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INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0471

Focus Ready Draft 6/17/2013

ENGINEER: Hall \ REC

PV (kg/yr): 33,000

SUBMITTER: H.B.Fuller Company

USE: Curable binder resin for adhesive used to

manufacture flexible packaging. Stepan Co. has provided

the identity of feedstock No references found.

Isocyanate FGEW = 869.

OTHER USES: Analogs adhesives for

laminating textiles; Analog reactive hot melt

adhesive for substrate lamination.

MSDS: Yes Label: No

Gen Eqpt: Wear safety glasses. // Wear chemically

resistant gloves and long sleeved shirt. // Use local

exhaust ventilation or other engineering controls to

minimize exposure.

Respirator: Use a respirator if general room ventilation

is not available or sufficient to eliminate symptoms.

NIOSH approved air purifying respirator with organic

vapor cartridge.

Health Effects: Eyes: Can cause irritation. / Skin: Can

cause moderate skin irritation, defatting, and dermatitis.

 Not likely to cause permanent damage. May cause

sensitization. // Inhalation: Can cause moderate

respiratory irritation. May cause allergic respiratory

reaction. Other possible symptoms include: wheezing and

coughing due to pulmonary edema (fluid build-up in lungs).

 If product is heated or if an aerosol/mist is generated,

airbone concentrations may be reached that cause

irritation or other adverse effects. Inhalation of high

concentrations may result in central nervous system (CNS)

effects such as dizziness, weakness, fatigue, nausea,

headache, and lack of coordination. // Ingestion: Harmful

if swallowed. Ingestion is not an anticipated route of

exposure. Irritating to mouth, throat, and stomach. //

Chronic Effects: May cause tumors based on tests with

laboratory animals. // Target Organs: Lungs, Skin.

TLV/PEL:

Ethyl Acetate (CASRN 141-78-6) 30 wt% 400 ppm TWA ACGIH

Exposure Limits

Ethyl Acetate (CASRN 141-78-6) 30 wt% 400 ppm TWA OSHA

PEL

Ethyl Acetate (CASRN 141-78-6) 30 wt% 1400 mg/m3 TWA OSHA

PEL
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Methylene Bisphenyl Diisocyanate (MDI) (CASRN 101-68-8) 5

wt% 0.005 ppm TWA (listed under Methylene bisphenyl

isocyanate (MDI)) ACGIH Exposure Limits

Methylene Bisphenyl Diisocyanate (MDI) (CASRN 101-68-8) 5

wt% 0.02 ppm Ceiling OSHA PEL

Methylene Bisphenyl Diisocyanate (MDI) (CASRN 101-68-8) 5

wt% 0.2 mg/m3 Ceiling OSHA PEL

CRSS (06/06/2013):

Chemical Name: Soybean oil, polymer with diethylene

glycol, dipropylene glycol, 1,

1'-methylenebis[4-isocyanatobenzene], phthalic anhydride,

polypropylene glycol and polypropylene glycol ether with

glycerol (3:1)

S-H20: Reacts g/L @

VP: 1.0E-6 torr @

MW: 1737.00 5.57%<500 10.17%<1000

Physical State and Misc CRSS Info:

Neat: Solid Mfg: Solution: 72.62% PMN substance in

formulation Proc/Form: Solution: 68.5% PMN substance in

formulation End Use: Destroyed. A letter of support was

submitted by the Stepan Company, which provides the PMN

case number and identity of the third feedstock known by

the tradename Stepanol PD-110LV. MW NAVG = 1737 with 5.

57% < 500 and 10.17% < 1000, by GPC. Submitted Data:

Solid; negligible solubility in water; density = 1.07

g/cm3. Estimated Data: BP > 500°C (High MW); VP < 0.

000001 torr (High MW); reacts with water (isocyanate).

Isocyanate FGEW = 1737/2 = 869. The substance will

hydrolyze with water with a half-life of hr-days to yield

the structure with NH2 groups in place of the terminal

N=C=O groups. Cont'd on p.6.

Consumer Use: No

SAT (concerns) (06/07/2013):

Related Cases and Related Cases and Misc SAT Info:

Ecotox: Analogs: 

Migration to groundwater: Hyd Pdt negl

PBT rating: P3B1T1 PMN - P1B1T1 // Hyd Pdt - P3B1T1

Health: 1-2 Dermal, Inhalation

Eco: 1 No releases to Water

OCCUPATIONAL EXPOSURE RATING: 2B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 
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POLLUTION PREVENTION CONSIDERATIONS:

P2 Claims: Food packaging reduction relieves our need for

glass, steel and paper as well as transportation and

manufacturing costs. This new polymer is a high solids,

low solvent, low usage volume product that will reduce

food containment costs. It also has improved bond

strength and is food safe within 3 days.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0471

Manufacturing: Batch

Number of Sites/ Location: 2

H.B. Fuller Company Grand Rapids MI 49544-1198

H.B. Fuller Company Pilot Facility St. Paul MN 55110

Days/yr: 3

Basis: Submitter specifies 2 sites, 6,136 kg/bt, 12

hrs/bt, 3 bt/yr, and 72.62% PMN in formulation. Due to a

mass balance discrepancy, CEB assumes 3 bt/site-yr and CS

calculates a use rate of 5,500 kg/st-bt.

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources
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to the same medium. Submitter estimates a release of 0.10

kg/bt from QC Sampling, 0.5 kg/bt from Filter Change Out,

and 10 kg/yr from Cleanup; all releases are disposed of

via landfill. Environmental releases are not assessed

for this IRER as the triggers for assessment were not met.

 Note: Water - not required, per SAT; Land - migration to

groundwater negl. and drinking water is not a concern;

Incin - potential releases <28,000 kg/site-day; and Air -

<0.54 kg/site-day and PMN is non-volatile (VP << 0.01

torr).

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 6

Basis: Submission estimates exposure for up to 4 total

workers. CEB assumes 3 workers/site and that all workers

conduct all activities.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 72.62% concentration

High End: 1.3E+3 mg/day over 3 days/yr

Number of workers (all sites) with dermal exposure: 6

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand

Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0471

Use: Curable Binder Resin

Number of Sites/ Location: 1

Sonoco Eau Claire WI

Days/yr: 260

Basis: Submitter specifies 1 site, 260 days/yr operation

(CEB assumes the number of exposure days is equivalent to

operating days), and the adhesive formulation arrives as

72.62% PMN. CS calculates a use rate of 126.92 kg/st-bt.
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ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium. Submitter estimates the following

releases: 1 kg/bt from container residue and 5 kg from

equipment cleaning; all wastes are cured to a water

insoluble solid and landfilled. Environmental releases

are not assessed for this IRER as the triggers for

assessment were not met. Note: Water - not required, per

SAT; Land - migration to groundwater negl. and drinking

water is not a concern; Incin - potential releases <28,

000 kg/site-day; and Air - <0.54 kg/site-day and PMN is

non-volatile (VP << 0.01 torr).

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: Submitter estimates exposure for up to 2 workers.

CEB assumes default minimum of 3 workers/site and that

all workers conduct all activities.

Inhalation:

Exposure to Particulate (Class I)

Low End of Range: 4.0E-1 mg/day over 250 days/yr

High End of Range: 2.6E+0 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 3

Basis: Roll Coating; EPA/OPPT UV Roll Coating Inhalation

Model (non-volatiles); airborned particulate

concentration (KcK is based on 8-hour TWA personal

monitoring data.

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)
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Dermal:

Exposure to Liquid at 72.62% concentration

High End: 1.3E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 3

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.