmental Protection Agency. DRAFT 2012 

Chemical Data Reporting (CDR) Database, version 2 (CBI). 

Accessed December 11, 2012.

Yamaguchi et al., 1999 Patent 5919851 – Paint Composition and Painted Article. 

Accessed, May 14, 2009, 

http://www.freepatentsonline.com/5919851.html