### MEMORANDUM

TO: Greg Macek, EPA/OPPT/CEB

FROM: Jason Sese , ERG

Kurt Rindfusz , ERG

DATE: May 31 , 201 3

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

“ Glyme s ” Category Chemicals

Through technical direction provided o n 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 propose s 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 glyme s 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 co mments 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 t he 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 Categor y .” In these cases, ERG also provided the original bas i s 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 provide d a separate CBI addendum to this memorandum that outline d 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 list ed a use as a solvent for printing inks (Novolyte, 2008 a ) and the Printers National Environmental Assistance Center (PNEAC) include d 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 distributor s (Novolyte, 2009).

Novolyte’s most recent comments on the proposed SNUR state th at 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 (Novoly te, 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 list ed use as a solvent for adhesives (Clariant, 2008 a ; 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 distributor s (Novolyte, 2009).

AAM and Global Automakers also reported use as a solvent in adhesives for liquid display panels, but in the contex t 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 list ed a use as a component of brake fluids (Clariant, 2008a) and a German MSDS list ed 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 trigl yme (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 list ed 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 pres ent 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 inform ation that confirms the use of triglyme in consumer paint/graffiti remove r s. 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 distributor s (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

– N ote 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.

### R EFERENCES



### 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, 2008 a 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.conti

online.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/cgi

bin/household/brands?tbl=chem&id=2925&query=110

- 71

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

Novolyte, 2008 a Novolyte Technologies, Diglyme

– diethylene glycol dimethyl ether . Accessed, May 14, 2009, http://www.novolyte.com/page%20docs/Diglyme%20doc.html

Novolyte, 2008b Novolyte Technologi es 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