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### Schaeffer, John

From: Boethling, Bob Sent: Tuesday, July 16, 2013 4:22 PM To: Lin, Chuantung; Schaeffer, John Cc: Lewis, Paul; Williamson, Tracy; Christian, Myrta Subject: RE: 22527-63-5 HPV 3 submissions -- M/FP BP VP W S Log P biodeg

I reviewed the ready biodegradation study for Benzo flex 1046 and first, thanks to Daniel for pointing out the mixture issue. This would not be evident from the ready bi odeg test report’s minimal characterization of the test material. It’s easy to see from the biodegradation curves in the r eport that the degradation process follows a biphas ic pattern. This could be easily explained by degradation of one par t of the molecule (say the benzoic acid, released b y initial hydrolysis), followed by degradation of other part(s), e.g. the alcohols. Of course there are two ester groups, an d several different molecules in the initial mixture, so in the end you are interpretationally challenged. The submitter says the data show the substance is readily biodegradable. Given the high observed degradation (94% ThOD) it’s unlikely that a significant amount of starting material remained undegraded. B ut if there is a need to be sure, for example if th e different components have very different toxicity profiles, t hen the study would need to be repeated using purif ied components. Here’s a rule of thumb. Do not test mixtures (with very few exceptions).

Robert Boethling, PhD Exposure Assessment Branch US EPA, Office of Pollution Prevention and Toxics 1200 Pennsylvania Ave, NW (7406M) Washington, DC 20460 202-564-8533 (P) 202-564-8892 (F) [EPI Suite] http://www.epa.gov/opptintr/exposure/pubs/episuite. htm

[FatePointer] http://esc.syrres.com/fatepointer/sea rch.asp

From: Lin, Chuantung
Sent: Tuesday, July 16, 2013 11:00 AM
To: Schaeffer, John; Boethling, Bob
Cc: Lewis, Paul; Williamson, Tracy; Christian, Myrta Subject: RE: 22527-63-5 HPV 3 submissions -- M/FP BP VP WS Log P biodeg



### Hi John,

I have reviewed the submitted test data (Freezing P oint, Boiling Point, Vapor Pressure, Log P, and Wat er Solubility endpoints) for the HPV3 chemical, 22527- 63-5. All these data and test methods are adequat e and acceptable to EPA. However, it needs to be noted that the test sample used for these testings was not a 100 % pure substance. Instead, it was a mixture chemic als which contained:

1) Propanoic acid, 2-methyl-, 3-(benzoyloxy)-2,2,4-tri methylpentyl ester [ 22527-63-5 ] (68.8 %) - This
chemical is the titled HPV3 Test substance 2) 1,3-Pentanediol, 2,2,4-trimethyl-, 1 ,3-dibenzoate [68052-23-3] (19.5 %) 3) 2,2,4-trimethyl-1 ,3-pentanediol, diisobutyrate [68 46-50-0 ] (7 %) 4) Misc. esters (4.2 %) 5) Volatiles (0.5%)2 

### If I remembered correctly that ICB had provided com ments before on the proposed test sample (a mixture of three chemicals (#1 -#3) listed above) that the Spo nsor proposed to be used for the HPV3 Test Rule requirements for all these five endpoints. However, I am not sure whether EPA has finally agre ed and accepted on such approach (i.e. using the mixture o f the three chemicals) to fulfill the testing requi rements for this HPV 3 Test Chemical.

Please let me know if you have other question.

Thanks!

Daniel

From: Schaeffer, John
Sent: Wednesday, June 26, 2013 9:59 AM
To: Lin, Chuantung; Boethling, Bob
Cc: Lewis, Paul Subject: 22527-63-5 HPV 3 submissions -- M/FP BP VP WS Log P biodeg

Daniel, Bob, good morning.

Attached for your respective reviews are physical-c hemical properties endpoint studies and a ready bio degradation study for the HPV3 test rule chemical Propanoic aci d, 2-methyl-, 3-(benzoyloxy)-2,2,4-trimethylpentyl ester (CASRN 22527-63-5). The submissions contain the following :

Physical Chemical Properties • Freezing Point (OECD 102) • Boiling Point (ASTM E 1719-05) • Vapor Pressure (ASTM E 1782-08) • Octanol/Water Partition Coefficient ( ASTM E 1147-92) • Water Solubility (40 FR 799.6784)

Environmental Fate – Ready Biodegradation • Ready Biodegradation (ISO 9408:1999(E ))

Please review these for data adequacy/acceptability by EPA. Please also let me know when we can antic ipate receiving your reviews.

Thank you.

John Schaeffer Senior Biologist USEPA/OPPT/CCD/CITB 1201 Constitution Ave, NW Washington, DC 20460 Mail Code: 7405M Phone: 202-564-8173