SAT Report

PMN Number: P-15-0026

SAT Date: 10/24/2014

Print Date: 4/1/2015

Related cases: Yes

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1 2

 Persistence Bioaccum Toxicity Comments

1 11

Exposure Based Review:

Health: No

Ecotox: No

Routes of exposure: Health:

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-15-0026

FATE: 

Liquid with MP < 25 °C (E)

log Kow = 15.8 (E) 

S < 0.001 mg/L at 25 °C (E)

VP < 1.0E-6 torr at 25 °C (E)

BP > 400 °C (E)

H = 1.23E-3 (E)

log Koc = 9.98 (E)

log Fish BCF = 0.50 (E)

log Fish BAF = 0.11 (E) 
POTW removal (%) = 90 via sorption and biodeg; Analog: N,N-di(hydrogenated tallow-alkyl)-

1,3-propanediamine: ISO 11733, OECD 303A (CAS test): >99.999%/63d.

Time for complete ultimate aerobic biodeg = wk-mo

Sorption to soils/sediments = strong

Volatilization half-life from a standard river = 4 hrs

Volatilization half-life from a standard lake = 10 da

Atmospheric Oxidation Half-life = 0.7 hr via OH radical

PBT Potential: P1B1

*CEB FATE: Migration to ground water = slow

 Health:

 Health Summary: Absorption is nil based on physical/chemical properties. 

No concerns.

 Ecotox:

Test Organism Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 * 3.22 without 

humic acid

62.1 and 74.7 with 

humic acid 

daphnid 48-h LC50 *

green algal 96-h EC50 *

fish _ chronic value * 0.322 ACR10

daphnid _ chronic 

value

*

algal _ chronic 

value

*

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic 

Value

_

Ecotox Values Comments: Predictions are based on SARs for Aliphatic Amines; SAR 

chemical class = Aliphatic Amines; MW 579; liquid with BP >500 C (P); 

log Kow = 15.81 (E); S <0.000001 mg/L at 25 C (P); pH7; effective concentrations based on 

100% active ingredients and nominal concentrations; hardness <150.0 mg/L as CaCO3; and 

TOC <2.0 mg/L;

low concern for toxicity; 

Ecotoxicity Data Results:

Case Number: P-15-0026

The test substance information and study summaries below are for an analogous chemical, not 

the actual PMN substance.

Chemical Name: N,N-di(hydrogenated tallow-alkyl)-1,3-propanediamine

Trade Name: Duomeen 2HT

CAS RN: Not assigned
Initial Submission Review

Fish Ecotoxocity Tests:

(1) conducted a 

96-hour acute toxicity test in zebra fish (Danio rerio) with an analog of the PMN substance 

(purity: > 90%) under semi-static conditions with 48-hour renewal. This study was reported to 

follow OPPTS 850.1075 (1996). Following a range-finding test, two replicates of seven D. rerio 

were exposed to the test substance at nominal concentrations of 4.7, 8.5, 15.4, 27.7 and 50 mg/L. 

Due to the test animals displaying a higher sensitivity than expected based on the range finding 

test in the first 48 hours of testing, 2 additional concentrations, 1.45 and 2.61 mg/L, were tested 

separately to ensure all desired endpoints could be determined and excessive animal use with a 

repeat test be avoided. Therefore, a total of 7 concentrations were tested (1.45, 2.61, 4.7, 8.5, 

15.4, 27.7 and 50 mg/L). The same fish batch and identical test procedures and conditions were 

used. Based on measurements at 0 and 48 hours (before renewal), corresponding time-weighted 

mean measured test concentrations were 1.0, 2.4, 3.7, 8.2, 14.2, 26.4 and 47.3 mg/L (66.2 – 

97.0% of nominal values); concentrations of 14.2, 26.4 and 47.3 mg/L were based on 0-hour 

measurements only). 

Based on measurements at 48 and 96 hours (after renewal), nominal concentrations of 1.45, 2.61 

and 4.7 mg/L corresponded to time-weighted mean measured concentrations of 1.1, 2.2 and 6.4 

mg/L (77.2 – 135.8% of nominal values). Analytical monitoring was conducted using an 

LC-MS/MS method (LOD = 0.34 μg/L; LOQ = 1.14 μg/L). Two replicates of seven D. rerio 

were exposed to the dilution water control (Dutch Standard Water; DSW) in each of the two 

tests.

To prepare the 100 mg/L stock solutions (one for each test), the test substance (0.5 g) was first 

ultra sonicated in 150 mL of DSW for approximately 8 minutes. Care was taken to avoid 

excessive heating of the test substance. The stock solution formed was milk white in color. This 

was then added to 4.5 L of test media under agitation. The beaker used for preparation was filled 

and sonicated for a second and third time for one minute to remove residue on the glassware. All 

liquid was transferred to the stock solution flask in the normal manner. The pH of the stock 

solution was then reduced from 8.8 to 8.2 with HCl. The volume of the stock was then made up 

to 5 L with DSW to reach the desired concentration. An opaque solution without visible 

particles was obtained. The stock solutions were then used to prepare the test solutions. All 

preparation was conducted whilst agitating the media with magnetic stirrers. Aquaria were 

covered with glass plates and gently aerated during the test. When prepared, the test solutions

were slightly turbid with no particles. Slight precipitate was observed in the higher 

concentrations at 48 hours. 

Over the course of testing, temperature ranged from 20.4 – 21.1°C in control vessels, pH ranged 

from 8.0 – 8.3 and dissolved oxygen ranged from 8.1 – 9.4 mg/L. The dilution water hardness 

was 74.3 mg/L of CaCO3; TOC was ≤ 2.0 mg/L. A mean biomass loading rate of 0.54 g fish/L 

was reported. Mortality was 100% at concentrations ≥ 4.7 mg/L. The percent mortality at 0 

(control), 1.45 and 2.61 mg/L was 0, 0 and 7%, respectively. Reduced activity was observed at 

concentrations of 2.61, 4.7, 8.5 and 27.7 mg/L and loss of equilibrium was observed at 50 mg/L. 

At 2.61 mg/L, all surviving fish showed reduced activity. Based on nominal concentrations, the 
96-hour LC50 was 3.22 mg/L.

96-hour LC50 = 3.22 mg/L

(2) conducted a 

96-hour acute toxicity test in zebra fish (Danio rerio) with an analog of the PMN substance 

(purity: > 90%), mitigated with 20 mg/L humic acid, under semi-static conditions with 48-hour 

renewal. This study was reported to follow OPPTS 850.1085 (1996). Following a range-finding 

test, two replicates of seven D. rerio were exposed to a dilution water control (Dutch Standard 

Water [DSW] and 20 mg/L humic acid) or the test substance at nominal concentrations of 10, 18, 

32.4, 58.3 and 104 mg/L. Corresponding initial measured concentrations (based on C16,C18 

component) were 10.4, 17.2, 30.8, 60.5, 103.1 and 101.0 mg/L (95.0 – 104.0% of nominal). 

After the 48-hour renewal, the nominal concentration of 32.4 mg/L corresponded to a measured 

concentration of 30.1 mg/L. Analytical monitoring was conducted using an LC-MS/MS method. 

The LOD and LOQ were 0.14 and 0.45 μg/L for the C18,18 component; the LOD and LOQ were 

0.15 and 0.52 μg/L for the C18,C16 component; the LOD and LOQ were 0.34 and 1.14 μg/L for 

the C16,C16 component.

To prepare the 104 mg/L stock solutions, the test substance (0.52 g) was ultra sonicated in 100 

mL of DSW for approximately 8 minutes. Care was taken to avoid excessive heating of the test 

chemical. The stock solution formed was milk white in color. This was then added to 4.5 liters 

of test media containing 20 mg/L of humic acid under agitation. The beaker used for preparation 

was filled and sonicated for a second and third time for one minute to remove test substance 

residue on the glassware. All liquid was transferred to the stock solution flask in the normal 

manner. Visible reaction with the dissolved humic acid was observed forming a finely dispersed 

precipitate. The pH of the stock solutions was then reduced from 8.8 to 8.2 with HCl in line with 

the normal pH of the test media. The volume of the stock was then made up to 5 liters to reach 

the desired concentration. The stock was used as the highest concentration. Dilutions of the 

stock solution in freshly prepared DSW test medium containing 20 mg/L humic acid were used 

to prepare the desired nominal concentrations. All preparation was conducted whilst agitating 

the media with magnetic stirrers. Aquaria were covered with glass plates and gently aerated 

during the test. Interaction of the test substance with humic acid was clearly seen in all test 

replicates during the test period. A brown sediment was formed in all concentrations except the 

control.

Over the course of testing, temperature ranged from 20.4 – 21.1°C in control vessels, pH ranged 

from 8.1 – 8.4 and dissolved oxygen ranged from 7.9 – 9.1 mg/L. The dilution water hardness 

was 74 mg/L of CaCO3; TOC was ≤ 2.0 mg/L. A loading rate of 0.5 g fish/L was reported. The 

percent mortality at 0 (control), 10, 18, 32.4, 58.3 and 104 mg/L was 0, 0, 0, 0, 14 and 100%, 

respectively. Reduced activity was observed in 1 and 3 fish at 58.3 and 104 mg/L, respectively. 

Based on nominal concentrations, the 96-hour LC50 was 74.7 mg/L.

96-hour LC50 = 74.7 mg/L

(3) conducted a 

96-hour acute toxicity test in the common carp (Cyprinus carpio) with an analog of the PMN 

substance (purity: > 90%), mitigated by 20 mg/L humic acid, under semi-static conditions with 

48-hour renewal. This study was reported to follow OPPTS 850.1085 (1996). Following a 
range-finding test, two replicates of ten C. carpio were exposed to a dilution water control 

(Dutch Standard Water [DSW] and 20 mg/L humic acid) or the test substance at nominal 

concentrations of 14.3, 25.7, 46.3, 83.3 and 150 mg/L. Corresponding initial measured 

concentrations were 12.5, 21.6, 38.8, 73.3 and 128 mg/L (83.9 – 88.0% of nominal). After the 

48-hour renewal, the nominal concentration of 46.3 mg/L corresponded to a measured 

concentration of 39 mg/L. Analytical monitoring was conducted using an LC-MS/MS method 

(LOD = 0.26 μg/L, LOQ = 0.88 μg/L).

To prepare the 150 mg/L stock solutions, the test substance (0.750 g) was ultra sonicated in 150 

mL of DSW for approximately 10 minutes. Care was taken to avoid excessive heating of the test 

chemical. After every minute of sonication, the stock was allowed to cool for around 30 

seconds. When test substance particles were no longer visible, the power on the ultra sonic 

mixer was reduced to approximately 50% to prevent overheating. The stock solution formed 

was milk white in color. This was then added to 4.5 liters of test media containing 20 mg/L of 

humic acid whilst stirring. Visible reaction with the dissolved humic acid was observed forming 

a finely dispersed precipitate. The pH of the stock solutions was then reduced from 8.9 to 8.2 

with HCl in line with the normal pH of the test media. The volume of the stock was then made 

up to 5 liters to reach the desired concentration. The stock was used as the highest 

concentration. Dilutions of the stock solution in freshly prepared DSW test medium containing 

20 mg/L humic acid were used to prepare the desired concentration range in the aquaria prior to 

addition of the test animals. All preparation was conducted whilst agitating the media with 

magnetic stirrers. Aquaria were covered with glass plates and gently aerated during the test.

Over the course of testing, temperature ranged from 20.55 – 22.15°C in control vessels, pH 

ranged from 7.8 – 8.2 and dissolved oxygen ranged from 7.0 – 8.9 mg/L. The dilution water 

hardness was approximately 80 mg/L of CaCO3. A loading rate of 0.7 g fish/L was reported. 

The percent mortality at 0, 14.3, 25.7, 46.3, 83.3 and 150 mg/L was 0, 0, 0, 0, 100 and 100%, 

respectively. Sub-lethal effects (surfacing, lying on bottom) were observed at 83.3 and 150.0 

mg/L. Based on nominal concentrations, the 96-hour LC50 was 62.1 mg/L.

96-hour LC50 = 62.1 mg/L 

 submitted three ecotoxicity studies on analog chemical for 

PMN substance, P-15-0026. EPA considers the submitted analog to be reasonable and 

acceptable for P-15-0026. Also, the submitted studies are considered to be acceptable. These 

test results will be used to calculate the concentrations of concern (CoC) for P-15-0026. QSAR 

values are not used because the values predicted were anomaly. 

The acute CoC for P-15-0026 is 640 ppb (3220 ppb÷5(uncertainty factor)), based on the 

experimentally-derived 96-hour LC50 of zebra fish. The chronic CoC for P-15-0026 is 32 ppb 

(3220 ppb ÷ ACR of 10, and then another ÷ 10 (uncertainty factor)), based on the experimentally 

derived 96-h fish study value. 

The reason for using this fish chronic value for calculating chronic CoC is that the zebra fish test 

without the humic acid, the pH level was stable and the values measured were still in 

environmentally relevant range.
Acute CoC = 644 ppb

Chronic CoC = 32 ppb

Ecotox Reviewer: 

October 30, 2014

Factors Values Comments

Assessment Factor

10

Concentration of Concern 

(ppb)

32

SARs Aliphatic Amines

SAR Class Aliphatic Amines

Ecotox Category 

Ecotox Factors Comments: 

 SAT Chair: