CONTAINS CONFIDENTIAL BUSINESS INFORMATION

The following is a summary of the hazard classification of the notified substance,

Endpoint US/OSHA GHS

Skin irritation Skin irritant Category 2 Eye irritation Eye irritant Category 2A Respiratory irritation Mild respiratory irritant Not classified

Aquatic toxicity Toxic to aquatic organisms and may cause long lasting effects to aquatic life Chronic/acute Cat. 2

I. Hazard Assessment
The borated ester alkyl amine category consists of fatty alkanolamides that are further reacted with
boric acid and glycerol to form borated esters. The preliminary hazard classification of the notified
substance,
is based on the existing hazard evaluation of an alkanolamide purchased

compone nt, which is a starting material of

the notified sub stance . The borated esters that are manufactured by the notifier (e.g.

are also included to determine whether the borate ester functional group will contribute any additional
hazards. Further, an evaluation of boric acid has been included as borate esters can hydrolyze with
water or with acidic solution releasing boric acid solution , although the intended use of this product is
exclusively in f inished oils contained in closed systems (engines)

, effectively eliminating the chances for
water contact, and thus hydrolysis

.

The fatty alkanolamides are an HPV chemical category, which contains both an industry toxicology
assessment/evaluation and E PA hazard characterization ; is a member of this category. Another material intentionally added to make the notified

substance is and the formalized spec for the notified substance
identifies <1% residual DEA in the final product , which has also been included in the hazard evaluation

.

Following is a breakdown of the contributions from the dif ferent func tionalities found in the notified

substance :

The analog alkanol ami de, is classified as

follows:
Endpoint US/OSHA GHS

Skin irritation Skin irritant Category 2 Eye irritation Eye irritant Category 2A Respiratory irritation Mild respiratory irritant Not classified

Aquatic toxicity Toxic to aquatic organisms and may cause long lasting effects to aquatic life Chronic/acute Cat. 2

There was uncertainty with whether borating the alkanolamide material will alter the toxicological
properties of the final notified substance

. The best read

- across substances available to understand th isCONTAINS CONFIDENTIAL BUSINESS INFORMATION

potential toxicity of adding a borate ester functional group are the borated monoglycerol s , including

. The hazard classification of the borated esters class is as follows:

Endpoint US/OSHA GHS

Skin irritation Skin irritant Category 2 Respiratory irritation Mild respiratory irritant Not classified
Aquatic toxicity May cause long lasting effects to aquatic life Chronic Cat. 4

Based on read across from borating the alk a nolamide is not expected to directly
alter the toxciologoy of the notified substance. R elease of boric acid solution via hydro lyzation of the

borate esters with water or with acidic solution can occur , but based on its intended use strictly in a
closed system, this scenario is not expected to occur

. Nevertheless , hazard c lassification of boric acid

should still be considered to fully evaluate the notified substance. The maximum amount of boric acid
expected to be released from the borate esters in the event of hydrolysis of the notified substance is

between 10

- 15% boric acid, with the boron content between 1.75

- 2.63%. Boric acid is classified as toxic
for reproduction GHS categ ory 1B at concentrations greater than or equal to 5.5%. Should the notified
substance hydrolyze and the maximum amount of boric acid released exceed this specific concentration
limit, it would be classifi ed as a reproductive hazard, see table below.

Boric acid is classified as follows:
Endpoint US/OSHA GHS Reproductive toxicity May impair fertility. May cause harm to unborn child. Repr o . Cat. 1B

Other co ntributing hazards include from r esidual (< 1%):
Endpoint US/OSHA GHS Target organ toxicity (liver, blood, kidney) May cause damage to the specified organs Category 2

Additionally, a Toxicity to Activated Sludge in a Respiration Inhibition range

- finding test conducted on

the notified substance showed a statistically significant toxic effect at the test concentration of 1000 mg/L and the pH of the test item dispersions were measured to be as follows:

10 mg/L pH 7.3 100 mg/L pH 7.1 1000 mg/L R1 pH 7.8 1000 mg/L R2 pH 7.8

1000 mg/L R3 pH 7.6

The results obtained are shown below:

Test Concentration (mg/L) % InhibitionCONTAINS CONFIDENTIAL BUSINESS INFORMATION

10 0

100 13

1000 R1 65

1000 R2 63

1000 R3 67

Based on these results the EC50 value for the notified substance is between 100 and 1000 mg/L.

II

. Read Across Summary and Justification

The notified substance is similar in structure to several analog substances and so is expected to have
similar toxicology. Following is a table summarizing the relevent materials used in this evaluation.

The notified substance and r ead across materials used to evaluate it :
Chemical Structure

N OTIFIED SUBSTANCE

A NALOG AND STARTING MATERIAL

ANALOG

R ESIDUAL IMPURITY

Boric Acid

CASRN 10043

- 35

- 3, 11113

- 50 -1

POTENTIAL HYDROLYSIS PRODUCT