MEMORANDUM

TO: Greg Macek, EPA/OPPT/CEB

Maj’d El-Zoobi, EPA/OPPT/CEB

FROM: Jason Sese, ERG

Kurt Rindfusz, ERG

DATE: May 31, 2013

SUBJECT: Glymes SNUR – Method Used to Identify Existing Consumer Uses

ERG has been supporting EPA since 2009 to identify current existing consumer uses of 

the Glymes Chemical Category in support of the Glymes Significant New Use Rule (SNUR). On 

February 13, 2013 (with subsequent direction on April 9, 2013 and May 20, 2013), EPA directed 

ERG to provide documentation of the methods used to identify these current existing consumer 

uses. EPA indicated that the documentation should include: 

1. Data sources investigated;

2. Contacts made and how chosen;

3. Discussion of any hierarchy used in reviewing the data. For example, was higher 

weight given to one source over the other;

4. The EPA reviews provided along the way; and

5. Step-by-step approach employed from the beginning of the project up to and 

including the recent deliverables.

Section 1.0 describes an overall summary of the methods used to identify existing 

consumer uses, while Section 2.0 outlines the chronological order of activity since 2009. 

1.0 SUMMARY OF METHOD

EPA tasked ERG with identifying consumer uses of glymes associated with the proposed 

SNUR in 2009. Over time a series of modifications to the original task were issued, ultimately 

leading to support for determining which glymes have been associated with confirmed (actual) 

consumer uses and unconfirmed (reported or potential) consumer uses. The methodology used to 

make determinations is outlined in the following steps:

Step 1: EPA provided a list of six glymes with potential consumer uses. 

Step 2: ERG conducted a literature search to find supporting or contradicting 

evidence for the listed potential consumer uses. The following information 

sources were used: the 2006 IUR database, the Hazardous Substance 

Database (HSDB), the Kirk-Othmer Encyclopedia of Technology, the NIH 

Household Products Database, and a general internet search.
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Using the available information, ERG identified existing consumer uses 

through two criteria: (1) whether a use currently exists; and (2) whether 

that use is a consumer use. In instances where a use was defined broadly 

(paints, coatings, batteries, etc.), ERG assumed that there may be potential 

consumer use.

Step 3: ERG then contacted industry representatives from Novolyte and Clariant, 

as directed by EPA (ERG was not provided the specific reasons why those 

companies were selected for contact). ERG completed this phase of the 

effort by updating the results from step 2 based on information provided 

by the industry contacts. In cases where the technical contact could not 

specifically state whether there were consumer uses, ERG assumed that 

there was potential consumer use.

EPA then tasked ERG with follow up work starting in 2012. These efforts and the 

methodology used to complete the associated tasks are summarized in Steps 4 and 5 as 

follows:

Step 4: EPA directed ERG to expand the work to include the eight additional 

glymes that were included in the Proposed SNUR.

Step 5: EPA directed ERG to review the following additional sources for use 

information:

 Information developed by EPAB that included information from the 

following sources: 1986-2006 IUR public database, SRI Chemical 

Economics Handbook and SRI Specialty Chemicals Program books,

industry and trade magazines such as industry and trade magazines 

such as the “Chemical Market Reporter” and the “Chemical 

Engineering News”, EPA Website; NIH’s Hazardous Substances 

Databank (HSDB), Score Card: The Pollution Information Website 

(Scorecard), and a general web search;

 Industry comments prepared in response to the proposed rule;

 Information from the draft 2012 Chemical Data Reporting (CDR) 

Rule; and

 The NIH Household Products Database (which was previously 

searched for the initial list of six glymes, but not for the additional 

eight glymes in the expanded work).

Step 6: EPA revised the scope of the work and directed ERG to limit the analysis 

from 14 glyme chemicals to a list of seven glyme chemicals.

ERG divided the uses for each of the seven glymes into three different 

categories, using the criteria described in step 2. ERG used all available 
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data to determine whether a particular use currently exists, but used direct

information from industry comments and contacts to determine whether 

there was consumer use. The three categories are as follows:

 Category 1 included the uses where there is a strong indication that 

there is an actual current consumer use. These uses were identified

based on the previous discussions with technical contacts from 

Clariant and Novolyte, if explicitly discussed by industry in comments 

on the proposed SNUR, or if listed in the NIH Household Products 

Database.

 Category 2 included the uses where there is a strong indication that 

there is no actual current consumer use. As with Category 1, these 

determinations were based on discussions with technical contacts from 

industry or from information provided in the SNUR comments.

 Category 3 included both potential consumer and non-consumer uses 

that have been reported in various sources but have not been 

confirmed by direct contact with industry. These uses were identified 

through internet and literature searches, but were not definitively 

classified in Categories 1 or 2.

2.0 CHRONOLOGICAL HISTORY

The following is a chronological summary of the work completed since 2009.

2.1 May 8, 2009 Technical Direction

EPA provided a table of six glymes to ERG with a preliminary list of uses for each

chemical. EPA directed ERG to review the uses and provide a “Yes/No” determination of 

whether the uses provided were potential consumer uses. 

ERG submitted a deliverable on May 22, 2009 (Glymes Review_052209.doc) that 

provided a consumer use determination for each of the uses listed by EPA and a basis for each 

determination. ERG reviewed the following sources for this effort: the 2006 IUR database, the 

Hazardous Substance Database (HSDB), the Kirk-Othmer Encyclopedia of Technology, the NIH 

Household Products Database, and a general internet search. The main sources of information 

obtained from the general internet search were Novolyte and Clariant websites. 

2.2 May 29, 2009 Technical Direction

On May 29, 2009, EPA directed ERG to contact industry representatives from Ferro, 

Novolyte and Clariant to refine consumer use determinations provided in the May 22, 2009 

deliverable. In separate emails from Greg Macek (via Amy Breedlove) to Dan-Tam Nguyen on 

June 2, 2009, EPA indicated that Ferro was bought by a company and renamed Novolyte and 
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provided ERG with contact information for Clariant and Novolyte. EPA did not provide 

background on how the contacts were chosen.

ERG provided a deliverable on June 15, 2009 (Glymes Review_061509.doc) that updated 

the May 22, 2009 deliverable with information from Novolyte and Clariant contacts. In cases 

where broad uses were possible (paints, coatings, etc.), but the technical contact could not 

specifically state whether there were consumer uses, ERG assumed that there was potential 

consumer use. The Novolyte contact indicated at the time that that Ferro transferred all glyme 

production to Novolyte and no longer manufactured those chemicals. 

2.3 February 29, 2012 Technical Direction

On February 29, 2012, EPA directed ERG to update the June 15, 2009 memorandum

based on the following criteria and documents: 

 The additional glymes that were included in the proposed rule (ERG’s June 15, 2009 

memorandum covered the initial six glymes, while the proposed rule covered 14 glymes);

 Additional use information gathered by EPAB after preparation of the June 15, 2009 

memo, as reported in a September 9, 2009 memo from Abt Associates, Inc. (Abt) to 

Nishkam Agarwal of EPAB that was also presented in the 2011 Economic Analysis;

 All of the comments provided to EPA on the proposal, which were submitted by the 

following trade associations and companies:

o American Chemistry Council;

o Alliance of Automobile Manufacturers;

o American Coatings Association;

o Boeing;

o Global Automakers;

o Novolyte Performance Materials;

o PRBA – The Rechargeable Battery Association; and,

o West Kern Water.

 Follow-up conversations by ERG with the commenters for clarification if needed; and,

 Any updated information from key databases such as IUR (after completion of the 2009 

work).

On March 22, 2012, ERG delivered an updated memorandum to EPA that compiled the 

information from the various data sources. ERG also incorporated the “actual” versus “reported” 

notations as used by the Abt analysis. For each use, the table assigned two separate 

classifications: (1) actual versus reported use; and (2) consumer versus non-consumer use. 

Confirmed uses were designated as “actual” while unconfirmed uses were designated as 

“reported” (this includes industrial, commercial, and/or consumer use). Uses were designated as 

“actual” only when verified through industry contacts or comments. ERG made a separate 

determination as to whether there was a potential consumer use. 
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2.4 May 29, 2012 Technical Direction

On May 29, 2012, EPA directed ERG to further refine the March 22, 2012 memorandum, 

dividing the single table into three separate tables, one for “strong Yes’s,” one for “strong No’s,” 

and one for everything in between. ERG delivered the memorandum on May 31, 2012, including 

the following details about each table:

 Table 1 included the uses where there is a strong indication that there 

is an actual current consumer use. These uses were identified as 

“strong Yes’s” based on discussions with technical contacts from 

Clariant and Novolyte, or if explicitly discussed by industry in 

comments on the proposed SNUR.

 Table 2 included the uses where there is a strong indication that there 

is no actual current consumer use. As with Table 1, these 

determinations were based on discussions with technical contacts from 

industry or from information provided in the SNUR comments.

 Table 3 included both potential consumer and non-consumer uses that 

have been reported in various sources but have not been confirmed by 

direct contact with industry. These uses were identified through 

internet and literature searches, but were not definitively classified in 

Tables 1 or 2. 

2.5 July 23, 2012 Technical Direction

ERG’s May 31, 2012 deliverable was forwarded to the Glymes workgroup with a request 

for review and comment. On July 23, 2012, EPA directed ERG to address comments from three 

workgroup members (Glen Farber, Jasbir Sama, and Kirsten Hesla). On August 3, 2012, ERG

delivered a comment response and revised glymes use memorandum based on the comments that 

were received.

2.6 December 6, 2012 Technical Direction (replaced with updated direction provided 

December 12, 2012)

EPA provided ERG with technical direction on December 6, 2012, which was superceded 

by direction that was provided on December 12, 2012. ERG was directed to propose updates to 

Table 1 of the July 12, 2011 proposed SNUR for the Glymes Chemical Category. This table

listed consumer uses of glymes that EPA was aware of at the time of publication. EPA directed 

ERG to propose updates to Table 1 based on the additional information that was received and 

reviewed, including data from the 2012 Chemical Data Reporting (CDR) Rule. EPA also 

directed ERG to prepare a separate CBI memorandum for information found in the CDR 

database, if necessary.

 
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ERG delivered a non-CBI memorandum on December 14, 2012, which proposed updates 

to Table 1 of the SNUR, primarily based on information received from industry comments. ERG 

delivered a revised version December 17, 2012 that stated that the consumer uses found in the 

draft 2012 CDR database (versions 1 and 2) were consistent with those reported in industry 

comments. Hence, ERG did not provide a separate CBI deliverable.

2.7 December 20, 2012 Technical Direction

On December 20, 2012, EPA directed ERG to prepare a summary of CBI information 

from the draft 2012 CDR (versions 1 and 2) pertaining to consumer uses for each of the 14 

glymes and to obtain select production volume information. Also, EPA requested that the 

December 17, 2012 memo be revised so that the basis for original inclusion of consumer use 

(from the June 15, 2009 deliverable) be included. ERG delivered the CBI CDR data on January

3, 2013 and the revised memorandum on Jan 4, 2013.

2.8 January 30, 2013 Technical Direction

On January 30, 2013, EPA directed ERG to add the identity of the manufacturer/importer 

to Table 2 of the January 4, 2013 CDR deliverable. ERG delivered the CBI CDR data on 

February 7, 2013. 

2.9 April 9, 2013 Technical Direction

On April 9, 2013, EPA directed ERG to investigate potential consumer uses reported in 

the NIH Household Products database for tetraethylene glycol dibutyl ether (112-98-1), 

pentaethylene glycol diethyl ether (23601-39-0), and (tetraethylene glycol diethyl ether 4353-

28-0). ERG re-searched all 14 glymes of interest in the NIH Household Products Database and 

updated the January 4, 2013 deliverable. ERG delivered the revised memorandum on April 16, 

2013.

2.10 May 20, 2013 Technical Direction

On May 20, 2013, EPA indicated that the scope of the Glymes SNUR Rule was reduced 

from 14 glyme chemicals to seven. The seven glymes included in the final scope are:

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
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EPA directed ERG to revise the following two supporting documents to include just the 

seven glymes that are in the current scope for the final rule:

a. August 3, 2012 “Glymes Use Review” memo

b. April 16, 2013 Potential Updates to Table 1 memo

ERG delivered these revised memorandums on May 31, 2013.