log Fish BCF = 3.98 (E) log Fish BAF = 6.52 (E) POTW removal (%) = 90 via sorption; OECD 301D(Closed Btl):

Time for complete ultimate aerobic biodeg > mo Sorption to soils/sediments = v.strong PBT Potential: P3B2 *CEB FATE: Migration to ground water = negl

Health : Health Summary: Absorption of the neat material is nil through the skin, p oor through the skin when in solution, p oor from the lung and GI tract ( p che m ). Concern for respiratory sensitization, mutagenicity, developmental toxicity, male reproductive, liver, kidney toxicity and marginal concern for oncogenicity based on the epoxides. Concern for respiratory irritation based on information in MSDS Test Data: (-) Salmonella with and without activation; (-) E. coli with and without activation; rat oral LD0 = 2500 mg/kg; rat dermal LD0 = 2500 mg/kg; no eye irritation in rabbits; no skin irritation in rabbits; no skin sensitization in guinea pigs using the Magnusson-Kligman assay; rat 28-day oral NOEL = 1000 mg/kg (highest dose tested)

Ecotox :

Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 * daphnid 48-h LC50 * green algal 96-h EC50 * fish

_ chronic value 0.001 daphnid

_ chronic value 0.002

algal

_ chronic value 0.035 Using Baseline Toxicity Values in the Absence of a QSAR. Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for Polyepoxides; SAR chemical class = epoxides- p oly; MW 593; solid with mp = 39-46 C (M); log Kow = 7.3 (P); S = 0.063 mg/L at 20 C (M); p H7; effective concentrations based on 100% active ingredients and mean measured concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Ecotoxicity Test Data ResultsP-15-0356 (Oxirane, 2,2'-[[1-[ 4-[1-methyl-1-[4-(2-oxiranylmethoxy) p henyl]ethyl] p henyl] ethylidene]bis(4,1- p henyleneoxymethylene)]bis- and 2-Propanol, 1,3-bis[4-[1-[4-[1-methyl-1-[4-(2-oxiranylmethoxy) p henyl]ethyl] p henyl]-1-[4-(2-oxiranylmetho xy) p henyl]ethyl] p henoxy]-) CAS RN: 115254-47-2 and 180063-56-3 Trade Name: TECHMORE VG3101L, VG3101L, PAEX (2nd chemical)

The PMN product is a "one pot mixture" consisting of two substances, CASRNs 115254-47-2 and 180063-56-3. The aquatic studies submitted for this PMN were previously submitted and reviewed under and . The ecotoxicity review for is p rovided below.

Two ecotoxicity studies were submitted with the from a 96-hour acute fish test and a 48-hour acute daphnid immobilization test. The studies were conducted in 1993 and the substance was described as light yellow solid with the water solubility of 63.4 μg/L, a mixture of 7,7,8-tris-[4-(2,3-epoxy- p ropoxyphenyl)]-7-methyl- p -cymene and its dimer (PAEX) with no reported ratios and purity. Both studies were conducted by the under GLP conditions with a certificate of analysis and a signed quality assurance statement also provided. The actual concentrations in the test solution were determined by HPLC (level of detection not reported). The studies complied with OECD guidelines 301 D and 202 (Daphnia sp., Acute Immobilization Test And Reproduction Test), and EC guidelines C.1 and 2., p ublished in the Official Journal of the European Communities L 383 A dated December 29th, 1992. The tests followed the OECD test guidelines for 1) O2, p H, and temperature; 2) species, age, number of organisms per replicate and 4) appropriate response in controls.

Fish Ecotoxicity Test: The 96-hour acute toxicity test for Gold orfe (Leuciscus idus) (10 fish/ concentration) was a limit test conducted under semi-static conditions (daily renewal), using a nominal concentration of 100mg/L. A control and a vehicle control (100 mg Tween 80/L) were also run. The test solution was prepared by suspending the test substance in 100 mg Tween 80 using a mortar and pestle, then mixing with 100 mL water, followed by sonication for 15 minutes. The volume was made up to 1000 mL with water. Water quality parameters were the following: temperature = 20.0-20.5°C, p H = 6.80-7.71, and DO = 62.0%-99.6%. N o mortality or behavioral changes were observed. The actual concentrations in the test solution were determined by HPLC. The analytical concentration in the test solution was 0.97 mg/L. 96-hour LC50 > 0.97 mg/L (analytical concentration) N OEC = 0.97 mg/L (analytical concentration)

Invertebrate Ecotoxicity Test: The 48-hour acute toxicity test for D. magna (four replicates per test concentration/ 5 daphnids p er replicate) was a limit test conducted under semi-static conditions with daily renewal, using a nominal concentration of 100 mg/L. A control and a vehicle control (100 mg Tween 80/L) were also run. The test solution was prepared by suspending the test substance in 100 mg Tween 80 using a mortar and pestle, then mixing with 100 mL water, followed by sonication for 15minutes. The volume was made up to 1000 mL with water. Water quality parameters were the following: temperature = 20±1°C, p H = 7.65-7.96, and DO = 94.1%-99.0%. N o mortality, immobilization or other indications of toxic effects were observed in D. magna. The actual concentrations in the test solution were determined by HPLC. The analytical concentration in the test solution was 0.84 mg/L. 48-hour EC50 > 0.84 mg/L (analytical concentration) N OEC = 0.84 mg/L (analytical concentration)

Both tests are considered invalid. There is no information on purity or the ratios of the mixture for the test substance. Also, the carrier, Tween 80, is an emulsifier and should not have been used as a vehicle, since this is not one of the recommended carriers. In addition, for this p olyepoxide, the concern is for chronic, not acute, therefore predicted values from ECOSAR (v. 1.00a) will be used to determine risk for under the chemical class of polyepoxides. The most appropriate and environmentally protective value used to determine the chronic concern concentration is the ChV for fish as 0.001 mg/L. This value is already the most conservative without an assessment (uncertainty) factor of 10, to yield 0.001 mg/L or 1 ìg/L. Chronic Concern Concentration = 1 p pb.

To address the acute concern concentration, based on a log Kow of 7.29 (EPI) and predicted water solubility of 0.003 mg/L at 25oC, acute concern concentrations are predicted to be no effects at saturation. Acute Concern Concentration = no effects at saturation.

Ecotox Reviewer: Date: April 9, 2015

Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) Acute Concentration of Concern ( p pb) Chronic 1

SARs Epoxides SAR Class Epoxides-Poly N ew Chemcial Category Epoxides

Ecotox Factors Comments:

SAT Chair: