Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-03-362 

EPA Docket EPA-HQ-OPPT-2011-0577 

EPA SANITIZED Page 1 of 20
Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-03-362 

A-002 Initial Review Engineering Report for 

PMN P-03-362 

A-003 Initial Review Exposure Report for 

PMN P-03-362 

EPA SANITIZED Page 2 of 20
A-001 

Structure Activity Team (SAT) Report

for PMN P-03-362 

EPA SANITIZED Page 3 of 20
STRUCTURE ACTIVITY TEAM REPORT 07 March 2003 

CASE NUMBER: P03-0362

RELATED CASES: 

CONCLUSIONS/DISCUSSIONS 

TYPE OF CONCERN: HEALTH ECOTOX 

LEVEL OF CONCERN: 1-2 2 

KEYWORDS: ONCO, IRR, NEURO, AQUATOX-A,C, SENS-S, DEVEL 

SUMMARY OF ASSESSMENT 

FATE: MW233 

liquid with mp < 20 C (P) 

log Kow = mf (ClogP), 3.5 (EPI) 

S = 103 mg/L at 25 C (P) 

H = 7.1E-8 (P) 

bp = 300 C (P) 

vp = 2.2E-3 (P) 

log Koc = 1.0 (P) 

log fish BCF = 2.0 (P) 

submitted test data for aerobic biodegradation were: 

17.5% biodegradation in 28 d, thus, not readily biodegradable, 

via the modified Sturm test (OECD301B) 

POTW removal = 25 to 90 percent via possible partial 

biodegradation 

time for primary aerobic biodegradation = weeks 

time for complete ultimate aerobic biodegradation = months 

sorption to soils and sediments = moderate 

atmospheric oxidation half-life via OH radical = 5.1 h (P) 

PBT Potential: P1B1T2 

*CEB FATE: migration to ground water = moderate 

HEALTH: Absorption is good all routes based on analogs; 

submitted test data with this PMN were 

rat acute oral (in progress) 

rabbit acute dermal LD20 = 2.0 g/kg with irritation at site of 

application which persisted for 7 days and not other significant 

 toxic signs; 

no skin irritation in rabbits; 

mild and transient (3 d) eye irritation in rabbits; 

Ames test was negative; 

E. coli test was negative; 

mouse micronucleus test via oral route was negative; 

mouse micronucleus test via oral route was weakly positive; 

chromosome aberration test with human lymphocytes was negative; 

skin sensitization in guinea pigs (in progress) 

EPA SANITIZED Page 4 of 20
test data for an analog, reported a rat acute oral LD50 = 

570 mg/kg; 

expected to be an irritant and to cause solvent-type 

neurotoxicity (sedation) based on its solvent properties; 

concern for developmental toxicity and a marginal concern for 

oncogenicity as a carbamate; 

concern for possible skin sensitization based on 

analogs; 

low to moderate concern for toxicity; 

*CEB HEALTH: Exposures to humans: inhalation, dermal, 

ingestion, and drinking water; XB: 

ECOTOX: Predicted (P) and measured (M) toxicity values in mg/L 

(ppm) are: 

fish 96-h LC50 = 9.9 P 

fish (RT) 96-h LC50 = 5.0 M S,N 

daphnid 48-h LC50 <= 10.0 P 

daphnid 48-h LC50 = 5.4 M S,N 

green algal 96-h EC50 <= 10.0 P 

algal 72-h EC50 = in progress 

fish chronic value = 1.0 P SAR 

fish ChV = 0.500 P RT96/ACR10 

daphnid ChV <= 1.0 P 

daphnid ChV = 0.500 P D48/ACR10 

algal ChV <= 1.0 P 

Predictions are based on SARs for thiocarbamates ; SAR 

chemical class = thiocarbamate ; log Kow = 3.5 (EPI); 

MW233; pH7; effective concentrations based on 100% active 

ingredients and mean measured concentrations; hardness <180.0 

mg/L as CaCO3; and TOC <2.0 mg/L; 

moderate concern for toxicity; 

assessment factor = 10.0 

concern concentration = 0.050 mg/L (ppm) 

*CEB ECOTOX: All releases to surface waters; XB: 

SAT co-chair: Vince Nabholz, 564.8909 

EPA SANITIZED Page 5 of 20
A-002 

Initial Review Engineering Report

for PMN P-03-362 

EPA SANITIZED Page 6 of 20
EPA SANITIZED Page 7 of 20
 

 

 

EPA SANITIZED Page 8 of 20
 

EPA SANITIZED Page 9 of 20
 

EPA SANITIZED Page 10 of 20
A-003 

Initial Review Exposure Report

for PMN P-03-362 

EPA SANITIZED Page 11 of 20
 

EPA SANITIZED Page 12 of 20
EPA SANITIZED Page 13 of 20
 

 

EPA SANITIZED Page 14 of 20
 

 

 

EPA SANITIZED Page 15 of 20
 

EPA SANITIZED Page 16 of 20
EPA SANITIZED Page 17 of 20
EPA SANITIZED Page 18 of 20
EPA SANITIZED Page 19 of 20
EPA SANITIZED Page 20 of 20