UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON

, D

. C

. 20460

June 7. 2011 O FFICE OF CHEMICAL SAFETY

AND P OLLUTION P REVENTION

MEMORANDUM

SUBJECT :

FROM:

T O:

T H RU :

In t roduction: Summary of Product Chemistry

, Environmental Fate, and Ecotoxicity Data for the Glycolic Acid Registration Review

Decision Document.

PC Code: 000101 DP Barcode : 383020

Deci s ion No.: 44082 1 Registration Nos. : See Tab l e I

Petition No(s).: NA Regulatory Action: Ecological Environmental Scapin.!!; Document for Regi s tration R e view

Risk Assessment Type: Case No

. : 4045 Single chemical

TXRNo .:N A CAS N o.: 79-14 -1

MRJD No s .: See Table 2 40 CFR: None

Srinivas Gowda, Microbiologist/Chemist 

## S**~** I.

### ~ V 

## 0..9..**~** Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (75 lOP)

Seiichi Murasaki, Chemical Review Manager Regulatory Management Branch I I

Antimicrobials Division (751 OP) 

# 4**~** ,4 

# if

Nader Elkassabany, Branch Chief

# ~~ Siroos Mostaghimi, Peer Reviewer

## ~ - 

# fltff6--v J L

___ _ Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (751 OP)

Glycolic acid

, also known as hydroxy acetic acid is a constituent of sugar cane
JUIce. It is a member of the group of compounds classified as alpha hydroxy acids
(AHAs). Pure (100%) glycolic acid is a co l orless

, odorless

, crysta llin e solid with high

water solubility. However, technical grade glycolic acid is usually so ld as a 68% s olution

which is a clear to li ght amber -c olored liquid with a mild burnt sugar odor.

The first product containing g l yco lic acid as an active ingredient was registered

wi t h the Agency on May 31, 200 I. Current l y, there are seven end-use products and one

Page I of9Page 2 of 9

manufacturing use product registered for use as a disinfectant/sanitizer for hard non

porous surfaces in residential and public access premises listed in Table 1

.

The m anufacturin g use product (68% a

. i

. ) is registered for use in the formulation

of liquid cleaning products or in the formulation of the following types of liquid antimicrobial cleaning product s: h ousehold disinfecting cleaners for use in cleaning toilet bowls, bathroo ms, floors, and other hard non

- porous surfaces. Industrial disinfecting cleaners for use in cleaning toilet bowls, urinals, bathrooms, floors, walls, ceilings, equipment, piping, and other hard non

- porous surfaces. Instituti onal and commercial premises d is infecting cleaners for use in cleaning toilet bowls, urinals, bathrooms, floors, walls, ceilings, and other hard non

- porous surfaces. Disinfecting cleaners for use in agricultural premises and food processing facilities and on food processing equipment.

End

- use products are registered for use in residential and public access premises

as a disinfectant/sanitizer for hard non

- porous household and domestics surfaces such as:

baby furniture (cribs, changing tables), stove tops, bathroom

- or

- restroom
surfa ces, bathtubs

, tables, cabinets, highchairs (non

- food contact areas), telephones, chairs, kitchen appliance[s] exteriors, light fixtures, toilet[s] exteriors, metal blinds, tubs, countertops

- or

- counters, microwave oven[s] exteriors, urinal exteriors, diaper pails, mirrors, washable kitchen surfaces, doorknobs, oven doors, [washable] walls, plastic laundry hampers

- or

- baskets, window(s) [sills], fiberglass bathtubs, range hoods, fiberglass shower and tub enclosures, refrigerator (exteriors), glass, s ealed fiberglass surfaces, (glass) [showers] [doors] [walls], sinks [and fixtures], glazed [bathroom

- or

- restroom] tiles, stainless steel or metal surfaces, glazed ceramic [tile(s)] bathrooms

- or

- restrooms and kitchens.

There are two active i ngredients in the g lycolic acid and salts case 4045; however, one of these active ingredients, sodium glycolate (PC Code 000103) , does not have registered products. This chemical is not being supported and is not addressed in this registration review. Glycolic acid is the only active ingredients in the case with active products. A Reregistration Eligibility Decision (RED) has not been issued by EPA for

g lycolic acid, and salts because of the initial registration date (i.e., post November 1984 mandated cutoff) they were not subject to the conduct of a RED action

.

Table 1. Registered Product s of Glycolic Acid

Registration # Registration

Name Company Name Formulation Type % of Active

Ingredient

5813

- 80 Clorox Patch The Clorox Company Soluble

Concentrate 1.5

5813

- 86 CBW The Clorox Company Impregnated

Materials 11.185

5813

- 87 X

- Men The Clorox Company Ready

- to

- Use

Solution 3.07Page 3 of 9

Registration # Registration

Name Company Name Formulation Type % of Active

Ingredient

5813

- 93 Show The Clorox Company Impregnated

Materials 11.185

5813

- 101 Tuck 3 The Clorox Company Ready

- to

- Use

Solution 1.75

71654

- 1 DuPontTM

Glyclean ® AM E.I. du Pont de Nemours

and Company Formulation

Intermediate 68

71654

- 2 DuPontTM Bowl

Cleaner E.I. du Pont de Nemours

and Company Ready

- to

- Use

Solution 9.5

71654

- 5 DuP ont TM KleanI t E.I. du Pont de Nemours and Company Ready

- to

- Use

Solut ion 5 .0

Science Findings

The Agency has conducted a review of the available product chemistry, environmental fate, and ecotoxicity data for glycolic acid. The findings are summarized

below.

Product Chemistry Summary

Common Name: Glycolic acid

Chemic al Name: Hydroxyacetic acid ; 2

- Hydroxyethanoic acid ; HAA CAS Registry Number: 79

- 14

- 1
OPP Chemical Code: 000 101
Case: 4045

Molecular Formula: C 2 H 4 O 3 Trade and Other Name: Glycolic acid Molecular weight: 76.05 g/mol

Molecular Structure: HO

- CH2

- COOH

Color: Colorless crystalline solid

. White, powdery solid ( 100 %) Clear, light amber

- colored liquid ( 68 % Technical solution)

Physical State: Solid ( 100 %)

. 68 % Technical solution is a liquid.

Odor: Odorless ( 100 %)

. 68 % Technical solution has a mild burnt sugar odor.Page 4 of 9

Stability: Stable under ordinary conditions of use and storage . Stable to normal and elevated temperature. Incompatible with bases, oxidizing agents and reducing agents.

Reactivity: Stable, will not decompose, polymerize, or bur n. Solid form m ay be combustible at high temperature

.

Oxidation/Reduction: Not applicable

- product does not contain any oxidizing or reducing agents. May react with oxidizers. Like most acids, it will react with active metals, such a s sodium or potassium , to release hydrogen gas.

Flammability: Not applicable

- product is not a liquid ( 100 %)

. As a 68 % solution, is non

- flammable.

Flash Point: 112 o C

Explodability: Product does not co ntain any explodable components

.

Storage Stability: Glycolic acid 6 8 % s olution is chemically stable in storage indefinitely. DuPont guarantees chemical stability for 2 years. If the material is cooled below 50 o F, crystals of glycolic acid will begin to form. These can be re

solubilized by warming with agitation with no ef fect on chemical composition.

Miscibility: Not applicable

- product is not an emulsifiable liquid intended to be mixed with p e troleum solvents

.

Corrosion Characteristics: Low c orrosiv ity to common materials of construction under

normal use conditions.

D ielectric breakdown voltage: Not Applicable

- product not intended for use around electrical equipment.

pH: 68 % Technical solution has a pH of 0.1 to 0. 5

UV/Visible absorption: Absorbs UV radiation up to approximately 310 nm, with a

maximum at 252 nm

. Gl ycolic acid is not susceptible to photochemical degradation

.

Viscosity: Not applicable product is not a liquid ( 100 %)

. Technical 68 % s olution: 11.28 m Pa/s at 15.6 ° C (60°F )

.

Melting point: 75

- 80°C (176 ° F) ( 100 %)

10°C (50 ° F) ( 68 % solution)Page 5 of 9

Boiling Point: Decomposes at > 100 °C (212°F) (100%)

112 ° C (234 ° F) ( 68 % solution)

Density: 1.2 5 g/ml at 2 5 °C ; 1.27 g/cm 3 ( 68 % solution) 10.6 lb/gal ( 68 % solution)

Specific Gravity: 1.49 at 25°C (100%)

Technical 68 % solution has a specific gravity of 1 .265 at

20 ° C

Dissociation Constant: Acidity (p K
a ) (pH of 50% dissociation) = 3.83 at 25°C

K
a = 1. 48 x 10 - 4 at 25° C

Technical 68 % s olution at 25°C: 1.5 x 10 - 4

log K
ow :

- 1. 11 at 19 ° C

Technical 68 % Solution

– not applicable Glycolic a cid is polar

.

Solubilit ies : Solubility in water 0.1 g/ml, clear Highly soluble in water Glycolic Acid is completely soluble in water ( 68 % Solution).

Solubility in organ ic solvents

Alcohols

Chloroform

Acetone

Acetic acid Ethyl acetate
Methanol

E ther

Sensitive: Hygroscopic ; Deliquescent (100%)

Vapor Pressure: 2.0 x 10 - 2 mm Hg at 25 ° C (extrapolated) ( 100 %)

0.017 mm Hg at 25°C (Source: EPI Suite) The vapor pressure of 6 8 % Technical solution is 11.2 m m Hg at 25°C

.

Henry's Law Constant: 8.5x 10 - 8 atm

- cu m/mole at 25° C (est imated )

Enf orcement Analytical Method s : Spectrophotometric method Thin layer chromatographyPage 6 of 9 All product chemistry data requirements have been sati sfied for the active ingredient glycolic acid

. ( Source: MRID 44556001 )

Environmental Fate and Ecological Effects Summary

The Agency has not received any guideline environmental fate studies on glycolic

acid , and no studies are required at this time. Unless a toxicological concern is identified, the Agency believes that, based on the currently registered use pattern of glycolic acid for

household use as a disinfectant/sanitizer for hard non

- porous surfaces in homes , guideline

environmental fate or ecological effects studies are inappropriate and unnecessary based on the following grounds.

Glycolic acid occurs widely in nature. Based on the available data and literature information on glycolic acid, its natural presence in human body, sugar cane, sugar beets, several fruits (pineapple, cantaloupe, unripe grapes) and vegetables (parsley, celery, beans), as well as in a wide variety of common foods including coffee, expected use patterns, safe history of use as indirect food additive, extensive use in cosmetics and skin care products, and because glycolic acid is practically nontoxic to nontarget organisms, the Agency has determined that environmental fate and ecological effects risk assessments are not needed for the current use of glycolic acid. Glycolic acid i s approved by the Food and Drug Administrations (FDA) as an indirect food additive for u se in food packaging adhesives. Also, the amount of glycolic acid disinfecting cleaners used in cleaning toilet bowls, bathrooms, floors, and other hard non

- porous sur faces would not result in environmental concentrations that would reduce the environmental margin of safety.

The available environmental fate and ecotoxicity data for glycolic acid from

literature indicate that this compound is expected to be readily biod egradable in the environment and is of low toxicity to fish and other aquatic organisms, mammals and birds. Therefore, EPA believes that the currently registered use pattern of glycolic acid

as a household disinfectant/sanitizer for hard non

- porous surfac es will not cause unreasonable adverse effects on the environment, and is not anticipated to cause adverse effects on fish, invertebrates, plants or wildlife.

Glycolic acid is a well

- known chemical that is not subject to hydrolysis based on

its chemical s tructure (lack of hydrolysable functional groups) and does not contain chromophores that absorb at wavelengths >290 nm and therefore is not expected to be susceptible to direct photolysis by sunlight. Because it has a pK

a of 3.83 , it is expected to

exist as negatively

- charged chemical specie s (anion) in the environmentally relevant pH

range and will be highly mobile in soil based on the estimated K

oc of 6 . However, it will

have a limited tendency to volatilize from soil or water based on the estimated Hen ry’s

Law constant of 8.5x10 - 8 atm

- m 3 /mole . The biodegradability of glycolic acid has been extensively studied and it is expected to be readily biodegradable (>90% mineraliz ation in less than 2 weeks) in the environment. From the experimental data on

bioc oncentration (est. BCF of 3.2)

, and rate of biodegradation, a low potential for bioaccumulation is to be expected.Page 7 of 9 Water Quality

Glycolic acid is not identified as a cause of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act, based on information provided

at the Agency’s National Pesticides Cause of Impairment of Waters website (searched April 7, 2011) 1

. In addition, no Total Maximum Daily Loads (TMDL) have been developed for glycolic acid , based on informatio n provided at the Agency’s National Pesticide TMDL web site (searched April 7, 2011) 2

. More information on impaired

water bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/

. The Agency

invites sub mission of water quality data for this pesticide. To the extent possible, data should conform to the quality standards in Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP’s Registra tion Review Risk Assessment and Management Process (see: http://www.epa.gov/oppfead1/cb/ppdc/2006/november06/session1

- sop.pdf ), in order to ensure they can be used quant itatively or qualitatively in pesticide risk assessments.

Ecological Effects Data Summary

The Agency has reviewed six ecotoxic ity studies for glycolic acid

. These data are adequate to provide the Agency with sufficient information to determine approximate label precautions, and may be seen in Table 2

.

Toxicity to Birds

Available data indicate that glycolic acid is practically non

- toxic to birds on a

sub

- acute dietary basis.

Toxicity to Mammals Glycolic acid is slightly toxic to mammals on an acute oral ba sis

.

Glycolic acid has no effect on reproductive performance in one

- generation reproduction study in rats.

Toxicity to Aquatic Animals On an acute basis, glycolic acid is practically non

- toxic to freshwater fish and

i nvertebrates.

Toxicity to Aquatic Pl

ants Algal toxicity data indicate that glycolic acid is not detrimental below 20,000 ppb (20 ppm).

1 http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p _cause_group_id=885

2 http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_g roup_id=885&p_p ollutant_group_name=PESTICIDESPage 8 of 9

Table 2 . Ecotoxicity Data Summary for Glycolic A cid

Guide

Line Common

Name Taxonomic

Name Test

Type %

a i Study Time Dose Type Toxi

c ity Tox

Level N OEL St udy

Status Tox icity

Category M RID

No. Avian Subacute Dietary Toxicity

8 5 0.2200 (71

- 2) Bobwhite quail Colinus

virginianus D 8 day LC 50 >500 0 ppm Supplemental Practically

non

- toxic 110131

8 5 0.2200 (71

- 2) Mallard

d uck Anas

platyrhynchos D 8 day LC 50 >5 00 0 ppm Supplemental Practically

non

- toxic 110129

Freshwater Fish Acute Toxicity

850.1075 (72

- 1) Bluegill

sunfish Lepomis

macrochirus S 70

-

90 48 hr EC 50 93 ppm Supplemental Slightly

toxic Lit.

850.1075 (72

- 1) Fathead

minnow Pimephales

promelas S 70

-

90 96 hr LC 50 164 ppm Supplemental Practically

nontoxic Lit.

Freshwater Invertebrate Acute Toxicity

850.1010 (72

- 2) Daphnia Daphnia

magna S 98 48 hr EC 50 141 ppm Supplemental Practically

nontoxic Lit.

Toxicity to Aquatic Plants

850.5400
( OECD

201 ) Gree n Algae Selenastrum

capricornutum S 98 72 hr EC 50 ( g rowth)

EC 50 ( biomass) 44

21.6 ppm 20 Supplemental Algistatic Lit

.

Mammal ian Acute Oral Toxicity

870.1100 (81

- 1) Sprague

Dawley Rat 70 LD 50 1938 mg/kg

bw Acceptable Slighty

toxic (III) 4497530 1

M ammalian Subchronic Oral Toxicity

870.3100 (82

- 1) Albino rat 70 90 d ay LOAEL 300 mg/k g

bw/ day 150 for systemic toxicity Acceptable Decreased

food consumption, body weight & body weight gain;

and renal insufficiency 44975304

One

- Generation Reproductio n in Rats

870.3550

NGL N Albino Rat 70 Follow

ing a

90

- day feeding study LOAEL Not

attained mg/kg

bw / day ≥600 for reproduc tive toxicity A cceptable No effect on Reproductive performance 44975304

Oral Developmental T oxicity

83

- 3 Crl:CD ® BR

Rat s 99.6 21 day LO EL

Maternal

Develop

m ental 300

3 00 mg/kg

bw / day

150

150 Acceptable N ot

considered

de velopmental
hazard to the
conceptus 44589501

Test Type

— D: dietary; S: static

Tox Level

—

ppm: parts per million (equivalent to milligrams per kilogram

- diet (mg/kg

- diet) for dietary exposure and milligrams per liter (mg/L) for aquatic exposures) Categories o f acute toxicity for aquatic organisms (U.S. EPA, 2004) based on EC 50 /LC 50 (mg/L): < 0. 1 very highly toxic; 0.1

- 1 highly toxic; >1

- 10 moderately toxic; >10

- 100 slightly toxic; >100 practically nontoxic. Toxicity categories for terrestrial plants have not b een defined. Categories of acute toxicity to terrestrial animals, avian and mammalian (U.S. EPA, 2004). LC 50 (ppm): < 50 very highly toxic; 50

- 500 highly toxic; 501

– 1000 moderately toxic; 1001

- 5000 slightly toxic; >5000 practically non

- toxic. LD 50 (mg/ kg bw): < 10 very highly toxic; 10

- 50 highly toxic; 51

- 500 moderately toxic; 501

- 2000 slightly toxic; >2000 practically non

- toxic.

Lit

— Robust Summary for Glycolic A cid dated April 2, 2002

NGL N

— Non

- guideline studyPage 9 of 9 Ecotoxicity data are adequate to prov ide the Agency with sufficient information to determine appropriate label precautions.

Ecological Effects Risk Assessment

Based on the environmental fate profile of glycolic acid, exposures from labeled

uses in household premises as a disinfectant/saniti zer for hard non

- porous surfaces are unlikely to reach concentrations necessary to create adverse effects in aquat ic organisms. Glycolic acid does not appear to be toxic to nontarget organisms (see Table 2) and adverse effects from labeled uses is not expe cted. Taking into account the rapid biodegradability, low bioaccumulation potential, low

- toxicity to non

- toxicity to most aquatic species, and the rapid metabolism of this substance, glycolic acid will pose no adverse risk to aquatic organisms. Therefore, t he Agency does not anticipate the need to conduct environmental fate and ecological risk assessments for glycolic acid use patterns

listed in this document.

Threatened and Endangered Species Effects Determination

A quantitative ecological risk assessmen t was not conducted on the glycolic acid use patterns described in this document. T he Agency has made a ―no effect‖ finding for the use pattern of glycolic acid based on favorable environmental fate and ecotoxicology

data.

Adverse Ecological Incidents

Th ere are no re ported incidents in the Agency' s Ecological Incident Information System (EIIS) regarding glycolic acid. The absence of documented incidents does not necessarily mean that such incidents did not occur.

Environmental Fate and Ecotoxicity Data Gaps and Anticipated Work

None.