United States Chemical Safety September 2011

Environmental Protection and Pollution Prevention

Agency (7510P)

Amines, C10-16 alkyldimethyl, N-oxides

Summary Document:

Registration Review: Initial Docket

September 2011
Docket Number: EPA-HQ-OPP-201 1-0616 

www.regulations.gov 

Amines, ClO- 16 alkyldimethyl, N-oxides 

Summary Document 

Registration Review: Initial Docket 

September 2011 

Case # 5003 

n Harrigan-Farrel y 

irector, Antimicrobials Division 

Date: 

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TABLE OF CONTENTS

Amines, C10-16 alkyldimethyl, N-oxides Registration Review Team...................................4

I. Preliminary Work Plan .....................................................................................................5

II. Fact Sheet ......................................................................................................................12

III. Summary of Anticipated Data Requirements..............................................................15

IV. Appendix A..................................................................................................................16

________________________________________

Please Note

This Preliminary Work Plan and Fact Sheet summarize the Environmental Protection Agency's 

current position based on the following documents:

1. Amines, C10-16 alkyldimethyl, N-oxides. Product Chemistry, Environmental Fate, and 

Ecological Effects Scoping Document for Registration Review. September 7, 2011

2. Summary of Human Health Effects Data for the Alkyl (C10-C16) Dimethyl Amine Oxide 

(ADAO) Registration Review Decision Document. August 24, 2011

Additional supporting documents for the Amines, C10-16 alkyldimethyl, N-oxides Case may be 

found in the registration review docket EPA-HQ-OPP-2011-0616 located on the internet at

www.regulations.gov.
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Amines, C10-16 alkyldimethyl, N-oxides Registration Review Team

Nathan Mottl

Human Health & Environmental Effects

Srinivas Gowda

Seiichi Murasaki

Risk Management

Lance Wormell

Philip Ross

Office of General Counsel
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I. Preliminary Work Plan -- Amines, C10-16 alkyldimethyl, N-oxides

The Food Quality Protection Act (FQPA) of 1996 mandated a registration review program. All 

pesticides distributed or sold in the United States generally must be registered by the U.S. 

Environmental Protection Agency (USEPA, EPA, or the Agency) based on scientific data 

showing that they will not cause unreasonable risks to human health or the environment when 

used as directed on product labeling. The registration review program is intended to make sure 

that, as the ability to assess risk evolves and as policies and practices change, all registered 

pesticides continue to meet the statutory standard of no unreasonable adverse effects to human 

health or the environment. Changes in science, public policy, and pesticide use practices will 

occur over time. Through the registration review program, the Agency periodically reevaluates 

pesticides to make sure that as change occurs, products in the marketplace can be used safely. 

Information on this program is provided at 

Introduction:

http://www.epa.gov/oppsrrd1/registration_review/.

The Agency is implementing the registration review program pursuant to Section 3(g) of the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and will review each registered 

pesticide every 15 years to determine whether it continues to meet the FIFRA standard for 

registration. The Agency will consider benefits information and data as required by FIFRA. The 

public phase of registration review begins when the initial docket is opened for each case. The 

docket is the Agency’s opportunity to state what it knows about the pesticide and what additional 

risk analyses and data or information it believes are needed to make a registration review 

decision. After reviewing and responding to comments and data received in the docket during 

this initial comment period, the Agency will develop and commit to a final work plan and 

schedule for the Amines, C10-16-Alkyldimethyl,N-Oxides case.

The first product containing amines, C10-16 alkyldimethyl, N-oxides (known chemically as alkyl 

dimethylamine oxides or ADAO) (PC Code 000439) as an active ingredient was registered in 

the United States in 1999. Currently, only one product containing this active ingredient is 

registered with EPA. The only registered antimicrobial use of ADAO is as an antibacterial

dishwashing detergent in residential premises. ADAO currently has an inert tolerance exemption 

under 40 CFR 180.910 for use as a surfactant in pesticide formulations. EPA does not maintain 

a tolerance or exemption from the requirement of a tolerance for residues for the ADAO active 

ingredient. During registration review, the Agency will determine if any tolerances or 

exemptions from the requirement of a tolerance are needed for antimicrobial uses.

ADAO was not subject to reregistration because the first pesticide product containing it was 

registered after November 1, 1984.

Documents associated with the registration review of ADAO can be viewed at 

www.regulations.gov in docket EPA-HQ-OPP-2011-0616. Below is a summary of the issues 

relevant to this registration review case.

The Agency anticipates the need to conduct a comprehensive ecological risk assessment, 

including an endangered species risk assessment, for all uses of ADAO. The Agency anticipates 

Anticipated Risk Assessment and Data Needs:
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the need to conduct a human health risk assessment. The Agency anticipates needing additional 

data for use in conducting the registration review for ADAO.

Ecological Risk:

• The Agency has not conducted a risk assessment that supports a complete endangered 

species determination for ADAO. The ecological risk assessment planned during 

registration review will allow the Agency to determine whether ADAO’s use has 'no 

effect' or 'may affect' federally listed threatened or endangered species (listed species) or 

their designated critical habitats. When an assessment concludes that a pesticide’s use 

'may affect' a listed species or its designated critical habitat, the Agency will consult with 

the U.S. Fish and Wildlife Service and/or National Marine Fisheries Services (the 

Services), as appropriate.

• The Agency anticipates the need to require the following additional ecological data for 

use in the registration review of ADAO.

850.2100 -- Avian acute oral toxicity test

850.5400 -- Algal Toxicity Tier I and Tier II

• The Agency anticipates the need to require the following additional environmental fate 

data for use in the registration review of ADAO.

835.1110 -- Activated Sludge Sorption Isotherm

835.2120 -- Hydrolysis

835.2240 -- Photodegradation in water

835.3110 -- Ready Biodegradability

835.3220 -- Porous Pot Test

835.3240 -- Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units

835.3280 -- Simulation Tests to Assess the Biodegradability of Chemicals Discharged 

to Wastewater

850.6800 -- Modified activated sludge, respiration inhibition test1

• For more information, please refer to Amines, C10-16 alkyldimethyl, N-oxides. Product 

Chemistry, Environmental Fate, and Ecological Effects Scoping Document for 

Registration Review, located in the docket.

Human Health Risk: 

 1

Based on the results of any required Activated Sludge Respiration Inhibition Test (ASRI), registrants may be able 

to request that EPA waive the requirements for additional biodegradation tests. If the ASRI test EC50 is less than or 

equal to 20 mg/L, registrants would need to perform one of 835.3220, 835.3240, or 835.3280. If the ASRI test EC50

is greater than 20 mg/L, registrants would need to perform either (i) 835.3110 or (ii) one of 835.3220, 835.3240, or 

835.3280. If the antimicrobial reaches pass levels for 835.3110 (i.e., 70% removal of dissolved organic carbon 

(DOC) and 60% removal of theoretical oxygen demand (ThOD) or theoretical carbon dioxide (ThCO2) production 

for respirometric methods) in a 10-day window within the 28-day period of the test, registrants would be able to 

request that EPA waive the requirements for additional biodegradation tests. If the antimicrobial does not pass 

835.3110, the registrants would need to perform one of 835.3220, 835.3240, or 835.3280.
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• The most recent human health risk assessments for ADAO were completed in 1999, in 

support of initial registration.

• The Agency anticipates the need to require the following additional human health data 

for use in the registration review of ADAO.

875.1200 -- Dermal indoor exposure

875.1600 -- Application exposure data reporting and calculations

875.1700 -- Product use information

875.2800 -- Description of human activity

• For more information, please refer to Summary of Human Health Effects Data for the 

Alkyl (C10-C16) Dimethyl Amine Oxide (ADAO) Registration Review Decision 

Document, located in the docket.

Product Chemistry:

• The Agency does not anticipate the need to require additional product chemistry data for 

this registration review case at this time.

• For more information, please refer to Amines, C10-16 alkyldimethyl, N-oxides. Product 

Chemistry, Environmental Fate, and Ecological Effects Scoping Document for 

Registration Review, located in the docket.

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse 

outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and 

chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, 

reproductive, and general or systemic toxicity. These studies include endpoints which may be 

susceptible to endocrine influence, including effects on endocrine target organ histopathology, 

organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, 

and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and 

chronic studies that assess growth, developmental and reproductive effects in different 

taxonomic groups. As part of its most recent registration decision, EPA reviewed these data and 

selected the most sensitive endpoints for relevant risk assessment scenarios from the existing 

hazard database. However, as required by FFDCA section 408(p), ADAO is subject to the 

endocrine screening part of the Endocrine Disruptor Screening Program (EDSP). 

Endocrine Disruptor Screening Program

EPA has developed the EDSP to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect

produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator 

may designate.” The EDSP employs a two-tiered approach to making the statutorily required 

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a 

chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal 

systems. Chemicals that go through Tier 1 screening and are found to have the potential to 

interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA 
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will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 

testing is designed to identify any adverse endocrine-related effects caused by the substance, and 

establish a dose-response relationship between the dose and the E, A, or T effect.

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between October 

2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 chemicals, 

which contains 58 pesticide active ingredients and 9 inert ingredients. ADAO is not among the 

group of 58 pesticide active ingredients on the initial list to be screened under the EDSP.

Accordingly, as part of registration review, EPA will issue future EDSP orders/data call-ins, 

requiring the submission of EDSP screening assays for ADAO. For further information on the 

status of the EDSP, the policies and procedures, the list of 67 chemicals, future lists, the test 

guidelines and the Tier 1 screening battery, please visit our website: http://www.epa.gov/endo/.

EPA has created the following estimated timeline for the completion of the Amines, C10-16-

alkyldimethyl,N-oxides registration review:

Timeline

Anticipated Schedule

Activities Estimated Month/Year

Phase 1: Opening the docket

Open Public Comment Period for Docket September 2011

Close Public Comment Period for Docket November 2011

Phase 2: Case Development

Develop Final Work Plan (FWP) March 2012

Issue DCI March 2013

Data Submission March 2014

Open Public Comment Period for Preliminary Risk Assessments September 2015

Close Public Comment Period for Preliminary Risk Assessments October 2015

Phase 3: Registration Review Decision

Open Public Comment Period for Proposed Reg. Review Decision March 2016

Close Public Comment Period for Proposed Reg. Review Decision May 2016

Final Decision and Begin Post-Decision Follow-up 2016

Total (years) 5

The public is invited to comment on EPA’s Preliminary Work Plan and rationale. The Agency 

will carefully consider all comments as well as any additional information or data provided in a 

timely manner prior to issuing a final work plan for the Amines, C10-16-alkyldimethyl,N-oxides

registration review case.

Guidance for Commenters:

Trade Irritants:
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Through the registration review process, the Agency intends to solicit information on trade 

irritants and, to the extent feasible, take steps toward facilitating irritant resolution. Growers and 

other stakeholders are asked to comment on any trade irritant issues resulting from lack of 

Maximum Residue Limits (MRLs) or disparities between U.S. tolerances and MRLs in key 

export markets, providing as much specificity as possible regarding the nature of the concern. 

ADAO 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 

http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=88

5. In addition, no Total Maximum Daily Loads (TMDL) have been developed for ADAO, based 

on information provided at 

http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id

=885&p_pollutant_group_name=PESTICIDES.

Water Quality:

More information on impaired water bodies and TMDLs can be found at 

http://www.epa.gov/owow/tmdl/. The Agency invites submission 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 Registration Review Risk Assessment and Management Process (see: 

http://www.epa.gov/oppsrrd1/registration_review/water_quality_sop.htm), in order to ensure the 

data can be used quantitatively or qualitatively in pesticide risk assessments.

EPA seeks to achieve environmental justice, the fair treatment and meaningful involvement of all 

people, regardless of race, color, national origin, or income, in the development, implementation, 

and enforcement of environmental laws, regulations, and policies. To help address potential 

environmental justice issues, the Agency seeks information on any groups or segments of the 

population who, as a result of their location, cultural practices, or other factors, may have 

atypical, unusually high exposure to ADAO compared to the general population. Please 

comment if you are aware of any sub-populations that may have atypical, unusually high 

exposure compared to the general population.

Environmental Justice:

EPA must rely upon information of appropriate quality and reliability for each decision made by 

the Agency. In the Office of Pesticide Programs (OPP), the evaluation process for a pesticide 

chemical traditionally begins with the applicant’s submission of a set of studies conducted with 

the specific pesticide chemical of interest. The use of the results of such testing (measured data) 

is a logical, scientifically rigorous process that identifies the physical, chemical, and 

environmental fate properties of the pesticide, as well as the dose and endpoints at which an 

adverse effect can occur in various animal species. 

Structure Activity Relationships: 

Today, there is significant interest in alternative techniques, i.e., techniques other than data 

generation that could significantly inform the Agency’s decision-making process. Recently, OPP 

has made increasing use of structure activity relationship (SAR) as part of its regulatory 
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decision-making process. In the SAR process, a chemical's molecular structure is compared to 

that of other chemicals for which data are available. These structural similarities are then used to 

make predictive judgments about a chemical’s physical, chemical, and biological properties. 

Thus, the chemical’s physical, chemical, and biological properties are a function of (or directly 

related to) the chemical’s molecular structure. Quantitative SAR is referred to as QSAR. To 

develop a QSAR, a selected set of measured data on a single physical, chemical, or biological 

property is used to derive a model (an equation) to predict the value of that property. 

Since SAR assessments and QSAR modeling are another set of tools that are available to Agency 

scientists, OPP has begun a process shift that envisions shifting from the current study-by-study 

approach to an approach in which the use of predicted data, generated using validated models, is 

considered along with information from open literature and studies specifically generated under 

Part 161 requirements. All relevant information would be considered as part of a weight-of-theevidence evaluation. 

At this time, EPA believes that for certain endpoints, especially physical/chemical and fate 

properties, that SAR and QSAR might be effectively utilized to fulfill these data requirements 

for many antimicrobial pesticide chemicals. When considering biological properties, at this time, 

EPA believes that SAR and QSAR can be most effectively utilized in the evaluation of 

chemicals that exhibit lower toxicity for human health and/or ecotoxicity parameters. This is 

appropriate because the risk assessment for lower toxicity chemicals can be stream-lined, i.e., a 

screening-level assessment procedure rather than multiple tiers of assessments with progressively 

more data requirements.

If stakeholders believe that submission of predicted data can fulfill one of the data needs for the 

Amines, C10-16-Alkyldimethyl,N-Oxides case, then the Agency invites submission of this 

information. The submitter would be expected to supply a rationale describing the utility of the 

information and provide documentation on the scientific validity of the information. The 

determination that the predicted data fulfills the data requirement would be at the sole discretion 

of the Agency. Pre-submission consultation with the Agency is encouraged.

Stakeholders are also specifically asked to provide available information and data that will assist 

the Agency in refining its risk assessments, including any species-specific ecological effects 

determinations. The Agency is interested in receiving the following information:

Additional Information:

1. Confirmation on the following label information:

a. Sites of application

b. Formulations

c. Application methods and equipment

d. Maximum application rates

e. Frequency of application, application intervals and maximum number of 

applications

f. Geographic limitations on use

2. Use or potential use distribution

3. Use history
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4. Usage/use information for non-agricultural uses (e.g., materials preservation)

5. Typical application interval

6. State or local use restrictions

7. Ecological incidents (non-target plant damage and avian, fish, reptilian, amphibian 

and mammalian mortalities) not already reported to the Agency

8. Monitoring data

Next Steps:

After the 60-day comment period closes in November 2011, the Agency will review and respond 

to any comments received in a timely manner, and then issue a Final Work Plan for the Amines, 

C10-16 alkyldimethyl, N-oxides case. 
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II. Fact Sheet

• Active Ingredient: alkyl dimethylamine oxides (amines, C10-16 alkyldimethyl, N-oxides)

Background Information:

• Case number: 5003

• PC Code: 000439

• CAS number: 70592-80-2

• Technical registrants: Proctor & Gamble

• First approved for use in a registered product: 1999

• ADAO currently has an inert tolerance exemption under 40 CFR 180.910 for use as a 

surfactant in pesticide formulations. EPA does not maintain a tolerance or exemption 

from the requirement of a tolerance for residues for the ADAO active ingredient. During 

registration review, the Agency will determine if any tolerances or exemptions from the 

requirement of a tolerance are needed for antimicrobial uses.

• Antimicrobials Division Chemical Review Manager (CRM): Seiichi Murasaki, 

murasaki.seiichi@epa.gov

• Antimicrobials Division Product Manager (PM): Velma Noble, noble.velma@epa.gov

• Chemical Structure: 

(ADAO – shortest and longest chains illustrated)

• The only registered antimicrobial use of ADAO is as an antibacterial dishwashing 

detergent in residential premises.

Use & Usage Information:

Please refer to Amines, C10-16 alkyldimethyl, N-oxides. Product Chemistry, Environmental 

Fate, and Ecological Effects Scoping Document for Registration Review, located in the docket, 

for a detailed discussion of the ecological risk assessments.

Ecological Risk Assessment Status:

• The Agency has not conducted a risk assessment that supports a complete endangered 

species determination for ADAO.

• ADAO is practically non-toxic to mammals on an acute oral basis; and moderately toxic 

to freshwater fish and invertebrate. For use in conducting an ecological risk assessment, 

including an endangered species assessment for all uses, the Agency anticipates requiring 

acute avian oral toxicity data and algal toxicity data.

Human Health Risk Assessment Status:
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The following are key findings of the recent human health risk assessments for Amines, C10-16-

alkyldimethyl,N-oxides. Please refer to Summary of Human Health Effects Data for the Alkyl 

(C10-C16) Dimethyl Amine Oxide (ADAO) Registration Review Decision Document, located in 

the docket, for a detailed discussion of the human health risk assessment.

Hazard Characterization:

• ADAO exhibits moderate acute toxicity (toxicity category II and III) and is a severe eye 

and skin irritant (Category I) based on acute oral and dermal studies in animals.

Dietary (Food and Water):

• Food and Drug Administration (FDA) worst case calculations described in "Sanitizing 

Solutions: Chemistry Guidelines for Food Additive Petitions" were used to estimate 

dietary exposure for a human health risk assessment in 1999. Acute and chronic dietary 

risks were assessed and found to be acceptable for all subpopulations listed. A new 

indirect dietary assessment is not anticipated to be required. A drinking water risk 

assessment was conducted for registration because, although likely to be infrequent, 

dietary exposures to ADAO from drinking water may occur from residues on a cup 

washed with ADAO. A new drinking water assessment is not anticipated to be required.

Residential:

• Assessments of residential risk are planned for registration review because potential 

exposure is expected through the dermal route resulting from the use of the dishwashing 

detergent.

Aggregate:

• In examining aggregate exposure, EPA takes into account available and reliable 

information concerning exposures to residues in food and drinking water, nonoccupational pesticide exposures, and inert uses. An aggregate risk assessment for 

ADAO is expected to be needed to assess aggregate exposures from dietary sources (food 

and water) and residential dermal exposures.

Occupational:

• Occupational handler exposure is not expected with currently registered uses, and an 

occupational risk assessment will not be conducted during registration review.

Cumulative:

• EPA does not have, at this time, available data to determine whether ADAO has a 

common mechanism of toxicity with other substances or how to include this pesticide in 

a cumulative risk assessment. For the purposes of this Registration Review, EPA has 

assumed that ADAO does not have a common mechanism of toxicity with other 

substances when used as an antimicrobial as registered.
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Ecological:

Incidents:

• No ADAO ecological incidents have been reported in the Agency’s Ecological Incident 

Information System (EISS).

Human Health:

• No ADAO human poisoning incidents have been reported in OPP’s Incident Data System 

(IDS).

Tolerances and International Harmonization:

• ADAO currently has an inert tolerance exemption under 40 CFR 180.910 for use as a 

surfactant in pesticide formulations. EPA does not maintain a tolerance or exemption 

from the requirement of a tolerance for residues for the ADAO active ingredient. During 

registration review, the Agency will determine if any tolerances or exemptions from the 

requirement of a tolerance are needed for antimicrobial uses.

• There are no outstanding data call-in (DCI) requirements for ADAO.

Data Call-In Status:

Labels:

Registered products, including EPA registration numbers are provided in Table 1 below. For 

future reference, during registration review a list of product registration numbers will be included 

in the docket. Product registration labels may be obtained from the Pesticide Product Label 

System (PPLS) website at: http://oaspub.epa.gov/pestlabl/ppls.home.

Table 1. Registered Products – ADAO

Registration # Registration Name Company Name Formulation Type % A.I.

3573-62 Cleaning Magic II Proctor & Gamble Ready to use 

solution

5.2
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III. Summary of Anticipated Data Requirements – ADAO

The table below summarizes anticipated data needs for the Amines, C10-16 alkyldimethyl, Noxides Case in Section I of this document (Preliminary Work Plan), Amines, C10-16 alkyldimethyl, 

N-oxides. Product Chemistry, Environmental Fate, and Ecological Effects Scoping Document 

for Registration Review, and Summary of Human Health Effects Data for the Alkyl (C10-C16) 

Dimethyl Amine Oxide (ADAO) Registration Review Decision Document.

Table 2. Summary of Anticipated Data Requirements – ADAO

Guideline

Number Anticipated Data Requirement Test Material

Estimated Timeframe 

(Measured in months 

from DCI Receipt)

850.2100 Avian acute oral toxicity TGAI 12

850.5400 Algal Toxicity Tier I and Tier II TGAI 12

835.1110 Activated Sludge Sorption TGAI 12

835.2120 Hydrolysis TGAI 12

835.2240 Photodegradation in water TGAI 12

835.3110 Ready Biodegradability TGAI 12

835.3220 Porous Pot Test TGAI 12

835.3240

Simulation Test – Aerobic Sewage Treatment: A. 

Activated Sludge Units

TGAI 12

835.3280

Simulation Tests to Assess the Biodegradability of 

Chemicals Discharged to Wastewater

TGAI 12

850.6800 Modified activated sludge, respiration inhibition test 2 TGAI 12

875.1200 Dermal indoor exposure TGAI 12

875.1600 Application exposure data TGAI 12

875.1700 Product use information TGAI 12

875.2800 Description of human activity TGAI 12

 2

Based on the results of any required Activated Sludge Respiration Inhibition Test (ASRI), registrants may be able 

to request that EPA waive the requirements for additional biodegradation tests. If the ASRI test EC50 is less than or 

equal to 20 mg/L, registrants would need to perform one of 835.3220, 835.3240, or 835.3280. If the ASRI test EC50

is greater than 20 mg/L, registrants would need to perform either (i) 835.3110 or (ii) one of 835.3220, 835.3240, or 

835.3280. If the antimicrobial reaches pass levels for 835.3110 (i.e., 70% removal of dissolved organic carbon 

(DOC) and 60% removal of theoretical oxygen demand (ThOD) or theoretical carbon dioxide (ThCO2) production 

for respirometric methods) in a 10-day window within the 28-day period of the test, registrants would be able to 

request that EPA waive the requirements for additional biodegradation tests. If the antimicrobial does not pass 

835.3110, the registrants would need to perform one of 835.3220, 835.3240, or 835.3280.
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IV. Appendix A: Use Patterns – ADAO

Use Category / Use Site / Treatment 

Site

Formulation/

EPA Reg. no.

Method of 

Application

Application Rate/ 

No. of applications

Residential and public access premises 

/ Household and domestic dwellings 

(Indoor food handling areas)

/ Dishes

Ready-to-Use Solution / 

3573-62

Open pour Five minute contact 

time